Resources & Information

Apr 26 2011

Site visits find most PAs in compliance, but many are unaware of requirements

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Since 2005, the NC Medical Board has conducted annual site visits to ensure compliance with administrative rules regarding the supervision of midlevel practitioners. The Board reviews a certain number of physician assistants, who are selected at random, each year. The NCMB is publishing a summary of the results of site visits conducted in 2010 in an effort to raise awareness of common areas of noncompliance and to encourage greater compliance.

2010 results
Sixty percent of physician assistants/sites reviewed in 2010 were found to be in full compliance with Board rules. In 30 percent of sites reviewed, the Board noted one or more instances of noncompliance. However, in all cases the PAs corrected the noted discrepancies and the Board took no formal action against their licenses. In the remaining 10 percent of sites reviewed, the Board issued confidential Private Letters of Concern (PLOC) to the PAs. In each of these cases, the PA began treating patients before filing an ‘Intent to Practice’ (ITP) with the Board. PAs must confirm that the Board has received their ITP before they perform any clinical duties.

Discrepancies noted during the 2010 compliance reviews included the following:
  • No written instructions for prescribing and/or policy for periodic review of these instructions as required according to rules 21 NCAC 32S .0212 and 21 NCAC 32S .0213;

  • Prescription blank did not contain the PA’s approval/prescribing number as required according to rule 21 NCAC 32S .0212 (5) (b);

  • Statement of Supervisory Arrangement was not signed as required according to rule 21 NCAC 32S .0213 (c);

  • Back up supervising physician list was not signed/dated as required according to rule 21 NCAC 32S .0215 (b);

  • Statement of Supervisory Arrangement lacked a clear explanation of the physician’s supervision of the PA as required according to rule 21 NCAC 32S .0213 (b); and

  • Quality Improvement Meeting documentation was not available for inspection as required according to rule 21 NCAC 32S .0213 (d)

What you can do
The NC Medical Board is already conducting PA compliance reviews for the current year. Don’t wait to be selected to make sure you are in compliance. Visit and go to the Professional Resources section to 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 Physician Assistant Site Visit/Interview Form, which is posted on the NCMB’s public website. Investigators use this prepared checklist when completing a site visit. Download or print a copy of the site visit checklist.

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. During this meeting, the PA is asked to produce certain documents that must be kept on file at the PA’s practice location. These documents include, but are not limited to: the Statement of Supervisory Arrangements (signed); written instructions for prescribing and/or policy for periodic review of these instructions; prescription blanks used by the PA; and an up-to-date list of backup supervising physicians. 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.

PA SITE VISIT: Items to have on hand
  • Proof of licensure and registration

  • Statement of supervisory arrangement with primary supervising physician (This document provides a detailed description of the PA’s scope of practice)

  • Signed and dated record of Quality Improvement meetings between primary supervising MD and PA relevant to clinical problems and QI measures

  • List of all back-up supervising physicians, signed and dated by MDs (primary and backups) and PA

  • Written prescribing instructions to include written policy for periodic review of these instructions by primary supervising MD

  • DEA registration and pharmacy permit, if applicable

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