Avoiding common pitfalls in PA practice
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Physician assistants and their supervising physicians often face a variety of challenging issues when obtaining and maintaining a license to practice medicine in North Carolina. The appropriate course of action is not always apparent, and unintentional missteps can sometimes land PAs, and/or their supervising physicians, in trouble with the Medical Board.
This article will review a selection of scenarios that involve common issues related to PA practice in NC and provide guidance on how to proceed in an appropriate manner. Becoming educated about these issues and their remedies may help both new and seasoned PAs avoid some of the common pitfalls of successful practice in North Carolina.
Scenario 1: No license, no practice – period
A new PA graduate is offered a job before successfully passing the PA National Certifying Examination (PANCE), a requirement for licensure in North Carolina. As the PA is preparing to begin practice, he is notified that he did not pass the PANCE. The PA’s well-intentioned employer extends an offer to the PA to shadow in the office while preparing for a second attempt on the exam. The practice offers a small stipend to the PA to offset living expenses, which the PA accepts. Meanwhile, the NC Medical Board receives information that an unlicensed, uncertified PA is “practicing” with the medical group. A Board investigation determines that the PA did, in fact, perform medical tasks. The Board issues the PA a nondisciplinary Public Letter of Concern, which is a public document posted on his information page on the NCMB website. The letter will remain on the PA’s record for the rest of his career and will likely need to be disclosed on all future license applications, hospital privilege applications, health insurance credential applications, etc.
Determining what a PA graduate can and cannot lawfully do before obtaining licensure in North Carolina is a frequent area of confusion for PAs and supervisors.
To obtain a license in North Carolina, PAs must complete an accredited PA program, and if applying for initial licensure, must successfully complete the PANCE and meet all other requirements. Once licensed, a PA cannot perform medical acts until he or she completes the Intent to Practice form on the Board’s website and confirms that the Board has received and processed the PA’s submission (an easy way to do this is to look up the supervising physician using the “Look Up a Licensee” tool on the Board’s website. If the PA’s name appears under that physician’s name as a supervisee, the ITP has been processed).
If any medical tasks are performed by the PA before he or she is licensed and listed as a supervisee, it constitutes practicing without a license and may result in discipline by the Board. Peggy Robinson, PA-C, a member of the faculty at Duke University’s PA Program who completes her second term on the Medical Board in October, has said that it’s best for new PA graduates to “keep their hands in their pockets” until they are fully licensed. In other words, the PA should refrain from performing any duties that can lead to practicing without a license or even giving the appearance of doing so. Remember, an unlicensed new graduate actually has less privilege than a current PA student to perform medical acts, because PA regulations do not apply to students. The Board recommends that PAs wait until they are “official” to avoid problems.
Scenario 2: Suddenly supervisor-less
A licensed PA with several years of clinical practice places an urgent call to the Board. She explains that her primary supervising physician has developed a sudden illness that will make it impossible for the physician to continue as her supervisor. The PA does not have a suitable backup physician who can take over as her primary supervising physician. The PA works in a busy primary care practice, where she carries an active caseload of more than 2,000 patients. She is concerned about a possible interruption in her ability to continue to care for her patients due to the loss of her primary supervising physician. NC law authorizes PAs to practice medicine only under the oversight of a primary supervising physician. Situations arise, however, when a PA loses a primary supervising physician due to circumstances out of his or her control. The Board has a policy to address these situations. When a primary supervisor is unable to continue supervision, the PA shall notify the Board within two (2) business days of the emergency situation by first calling the Board and then following up with a letter describing the emergency situation. The PA then has 30 days to submit an Intent to Practice for a new primary supervising physician.
Scenario 3: Shadowing before resuming practice
A PA who had been out of clinical practice for eight years asks a physician colleague if he can shadow the physician as the PA prepares to reenter the workforce. Under some circumstances it is permissible for a non-licensee to shadow a physician. However, it is recommended that a PA whose ultimate goal is to regain licensure wait until the license is issued before shadowing or observing in a clinical setting. While lay and unlicensed people may perform delegated tasks in a physician’s office, PAs are not allowed to perform medical acts under any circumstances without an active PA license. In the Board’s view, it is too easy for an unlicensed PA who begins shadowing with the best of intentions to slip into performing medical acts (practicing without a license).
Any applicant who has been out of active clinical practice for two or more years (eight years in this example) would be required to complete a program of reentry to clinical practice, which consists of a period of mentoring under the supervision of a Board-approved physician mentor. Typically, the first phase of a reentry program involves having the reentering applicant shadow his or her physician mentor. The reentry process is designed to ensure that the reentering licensee has ample time to reacclimate to clinical practice before they are cleared for a full and unrestricted license.
Katharine D. Kovacs PA-C is the staff physician assistant in the NCMB’s Office of the Medical Director. Jane Paige is a physician assistant licensing coordinator at the Board.
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More Information
This article will review a selection of scenarios that involve common issues related to PA practice in NC and provide guidance on how to proceed in an appropriate manner. Becoming educated about these issues and their remedies may help both new and seasoned PAs avoid some of the common pitfalls of successful practice in North Carolina.
Scenario 1: No license, no practice – period
A new PA graduate is offered a job before successfully passing the PA National Certifying Examination (PANCE), a requirement for licensure in North Carolina. As the PA is preparing to begin practice, he is notified that he did not pass the PANCE. The PA’s well-intentioned employer extends an offer to the PA to shadow in the office while preparing for a second attempt on the exam. The practice offers a small stipend to the PA to offset living expenses, which the PA accepts. Meanwhile, the NC Medical Board receives information that an unlicensed, uncertified PA is “practicing” with the medical group. A Board investigation determines that the PA did, in fact, perform medical tasks. The Board issues the PA a nondisciplinary Public Letter of Concern, which is a public document posted on his information page on the NCMB website. The letter will remain on the PA’s record for the rest of his career and will likely need to be disclosed on all future license applications, hospital privilege applications, health insurance credential applications, etc.
Determining what a PA graduate can and cannot lawfully do before obtaining licensure in North Carolina is a frequent area of confusion for PAs and supervisors.
To obtain a license in North Carolina, PAs must complete an accredited PA program, and if applying for initial licensure, must successfully complete the PANCE and meet all other requirements. Once licensed, a PA cannot perform medical acts until he or she completes the Intent to Practice form on the Board’s website and confirms that the Board has received and processed the PA’s submission (an easy way to do this is to look up the supervising physician using the “Look Up a Licensee” tool on the Board’s website. If the PA’s name appears under that physician’s name as a supervisee, the ITP has been processed).
If any medical tasks are performed by the PA before he or she is licensed and listed as a supervisee, it constitutes practicing without a license and may result in discipline by the Board. Peggy Robinson, PA-C, a member of the faculty at Duke University’s PA Program who completes her second term on the Medical Board in October, has said that it’s best for new PA graduates to “keep their hands in their pockets” until they are fully licensed. In other words, the PA should refrain from performing any duties that can lead to practicing without a license or even giving the appearance of doing so. Remember, an unlicensed new graduate actually has less privilege than a current PA student to perform medical acts, because PA regulations do not apply to students. The Board recommends that PAs wait until they are “official” to avoid problems.
Scenario 2: Suddenly supervisor-less
A licensed PA with several years of clinical practice places an urgent call to the Board. She explains that her primary supervising physician has developed a sudden illness that will make it impossible for the physician to continue as her supervisor. The PA does not have a suitable backup physician who can take over as her primary supervising physician. The PA works in a busy primary care practice, where she carries an active caseload of more than 2,000 patients. She is concerned about a possible interruption in her ability to continue to care for her patients due to the loss of her primary supervising physician. NC law authorizes PAs to practice medicine only under the oversight of a primary supervising physician. Situations arise, however, when a PA loses a primary supervising physician due to circumstances out of his or her control. The Board has a policy to address these situations. When a primary supervisor is unable to continue supervision, the PA shall notify the Board within two (2) business days of the emergency situation by first calling the Board and then following up with a letter describing the emergency situation. The PA then has 30 days to submit an Intent to Practice for a new primary supervising physician.
Scenario 3: Shadowing before resuming practice
A PA who had been out of clinical practice for eight years asks a physician colleague if he can shadow the physician as the PA prepares to reenter the workforce. Under some circumstances it is permissible for a non-licensee to shadow a physician. However, it is recommended that a PA whose ultimate goal is to regain licensure wait until the license is issued before shadowing or observing in a clinical setting. While lay and unlicensed people may perform delegated tasks in a physician’s office, PAs are not allowed to perform medical acts under any circumstances without an active PA license. In the Board’s view, it is too easy for an unlicensed PA who begins shadowing with the best of intentions to slip into performing medical acts (practicing without a license).
Any applicant who has been out of active clinical practice for two or more years (eight years in this example) would be required to complete a program of reentry to clinical practice, which consists of a period of mentoring under the supervision of a Board-approved physician mentor. Typically, the first phase of a reentry program involves having the reentering applicant shadow his or her physician mentor. The reentry process is designed to ensure that the reentering licensee has ample time to reacclimate to clinical practice before they are cleared for a full and unrestricted license.
Katharine D. Kovacs PA-C is the staff physician assistant in the NCMB’s Office of the Medical Director. Jane Paige is a physician assistant licensing coordinator at the Board.
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More Information
- PAs are expected to be familiar with applicable laws, rules and position statements, all of which are available on the Board’s website. Review this information at least annually, perhaps when renewing your license.
- Answers to the questions raised in this article, and many others, are provided in the PA “Frequently Asked Questions” or FAQs on the Board’s website.
- If you, your supervising physician or employer are confused about any aspect of PA licensure and acceptable conduct or practice, call 919-326-1000 or 1-800-253-9653 and ask to speak to the PA liaison or PA license coordinator.
