Coming soon: PA team based practice
Categories: Licensing and Registration Comments: 1 comment Print Friendly Version | Share this itemEffective June 30, certain experienced PAs will have the opportunity to practice without the need to establish with a primary supervising physician.
This type of practice, known as PA team-based practice, was authorized through licensing provisions in HB67, which was approved in July 2025. Since then, NCMB has received multiple inquiries from licensees asking whether it is true that PAs can now practice “without supervision”. This is NOT the case. PA team-based practice is an alternative type of PA practice that involves working in specific practice environments where eligible PAs regularly collaborate, consult and refer with members of the health care team, including physicians.
Here’s how it’s going to work in NC:
• Before initiating team-based practice, PAs meeting the eligibility criteria must submit an online request seeking NCMB’s approval. This form will be available by June 30. PAs must submit supporting documentation for the following:
1. Have at least 4,000 documented hours of clinical practice as a licensed PA
2. Have at least 1,000 documented hours of clinical practice in each specialty area of practice in which the PA will practice; and
3. Will be practicing in a team-based practice setting as defined by state law.
• PAs may not begin active clinical team-based practice until they receive acknowledgement from NCMB, or confirm via NCMB’s website, that their request for team-based practice has been processed.
• The PA must notify NCMB of changes to their specialty area of practice or practice setting. If circumstances change such that the PA is no longer working in a team based setting or has less than 1,000 hours of practice in the new specialty area of practice, the PA shall become ineligible for team-based practice and would need to establish with a primary supervising physician and comply with all applicable laws and rules related to supervision.
Find a draft of the proposed administrative rules related to PA team-based practice on NCMB’s online Rule Change Tracker.
Comments on this article:
Thank you for the opportunity to comment on the proposed rules implementing Session Law 2025-37.
These comments are offered in support of clear implementation of legislative intent, sound rule construction, and avoidance of unintended consequences that may arise when operational details introduced in rule potentially extend beyond or complicate the statutory framework enacted by the General Assembly.
1. Alignment of Proposed Rule Language With Statutory Direction
The rulemaking summary indicates that Session Law 2025-37 authorizes qualifying physician assistants to practice in a team-based setting without physician supervision. Several proposed provisions, however, retain language defining physicians as accountable to the Board for acts performed by team-based physician assistants in certain settings.
This may merit further examination to ensure the final rule fully reflects, and does not inadvertently narrow through rule construction, the practice model contemplated by the statute.
To the extent retained supervisory constructs functionally reintroduce elements the legislation appears designed to modify, clarification may be appropriate to avoid interpretive tension between statute and rule.
2. Accountability Provisions in Institutional Settings
The proposed rules appear in several places to assign accountability primarily at the individual physician level while many of the relevant controls in modern employed practice environments may reside substantially within institutional credentialing, privileging, protocol, and enterprise risk structures.
Where practical control is materially shared or constrained, assigning responsibility principally through an individual licensure framework may raise questions of operational fit and, potentially, whether certain matters are better addressed through institutional governance rather than professional regulation alone.
Consideration of shared-accountability concepts may strengthen both the rule’s practical implementation and its coherence.
3. Avoiding Unintended Expansion Through Rule
Some provisions—particularly around protocol obligations and retained supervisory expectations—may warrant review to ensure implementation details supplied in rule do not unintentionally expand obligations beyond those necessary to effectuate the statute.
That observation is offered simply in recognition that administrative rules are strongest when they closely track legislative direction while avoiding ambiguity as to whether substantive conditions have been added through implementation.
4. Independent Judgment Within Team-Based Practice
The provisions addressing radiographic interpretation similarly raise a broader question whether the proposed framework fully reflects the Legislature’s apparent recognition that highly experienced physician assistants may exercise significant professional judgment within team-based practice.
Ensuring internal consistency in this regard may help avoid confusion in both interpretation and implementation.
5. Possible Refinements for Consideration
I respectfully encourage consideration of whether final rules may benefit from:
* Further reconciliation of supervisory terminology with statutory language
* Clarification where collaboration is intended rather than retained supervision
* Recognition of shared institutional accountability where system controls materially shape practice
* Review of whether certain operational requirements are best situated in Board rule versus institutional policy or credentialing structures
* Careful attention to preserving close alignment between rule implementation and statutory authority.This rulemaking presents an important opportunity to implement legislative modernization in a manner that reflects contemporary care delivery while maintaining fidelity to public protection principles and established administrative law norms.
These comments are offered respectfully and in support of strengthening an important framework.
Respectfully submitted
By Karen Burke, MD on Apr 28, 2026 at 11:15am
