SB 697 changes to Physician Assistant practice agreements and supervision
Customize your policy alerts
Sign up for all centralcaliforniaallianceforhealth policy alerts
Know when centralcaliforniaallianceforhealth releases new policies or updates existing guidance.
Monitor payer policy activity
Summarizes California SB 697 (effective 2020-01-01) changes to the Physician Assistant Practice Act governing practice agreements, PA authority to furnish/order drugs (including certain controlled substances), supervision requirements, and required education; applies to physician assistants, supervising physicians, and organizations in California.
Removed requirement that medical records identify the responsible supervising physician and that supervising physician physically be present; replaced prior delegation framework with a required practice agreement defining supervision and PA-authorized services.
Authorizes PAs to furnish or order Schedule II and III controlled substances if authorized by the practice agreement or patient-specific order and if PA has DEA registration and completes required controlled-substance education.
Supervising physician no longer required to review or countersign PA medical records unless the practice agreement or Board-imposed condition requires it.
Coverage Criteria and Authorization Rules
Authorization conditions for PA medical services
PAs are authorized to perform medical services when ALL of the following are met:
The practice agreement must specify the types of medical services the PA is authorized to perform, policies and procedures to ensure adequate supervision, and methods for continuing evaluation of the PA's competency.
Physical presence is not generally required; the Board may require physical presence or chart review/countersignature only as a condition of probation, reinstatement, or discipline. For hospital practice, the supervising physician must have hospital privileges and the practice agreement must identify the supervising physician within the hospital.
A PA furnishing any drug or device must complete required pharmacology coursework; PAs authorized to furnish Schedule II controlled substances must complete the Board-required controlled substance education course and, for Schedule II/III, have any required DEA registration as applicable.
PAs remain prohibited from owning a majority share in a professional medical corporation. Under the Moscone‑Knox Professional Corporation Act a physician assistant may not own more than 49% of a professional medical corporation.
This document does not establish medical necessity criteria. It addresses licensure, scope of practice, supervision, and practice‑agreement requirements under SB 697; therefore it is not applicable as a medical necessity determination or coverage decision.
Provider Actions, Practice Agreements, and Controlled Substances
Prior authorization: practice agreement or patient-specific order required
A practice agreement or a patient-specific order approved by the treating or supervising physician is required to authorize a PA to furnish or order Schedule II or III controlled substances; the PA may furnish or order Schedule II–V substances only as agreed in the practice agreement and consistent with the PA's education or established clinical competency.
- No separate protocols or formularies are required to authorize furnishing controlled substances.
Details required when Schedule II are authorized
If the practice agreement authorizes furnishing Schedule II controlled substances it must specify the diagnosis, illness, injury, or condition for which the PA may furnish the Schedule II drug, and the agreement must also specify which PAs may furnish or order the drug, which drugs, the circumstances for furnishing, extent of physician supervision, and methods for periodic review of the PA's competence.
- Practice agreement must list which PA(s) may furnish/order the drug
- Must identify which drugs/devices and under what circumstances they may be furnished
- Must specify extent of physician supervision and method of periodic competency review
- If Schedule II is authorized, the agreement must address the diagnosis or condition for which it may be furnished
Document requirement: contents of the practice agreement
The practice agreement must be a written, signed document developed collaboratively and must include: the types of medical services the PA is authorized to perform; policies and procedures to ensure adequate supervision; methods for continuing evaluation of PA competency; and provisions addressing the furnishing or ordering of drugs or devices (including the specific terms described in statute).
- Must be signed by the PA and one or more physicians (or an authorized physician on behalf of staff)
- Must include supervision policies/procedures, competency evaluation methods, and drug/device furnishing terms
Noncompliance risk: required controlled substance education for Schedule II authorization
A PA who is authorized through a practice agreement to furnish Schedule II controlled substances, holds an active license, and is registered with the DEA must complete the Board‑standard controlled substance education course covering Schedule II substances and addiction risk as part of continuing education; if not yet completed, the PA must finish the course prior to license renewal—failure to complete the required course may jeopardize license renewal or compliance.
- Course requirement applies to PAs authorized to furnish Schedule II and registered with the DEA
- Completion is required before renewing the PA license if not already completed
Background and Legislative Summary
SB 697 modernized the Physician Assistant Practice Act by replacing the older delegation framework with a required written practice agreement that defines the medical services a PA may perform and the agreed method of supervision. The law removed prescriptive requirements for the supervising physician’s physical presence and chart countersignature except where a practice agreement or Board‑imposed condition (for example, probation or reinstatement) requires otherwise, and it permits PAs to furnish or order certain controlled substances when authorized by the practice agreement or a patient‑specific order and when education and DEA requirements are met.
Definitions
OpenPayer is powered by Trek Health's payer performance platform. Trek continuously ingests, validates, and normalizes Transparency in Coverage data alongside payer policies and other commercial payer data to create a structured payer intelligence foundation. OpenPayer uses this foundation to deliver personalized search results, dynamically generated policy pages, and tailored policy monitoring based on each user's payers, specialties, billing codes, and areas of interest. The same intelligence powers broader payer performance workflows, including reimbursement benchmarking, contract evaluation, payer negotiations, and financial decision-making.