Frequently Asked Questions about Supervising Physician Assistants

Does a physician need approval to supervise a PA?
How many PAs can a physician supervise?
What is the scope of practice of a PA?
How do I verify a PA license?
What documents are required to supervise a PA?
Can a PA practice independently??
Why supervision is required for a PA?
Is the supervising physician required to be on-site when the PA is practicing?
Are PAs allowed to write drug orders?
What information must be on a PA's drug order?
Is a PA allowed to issue drug orders for controlled substances?
Can the PA use the supervising physician's DEA number on drug orders for controlled substances?
Is the supervising physician required to sign all of the patient's medical records?
Can a PA perform surgery?
Can a PA evaluate a patient for the medical use of Marijuana?
Can medical assistants be supervised by a physician assistant in the absence of a physician and surgeon?

1. 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.

2. How many PAs can a physician supervise?

Current law limits a physician to supervise no more than four PAs at any moment in time.

3. What is the scope of practice of a PA?

Article 4 of the Board's regulations addresses PA practice. You may want to review Title 16, California Code of Regulations sections 1399.540 through 1399.546 for information on the supervision of PAs.

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.

4. How do I verify a PA's license?

You can verify a PA license on-line, or call (916) 561-8780.

5. 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.

6. 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.

7. What supervision is required for a PA?

The supervising physician may choose one or more of the following four mechanisms to provide the supervision as required by Section 1399.545 of Title 16 of the California Code of Regulations.

  1. The physician sees the patients the same day that they are treated by the PA.
  2. The physician reviews, signs and dates the medical record of every patient treated by the physician assistant within thirty days of the treatment.
  3. The physician adopts written protocols which specifically guide the actions of the PA. The physician must select, review, sign and date at least 5% of the medical records of patients treated by the physician assistant according to those protocols within 30 days.
  4. Or, in special circumstances, the physician provides supervision through another mechanism approved in advance by the Board.

8. 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.

9. 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

10. 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.

11. 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. The medical record of any patient for a Schedule II drug order must be reviewed, countersigned, and dated by the supervising physician within 7 days.

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.

12. 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.

13. Is the supervising physician required to sign all of the patient's medical records?

It depends on the method of supervision used by the supervising physician.

If the supervising physician adopts written protocols that specifically guide the action of the PA, the physician must select, review, sign and date at least 5% of the medical records of patients treated by you within 30 days, pursuant to Business and Professions Code section 3502.

If protocols are not in place, then the supervising physician must either

  1. examine the patient the same day as the care is provided by the PA or
  2. countersign and date all medical records of all patients cared for by the PA within 30 days.

14. 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.

15. 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: www.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: www.mbc.ca.gov/Licensees/Prescribing/.

16. 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.

For further information concerning medical assistants, visit the Medical Board of California's website at http://www.mbc.ca.gov/licensees/physicians_and_surgeons/medical_assistants