© 2018 American Medical Association. All rights reserved.
Physician assistant scope of practice
The AMA opposes enactment of legislation to authorize the independent practice of medicine by any individual who has not completed the state’s requirements for licensure to engage in the practice of
medicine and surgery.
1
The AMA believes that physicians must maintain the ultimate responsibility ultimately responsible for coordinating and managing the care of patients and, with the appropriate input of
the physician assistant, ensuring the quality of health care provided to patients.
2
With regard to physician assistants specifically, AMA policy states that physician assistants should be authorized to provide patient care services only so long as the physician assistant is functioning under the
direction and supervision of a physician or group of physicians.
3
Accordingly, the AMA opposes legislation or proposed regulations authorizing physician assistants to make independent medical judgment
regarding such decisions as the drug of choice for an individual patient.
4
AMA policy also addresses regulation of physician assistants. In particular, the AMA advocates in support of maintaining the authority of medical licensing and regulatory boards to regulate the practice of
medicine through oversight of physicians, physician assistants and related medical personnel.
5
The AMA also opposes legislative efforts to establish autonomous regulatory boards meant to license, regulate,
and discipline physician assistants outside of the existing state medical licensing and regulatory bodies' authority and purview.
This state law chart outlines several aspects of state laws regulating physician assistant practice.
Co signature – 20 states
6
require a certain percentage or number of PA charts to be co-signed by a physician
Ratio requirements – 39 states
7
have established limits on the number of PAs a physician can supervise or collaborate with
1
AMA Policy H-35.989, Physician Assistants; AMA Policy H-35.988, Independent Practice of Medicine by Nurse Practitioners.
2
AMA Policy H-35.988, Independent Practice of Medicine by Nurse Practitioners.
3
AMA Policy H-35.989, Physician Assistants.
4
Id.
5
AMA Policy H-35.965, Regulation of Physician Assistants.
6
AL, CA, CO, IN, KS, KY, LA, MS, MO, MT, NE, NV, NJ, OH, PA, SC, TN, UT, VT, VA
© 2018 American Medical Association. All rights reserved.
2
Prescriptive authority
PAs are authorized to prescribe Schedule II-V medication in most states (44)
PAs lack the authority to prescribe Schedule II medication in 6 states (AL, AR, GA, HI, IA, WV)
PAs lack the authority to prescribe legend drugs in 1 state (KY)
Requirements for collaborative or supervisory arrangement
In 47 states, PAs are supervised by physicians
In 2 states, PAs are subject to collaborative agreements with physicians (AK, IL)
2 states allow for an alternate arrangements: New Mexico calls for supervision for PAs with less than 3 years of clinical experience, and for specialty care PAs, and in Michigan, PAs work under a
participating physician
Regulation – In most states (43), PAs are regulated by the medical board. However, in 8 states (AZ, CA, IA, MA, MI, RI, TN, UT), PAs have a separate and independent regulatory board
Scope of practice determination – In most states (47), PA scope of practice is determined with the supervising/collaborating physician at the practice site
7
No ratios in AK, AR, ME, MA, MI, MN, MS, NM, NC, ND, RI, TN
© 2018 American Medical Association. All rights reserved.
3
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
Alabama
Required (AAC
540-X-7-.23)
Physician may
not supervise
more than a
cumulative 160
hours per week
for all PAs.
(AAC 540-X-7-
.26)
Schedule III-V
Supervisory
The supervising physician shall be readily available for direct
communication or by radio, telephone, or telecommunication.
There shall be no independent, unsupervised practice by PAs
Prescribing is subject to any limitations stated in protocols and
medical regimens adopted by the Board and subject to any
limitations by the supervising physician in the approved
formulary (AAC 540-X-7-.23)
Alabama
Board of
Medical
Examiners
Yes
Alaska
None
None
Schedule II-V
Collaborative
Collaborative plans must include at least monthly telephone,
radio, electronic, or direct personal contact between the PA and
the primary or alternate collaborating physician reviewing the
PAs performance in the practice, knowledge, skills, patient care,
and health care records. (12 AAC 40.430)
Alaska State
Medical Board
Yes
Arizona
None
Physician may
not supervise
more than 4 PAs
who work at the
same time.
(ARS. 32-2533)
Schedule II-V
II-III limited to
30-days, no
refills without
written consent
from physician;
IV-V not more
than 5 times in
6-months.
Supervisory
PA must meet in-person or by telecommunication with the
supervising physician at least once each week to ensure ongoing
direction and oversight of PA work. Patient records must also be
made available to the supervising physician.
A supervising physician shall develop a system for recordation
and review of all instances in which the PA prescribes schedule
II or schedule III controlled substances. (ARS 32-2531)
Arizona
Regulatory
Board of
Physician
Assistants
Yes
Arkansas
None
None
Schedule III-V
Supervisory
Continuous supervision is required, but does not necessitate
physical presence at the time and place services are rendered.
Arkansas State
Medical Board
Yes
© 2018 American Medical Association. All rights reserved.
4
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
A supervising physician should be available for immediate
telephone contact with the PA any time the PA is rendering
services to the public. A supervising physician must be able to
reach the location of where the PA is rendering services to the
patients within one hour. (ACA 17-105-109)
California
Sample of at
least 10 charts
per month, for at
least 10 months
during the year.
(Minimum of
5% of the PAs
medical
records).
(CCR 3502)
Physician may
not supervise
more than 4 PAs
at any one time.
(CCR 3516(b))
Schedule II-V
Supervisory
A supervising physician shall be available in person or by
electronic communication at all times when the PA is caring for
patients.
A supervising physician shall delegate to a PA only those tasks
and procedures consistent with the supervising physician's
specialty or usual and customary practice.
A supervising physician shall observe or review evidence of the
PAs performance until assured of competency. (CCR 1399.545)
California
Physician
Assistant
Board
Yes
Colorado
Required, but
varies with PA
experience.
(Rule 400; 3
CCR 713-7)
Physician may
not be the
primary
supervising
physician for
more than 4
individual PAs.
(Rule 400; 3
CCR 713-7)
Schedule II-V
Supervisory
PAs are subject to tiered supervision requirements concerning
performance assessments, chart reviews, in person meetings, and
on-site supervision. If not physically on site, the physician
supervisor must be readily available by telephone, radio, pager,
or other telecommunication device. (CCR Rule 400)
Colorado
Medical Board
Yes
Connecticut
None
Physician may
Schedule II-V
Supervisory
Physician should be continuously available by direct
Connecticut
Yes
© 2018 American Medical Association. All rights reserved.
5
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
not be the
supervising
physician for
more than 6 PAs
practicing full
time, or the part-
time equivalent
thereof. (CGS
20-12c)
communication either in person or by radio, telephone, or
telecommunications.
There should be active and continuing overview of the PA’s
activities, personal review by the supervising physician of the
PA’s practice on a regular basis, review of the charts and records
of the PA on a regular basis, and designation of an alternate
licensed physician in the absence of the supervising physician.
(CGS 20-12a)
Medical
Examining
Board
Delaware
None
Physician may
not supervise
more than 4 PAs
at a given time.
(Del. C. 1771)
Schedule II-V
Supervisory
If the supervising physician delegates the authority to a PA to
treat patients in a setting where the supervising physician is not
routinely present, the physician must assure that the means and
methods of supervision are adequate to assure appropriate
patient care. This may include telecommunication, chart review,
or other methods of communication and oversight that are
appropriate to the care setting and the education and experience
of the PA. (Del. C. 1771)
Board of
Medical
Licensure and
Discipline
Yes
District of
Columbia
None
Physician may
not supervise
more than 4 PAs
at a given time.
(DCMR
4914.10)
Schedule II-IV
Supervisory
In an inpatient setting, supervision of a PA shall include, but not
be limited to, continuing or intermittent physical presence of the
supervising physician with constant availability through
electronic communications. (DCMR 4914.2)
In an outpatient setting, supervision of a PA shall include, but
not be limited to, constant availability through electronic
communications. (DCMR 4914.3)
DC Board of
Medicine
Yes
Florida
None
Physician may
Schedule II-V
Supervisory
Except in cases of emergency, supervision requires the easy
Florida Board
Yes
© 2018 American Medical Association. All rights reserved.
6
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
not supervise
more than 4
currently
licensed PAs at
any one time.
(Fla. Stat.
458.347(3))
7-day limit on
Schedule II.
availability or physical presence of the licensed physician for
consultation and direction of the actions of the PA. “Easy
availability” includes the ability to communicate by way of
telecommunication. The boards shall establish rules as to what
constitutes responsible supervision of the PA. (Fla. Stat.
458.347)
of Medicine
Georgia
None
Physician may
not serve as
primary
supervising
physician to
more than 4
PAs. (GCR 360-
5-.05)
Schedule III-V
Supervisory
The supervising physician shall provide for immediate
consultation between the PA and primary or alternate
supervising physician. "Immediate consultation" means that the
supervising physician shall be available for direct
communication or by telephone or other means of
telecommunication. (GCR. 360-5-.04(3))
Georgia
Composite
Medical Board
Yes
Hawaii
None, but
supervising
physician must
personally
review the
records of each
patient seen by
the PA within
seven working
days.
Physician may
not supervise
more than 2 PAs
at one time.
(HAR 16-85-49)
Schedule III-V
Schedule II may
be allowed if PA
is employed or
extended
privileges by a
hospital or
extended care
facility.
Supervisory
Supervision shall be continuous but shall not be construed as
necessarily requiring the physical presence of the supervising
physician at the time and place the services are rendered. The
direct communication may occur through the use of technology
which may include but is not limited to, two-way radio,
telephone, fax machine, modem, or other telecommunication
device. (HAR 16-85-49)
Hawaii
Medical Board
Yes
Idaho
None, but a
Physician may
Schedule II-V
Supervisory
Supervision includes: an on-site visit at least monthly; regularly
Idaho Board
Yes
© 2018 American Medical Association. All rights reserved.
7
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
periodic review
of a
representative
sample of
records is
required.
not supervise
more than 3
total PAs at the
same time. The
Board may
authorize 6 total
PAs if necessary
and upon prior
petition. (IAC
22.01.03.010)
scheduled conferences between the supervising physician and
the licensee, and a periodic review of the patient services being
provided by the licensee, the availability of the supervising and
alternate supervising physician to the licensee in person or by
telephone and procedures for providing backup and supervision
in emergency situations (IAC 22.01.03.030)
of Medicine
Illinois
None
Physician may
not enter into
collaborative
agreements with
more than 5
FTE PAs.
(SB1585, Public
Act 100-0453)
Schedule II-V
Collaborative
Collaboration with the PA shall not be construed to necessarily
require the personal presence of the collaborating physician at
all times at the place where services are rendered, as long as
there is communication available for consultation by radio,
telephone, telecommunications, or electronic communications.
(SB1585, Public Act 100-0453)
Illinois State
Medical
Licensing
Board
Yes
Indiana
Required, but
varies with PA
experience and
authority. (Ind.
C. 25-27.5-6-
1(c))
Physician may
enter into a
supervising
agreement with
more than 4
PAs, but may
not supervise
more than four 4
Schedule II – V,
Supervisory
Supervision by the supervising physician or the physician
designee must be continuous but does not require the physical
presence of the supervising physician at the time and the place
that the services are rendered. (Ind. C. 25-27.5-6-1)
Indiana
Medical
Licensing
Board
Yes
© 2018 American Medical Association. All rights reserved.
8
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
PAs at the same
time. (IC 25-
27.5-6-2)
Iowa
Required only if
PA is at a
remote medical
site: Supervising
physician must
review patient
care weekly and
sign all charts
unless an
exception is
provided.
(IAC 645-
327.4(148C))
Physician may
not supervise
more than 5 PAs
at one time.
(IAC 645-
326.8(148C))
Schedule III – V
The PA may
order Schedule
II controlled
substances
which are listed
as depressants in
Iowa Code
chapter 124 only
with the prior
approval and
direction of a
physician.
Supervisory
"Supervision" means that a supervising physician retains
ultimate responsibility for patient care, although a physician
need not be physically present at each activity of the PA or be
specifically consulted before each delegated task is performed.
Supervision shall not be construed as requiring the personal
presence of a supervising physician at the place where such
services are rendered except insofar as the personal presence is
expressly required by these rules or by Iowa Code chapter 148C.
(IAC 645-326.1(148C))
A supervising physician must visit a remote site to provide
additional medical direction, medical services and consultation
at least every two weeks.. When visits are less frequent than
every two weeks in unusual or emergency circumstances, the
board shall be notified in writing of these circumstances. (IAC
645-327.4(148C))
Iowa Board of
Physician
Assistants
Yes
Kansas
Required, but
varies with time
and physician-
PA relationship.
Physician may
not supervise
more than 3
total PAs who
Schedule II-V
Supervisory
The types of supervision shall include direct supervision,
indirect supervision, and off-site supervision as applicable per
the written practice agreement. (KAR 100-28a-1a)
Kansas State
Board of
Healing Arts
Yes
© 2018 American Medical Association. All rights reserved.
9
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
(KAR 100-28a-
10)
provide services
at a different
practice
location. (KAR
100-28A-17)
Additional requirements if the PA is practicing in a location
different than the location that the supervising physician
primarily practices. (KAR 100-28a-14)
Kentucky
Required for a
sufficient
number of
medical notes,
sufficiency
determined at
practice.
(KRS 311.856)
A physician may
not enter into
agreements with
more than 4
PAs, and may
not supervise
more than 4 PAs
at any one time.
(KRS 311.854)
No legend drugs
(Ky. Rev. Stat.
311.858 and
311.856)
Supervisory
Physician is required to provide adequate, active, and continuous
supervision of a PA’s activities to assure that the PA is
performing as directed and complying with the statutes and all
related administrative regulations. (Ky. Rev. Stat. 311.856)
Under specific conditions, a PA may perform services in a
location separate from the supervising physician if the
supervising physician is continuously available via
telecommunication. (KRS 311.860)
Kentucky
Board of
Medical
Licensure
Yes
Louisiana
Required, but
varies based on
practice site
arrangement,
and physician-
PA relationship.
(LAC 46, XLV
4512)
Physician may
not serve as a
primary for
more than 4
PAs. (LAC 46,
XLV 4507)
Schedule II-V
Supervisory
Supervision means responsible direction and control, with the
supervising physician assuming responsibility for the services
rendered by a PA in the course and scope of the PA's
employment.
Supervision shall not be construed in every case to require the
physical presence of the supervising physician. However, the
supervising physician and PA must have the capability to be in
contact with each other by either telephone or other
telecommunication device. Supervision shall exist when the
supervising physician gives informed concurrence of the PA
actions, and when a medical treatment plan or action is made in
accordance with written clinical practice guidelines or protocols.
(LAC 46, XLV 1503)
Louisiana
State Board of
Medical
Examiners
Yes
© 2018 American Medical Association. All rights reserved.
10
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
Maine
None, but
regular (at least
quarterly)
review of
selected charts.
(02-373 Ch. 2 §
4(5)(C))
None
Schedule II-V
Supervisory
A supervising physician is responsible for providing continuous
supervision of the PA. Constant physical presence of the
supervising physician at the time and place that the services are
rendered by the PA is not required so long as the supervising
physician and the PA are, or can be, easily in contact with one
another by electronic communication, including but not limited
to telecommunication; and unless physical presence is necessary
to provide the same quality of patient care as provided by the
physician.
Appropriate supervision shall include: active and continuing
overview of the PA’s activities, immediate availability of the
supervising physician, personal and regular review, and
periodic, in person, education and review sessions. (02-373 Ch.
2 § 4(5))
Board of
Licensure in
Medicine;
joint rules
with Board of
Osteopathic
Medicine
Yes
Maryland
None
Physician may
not delegate
medical acts to
more than 4 PAs
at any one time.
(ACM Health
Occupations
15-302(h))
Schedule II-V
Supervisory
Physician supervision requires continuous physician supervision
mechanisms that are reasonable and appropriate to the practice
setting.
Physician is expected to respond in a timely manner when
contacted by the PA. (ACM Health Occupations § 15-302)
Maryland
Board of
Physicians
Yes
Massachusetts
None
None
Schedule II-VI,
Schedule II must
be reviewed by
Supervisory
Physician must provide direct (physician in room), personal
(physician in building), or general (physician available by
telephone) supervision as appropriate. Supervision is adequate if
it permits a PA who encounters a new problem not covered by a
Board of
Registration of
Physician
Assistants
Yes
© 2018 American Medical Association. All rights reserved.
11
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
supervising
physician within
96 hours.
written protocol, or which exceeds established parameters, to
initiate a new patient care plan and consult with the supervising
physician. (263 CMR 5.04)
Michigan
None
None,
Reasonable
standard-of-
practice
threshold.
Schedule II-V
Participating
PAs in Michigan are no longer required to work under
supervision or delegation of a physician (2017). PAs are
required to work with a participating physician according to the
terms in a written practice agreement.
Notwithstanding any law or rule to the contrary, a PA may make
calls or go on rounds without restrictions on the time or
frequency of visits by a physician or the PA. (MCL 333.17076
(1))
Michigan
Task Force on
Physician
Assistants
Yes
Minnesota
None
None
Schedule II-V
Supervisory
PAs may perform those duties and responsibilities as delegated
in the physician-PA delegation agreement and delegation forms
maintained at the address of record by the supervising physician
and PA.
Patient service must be limited to: services within the training
and experience of the PA, services customary to the practice of
the supervising physician, services delegated by the supervising
physician under the delegation agreement, and services within
the parameters of the laws, rules, and standards of the facilities
in which the PA practices. (Minn. Stat. 147A.09)
Board of
Medical
Practice
Yes
© 2018 American Medical Association. All rights reserved.
12
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
Mississippi
Required for
10% of charts
per month.
(MCA 73-26-5;
R. 1.7)
None
Schedule II-V
Supervisory
New graduate PAs and all PAs whose Mississippi license is their
initial license require the on-site presence of a supervising
physician for 120 days or its equivalent of 960 hours.
The PA's practice shall be confined to the primary office or
clinic of the supervising physician or any hospital(s) or clinic or
other health care facility within 30 miles of where the primary
office is located, where the supervising physician holds medical
staff privileges. (MCA 73-26-5; R. 1.7)
Mississippi
State Board of
Medical
Licensure
Yes
Missouri
Required for
10% of charts
every 14 days.
(MAS 334.735)
Physician may
not serve as
supervising
physician for
more than 3
FTE licensed
PAs. (MAS
334.735)
Schedule II-V
Schedule II
(hydrocodone
only) and III
limited to 5-day
supply with no
refill.
Supervisory
A licensed PA shall practice with a supervising physician
continuously present for at least 1 month before practicing
where a supervising physician is not continuously present.
Unless designated in the code or otherwise in the PA supervision
agreement, the supervising physician must be on-site 66% of
the time (per calendar quarter) that the PA is practicing.
A PA shall be limited to practicing at locations where the
supervising physician is no further than 30 miles by road, or
otherwise so distanced as to create an impediment to effective
intervention, supervision of patient care, or adequate review of
services. (20 CSR 2150-7.135)
Missouri
Board of
Medical
Licensure
Limited
Montana
Required but
varies with PA
experience and
tenure. (MAR
24.156.1623)
Physician may
not supervise
more than one
PA unless
certain criteria
are met. (MAR
Schedule II-V,
Schedule II must
not exceed 34
days
Supervisory
The supervising physician shall meet face-to-face with each PA
a minimum of once a month for the purposes of discussion,
education, and training, to include but not be limited to practice
issues and patient care. (MAR 24.156.1622)
On-site or direct supervision of a PA by a supervising physician
Montana
Board of
Medical
Examiners
Yes
© 2018 American Medical Association. All rights reserved.
13
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
24.156.1622)
is not required if the supervising physician has provided a means
of communication between the supervising physician and the PA
or an alternate means of supervision in the event of the
supervising physician's absence. (MCA 37-20-403)
Nebraska
Required for at
least 20% per
month; 100%
when less than
20 patients.
(NAR Tit. 172,
90-006.08)
Physician may
not supervise
more than 4 PAs
unless good
cause is shown.
(NAR Tit. 172,
90-006.01E)
Schedule II-V
Supervisory
For PAs with less than two years’ experience: A PA with a
temporary NE license shall practice only when the supervising
physician is actually present at the practice site, A PA licensed
for less than 3 months must have the supervising physician
physically present at least 20% of the time, and a PA licensed
for more than 3 months must have the supervising physician
present 10% of the time. (NAR Tit. 172, 90-006.07)
Nebraska
State Board of
Health; PA
Committee
Yes
Nevada
Required for at
least 10% of
charts at least 4
times each year.
(NAC
633.289(3))
Physician may
not supervise
more than 3
total PAs at one
time. (NAC
633.288(6))
Schedule II-V
Collaborative
Agreement
with
Supervising
Physician
The supervising physician shall provide supervision in person at
least once each month to the PA. They must be available for
consultation at all times during which the PA is performing
medical services, and shall develop and carry out a program to
ensure the quality of care provided by the PA. (NAC
633.289(3))
Nevada Board
of Medical
Examiners
Yes
New Hampshire
Regular,
ongoing
evaluation of a
representative
sample of
charts. (N.H.
Physician may
not be the
responsible
supervising
physician for
more than 4
Schedule II-V
Supervisory
The supervising physician shall not be required to be physically
present while the PA is providing care, so long as the
supervising physician and the PA are, or can easily be, in
contact with each other by an electronic communication device.
(N.H. Rules, Med 602.01)
New
Hampshire
Board of
Medicine
Yes
© 2018 American Medical Association. All rights reserved.
14
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
Rules, Med
602.01)
PAs. (N.H.
Rules, Med
602.02)
New Jersey
Required,
physician must
personally
review all charts
and
patient records
and countersign
all medical
orders. (NJAC
13:35-2B.10)
Physician may
not supervise
more than 4 PAs
at any one time.
(NJAC 13:35-
2B.10)
Schedule II-V
Supervisory
The PA shall not render care unless the following conditions are
met: (1) In an inpatient setting, the supervising physician is
continuously or intermittently present on-site with constant
availability through electronic communications for consultation
or recall; (2) In an outpatient setting, the supervising physician
is constantly available through electronic communications for
consultation or recall; (3) The supervising physician regularly
reviews the practice of the PA; (4) The supervising physician
personally reviews all charts and patient records and
countersigns all medical orders. (NJAC 13:35-2B.10)
New Jersey
State Board of
Medical
Examiners
No
New Mexico
None
None
Schedule II-V
Dependent on
Practice Area
Collaboration shall not be construed to require the physical
presence of the licensed physician at the time and place services
are rendered. (SB 215)
New Mexico
Medical Board
No
New York
None
Physician may
not employ or
supervise more
than 4 licensed
PAs in private
practice; or
more than 6
licensed PAs in
a hospital
Schedule II-V
Supervisory
Supervision shall be continuous but shall not necessarily require
the physical presence of the supervising physician at the time
and place where the services are performed. (10 NYCRR 94.2)
New York
State Office of
the
Professions
Yes
© 2018 American Medical Association. All rights reserved.
15
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
setting. (10
NYCRR 94.2)
North Carolina
None
None
Schedule II-V,
Schedule II &
III shall not
exceed a
legitimate 30
day supply
Supervisory
A primary supervising physician and a PA in a new practice
arrangement shall meet monthly for the first six months to
discuss practice relevant clinical issues and quality improvement
measures. Thereafter, the primary supervising physician and the
PA shall meet at least once every six months. (21 NCAC 32S
.0213)
North
Carolina
Medical Board
Yes
North Dakota
None
None
Schedule II-V
Supervisory
Supervision shall be continuous but shall not be construed as
necessarily requiring the physical presence of the supervising
physician at the time and place that the services are rendered.
The supervising physician must be available continuously for
contact personally or by telephone or other electronic means.
(NDAC 50-03-01-04)
North Dakota
Board of
Medicine
Yes
Ohio
Required review
of selected
patient record
entries made by,
Physician may
enter into
supervision
agreements with
Schedule II-V
II limited under
R.C. 4730.411
Supervisory
The supervising physician shall be continuously available for
direct communication with the PA
by either of the following means: (1) Being physically present at
the location where the PA is practicing; or (2) Being readily
State Medical
Board of Ohio
Yes
© 2018 American Medical Association. All rights reserved.
16
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
and medical
orders issued by
the PA. (R.C.
4730.21)
any number of
PAs, but may
not supervise
more than 3 PAs
at any one time.
A PA may enter
into supervision
agreements with
any number of
supervising
physicians.
(R.C. 4730.21)
available to the PA through some means of telecommunication
and being in a location that is a distance from the location where
the PA is practicing that reasonably allows the physician to
assure proper care of patients. (R.C. 4730.21)
Oklahoma
Required only in
a locum tenens
arrangement.
Physician may
not generally
serve as the
supervising
physician for
more than 4 PAs
at any one time
(OAC 435:15-3-
13)
Schedule II-V
Schedule III-V
limited to 30-
day supply with
no refills
Schedule II for
administration
on site.
Supervisory
The supervising physician must oversee the activities of, and
accept responsibility for, the medical services rendered by a PA.
The constant physical presence of the supervising physician is
not required as long as the supervising physician and PA are or
can be easily in contact with each other by telecommunication.
(Okla. PA Act 519.2)
Oklahoma
Medical Board
Yes
© 2018 American Medical Association. All rights reserved.
17
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
Oregon
None
Physician not
acting as part of
a supervising
physician
organization
may supervise 4
PAs, unless the
board approves
otherwise. (ORS
677.510)
Schedule II-V
Supervisory
The supervising physician need not be physically present at all
times when the PA is providing services, but maybe required to
ensure that: (1) The PA have access to personal or telephone
communication with a supervising physician when the PA is
providing services; and (2) The proximity of a supervising
physician and the methods and means of supervision are
appropriate to the practice setting and the patient conditions
treated in the practice setting. (ORS 677.510)
Oregon
Medical Board
Yes
Pennsylvania
Required for
100% -
decreasing with
PA experience.
(63 PS 422.13)
Physician may
not supervise
more than 4 PAs
at any time. (63
PS 422.13)
Schedule II-V,
Schedule II
limited to 72
hours with
notification to
supervising
physician within
24 hours of
issuance.
Supervisory
The constant physical presence of the supervising physician is
not required so long as the supervising physician and the PA are,
or can be, easily in contact with each other by radio, telephone
or other telecommunications device.
An appropriate degree of supervision includes:
active and continuing overview of the PA’s activities to
determine that the physician’s directions are being implemented,
immediate availability of the supervising physician to the PA for
necessary consultations, and personal and regular review within
10 days by the supervising physician of the patient records upon
which entries are made by the PA. (Pa. Code 18.122)
Pennsylvania
State Board of
Medicine
Yes
© 2018 American Medical Association. All rights reserved.
18
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
Rhode Island
None
None
Schedule II-V
Supervisory
Supervision means overseeing the activities of, and accepting
the responsibility for, the medical services rendered by the PAs.
Supervision shall be continuous and under the direct control of a
licensed physician expert in the field of medicine in which the
PA practices.
The constant physical presence of the supervising physician is
not required in every circumstance. It is the responsibility of the
supervising physician and PA to assure an appropriate level of
supervision depending upon the services being rendered. (216
RICR 40-05-24.6.2)
Board of
Licensure for
Physician
Assistants
Yes
South Carolina
Required for
10% per month
when PA works
off- site (PA
Pract. Act 40-
47-955)
Physician may
not
simultaneously
supervise more
than 3 FTE PAs
providing
clinical service
at one time. (PA
Pract. Act 40-
47-910. 955)
Schedule II-V
For schedule II
must only be an
initial dose and
must not exceed
a72-hour supply
Supervisory
Supervision must be continuous but must not be construed as
necessarily requiring the physical presence of the supervising
physician at the time and place where the services are rendered,
except as otherwise required for limited licensees.
A PA must have 6 months of clinical experience with the current
supervising physician before being permitted to practice at a
location off-site from the supervising physician. The off-site
location may not be more than 60 miles of travel from the
supervising physician or alternate supervising physician without
written approval of the board. (PA Pract. Act 40-47-910. 955)
South
Carolina
Board of
Medical
Examiners
Yes
© 2018 American Medical Association. All rights reserved.
19
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
South Dakota
None
Physician may
supervise up to
4 FTE PAs with
board approval.
(SDCL 36-4A-
29.1)
Schedule II-V
Schedule II not
exceeding 30
days
Supervisory
Supervision may be by direct personal contact, or by a
combination of direct personal contact and contact via
telecommunication, as may be required by the board. If the
office of a PA is separate from the main office of the supervising
physician, the supervision shall include on-site personal
supervision by a supervising physician as required by the board.
(SDLRC 36-4A-29)
South Dakota
Board of
Medical and
Osteopathic
Examiners
Yes
Tennessee
Required for at
least 20% of
charts, and
100% of charts
of specific
categories of
patients every
30 days. (TCR
0880-02-.18)
None
Schedule II-V
II and III
typically limited
to 30-day supply
Supervisory
Supervision does not require the continuous and constant
presence of the supervising physician. However, the supervising
physician must be available for consultation at all times or shall
make arrangements for a substitute physician to be available.
(TCR. 0880-02-.18)
Tennessee
Committee on
Physician
Assistants
Yes
Texas
Required chart
review for
prescriptive
authority
determined by
practice
agreement. (22
TAC 185.31)
None. Physician
may delegate
prescriptive
authority to a
maximum of 7
PAs or their
FTE. (TAC
157.0512)
Schedule II-V,
II only under
Chapter 481
Provisions
III-V limited to
90-day supply
Supervisory
Supervision shall be continuous, but shall not be construed as
necessarily requiring the constant physical presence of the
supervising physician at a place where PA services are
performed while the services are performed. Telecommunication
shall always be available. (22 TAC 185.14)
Texas Medical
Board
Yes
© 2018 American Medical Association. All rights reserved.
20
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
Utah
Required for a
sufficient
number of charts
and records to
ensure that the
patient's health,
safety, and
welfare will not
be adversely
compromised.
(UAC R156-
70a)
Physician may
not supervise
more than 4
FTE PAs
without prior
approval. (UAC
R156-70a)
Schedule II-V
Supervisory
The supervising physician shall provide supervision to the PA to
adequately serve the health care needs of the practice population
and ensure that the patient's health, safety and welfare will not
be adversely compromised. The degree of on-site supervision
shall be outlined in the Delegation of Services Agreement
maintained at the site of practice.
There shall be a method of immediate consultation by electronic
means whenever the PA is not under the direct supervision of
the supervising physician. (UAC R156-70a)
Utah
Physician
Assistant
Licensing
Board
Yes
Vermont
Regular, review
of selected
charts with
documentation
within 72-hours
of provision of
care. (VAC 12-
5-200:7)
Physician may
not supervise
more PAs
concurrently
than have been
approved by the
Board after
review of the
system of care
delivery. (VAC
12-5-200:7)
Schedule II-V
Supervisory
As determined by the Board, supervision entails the direction
provided, and review performed, by the supervising physician of
the medical services provided by the PA. The supervising
physician need not be present on the premises where the PA
renders medical services and may provide supervision by
telephonic or electronic means of communication. (VAC 12-5-
200:5)
Vermont
Board of
Medical
Practice
Yes
Virginia
Required if
established in
practice
Physician may
not supervise
more than 6 PAs
Schedule II-V
Supervisory
The physician shall provide continuous supervision as required
by this section. However, the requirement for physician
supervision of PAs shall not be construed as requiring the
Virginia
Board of
Medicine
Yes
© 2018 American Medical Association. All rights reserved.
21
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
agreement. (18
VAC 85-50-
101)
at any one time.
(450 Va. C.
54.12952)
physical presence of the supervising physician during all times
and places of service delivery by PAs. Each team of supervising
physician and PA shall identify the relevant PA's scope of
practice, including the delegation of medical tasks as appropriate
to the PA's level of competence, the PA's relationship with, and
access to, the supervising physician, and an evaluation process
for the PA's performance. (450 Va. C. 54.12952)
Washington
None
Physician may
not enter into
delegation
agreements with
more than 5
PAs, but may
petition the
commission for
a waiver of this
limit. (WAC
246-918-055)
Schedule II-V
Supervisory
The supervising physician and the PA shall determine which
procedures may be performed and the degree of supervision
under which the procedure is performed. (WAC 246-918-055)
Washington
State Medical
Commission
Yes
West Virginia
None
Physician may
not enter into
practice
agreements with
more than 5 FT
PAs at any one
time. (W. Va. C.
30–3E–9)
Schedule III-V,
Schedule III
shall be limited
to a 30-day
supply without
refill.
Collaborative
Collaboration means overseeing the activities of, and accepting
responsibility for, the medical services rendered by a PA.
Constant physical presence of the collaborating physician is not
required as long as the physician and PA are, or can be, easily in
contact with one another by telecommunication.
Collaboration does not require the personal presence of the
collaborating physician at the place or places where services are
rendered. (W. Va. C. 30–3E–1)
West Virginia
Board of
Medicine
Yes
© 2018 American Medical Association. All rights reserved.
22
State
Co-Signature
PA Ratios
Rx Authority
Supervision/
Collaboration
Language
Supervision/Collaboration Requirements/“Barriers”
Physician/PA
Board?
Scope
Determined
at Practice
Site?
Wisconsin
None
Physician may
not supervise
more than 4 on-
duty PAs at any
time unless a
written plan to
do so has been
submitted to and
approved by the
board. (WAC
Med 8.10)
Schedule II-V
Supervisory
A supervising physician shall be available to the PA at all times
for consultation either in person or within 15 minutes of contact
by telecommunication or other means. (WAC Med 8.10)
Wisconsin
Medical
Examining
Board
No
Wyoming
None
Physician may
not supervise
more than 3
PAs. (Wy. Med.
Pract. Act 33-
26-504)
Schedule II-V
Supervisory
Supervision means the ready availability of the supervising
physician for consultation and direction of the activities of the
physician assistant. Contact with the supervising physician by
telecommunications is sufficient to show ready availability if the
board finds that such contact is sufficient to provide quality
medical care. (Wy. Med. Pract. Act 33-26-501)
Wyoming
Board of
Medicine
Yes
December 2017
