Q: May a hospital, hospital system, or multi-specialty group practice temporarily reassign a physician assistant to a new practice area to meet a critical need without submitting a new intent to practice and updating supervisory arrangements?
A: Yes, with conditions.
During the current state of emergency, if a PA is reassigned to a new practice area within the same facility (i.e., hospital, multi-specialty group practice), the primary supervising physician and facility administration should ensure the following:
• The PA is reassigned to perform only those medical tasks which the physician assistant is competent and qualified to do, and
• The PA has reasonable and immediate access to a physician, either in person or electronically, should medical issues arise.
To reduce administrative burden during the current state of emergency, NCMB has temporarily waived the requirement to submit a new Intent to Practice form or other paperwork, such as an updated supervisory agreement, prior to, or after, the reassignment.
During the temporary emergency reassignment, the PA is expected to comply with all other applicable rules including the requirement to confer at least monthly with a physician to ensure meaningful supervision and quality assurance within the new practice setting.
Once Governor Cooper has lifted the state of emergency, any PA who continues practicing in the new setting is expected to file a new Intent to Practice and update his or her supervisory arrangements within 30 days.
NCMB and the NC Board of Nursing, which jointly regulate nurse practitioners (NP), have approved similar provisions to allow paperwork-free emergency reassignments for NPs. Read NCMB’s order authorizing this.
In response to the pandemic, does a reassigned PA need to change the required information on his or her prescriptions to reflect the new practice arrangement?
The Board staff recognizes the practical limitations and burdens an emergency reassignment may present and offers the following: the PA should make reasonable efforts to ensure there is accurate contact information on each prescription for a pharmacy or patient to use should there be any questions about a particular prescription.
What does the Board mean when it says a PA should “confer” at least monthly with a physician? Does it need to be documented?
Until December 31, 2021, SL 2020-3 supersedes section 2 of the Order, which requires monthly conferences. See the FAQ on how the Board interprets “other applicable rules.”
The Board’s Order related to emergency reassignments states that PAs reassigned within a facility or multi-specialty practice do not have to file a new intent to practice with the Board or update their supervisory arrangement prior to beginning the new assignment. However, the Order also states the reassigned PA is expected to comply with all other applicable Board rules. What are the “other applicable Board rules”?
“Other applicable Board rules” means all other rules found in 21 NCAC 32S ; however, PAs licensed prior to February 1, 2020, do not have to hold monthly quality improvement meetings so long as they were practicing within their scope practice before February 1, 2020, and continue to do so. Newly licensed physician assistants and reassigned physician assistants working outside of their scope are not required to have monthly quality improvement meetings for the first six months but do need to meet every six months. SL 2020-3 supersedes section 2 of the Order which states the physician assistant must “confer at least monthly with a physician to ensure meaningful supervision and quality assurance within the new practice setting.”
Even though quality improvement meetings are no longer required under certain circumstances per SL 2020-3, physician assistants and their supervising physicians may still choose to have these meetings. The Board encourages physician assistants and their supervising physicians to continue to engage in quality improvement processes to ensure high quality patient care.
Is the physician who confers with a PA who has been reassigned the PA’s Primary Supervising Physician?
No. If a reassignment lasts longer than six months for a newly licensed physician assistant or a physician assistant working outside of his or her scope such that a quality improvement meeting shall be held, then any physician who is familiar with the physician assistant’s practice in the new setting can conduct the meeting.
If a fully licensed PA chooses to volunteer, how does the volunteer PA meet the intent to practice and supervisory requirements?
When a PA volunteers, he or she must still submit an intent to practice notification with the Board designating a primary supervising physician. SL 2020-3 applies to volunteer physician assistants.
Q: Are physician assistants and nurse practitioners, including out-of-state clinicians volunteering in North Carolina, required to have a supervising physician during the current state of emergency?
A: Yes. Physician assistants and nurse practitioners, including those who are licensed elsewhere but volunteering in North Carolina during the state of emergency, are subject to the laws and rules of North Carolina. Both physician assistants and nurse practitioners are required to have a supervising/collaborating physician prior to practicing in North Carolina. You can find the rules for physician assistants here and nurse practitioners here.