2013 physician assistant site visits find most in compliance, but serious violations persist
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An unprecedented 86 percent of physician assistants selected for compliance review visits in 2013 were in full compliance with state law and related Board rules. The site visits resulted in no public actions being issued against PAs for the first time since 2005, when the Board began conducting random site visits of PA practice locations. The Board commends these licensees.
The Board did issue private letters of concern to some PAs who were found to be out of compliance. Areas of noncompliance included: no evidence of Quality Improvement Meetings being held and/or documented; no periodic review of written instructions for prescribing drugs; no Scope of Practice document; no back-up supervising physician list; failure to timely file the required Intent to Practice with the Board; and supervising physician’s name and phone number not documented on the practice’s prescription blank. The Board has already selected PAs for site visits to be conducted in 2014. PAs will be contacted by a Board field investigator, who will schedule the site visit. During the visit, PAs will be asked to produce certain documents that are required
to be kept on file at each of the PA’s practice locations.
Highlights of information PAs will be expected to produce include:
• Written Supervisory Arrangement Statement: Rule NCAC 32S .0213 (c) requires a signed written Supervisory Arrangement statement to be kept on file at all practice sites and be available upon request by the Board.
• Intent to Practice Form: Rule NCAC 32S .0203 mandates that a notification of intent to practice form be submitted to the Board prior to the performance of any medical acts, tasks, or functions under the supervision of a primary supervising physician. Such form is located on the Board’s website. The rule further reads that the physician assistant shall not commence practice until he/she receives acknowledgment from the Board that the Board has received and processed the Intent to Practice Form.
• Quality Improvement Meetings: Rule NCAC 32S .0213 (d) requires the primary supervising physician and physician assistant in a new practice arrangement to meet monthly for the first six months to discuss practice relevant clinical issues and quality improvement measures and thereafter, meet at least once every six months. A written record of these meetings shall be signed and dated by both the supervising physician and physician assistant and shall be available for inspection upon request by the Board agent.
• Prescriptive authority: Rule NCAC 32S .0212 requires that each prescription issued by the physician assistant contains the physician assistant’s name, practice address,and telephone number; the physician assistant’s license number and, if applicable, the physician assistant’s DEA number; and the responsible supervising physician’s (primary or back-up) name and telephone number. Be aware that when using an electronic prescription, this same information is required to be on that prescription format as well.
• Instructions for Prescribing, Ordering, and Administering Drugs and Medical Devices and a Policy for Periodic Review by the Physician of These Instructions and Policy: Rule NCAC 32S .0212 (2) requires each supervising physician and physician assistant team to incorporate within his or her written supervisory arrangements instructions for prescribing, ordering, and administering drugs and medical devices and a policy for periodic review by the physician of these instructions/policy. The periodic review should occur at least annuallybetween the physician and physician assistant.
• Back-up Supervising Physicians: Each physician assistant needs to maintain an ongoing list of back-up supervising physicians, if any are used. This document must be signed and dated by all involved and retained as part of the Supervisory Arrangement. At a minimum, it should be updated yearly; more often if a new physician agrees to serve as the physician assistant’s back-up.
Are you in compliance?
Don’t wait to be selected for a site review to make sure you are in full compliance with supervisory rules. Review the PA rules and regulations. A complete description of the information PAs should expect to provide during a compliance review is available on the PA Site Visit Checklist, which is available online in the Professional Resources section of the Board’s website under “Physician Assistant Forms”. The Board publishes this information on its website in an effort to encourage compliance.
PA site visits: How they work
PAs selected for review are notified in advance by a Board investigator, who schedules a face-to-face meeting. The PA is asked to produce certain documents that must be kept on file at the PA’s practice location. The Board investigator also asks the PA a series of questions regarding his or her practice arrangement, such as how frequently he or she has one-on-one direct contact with the supervising physician.
The Board did issue private letters of concern to some PAs who were found to be out of compliance. Areas of noncompliance included: no evidence of Quality Improvement Meetings being held and/or documented; no periodic review of written instructions for prescribing drugs; no Scope of Practice document; no back-up supervising physician list; failure to timely file the required Intent to Practice with the Board; and supervising physician’s name and phone number not documented on the practice’s prescription blank. The Board has already selected PAs for site visits to be conducted in 2014. PAs will be contacted by a Board field investigator, who will schedule the site visit. During the visit, PAs will be asked to produce certain documents that are required
to be kept on file at each of the PA’s practice locations.
Highlights of information PAs will be expected to produce include:
• Written Supervisory Arrangement Statement: Rule NCAC 32S .0213 (c) requires a signed written Supervisory Arrangement statement to be kept on file at all practice sites and be available upon request by the Board.
• Intent to Practice Form: Rule NCAC 32S .0203 mandates that a notification of intent to practice form be submitted to the Board prior to the performance of any medical acts, tasks, or functions under the supervision of a primary supervising physician. Such form is located on the Board’s website. The rule further reads that the physician assistant shall not commence practice until he/she receives acknowledgment from the Board that the Board has received and processed the Intent to Practice Form.
• Quality Improvement Meetings: Rule NCAC 32S .0213 (d) requires the primary supervising physician and physician assistant in a new practice arrangement to meet monthly for the first six months to discuss practice relevant clinical issues and quality improvement measures and thereafter, meet at least once every six months. A written record of these meetings shall be signed and dated by both the supervising physician and physician assistant and shall be available for inspection upon request by the Board agent.
• Prescriptive authority: Rule NCAC 32S .0212 requires that each prescription issued by the physician assistant contains the physician assistant’s name, practice address,and telephone number; the physician assistant’s license number and, if applicable, the physician assistant’s DEA number; and the responsible supervising physician’s (primary or back-up) name and telephone number. Be aware that when using an electronic prescription, this same information is required to be on that prescription format as well.
• Instructions for Prescribing, Ordering, and Administering Drugs and Medical Devices and a Policy for Periodic Review by the Physician of These Instructions and Policy: Rule NCAC 32S .0212 (2) requires each supervising physician and physician assistant team to incorporate within his or her written supervisory arrangements instructions for prescribing, ordering, and administering drugs and medical devices and a policy for periodic review by the physician of these instructions/policy. The periodic review should occur at least annuallybetween the physician and physician assistant.
• Back-up Supervising Physicians: Each physician assistant needs to maintain an ongoing list of back-up supervising physicians, if any are used. This document must be signed and dated by all involved and retained as part of the Supervisory Arrangement. At a minimum, it should be updated yearly; more often if a new physician agrees to serve as the physician assistant’s back-up.
Are you in compliance?
Don’t wait to be selected for a site review to make sure you are in full compliance with supervisory rules. Review the PA rules and regulations. A complete description of the information PAs should expect to provide during a compliance review is available on the PA Site Visit Checklist, which is available online in the Professional Resources section of the Board’s website under “Physician Assistant Forms”. The Board publishes this information on its website in an effort to encourage compliance.
PA site visits: How they work
PAs selected for review are notified in advance by a Board investigator, who schedules a face-to-face meeting. The PA is asked to produce certain documents that must be kept on file at the PA’s practice location. The Board investigator also asks the PA a series of questions regarding his or her practice arrangement, such as how frequently he or she has one-on-one direct contact with the supervising physician.
