Frequently Asked Questions

The law limits a physician to supervise no more than four PAs, except as provided in Business and Professions Code (BPC) section 3502.5, which applies only in a state of emergency.

In addition, Assembly Bill (AB) 1070 (Low, Chapter 827, Statutes of 2023), effective January 1, 2024, amended (BPC section 3516), allowing a physician to supervise up to eight PAs at one time, provided that the PAs are focused solely on performing in home health evaluations. Under this law, these in home health evaluations must only be performed to gather patient information and perform an annual wellness visit or health evaluation and must not involve direct patient treatment or prescribing medication.

This law defines an "‘In home health evaluation" as a comprehensive physical exam, assessment of current and prior health conditions, a complete medication review, screening tests, health education, and assessment of social determination of health needs to be used for diagnosing individual medical conditions.

This law also defines an "annual wellness visit" as a preventive visit with correlating current procedural terminology codes performed annually to a patient, to be used for the purposes of diagnosing patient conditions during the annual wellness visit, which may include a nonphysical examination for patients covered by Medicare Part B for more than 12 months.

A PA is authorized to perform those medical services described in the practice agreement. The PA must also have the competency to perform the medical services, and the PA's education, training, and experience must have prepared the PA to render the services, pursuant to BPC section 3502(a). Before authorizing a PA to perform any medical procedure, the physician is responsible for evaluating the PA's education, experience, knowledge, and ability to perform a procedure safely and competently. In addition, the physician should verify that the PA has a current license issued by the Physician Assistant Board of California.

A physician assistant may not perform any of the following medical services pursuant to BPC section 3502(d):

• The determination of the refractive states of the human eye, or the fitting or adaptation of lenses or frames;
• The prescribing or directing the use of, or using any optical device in connection with ocular exercises, visual training or orthoptics;
• The prescribing, fitting or adaptation of contact lenses; and
• The practice of dentistry or dental hygiene or the work of a dental auxiliary.

A PA may perform a routine visual screening which is defined in BPC section 3501(h) as a noninvasive, nonpharmacological simple testing for visual acuity, visual field defects, color blindness, and depth perception.

You can verify a PA's license on-line at: pab.ca.gov, or by calling the Physician Assistant Board at (916) 561-8780.

Pursuant to BPC section 3502.3, a practice agreement shall include the following provisions:

• The types of medical services the PA is authorized to perform.
• Policies and procedures to ensure adequate supervision of the PA.
• Methods for the continuing evaluation of the competency and qualifications of the PA.
• The furnishing or ordering of drugs or devices by a PA.
• Any additional provisions agreed to by the PA and physician.

The agreement must be completed and signed by the PA and one or more physicians before the PA starts practicing. The agreement does not need to be submitted to the Board.

The supervising physician oversees the activities of and accepts responsibility for the medical services rendered by the PA. The supervising physician is required to adhere to the following mechanisms to provide supervision:

1. Adherence to adequate supervision as agreed to in a practice agreement that meets the requirements of BPC section 3502.3.
2. The physician must, at a minimum, be available by telephone or other electronic communication method at the time the PA examines the patient.

Section 1399.541 of Title 16 of the California Code of Regulations specifies when a physician is required to be "immediately available" as defined.

Otherwise, the supervising physician is not required to be on site when the PA is practicing; however, the supervising physician must be available by telephone or other electronic communication at the time the PA examines a patient.

Yes, PAs are authorized to order or furnish a drug, pursuant to BPC section 3502.1. PAs may also administer or provide medication to a patient as authorized by a supervising physician to the PA in the practice agreement. When ordering a drug, the PA is acting on behalf of, and as an agent for, the supervising physician.

Yes, a PA may issue drug orders for Schedule II through V controlled substances, if authorized under the practice agreement with their supervising physician. Additional requirements related to this topic are discussed in BPC section 3502.1.

A PA that is authorized through a practice agreement to issue drug orders for Schedule II controlled substances must register with the United States Drug Enforcement Administration (DEA) obtain a DEA number, and complete a one-time course in compliance with sections 1399.610 and 1399.612 of Title 16 of the California Code of Regulations.

Yes, a PA may perform surgery if the supervising physician has authorized it and it is included in the PA's practice agreement. If authorized by the practice agreement, a PA may perform surgical procedures under local anesthesia without the personal presence of the supervising physician.

A PA may perform surgical procedures requiring other forms of anesthesia if authorized by the practice agreement and only when the supervising physician is "immediately available" as defined by Title 16 of the California Code of Regulations section 1399.541. A PA may act as first, or second, assistant in surgery under the supervision of the supervising physician.

Yes, a PA may be authorized in their practice agreement to perform abortions by aspiration techniques or through prescribing medication pursuant to BPC section 2253, consistent with the standard of care, and only within the first trimester of a pregnancy. A PA who performs abortions using aspiration techniques must meet additional requirements, as described below.

Senate Bill (SB) 385 (Atkins, Chapter 178, Statutes of 2023), effective January 1, 2024, updated these requirements. Accordingly, training must include a clinical and didactic component and be provided by any of the following:

• Training programs approved by the Physician Assistant Board pursuant to BPC section 3513.
• Training to perform medical services that augment the PA's current areas of competency pursuant to Section 1399.543 of Title 16 of the California Code of Regulations.
• A course offered by a state or national health care professional or accreditation organization.
• Training based on the competency-based training protocols established by the Health Workforce Pilot Project (HWPP) No. 171 through the Office of Statewide Health Planning and Development, now known as the Department of Health Care Access and Information.
• Training and evaluation of clinical competency, performed at a clinic or hospital, on performing abortion by aspiration techniques that is provided by a physician and surgeon, nurse practitioner, certified nurse midwife, or PA authorized to perform abortion by aspiration techniques.

Unless otherwise specified in their practice agreement, a clinically competent PA who meets the practice requirements of BPC section 3502 and the training requirements of BPC section 3502.4 may perform an abortion using aspiration techniques without the personal presence of a supervising physician.

A PA may evaluate a patient for the medical use of marijuana consistent with their practice agreement. However, only a physician is authorized to recommend medical use of marijuana, pursuant to Health and Safety code section 11362.5.

Health and Safety Code section 11362.7 (a) sets forth the definition of "attending physician" for purposes of the Compassionate Use Act. It states that the attending physician shall complete a medical examination before providing a recommendation for medical marijuana (emphasis added). A PA may perform an examination and give an evaluation of the patient. In addition to personally completing the medical examination, the attending physician must record in the patient's medical record their assessment of whether the patient has a serious medical condition and whether the medical use of marijuana is appropriate.

For additional information about the Medical Marijuana Program, please visit the Department of Public Health website.

For additional information for physicians who wish to recommend medical marijuana as part of their regular practice of medicine please visit the Medical Board of California's website.

Pursuant to Business and Professions Code section 2069 (a)(1), a supervising physician and surgeon at a "community clinic" licensed under Health and Safety Code section 1204(a) may, at their discretion, in consultation with the nurse practitioner, nurse midwife, or PA provide written instructions to be followed by a medical assistant in the performance of tasks or supportive services. The written instructions may provide that the supervisory function for the medical assistant in performing these tasks or supportive services may be delegated to the nurse practitioner, nurse midwife, or PA and that those tasks may be performed when the supervising physician and surgeon is not on site.