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Policy No.:   G0163 
 

 
 
 

 

Area of Need 
Policy Guideline 

 
Version No.:  2.0  
Approval date:  9 April 2020 

 
  



 
 

 

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Contents  
 
1. Policy Statement .................................................................................................................. 3 

2. Roles and Responsibilities ................................................................................................... 3 

3. Policy Requirements ............................................................................................................ 4 

3.1 Detail ........................................................................................................................ 4 

3.2 Area of Need Criteria ................................................................................................ 4 

3.2.1 Position vacancy advertising as evidence of labour market testing ..................... 4 

3.2.2 Evidence of need .................................................................................................. 5 

3.2.3 Position details and description ............................................................................ 5 

3.2.4 Health service support (if applicable) .................................................................... 5 

3.3 Area of Need Applications ........................................................................................ 6 

3.3.1  Area of Need - new application ............................................................................. 6 

3.3.2  Area of Need   extension application ................................................................... 6 

3.3.3 Area of Need   modification location application .................................................. 7 

3.4 Timeframe for assessment ....................................................................................... 7 

3.5 Area of Need Application for Appeal ........................................................................ 8 

3.6 Distribution Priority Area (DPA) and District of Workforce Shortage (DWS)............ 8 

4. Implementation and Monitoring............................................................................................ 8 

5. National Safety and Quality Health Service Standards ....................................................... 9 

6. Definitions ............................................................................................................................ 9 

7. Associated Policy Directives / Policy Guidelines &amp; Resources ......................................... 10 

8. Document Ownership &amp; History ......................................................................................... 10 

  



 
 

 

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Area of Need Policy Guideline 
 

1. Policy Statement 
The Area of Need (AoN) Program was established to help provide general practice and 
specialist medical services to South Australian locations with limited access to healthcare 
services. The AoN Program provides employers with the ability to recruit a suitably 
qualified International Medical Graduate (IMG) to a vacant medical practitioner position, 
when difficulty is experienced recruiting unrestricted medical practitioners with general or 
specialist registration. 
 
The AoN Policy Guideline describes the: 
  application process to determine AoN status; 
  required supporting documentation as evidence; 
  process to assess AoN applications; and 
  obligations of employers when recruiting IMGs. 
 
The AoN Program is intended to provide temporary assistance to locations and services 
across South Australia that have been experiencing medical practitioner service 
shortages. Employer priorities, however, should remain to attract and recruit Australian 
citizen/permanent resident medical practitioners who hold general or specialist 
registration with the Australian Health Practitioners Regulation Agency (AHPRA). 
 
AoN is assessed at the state level, and the Chief Medical Officer has delegation to 
approve the AoN status. AoN approvals are for IMGs who are on/or applying for their 
Limited Registration with AHPRA (medical registration). 
 
AoN is approved only for a person taking up a specific position. Whole practices or areas 
cannot be declared AoN. 
 
1.1 Scope 
The AoN Policy Guideline explains the application process for approving an AoN 
determination in South Australia and stipulates the mandatory criteria for AoN 
applications. The Policy Guideline applies to both public and private medical practitioner 
vacancies. 
 
1.2 Principles 
Section 67 of the Health Practitioner Regulation National Law (South Australia) Act 2010 
stipulates that an IMG may apply for Limited registration with AHPRA to practice in a 
health profession in an AoN as determined by the Chief Medical Officer of South Australia 
who has been delegated this authority by the Minister for Health and Wellbeing. 
 
AoN declarations are available only for International Medical Graduates (IMGs) applying 
for their Limited registration with AHPRA.  
 
Refer to the AHPRA website for further information about Limited registration. 
 

2. Roles and Responsibilities 
 
SA Health, Chief Medical Officer 
The Chief Medical Officer has the delegation to approve AoN declarations. The Chief 
Medical Officer has delegation of the Australian Health Practitioner Regulation Agency 
under the repealed Law and is appointed to the National Agency under this Law as 
outlined in the Health Practitioner Regulation National Law (SA) Act 2010. 



 
 

 

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SA Health, South Australian Medical Education &amp; Training (SA MET) Unit 
The Project Officer   Medical Workforce employed within the SA MET Unit will assess, 
maintain and process AoN applications in accordance with this policy. 
 
The Project Officer   Medical Workforce will report regularly to the Chief Medical Officer 
on any applications of concern and will produce reports as required. 
 
Australian Health Practitioner Regulation Agency (AHPRA) &amp; South Australian 
Board of the Medical Board of Australia 
The South Australian Board of the Medical Board of Australia and AHPRA consider and 
grant limited registration to appropriately qualified IMGs who do not qualify for general, 
provisional or specialist registration, to practise in an AoN position.  
 
Australian Medical Council (AMC) 
The AMC facilitates assessment pathways administration and national examinations for 
IMGs who wish to practise medicine in Australia. 
 

3. Policy Requirements 
 

3.1 Detail 
The AoN Program supports health service providers experiencing a medical workforce 
shortage and can demonstrate that they have been unable to recruit an Australian-trained 
medical practitioner to the vacant position. The Program was established to help provide 
general practice and specialist medical services to South Australian locations with limited 
access to such services. 
 
The Medical Board of Australia can grant Limited registration to a suitable IMG to be 
employed into a declared AoN position under the Health Practitioner Regulation National 
Law (SA) Act 2010. All other registration requirements as outlined by the Medical Board of 
Australia must also be met. 
 
3.2 Area of Need Criteria 
AoN applications must be supported with evidence and will be assessed against the AoN 
criteria.  
 
The AoN application must include evidence of: 

? Position vacancy advertising as evidence of labour market testing 
? Evidence of a need 

? Position details and description 

? Health service support (if applicable) 

3.2.1 Position vacancy advertising as evidence of labour market testing 
All AoN applications must provide documented evidence of labour market testing. The 
advertising evidence will demonstrate there have been genuine attempts to recruit 
Australian-trained medical practitioners to the position. 
 
The position must have been advertised: 

? for a minimum of three months, with at least one attempt being made within the 
last four weeks. 

? within 12 months of the AoN application being received by SA Health. 

? both in South Australia, and nationally, with at least one attempt having been in an 
appropriate medical college publication or website (for example, SEEK, My 
Career, RACGP). 



 
 

 

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Documented advertising evidence means copies of each advertisement. All advertising 
must show the: 

1. position title;  
2. name and location of the practice;  
3. incumbent s required qualifications, skills and expected duties; 
4. remuneration range and other benefits of the position; remuneration must be in 

dollar value not percentage based (for example $120,000 or $150,000 - $250,000) 
5. where and when the advertisement was published (open and close dates); if 

advertising is for 30 days from 01 August then the closing date will be 30 August 
and will be considered one month of advertising.  

 
The employer/authorised agent must keep a copy of all advertising when it has been 
published.  
 
Invoices and/or copies of booking forms are not acceptable pieces of evidence and will be 
rejected if provided. 
 
Advertising explicitly referring to  Area of Need doctors , or similar wording that can limit 
the available pool of applicants in any way, will not be considered as adequate forms of 
labour market testing and will not satisfy the criteria. 
 
Contact Area of Need by email at Health.AreaofNeed@sa.gov.au for before advertising to 
ensure that criteria are met.  

3.2.2 Evidence of need 
Information must be provided to SA Health to explain and describe: 

1. the reason for the vacancy; 
2. the size and profile of the health service/practice;  
3. whether or not health services are accessible to patients;  
4. the effect on service delivery and the community if the position is left vacant; 
5. the effect on public health services if the position is left vacant. 

 
The supporting documentation listed above can be included within the AoN application 
form as narrative or provided as a separate attachment for example, as a practice profile 
document. 

3.2.3 Position details and description 
The position details must be supported by a job description that includes information 
about the working conditions, hours and the total remuneration of the position. The job 
description must be current and be included as an attachment with the AoN application 
form. 
 
A position description that is missing information, as described previously, will be rejected.  

3.2.4 Health service support (if applicable) 
The following additional letters of support are required to support an AoN application if the 
position is either a: 

  Procedural GP;  
  Medical specialist. 

 
The letter of support must be signed by the Chief Executive Officer, Managing Director or 
equivalent employing person, and must clearly indicate whether or not support is provided 
for the IMG to be employed into the position. 
 




 
 

 

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3.3 Area of Need Applications 
AoN applications are to be completed by the employer/authorised agent. There are four 
AoN application forms: 

? Area of Need   new application 
? Area of Need   extension application 
? Area of Need   modification location application 
? Area of Need - appeal 

 
The employer/authorised agent will be advised of the application outcome when the AoN 
assessment is completed and, if it is successful, the employer/authorised agent will be 
provided with an AoN letter. 
 
The employer/authorised agent must provide a copy of the AoN letter to AHPRA. 

3.3.1  Area of Need - new application 
The application supporting evidence, as described in criteria 3.2, must be submitted with 
the AoN new application. 
 
An approved AoN expiry date will not exceed three years, and is dated at the end of the 
month (that is, three years from the date of the signed approval letter). The AoN expiry 
date will be in line with the Limited registration expiry date where the practitioner has 
current Limited registration with APHRA. 
 
The worksite location(s) where the practitioner will be employed must be identified in full 
on the application form. Full details of all sites must be included if the practitioner is 
required to work in more than one site. Any changes  at any time must be advised to the 
AoN;   an updated support letter will be provided to the employer/agent who in turn must 
provide a copy to AHPRA. 

3.3.2  Area of Need   extension application 
The employer/authorised agent may apply for an extension if the practitioner has not 
progressed from Limited registration to General or Specialist registration within the initial 
three year period.   
 
Applications for extensions should be received by the SA MET Unit 90 days before the 
current AoN letter expires. It is the employers/authorised agents responsibility to ensure 
this deadline is met. 
 
A position having been successful previously in obtaining AoN status will not guarantee 
that a request to extend the position will be approved. 
 
The AoN extension expiry date will not exceed 12 months (one year). The new date will 
be 12 months from the expiry date in the current letter. 
 
The National Law states that Limited registration may not be renewed more than three 
times. A medical practitioner who wishes to continue practising after three Limited 
registration renewals needs to make a new application for registration. Refer to the 
AHPRA website for further information.  
 
The worksite location(s) where the practitioner will be employed must be identified in full 
on the application form. Full details of all sites must be included in the AoN application 
and identified as either the primary location or additional location(s) if the practitioner is 
required to work in more than one site. The SA MET Unit must be advised if the location 




 
 

 

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status changes at any time. An updated letter will be provided to the employer/authorised 
agent. The employer/authorised agent must forward the updated letter to AHPRA. 
 
The employer/authorised agent seeking extension of an AoN must provide the following 
information: 
 

1. a copy of the previous AoN approval letter; 
2. a copy of the AHPRA registration details confirming that the practitioner has 

Limited registration; the extension expiry date will be in line with the AHPRA 
expiry date; 

3. full details of primary and additional locations; advise if work site locations have 
changed since the previous application; 

4. a copy of a current (12 months) position description that must include the 
remuneration range and other benefits of the position; remuneration must be in 
dollar value not percentage based. (for example, $150,000 or $150,000 - 
$250,000); and  

5. copies of exam result statements, with evidence of registration to sit future 
exams (if applicable). 

3.3.3 Area of Need   modification location application 
AoN status attaches to a specific position and cannot be transferred to another person, 
position or location. Requests for minor modifications (for example, change in practice 
name or change of practice address within the location) will be considered. 
 
Modification requestions for new locations or removal of locations must include a Request 
for Modification/Location form from the employer/authorised agent. The request must 
include: 
 

? Previous AoN approval letter  

? Full details of the site(s) to be removed or included (that is, the name of 
practice/hospital/site, full address. 

? The name and location of the primary site. 
 
The employer/authorised agent must forward the approved AoN letter confirming 
modification of location(s) to AHPRA. 

3.4 Timeframe for assessment 
AoN applications will be processed within 10 working days, provided all necessary 
information was submitted with the application. Incomplete applications will be processed 
only once all required information is submitted, as described in sections 3.2, 3.3 and 3.4 
respectively. The employer/authorised agent must address all criteria and provide the 
required information. 
 
Incomplete applications are kept open for a maximum of 10 days from the date the 
application is received, so that the employer/authorised agent can provide required 
missing information. The application will be closed if the required information is not 
received within the 10 day limit. All documentation will need to be resubmitted as a new 
application after the 10-day period has expired. 
 
The employer/authorised agent will be advised of the outcome after the assessment is 
completed. An AoN support letter will be sent to successful applicants from the Chief 
Medical Officer. The letter is personalised and unique confirming employment of an IMG 
into the specific position. 
 



 
 

 

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The employer/authorised agent must advise AHPRA of the AoN approval for the IMG, and 
provide them with a copy of the support letter. 

3.5 Area of Need Application for Appeal 
Employers/authorised agents may appeal the decision if they have been unsuccessful in 
obtaining an AoN approval for a position. The appeal must be lodged within 28 days of 
the date of the decision. 
 
Appeals are to be submitted in writing to Health:AreaofNeed@sa.gov.au and address 
each section of the AoN application describing why the AoN application criteria have not 
been met. Describe the grounds for appeal and ensure the appeal addresses all the AoN 
Policy Guidelines requirements before submission. 
 
The appeal will be reviewed by the Appeals Committee which will comprise of three 
members not involved in the initial assessment or decision making process of the original 
AoN application. 
 
The review will be processed within 28 business days from receipt of the appeal 
application. The sponsoring employer/authorised agent will be advised of the outcome in 
writing. 
 
The decision made by the Committee will be final. 

3.6 Distribution Priority Area (DPA) and District of Workforce Shortage (DWS) 
The Commonwealth Department of Health introduced on 1 July 2019 the health workforce 
Distribution Priority Area (DPA) classification system that replaces District of Workforce 
Shortage (DWS) for General Practitioners (GPs) and Bonded Doctors.  
 
International medical graduates who are GPs need to work in an area classified DPA to 
access Medicare under section 19AB of Australia's Health Insurance Act 1973. 
 
The DWS classification is used for areas that have poor access to specialist medical 
practitioners.  
 
The DPA and DWS are determined by the Commonwealth Department of Health and 
relate to a geographical area of Australia where the population s needs for healthcare are 
not being met. This unmet need is determined by the Commonwealth Department of 
Health using Australian Bureau of Statistics data and the latest Medicare billing statistics.  
 
The locator map on the DoctorConnect website (www.doctorconnect.gov.au) shows areas 
that are considered to be DPA and DWS for general practice positions. 
 
DPA and DWS are not considered in South Australia when assessing an AoN. Other 
states in Australia will not approve an AoN if it is not in a DPA and DWS area. 
 
DPA and DWS queries, particularly around exemptions, can be emailed to the 
Commonwealth Department of Health at 19AB@health.gov.au. 
 

4. Implementation and Monitoring 
 
The Project Officer   Medical Workforce will report regularly to the Chief Medical Officer 
on any applications of concern, and produce reports as required. 
 
 






 
 

 

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5. National Safety and Quality Health Service Standards  
 
The Australian Commission on Safety and Quality in Health Care has developed eight 
National Safety and Quality Health Service Standards (the Standards). 
 
The Standards provide a nationally consistent and uniform set of measures of safety and 
quality for application across a wide variety of health care services. They propose 
evidence-based improvement strategies to deal with gaps between current and best 
practice outcomes that affect a large number of patients.  
 

 

6. Definitions  
 
In the context of this document: 
 
Area of Need (AoN)   is determined by SA Health s Chief Medical Officer and relates to a vacant 
medical position where there is a lack of Australian-trained medical practitioners and where the 
medical position remains unfilled following multiple recruitment attempts over a period of time. The 
AoN Program provides temporary assistance in filling these vacant positions and applies to both 
the public and private sector. 
 

Distribution Priority Area (DPA)   is determined by the Commonwealth Department of Health. 
The classification identifies locations in Australia with a shortage of medical practitioners. 
International medical graduates who are GPs need to work in an area classified DPA to access 
Medicare under section 19AB of Australia's Health Insurance Act 1973. 
 
Refer to the DoctorConnect website (www.doctorconnect.gov.au) for further information and to 
access the locator map.  
 
DWS is not considered in South Australia when assessing an AoN. Other states in Australia will 
not approve an AoN if it is not in a DWS area. 
 
DWS queries, particularly around exemptions, should be emailed to the Commonwealth 
Department of Health at 19AB@health.gov.au. 
 

International Medical Graduate (IMG)   IMGs are defined as medical practitioners whose primary 
medical degree has not been obtained from an AMC accredited university, or who have not gained 
specialty qualifications from an AMC Professional Medical College in Australasia. 
 

Limited Registration for AoN   is a type of registration granted by the Medical Board of Australia 
for IMGs who do not qualify for general, provisional or specialist registration. 
Medical practitioners with this type of registration must comply with the Medical Board of 
Australia s Limited registration for area of need registration standard.  

  

 
 

National Standard 
1 
 

Clinical 
Governance 

 
 

National 
Standard 2 

 
Partnering 

with 
Consumers 

 
 
 

 
 

National 
Standard 3 

 
Preventing &amp; 
Controlling 
Healthcare- 
Associated 
Infection 

 
 

National 
Standard 4 

 
Medication 

Safety 
 
 
 
 

 
 

National 
Standard 5 

 
Comprehensiv

e Care 
 
 

 
 

National 
Standard 6  

 
Communica

ting for 
Safety 

 
 
 

 

 
 

National 
Standard 7 

 
Blood 

Management 

 
 

National 
Standard 8 

 
Recognising &amp; 
Responding to 

Acute 
Deterioration 

 
 

? ? ? ? ? ? ? ? 





















































 
 

 

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7. Associated Policy Directives / Policy Guidelines &amp; Resources 
 
SA Health, Area of Need 
http://www.sahealth.sa.gov.au/wps/wcm/connect/public+content/sa+health+internet/careers+at+sa
+health/medical+-+public+and+private+sector+-+area+of+need#main 

 
SA Health, Area of Need Application Form 
 
SA Health, Area of Need Extension Application Form 
 
SA Health, Area of Need Request for Modification/location form 
 
SA Health, Area of Need Application for Appeal 
 
SA Health, Area of Need Advertising examples 
 
Medical Board of Australia, Limited registration for area of need registration standard 

https://www.medicalboard.gov.au/Registration-Standards.aspx 
 
Australian Medical Council, Assessment Pathways 
http://www.amc.org.au/assessment/pathways 
 
Health Workforce Certificate, a requirement for employer sponsored visas 
http://www.doctorconnect.gov.au/internet/otd/publishing.nsf/Content/visas_for_GPs 
 
DoctorConnect, for information about Distribution Priority Area (DPA) and District of Workforce 
Shortage (DWS) 
https://www.health.gov.au/initiatives-and-programs/doctorconnect 

 
TSS visa (subclass 482) Short-term stream and medium-term stream labour market testing 
https://immi.homeaffairs.gov.au/visas/employing-and-sponsoring-someone/sponsoring-
workers/nominating-a-position/labour-market-testing 

 
 

8. Document Ownership &amp; History 
 

Approval 
Date 

Version 
Who approved New/Revised 
Version 

Reason for Change 

09/04/20  V2.0 Chief Medical Officer 
Formally reviewed in line with 1-5 year 
scheduled timeline for review. 

21/10/15  V1.0 Portfolio Executive 
Original Portfolio Executive approved 
version. 

 

 

Document developed by:  South Australian Medical Education and Training (SA MET) Unit 
Department for Health and Wellbeing 

File / Objective No.: 2018-04216  |  eA2026015 
Next review due:   01/12/2024  (usually 1-5 years  time)  
Policy history: Is this a new policy (V1)?   N 
 Does this policy amend or update an existing policy version   Y 
 If so, which version?   V2.0 
 Does this policy replace another policy with a different title?   N 

If so, which policy (title)? N/A 
 
ISBN No.:     978-1-76083-255-1 
 










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