Physician Assistant practice agreement and supervision requirements (SB 697)
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Summarizes California SB 697 changes to the Physician Assistant Practice Act governing practice agreements, supervision, prescribing (including controlled substances), and related delegation of services requirements for physician assistants and supervising physicians in settings including hospitals and organized health care systems.
Removed requirements that the medical record identify the responsible supervising physician and that physicians physically be present for supervision; replaced delegation of services agreement with a practice agreement that sets supervision policies and procedures.
Authorized physician assistants to furnish or order drugs and devices (including Schedule II and III controlled substances) subject to practice agreement terms, competency, and DEA registration where applicable.
Practice agreements replace 'delegation of services agreements' and prior delegation agreements in effect prior to Jan 1, 2020 are deemed to meet the new requirements.
Coverage and Practice Agreement Criteria
inv-01: Coverage and operational criteria for PA practice and prescribing
Covered when ALL of the following are met:
inv-02: Practice Agreement Criteria
Requirements and permissible provisions for a PA practice agreement under California law:
May include
- A practice agreement may designate a PA as an agent of a supervising physician (Section 3502.3(a)(4))
- A practice agreement may authorize a PA to order durable medical equipment, subject to limitations and third-party payer prior approval (Section 3502.3(b)(1))
- After a supervised PA physical exam, the PA may certify disability pursuant to Section 2708 of the Unemployment Insurance Code (Section 3502.3(b)(3))
Controlled Substances and Supervision Limits
| Schedule II–V | Controlled substance schedules that may be furnished/ordered if authorized by practice agreement and competency requirements met |
| Schedule II–V | Controlled substance schedules the PA may be authorized to order/sign |
Authorized Actions and Operational Requirements for PAs and Supervising Physicians
Prescribing and furnishing controlled substances
Physician assistants may furnish or order drugs and devices, including Schedule II–V controlled substances, only as authorized in a practice agreement or a patient-specific order approved by the treating or supervising physician and consistent with the PA's education/competency; PAs authorized to furnish Schedule II controlled substances must have DEA registration and complete the required controlled‑substance education course by their next renewal if not already completed.
- Practice agreement must specify which PAs, which drugs/devices, circumstances for furnishing, extent of physician supervision, methods for periodic competency review, and review of the agreement (BPC § 3502.1(b)).
- PA must complete a pharmacology course meeting Title 16 §1399.530 requirements to furnish any drug or device; controlled substance education course is mandatory for PAs authorized to furnish Schedule II substances.
- Schedules II–V may be furnished/ordered only if agreed in the practice agreement and consistent with PA competency.
Supervising physician availability and supervision limits
A supervising physician must provide the level of supervision set in the practice agreement, be available by telephone or other electronic communication at the time the PA examines the patient, and may not supervise more than four physician assistants at any one time except as provided by statute for emergencies.
- Physical presence of the supervising physician is not required unless imposed by the Board as a term or condition of reinstatement, probation, or discipline.
- In a general acute care hospital the practice agreement must identify a supervising physician with hospital privileges.
PA authority to write and sign controlled‑substance orders
The PA may be authorized by the practice agreement to write and sign drug orders for Schedule II, III, IV, and V either without advance approval or with advance patient‑specific approval as specified in the agreement or delegation template; such authorization is tied to the supervising physician and practice protocols.
- Delegation template lists options: (a) write and sign for specified schedules without advance approval (with proof of drug course and DEA number) or (b) write and sign with advance patient‑specific approval.
- Authorization must be consistent with practice agreement provisions and PA competency.
Authorized clinical services and procedures
The PA is authorized to perform the clinical, laboratory, screening, and therapeutic procedures listed in subsections (a)–(h) of Section 1399.541 when acting under supervision and may perform additional authorized services as specified in the practice agreement or practice protocols.
- Delegation/practice agreement template permits listing specific authorized laboratory, screening, and therapeutic procedures or deferring to practice protocols or specific supervising physician authorization.
- The practice agreement must specify the types of medical services the PA is authorized to perform (BPC § 3502.3(a)(1)(A)).
Prescription transmission and medical record drug orders
A PA may transmit the supervising physician's prescription to a pharmacist by telephone and may enter drug orders on the patient's medical record in accordance with applicable law, and any medication handed to a patient by the PA must be authorized by the supervising physician's prescription and prepackaged/labeled per law.
- PA may transmit prescriptions orally to a pharmacist or record them on the patient's medical record per BPC § 3502.1 and Physician Assistant regulations.
- Medications handed to patients by the PA must comply with Business and Professions Code § 4076 requirements for prepackaging and labeling.
Key Definitions
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