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Written Physician Assistant Supervisory Agreements Are Now Required in Iowa

on Wednesday, 4 October 2017 in Health Law Alert: Erin E. Busch, Editor

On September 15, 2017, the Iowa Board of Medicine published final administrative regulations governing the supervision of physician assistants PAs in Iowa.  Although the new rules are effective September 20, 2017, enforcement of the rule is delayed until January 1, 2018 in order to allow time for education and implementation.  Physicians supervising PAs may be subject to licensee discipline for failing to arrange for written agreements by that date. 

Although the substance of the supervisory relationship  between physicians and PAs has not changed, the amended rules, especially 653 IAC §21.4 requiring written supervisory agreements meeting certain requirements, provides greater detail in defining the nature and content of supervision.  Also amended is 653 IAC §21.3 requiring physicians to notify the Board of a supervisory relationship with a PA within 60 days of commencement,  

A variety of informational materials are posted on the Iowa Board of Medicine website, including a summary document highlighting the new requirements and a sample agreement.  The website also sets out several dates for one-hour training sessions on the new rule, along with FAQs.

The exact form of the sample agreement does not have to be used, but the agreement is required to include the following minimum requirements:

  1. Review Requirement – A provision ensuring that the physician and PA review all requirements of PA licensure, practice, supervision and the delegation of medical  services as required by Iowa law. 
  2. Assessment of Education, Training, Skills and Expertise – Documentation that the physician has assessed these aspects of the PA’s qualifications as relevant to delegated responsibilities prior to commencing supervision and on an ongoing basis. 
  3. Delegated Services – An outline of the medical services delegated to the PA by the physician which must be within the scope of practice of both the physician and the PA.
  4. Communication – Documentation of a communication plan between the physician and PA, including the mode of communication, topics, expectations, and delineated areas where physician consultation is required.   For critical access hospitals, this would include mandatory reporting of hospital inpatient admissions where the PA has co-admitting privileges.
  5. Chart Review – Statement of a plan for physician review of a representative sample of the PA’s medical records and a means of documenting that such review has taken place.  
  6. Alternative Supervision – A plan for back-up physician supervision when the primary supervising physician is unavailable.  A PA may not practice when a physician supervisor is not available.
  7. Remote Medical Practice – Special arrangements must be made when the physician and PA practice at a site where the physician is present less than 50 percent of the time the clinic is open to patients. 

If the PA has more than one supervising physician, all supervising physicians may sign a single agreement.  

Hospitals and other facilities with medical staff credentialing processes should review their Bylaws and Rules and Regulations and/or credentialing policies and procedures to be sure that the written agreement requirements are properly included in credentialing of PAs.  Further, care should be taken to carefully review agreements to be sure that they appropriately include the required elements.  

Julie A. Knutson


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