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At 3rd level, a vitalist gains Steal Health, a supernatural ability, the rules for which state that such actions take a standard action to perform unless otherwise specified.

As a touch attack, the vitalist may deal a number of hit points in damage to the target equal to his vitalist level + his Wisdom modifier and heal an equal amount of damage[...]
At 7th level, a vitalist is able to use steal health as a ranged touch attack with a range of 30 feet.

A friend is arguing that due to language standards, "touch attack" is the action specified by the ability, and thus Steal Health can be used as an attack, specifically a touch attack granted by a Supernatural ability, (i.e., not costing a standard action), in a fashion similar to a lamia's Wisdom Drain ability.

Is this the case, or do you need to spend a standard action to activate Steal Health?

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Your friend would be right, except that he missed some key information about specific vs general. The Lich's paralyzing touch attack is a secondary natural weapon, but only because it's specifically noted as such:

A lich has a touch attack that it can use once per round as a natural weapon. A lich fighting without weapons uses its natural weapons (if it has any) in addition to its touch attack (which is treated as a primary natural weapon that replaces one claw or slam attack, if the creature has any). A lich armed with a weapon uses its weapons normally, and can use its touch attack as a secondary natural weapon.

The Vitalist's Steal Health ability, on the other hand, says:

As a touch attack, the vitalist may deal a number of hit points in damage to the target equal to his vitalist level + his Wisdom modifier and heal an equal amount of damage.

Steal Health is a Supernatural ability, and this is what the rules have to say about those:

Using a supernatural ability is usually a standard action (unless defined otherwise by the ability's description). Its use cannot be disrupted, does not require concentration, and does not provoke attacks of opportunity.

Unless the ability defines a different action (which Steal Health doesn't, and Lich's touch does), it defaults to a standard action.

The Lamia's Wisdom Drain ability appears to be of a different sort of ability. It says:

A lamia drains 1d4 points of Wisdom each time it hits with its melee touch attack.

... and lists a Touch as an attack taken within its full attack action. The wisdom drain ability is a rider effect, much like Poison or Disease, rather than a Supernatural ability used "as a touch attack."

Amusingly, I think this would mean that a Lamia Lich would both paralyze and drain wisdom if it poked someone, and that a Lamia Vitalist could steal health in addition to sapping their target's will.

Naturally, the DM might read things differently. It's entirely possible to interpret "as a touch attack" as "this is an Attack action that is also a touch attack" rather than "this is a touch attack", but I feel that it's unfounded in the RAW. My suggestion is to ask your DM, after pointing out various examples of things that are and are not listed as used as part of Attack actions.

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As the friend in question, my claim is that Steal Health, as written, is a Supernatural ability granting a touch attack, analogous to a lamia's Wisdom Drain. This is not a supernatural ability that can be activated as a standard action to gain a touch attack charge, as though casting a touch spell; the wording doesn't support that. It is an always-available attack, as though you were holding a charge all the time, and is not used as a standard action, but, as per the ability text, "As a touch attack". That's "an attack" as in "your sixth level ranger gets 2 attacks with his longsword and 1 attack with his dagger when he uses the full attack action".

Elsewhere, the "As a foo, do bar" language is consistently used to indicate that "foo" is the action type. Nothing here precludes this being the case; "touch attack" is entirely viable as a specification of a type of action (technically, a type of non-action, since "attacks" in this sense of the word are components of other actions, not actions of their own). The confusion comes from another case of TSR/Wizards/Paizo needing to spend more time with a thesaurus. This isn't "attack" as in "attack action", but as in the several attacks you get when making the full attack action, or as in the attack you can make when an AoO is provoked.

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    \$\begingroup\$ The lamia's Wisdom Drain doesn't grant a touch attack, it only provides an additional/modified effect to the lamia's existing touch attack; so it's not analogous either. \$\endgroup\$ – SevenSidedDie Dec 1 '14 at 23:27
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    \$\begingroup\$ Melee +1 dagger +13/+8 (1d4+4/19–20), touch +7 (1d4 Wisdom drain), 2 claws +7 (1d4+2). In this instance, 1d4 Wisdom drain is the damage it deals as a result of their Special Attack, "Wisdom drain", which reads "A lamia drains 1d4 points of Wisdom each time it hits with its melee touch attack." \$\endgroup\$ – Powerdork Dec 1 '14 at 23:36
  • \$\begingroup\$ @Metool The entire existence of that touch attack is a result of the Wisdom Drain ability, though, not just the damage. \$\endgroup\$ – Matthew Najmon Dec 1 '14 at 23:46

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