Sean K Reynolds Designer, RPG Superstar Judge |
RumpinRufus |
No, Lay on Hands is a supernatural ability, and Su abilities don't provoke unless specifically mentioned.
Maybe the reason it specifies using LoH as an attack doesn't provoke is that you are using a touch attack, and maybe they thought touch attacks seem similar enough to unarmed strikes that people might assume it provoked? Although touch attack spells also don't provoke.
Anyway, the rules are redundant and I'm not sure why, but neither using it to heal nor to hurt provokes.