Does a physician need approval to supervise a PA?
No. Any physician (either M.D. or D.O.) may supervise a PA if they have a current
medical license and there are no disciplinary or probationary conditions on the
physician's license prohibiting supervision of PAs.
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How many PAs can a physician supervise?
Current law limits a physician to supervise no more than four PAs at any moment
in time.
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What is the scope of practice of a PA?
The scope of a given PA's practice is limited by his/her supervising physician.
Whatever medical specialty a physician practices (e.g., general practice, cardio-thoracic
surgery, dermatology, etc.) limits the PA's scope of practice. The Delegation of
Services Agreement between the PA and the supervising physician then further defines
exactly what tasks and procedures a physician is delegating to the PA. These tasks
and procedures must be consistent with the supervising physician's specialty or
usual and customary practice and with the patient's health and condition.
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
the procedure safely and competently. In addition, the physician should verify that
a PA has a current California license issued by the Physician Assistant Board (Board).
A PA may not perform any of the following medical services pursuant to Business
and
Professions Code section 3502 (c):
- The determination of the refractive states of the 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 orthopedics.
- The prescribing, fitting or adaptation of contact lenses.
- The practice of dentistry or dental hygiene or the work of a dental auxiliary.
A PA may perform a routine visual screening defined pursuant to Business and Professions
Code section 3501(i) as an un invasive non pharmacological simple testing for visual
acuity, visual field defects, color blindness, and depth perception.
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How do I verify a PA's license?
You can verify a PA license on-line at: http://www.pac.ca.gov/forms_pubs/online_services/license_lookup.shtml
Or you can call the PA Board at (916) 561-8780.
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What documents are required to supervise a PA?
Title 16 of the California Code of Regulations section 1399.540 requires the supervising
physician to delegate in writing those medical services that the PA may provide.
This document is often referred to as a Delegation of Services Agreement.
The Delegation of Services Agreement defines exactly what tasks and procedures a
physician is delegating to their PA. These tasks and procedures must be consistent
with the supervising physician's specialty or usual and customary practice and with
the patient's health. The agreement must be completed before the PA starts practicing.
The document does not need to be submitted to the board.
You can obtain a sample delegation of services agreement on-line, or call (916)
561-8780.
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Can a PA practice independently?
No, PAs cannot practice independently. Every PA must be supervised by a licensed
physician (either M.D. or D.O.). The supervising physician is responsible for all
medical services provided by a PA under his/her supervision and for following each
patient's progress.
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What supervision is required for a PA?
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:
- Adherence to adequate supervision as agreed to in a practice agreement that meets the requirements of Business and Professions Code section 3502.3.
- The physician must be available by telephone or other electronic communication method at the time the PA examines the patient.
Business and Professions Code section 3501
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Is the supervising physician required to be on-site when the PA is
practicing?
No. The supervising physician is not required to be on site but must be available
in person or by electronic communication at all times when the PA is caring for
patients.
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Are PAs allowed to write drug orders?
Yes. Business and Professions Code section 3502.1 authorizes PAs to issue a drug
order. PAs may also administer or provide medication to a patient. The supervising
physician must delegate that authority to the PA in the delegation of services agreement.
When issuing a drug order, the PA is acting on behalf of and as an agent for the
supervising physician.
Before a PA can issue drug orders, the supervising physician must first prepare
and
adopt a written, practice specific formulary and protocols that specify all criteria
for the use of a particular drug and any contraindications. The drugs listed constitute
the formulary and may only include drugs that are appropriate for use in the practice.
Any variations require advance approval from the supervising physician for the particular
patient before the PA may issue a drug order.
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What information must be on a PA's drug order?
Business and Professions Code section 3502.1 (d) requires that a PA's written drug
order contain the printed name, address, and phone number of the supervising physician,
and the signature, printed or stamped name, and license number of the PA. If the
drug order is for a controlled substance, it must also include your DEA number.
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Is a PA allowed to issue drug orders for controlled substances?
Yes, a PA may issue drugs orders for Schedule II through V controlled substances
if the supervising physician delegates that authority to the PA. However, the PA
may not administer, provide or issue a drug order for Schedule II through V controlled
substances, including refills, without advance approval by the supervising physician
for the particular patient, unless the PA completed an approved education course
in controlled substances and is delegated by the supervising physician. Existing
law allows two mechanisms for reviewing and signing off on medical charts for Schedule
II drug orders:
- The first requires the medical charts for these drug orders to be countersigned
within seven days by the supervising physician.
- The second is only allowed if the PA has documentation evidencing the successful
completion of an education course that covers controlled substances and meets specified
standards. This mechanism requires the supervising physician to review, countersign,
and date, within seven days, a sample consisting of the medical records of at least
20 percent of the patients cared for by the PA for whom the PA’s Schedule II drug
order has been issued or carried out.
A PA that is authorized to issue drug orders for controlled substances must register
with the United States Drug Enforcement Administration (DEA) and obtain a DEA number.
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Can the PA use the supervising physician's DEA number on drug orders
for controlled substances?
PAs that are authorized to issue drug orders for controlled substances must register
with the United States Drug Enforcement Administration (DEA) and obtain their own
DEA number.
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Is the supervising physician required to sign all of the patient's
medical records?
Existing law allows two mechanisms to ensure proper supervision of PAs by physicians.
The first requires a supervising physician to review, countersign, and date a sample
consisting of, at a minimum, five percent of the medical records of patients treated
by a PA within 30 days of the date of treatment. The supervising physician is required
to select for review those cases that by diagnosis, problem, treatment, or procedure
represent the most significant risk to the patient. The second allows for medical
records review meetings, which is a meeting between the supervising physician and
the PA during which medical records are reviewed to ensure adequate supervision
of the PA. The supervising physician must review a sample of at least 10 medical
records per month, for at least 10 months during the year, using a combination of
the countersignature mechanism and the medical records review mechanism.
If protocols are not in place, then the supervising physician must either:
- examine the patient the same day as the care is provided by the PA or
- countersign and date all medical records of all patients cared for by the PA within
30 days.
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Can a PA perform surgery?
Yes, if the supervising physician has delegated the PA authority to do so in writing.
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 only in the personal presence of the supervising physician.
A PA may act as first or second assistant in surgery under the supervising of the
supervising physician.
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Can a PA evaluate a patient for the medical use of Marijuana?
A PA can evaluate a patient consistent with the PA's delegation of services 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 physician assistant may perform an examination
and give an evaluation of the patient. In addition to personally completing the
medical examination, the attending physician himself or herself 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. It is the Physician
Assistant Board's understanding that these responsibilities must be performed by
the attending physician and cannot be delegated to a physician assistant.
For additional information about Medical Marijuana Program, please visit the Department
of Public Health website at: archive.cdph.ca.gov/programs/MMP/Pages/default.aspx
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 at: http://www.mbc.ca.gov/Licensees/Prescribing/
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Can medical assistants be supervised by a physician assistant in
the absence of a physician and surgeon?
Per 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 his or her discretion, in consultation with the nurse practitioner, nurse
midwife, or physician assistant 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 physician assistant and that those tasks may be performed when
the supervising physician and surgeon is not on site.
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