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Supervision

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Physician Supervision Questions

What written form of “Supervisory Arrangement” is required between a PA and supervising physician?

A supervisory arrangement is a written statement that describes medical acts, tasks and functions (including prescriptive authority instructions) delegated to the PA by the primary supervising physician appropriate to the PA’s qualification, training, skill and competence. The primary supervising physician and the PA must sign and date the supervisory arrangement, keep it on file at all practice sites and make it available to the Board if requested.

If there is a back-up supervising physician, they are required to complete the back-up supervising physician form. This form must be signed and dated by the back-up supervising physician, primary supervising physician and the PA.  This form must be kept onsite as a part of the supervisory arrangement.

How many PAs can a physician supervise?

There is no specific limit. However, the supervising physician is expected to provide adequate supervision and comply with all applicable laws and rules.

How many supervising physicians are required to be designated for each PA?

A PA is only required to have one primary supervising physician. The primary supervising physician is the physician who accepts full responsibility and liability for the PA’s medical activities and professional conduct at all times, whether the physician personally is providing supervision or supervision is being provided by a back-up supervising physician.

A physician assistant is not required to have a back-up supervising physician but is encouraged to have one during those times a primary supervising physician may not be readily available. The back-up supervising physician is the physician who accepts responsibility for supervision of PA’s activities in absence of primary supervising physician. The back-up supervising physician is responsible and liable for PA’s activities ONLY when providing supervision.

All supervising physicians must be licensed by NCMB and not prohibited from supervising PAs. Primary and back-up supervising physicians must ensure PA has adequate back-up for any procedure performed by PA in any practice location (office, home, hospital, etc.).

Is the supervising physician responsible for the PA’s medical acts?

Yes, the supervising physician is accountable to the Board for the physician assistant’s medical activities and professional conduct at all times, whether the physician personally is providing supervision or the supervision is being provided by a Back-up Supervising Physician.

Does the NCMB specify what medical tasks a PA may perform?

No. The primary supervising physician must ensure that the PA’s scope of practice is clearly identified and that the delegation of the medical tasks is appropriate to the skills and competencies of both the supervising physician and the PA.

Is on-site, physical presence of supervising physician required at all times the PA is practicing?

No. However, PAs may not practice without a primary supervising physician in place. Physician and PA teams must ensure that the PA’s scope of practice is identified, that the delegation of medical tasks is appropriate to the skills of the supervising physician as well as the PA’s competence level, and that the relationship of, and access to, each supervising physician is defined, and that the PA’s performance evaluation process is established.

Does the supervising physician have to cosign inpatient chart entries made by a PA?

No, this is not required under state law or by the NCMB. However, PA entries into inpatient charts (hospital, long-term care facilities) must comply with the institution’s rules and regulations. This means that any given supervising physician, medical practice, hospital or medical facility is free to impose its own guidelines, including co-signing of patient charts, and the physician assistant is expected to comply with that physician’s or institution’s rules and regulations.

How often must a supervising physician meet with the PA?

First six months of new supervisory arrangement: The primary supervising physician and the PA in a new practice arrangement must meet monthly for first six months to discuss relevant clinical problems and quality improvement measures.

After first six months: The primary supervising physician and PA must meet at least every six months to discuss relevant clinical problems and quality improvement measures.
A record of all of these meetings must be signed and dated by both primary supervising physician and PA and be available for NCMB representative inspection.

Do PAs need to meet face-to-face with their primary supervising physician for quality improvement meetings?

No. The NCMB accepts electronic communication between a PA and his or her primary supervising physician as valid quality improvement meetings as long as the spirit of Rule 21 NCAC 32S.0213 (d) Supervision of Physician Assistants is satisfied.

What does the Board expect to be documented in a PA/Primary Supervising Physician’s record of meetings?

The physician assistant and his or her Primary Supervising Physician should document a discussion of relevant clinical issues.  The meeting and its documentation can take a variety of forms.  Some PA/physician teams perform a medical record review while others structure the meeting as a journal club or choose a specific clinical topic for review.  As long as the meetings occur, are documented and signed, and include a substantive discussion or review of relevant clinical issues, then the documentation requirement for meetings is likely to meet Board expectations.

May PAs and their supervising physicians use an electronic signature for those supervisory documents requiring a signature per Board rules?

Yes. Board rules 21 NCAC 32S.0213 (d) and (e) require signatures by the physician assistant, primary supervising physicians, and if applicable, back-up supervising physicians for supervisory arrangements and quality improvement meetings. Rule 21 NCAC 32S .0215 requires a current list of signatures from the physician assistant, primary supervising physician, and all backup supervising physicians. For these documents, an electronic signature is acceptable.

A PA I no longer supervise is still listed as my supervisee on my online profile on NCMB’s website. How can I remove the PA?

To remove a former supervisee, email NCMB at .(JavaScript must be enabled to view this email address) and indicate your need to have a PA removed from your active supervisees. Physicians are not able to remove former supervisees on their own. If the former supervisee is a nurse practitioner, contact the NC Board of Nursing.

Physician Assistant Supervision Questions

Do I need a primary supervising physician prior to applying for a PA license?

No; however, you may not commence practice until you receive notification that your Intent to Practice form has been processed by the Board.

What’s the best way to complete the Intent to Practice form?

Intent to Practice forms are processed on the Board’s website. You may access the ITP form and check the status of your current and past supervisory relationships by logging into your Licensure Gateway.

I completed my Intent to Practice form, when can I begin practicing?

You must see “active” under your name and the primary supervising physician’s name along with the date on the website in order to begin practicing. An email acknowledging receipt of the ITP will be sent to the PA and the supervising physician. The Board no longer sends letter via snail mail. A copy of the emailed ITP acknowledgment should be kept at all practice sites.

Must I receive written acknowledgement of my Intent to Practice from NCMB before I may practice?

No. You can verify your Intent to Practice was received by utilizing NCMB’s Licensee Search tool. If you look up your name on the website and can see your name as active with the primary supervising physician’s name as active along with the date, you can begin practicing. The Intent to Practice acknowledgement letter is emailed to the physician assistant and to the primary supervising physician once the ITP is completed online. PAs and their primary supervising physician(s) should keep a copy of the Intent to Practice acknowledgment letter at all practice sites. The NCMB provides copies of Intent to Practice letters in the PAs Licensure Gateway.

Does the NCMB specify what medical tasks a PA may perform?

No. The primary supervising physician must ensure that the PA’s scope of practice is clearly identified and that the delegation of the medical tasks is appropriate to the skills and competencies of both the supervising physician and the PA.

What is meant by “scope of practice”?

A PA’s scope of practice includes those medical acts, tasks or functions, including prescribing and dispensing of drugs and medical devices, that are delegated by the supervising physician in his or her individualized supervisory arrangement.

What written form of “Supervisory Arrangement” is required between a PA and supervising physician?

A supervisory arrangement is a written statement that describes medical acts, tasks and functions (including prescriptive authority instructions) delegated to the PA by the primary supervising physician appropriate to the PA’s qualification, training, skill and competence. The primary supervising physician and the PA must sign and date the supervisory arrangement, keep it on file at all practice sites and make it available to the Board if requested.

If there is a back-up supervising physician, they are required to complete the back-up supervising physician form. This form must be signed and dated by the back-up supervising physician, primary supervising physician and the PA.  This form must be kept onsite as a part of the supervisory arrangement.

Is the supervising physician responsible for the PA’s medical acts?

Yes, the supervising physician is accountable to the Board for the physician assistant’s medical activities and professional conduct at all times, whether the physician personally is providing supervision or the supervision is being provided by a Back-up Supervising Physician.

How often must a supervising physician meet with the PA?

First six months of new supervisory arrangement: The primary supervising physician and the PA in a new practice arrangement must meet monthly for first six months to discuss relevant clinical problems and quality improvement measures.

After first six months: The primary supervising physician and PA must meet at least every six months to discuss relevant clinical problems and quality improvement measures.
A record of all of these meetings must be signed and dated by both primary supervising physician and PA and be available for NCMB representative inspection.

Do I need to send NCMB a list of backup supervising physicians?

No, but you are required to keep a backup supervising physician list at all practice sites of all backup supervising physicians. The lists must be signed and dated by each backup supervising physician, the primary supervising physician, and the PA.

Do PAs need to meet face-to-face with their primary supervising physician for quality improvement meetings?

No. The NCMB accepts electronic communication between a PA and his or her primary supervising physician as valid quality improvement meetings as long as the spirit of Rule 21 NCAC 32S.0213 (d) Supervision of Physician Assistants is satisfied.

What does the Board expect to be documented in a PA/Primary Supervising Physician’s record of meetings?

The physician assistant and his or her Primary Supervising Physician should document a discussion of relevant clinical issues.  The meeting and its documentation can take a variety of forms.  Some PA/physician teams perform a medical record review while others structure the meeting as a journal club or choose a specific clinical topic for review.  As long as the meetings occur, are documented and signed, and include a substantive discussion or review of relevant clinical issues, then the documentation requirement for meetings is likely to meet Board expectations.

I lost my primary supervising physician on short notice. What should I do?

The Board has an emergency policy to cover these situations. It involves notifying the Board within two days of the loss of supervisor and securing a new primary while practicing during a 30-day grace period.

Do NC rules for PAs apply to those employed by the federal government and working in a federal facility?

The federal government may employ a PA to work in a federal facility in North Carolina without requiring the PA to hold a NC license. However, many PAs employed by the federal government and working in federal facilities do hold an active NC license.

Federally employed PAs are governed by federal rules and regulations in regard to how they practice while working within federal facilities. However, a federally employed PA who holds a NC license and wants to maintain the license must comply with NC rules that pertain to maintaining an active license (i.e., annual renewal, CME and payment of fees). Also, any PA who carries a NC license is expected to practice competently, act professionally and be of requisite good character no matter where, or for whom, he or she works. PAs employed by federal facilities are not required to submit an Intent to Practice Form with the Board prior to beginning their practice at the federal facility.

May PAs and their supervising physicians use an electronic signature for those supervisory documents requiring a signature per Board rules?

Yes. Board rules 21 NCAC 32S.0213 (d) and (e) require signatures by the physician assistant, primary supervising physicians, and if applicable, back-up supervising physicians for supervisory arrangements and quality improvement meetings. Rule 21 NCAC 32S .0215 requires a current list of signatures from the physician assistant, primary supervising physician, and all backup supervising physicians. For these documents, an electronic signature is acceptable.

Are physician assistants working part time or locum tenens positions required to document PA/supervising physician meetings at the same intervals as full time physician assistants?

Yes.  There is no exception in the rules for physician assistants working part time or locum tenens positions.  Physician assistants in any new practice arrangement are expected to meet monthly with their primary supervising physician for six months, then every six months thereafter.  Physician assistants must make and maintain a written record of these meetings as required by board rule, 21 NCAC 32S .0213(e).

May a PA supervise a physician in a resident training program?

No. A physician in a resident training program must be supervised by a fully licensed physician.

How many supervising physicians are required to be designated for each PA?

A PA is only required to have one primary supervising physician. The primary supervising physician is the physician who accepts full responsibility and liability for the PA’s medical activities and professional conduct at all times, whether the physician personally is providing supervision or supervision is being provided by a back-up supervising physician.

A physician assistant is not required to have a back-up supervising physician but is encouraged to have one during those times a primary supervising physician may not be readily available. The back-up supervising physician is the physician who accepts responsibility for supervision of PA’s activities in absence of primary supervising physician. The back-up supervising physician is responsible and liable for PA’s activities ONLY when providing supervision.

All supervising physicians must be licensed by NCMB and not prohibited from supervising PAs. Primary and back-up supervising physicians must ensure PA has adequate back-up for any procedure performed by PA in any practice location (office, home, hospital, etc.).

I am changing primary supervising physicians and will no longer be working with my current supervisor. Do I need to notify the Board?

Yes. It is the responsibility of the PA to submit an online Intent to Practice (ITP) form via NCMB’s website to remove a primary supervising physician. Login to your Licensure Gateway account and select Intent to Practice from the options. Physicians are not able to remove former supervisees on their own.