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Frequently Asked Questions for Physician Assistants
Licensure
1 What are the requirements for licensure?
2 What are the fees?
3 How long does it take to be licensed?
Delegation Agreements
4 What is a delegation agreement?
Delegation Agreements For Core Duties
5 What are core duties?
6 What is the delegation agreement process for core duties?
7 How long does the process take?
Delegation Agreements Addendum For Advanced Duties
8 What are advanced duties?
9 What is the delegation agreement addendum process for advanced duties in accredited healthcare facilities?
10 What does the Board consider an accredited facility?
11 What does the Board consider a non-accredited facility?
12 What is the delegation agreement process for advanced duties in non-accredited facilities?
13 Is there a way to expedite the process?
Renewal / Reinstatement / Continuing Education
14 What are the requirements for renewal?
15 What are the requirements for reinstatement?
16 What are the continuing education requirements?
Alternate Supervising Physicians
17 What is an alternate supervising physician?
18 When may a PA practice under the supervision of an ASP?
19 When should a PA notify the Board that he/she will no longer be working under the supervision of the PSP whose name appears on the approved delegation agreement on file with the Board?
20 May a PA practice under an ASP if the PSP supervising physician is no longer with the practice?
Prescriptive Authority and Dispensing
21 What are the requirements for prescriptive authority?
22 May a PA dispense prescription drugs?
Practice Issues
23 What is a PA scope of practice?
24 Is there a scope of practice that a PA may not practice?
25 What are the reporting requirements?
26 May a PA take x-rays or inject radiopharmaceuticals?
27 May a PA pronounce a patient dead?
28 May a PA sign an emergency medical services (EMS) do not resuscitate (DNR) orders form
29 May a PA sign a "regular" DNR in an inpatient facility or hospital?
30 May a PA sign a death certificate?
31 May a PA write orders for restraints?
32 Are supervising physicians required to co-sign medical charts?
Practicing Psychotherapy
33 May a physician assistant practice psychotherapy?
34 If a PA does not have the required education, training and experience to practice psychotherapy, what type of treatment may a PA provide for a psychiatric patient?
Verification of Licensure
35 How can individuals verify a license / certification?

 

1. Question: What are the requirements for licensure? (back to top)
 

Answer:

  1. Submission of a completed application and the appropriate fee mailed to the address indicated on the top of the application. (P.O. Box 37217, Baltimore, MD 21297). Mailing the application to any other address will delay the processing of the application.
  2. Good moral character.
  3. At least 18 years old.
  4. Demonstration of oral and written competency in the English language.
  5. Graduation from a physician assistant educational program accredited by the Accreditation Review Commission on Education for the Physician Assistant (ARC-PA) or its successor.
  6. Applicants who graduate from an accredited physician assistant educational program after October 1, 2003, must have a baccalaureate degree or the equivalent education to a baccalaureate degree.
  7. Current certification by the National Commission on Licensure of Physician Assistants (NCCPA).
The Board may accept the Federation Credential Verification Service (FCVS) for primary source verification of a physician assistant's core credentials. For more information about the FCVS, contact them at 817-868-4000; fcvs@fsmb.org or go to their website at www.fsmb.org/fcvs.html
   
2. Question: What are the fees? (back to top)
  Answer: Click here for fee schedule.
   
3. Question: How long does it take to be licensed? (back to top)
 

Answer:

The application process generally takes approximately 2-4 weeks. However, the process may take longer depending on the individual applicant's circumstance or if the individual does not provide the required documentation on a timely basis.

 

LICENSURE IS ONLY ONE PART OF THE PROCESS. ALL PHYSICIAN ASSISTANTS MUST FILE A DELEGATION AGREEMENT WITH THE BOARD. THE PA MAY BEGIN WORKING ONCE THE BOARD HAS RECEIVED THE COMPLETED DELEGATION AGREEMENT AND ACKNOWLEDGES RECEIPT.
   
4. Question: What is a delegation agreement? (back to top)
 

Answer: A delegation agreement is a document that is executed by a primary supervising physician (PSP) and a PA (PA) containing the requirements of Health Occupations Article, § 15-302, Annotated Code of Maryland.

   
5. Question: What are core duties? (back to top)
 

Answer:

Core duties are medical acts that are included in the standard curricula of accredited PA education programs.

 

   
6. Question: What is the delegation agreement process for core duties? (back to top)
 

Answer:

PAs and PSPs must file the completed delegation agreement and appropriate fee with the Board. The delegation agreement and fee must be sent to the address indicated on the top of the delegation agreement. (P.O. Box 37217, Baltimore, MD 21297). Mailing the delegation agreement to any other address, will delay the processing of the delegation agreement. The Board will not accept faxed delegation agreements or walk-ins.

The Board is no longer required to approve a delegation agreement before the PA begins working if the delegation agreement does not include advanced duties.

The PA may begin working once the Board has received the delegation agreement and acknowledges receipt in writing. Board staff will email acknowledgment letters to the PA and the PSP.

   
7. Question: How long does the process take? (back to top)
  Answer: The process may take up to seven weeks.
   
8. Question: What are advanced duties? (back to top)
 

Answer:

Advanced duties are medical acts that require additional training beyond the basic PA education program required for licensure.
   
9. Question: What is the delegation agreement addendum process for advanced duties in accredited healthcare facilities?(back to top)
 

Answer:

PAs and PSPs must file the completed delegation agreement with the Board. The delegation agreement must be sent to the address indicated on the top of the delegation agreement. (P.O. Box 2571, Baltimore, MD 21215).

 

Delegation agreements with advanced duties will not require prior Board approval if the advanced duty listed in the delegation agreement will be performed in a hospital or an ambulatory surgical facility that:

 

  1. Is accredited by an accrediting agency recognized by the Board.
  2. Credentials supervising physicians as a condition of employment, as an independent contractor or as a member of the medical staff before the supervising physician begins practicing in the facility;
  3. Credentials PAs as a condition of employment, as an independent contractor or as a member of the medical staff before the PA begins practicing in the facility; and
  4. Through its governing body has already reviewed and approved the PAs to perform each requested advanced duty before the delegation agreement with advanced duties is filed with the Board.

(A PA may begin working after the Board receives the delegation agreement for advanced duties and acknowledges receipt in writing. Board staff will email acknowledgment letters to the PA and the PSP. )

Note: Pursuant to §15-302.1(e), the Board is authorized to disapprove any delegation agreement not meeting the requirements of the law or if the Board believes that a PA is unable to perform the delegated duties safely.

   
10. Question: What does the Board consider an accredited facility?(back to top)
 

Answer: An accredited facility is a hospital or ambulatory surgical facility accredited by The Joint Commission, the American Association for Accreditation of Ambulatory Surgical Facilities, the Accreditation Association for Ambulatory Health Care, is certified to participate in the Medicare program, as enacted by Title XVIII of the Social Security Act or meets the criteria in Health Occupations Article, §15-302(c)(1).

   
11. Question: What does the Board consider a non-accredited facility? (back to top)
 

Answer: Non-accredited facilities are facilities that do not meet the criteria in Health Occupations Article, §15-302(c)(1). For example:

    1. non-accredited hospitals;
    2. non-accredited ambulatory surgical centers;
    3. private practices;
    4. detention centers;
    5. public health facilities;
    6. correctional facilities;
    7. hospitals or ambulatory surgical facilities whose governing body has not approved the PA to perform the requested procedure prior to submitting the advanced duties request to the Board
   
12. Question: What is the delegation agreement process for advanced duties in non-accredited facilities? (back to top)
 

Answer: PAs and PSPs must obtain prior Board approval before the PA may begin practicing any advanced duty.   PAs in these practice settings are required to submit training and education documentation. The criteria for Board approval is as follows:

  1. Completion of the Delegation Agreement Addendum for Advanced Duties. (http://www.mbp.state.md.us/forms/della_adv_duties.pdf)
  2. Documentation, including but not limited to:
    1. Procedure logs showing at least 10 – 25 successful procedures (200 for stress testing)
    2. Advanced education/training, including training certificates indicating training completion or a delineation of hospital privileges for the PA;
    3. Consent forms;

    (Please note that the PAAC or the Board may require a PA or SP to meet additional requirements before approving a request to perform advanced duties. The requirements will depend upon the type of advanced duty.)

    Note: A PSP is required to obtain the Board’s approval of a delegation agreement before the PA may administer, monitor or maintain general anesthesia or neuroaxial anesthesia, including spinal and epidural techniques.

   
13. Question: Is there a way to expedite the process?(back to top)
 

Answer:

Yes. For delegation agreements with advanced duties that require prior Board approval, the PA and PSP may apply for a temporary practice letter. The Board may approve a temporary practice letter if:

 

    1. The Board previously approved the PSP to supervise one or more PAs in the performance of the requested advanced duty; AND
    2. The Board previously approved the PA to perform the advanced duty.

 

The temporary practice letter will allow a PA to practice while the delegation agreement is pending Board approval. The temporary practice letter request must be submitted with the delegation agreement.


A PA and PSP will not qualify for a temporary practice letter if:
    1. The PSP has never been approved by the Board to supervise a PA in the performance of the requested advanced duty; OR
    2. The Board never approved the PA to perform the requested advanced duty.
   
14. Question: What are the requirements for renewal? (back to top)
 

Answer:

  1. Submission of a completed renewal application with the appropriate renewal fee.
  2. Satisfactory evidence of compliance with the continuing education requirements.
  3. Verification from the Maryland Office of the Comptroller that the applicant has paid all undisputed taxes and unemployment insurance contributions payable to the Comptroller or the Secretary of Labor, Licensing, and Regulation or that the applicant has provided for payment in a manner satisfactory to the unit responsible for collection. (Maryland Health Occupations Annotated Code, § 1-213).

All licenses expire on June 30th of every odd year. Individuals should receive a renewal notice at least 30 – 60 days prior to the expiration of the license. Notices are mailed to most current address on file with the Board. It is the responsibility of the individual to notify the Board of an address change within 60 days of the change. You may download a copy of the Address Change application or change your address online.

PAs who fail renew their licenses by to the June 30th expiration date are considered non-renewed and may not practice until their licenses have been reinstated by the Board. PAs who allow their licenses to expire will be required to file a new delegation agreement. A delegation agreement is valid as long as the PA’s license is active.

 

   
15. Question: What are the requirements for reinstatement? (back to top)
 

Answer:

  1. Submission of a completed reinstatement application and the appropriate fee mailed to the address indicated on the top of the application.  (P.O. Box 37217, Baltimore, MD 21297).  Mailing the application to any other address, will delay the processing of the application. 
  2. Meeting the continuing education requirements.
  3. Verification from the Maryland Office of the Comptroller that the applicant has paid all undisputed taxes and unemployment insurance contributions payable to the Comptroller or the Secretary of Labor, Licensing, and Regulation or that the applicant has provided for payment in a manner satisfactory to the unit responsible for collection. (Maryland Health Occupations Code Annotated, § 1-213).
The continuing education requirement does not apply to the first renewal after initial certification or reinstatement of certification.
   
16. Question: What are the continuing education requirements? (back to top)
 

Answer:

  1. Fifty hours (50) of Category I continuing education earned within the 2 years preceding the date of the application for renewal or reinstatement. A minimum of eight (8) must relate to pharmacology topics; OR
  2. Current certification by the National Commission on Certification of Physician Assistants (NCCPA).

The Board may request a PA to submit evidence of having met the continuing education requirements specified in this regulation. If a PA cannot demonstrate completion of the required continuing education credit hours, the Board may impose a civil penalty of up to $100 per missing continuing education credit hour.

   

17.

Question: What is an alternate supervising physician? (back to top)
 

Answer:

An alternate supervising physician (ASP) is a physician designated by a PSP to supervise a PA in accordance with the delegation agreement on file with the Board.

Except in a hospital, correctional facility, detention center, or public health facility, the PSP must submit the names of the ASP, PA, the ASPs scope of practice and a statement from that the ASP will accept the responsibility of supervising the PA. This may be done by completing a designated alternate supervising physician form http://www.mbp.state.md.us/forms/add_alt_sp.pdf or in a letter.

In a hospital, correctional facility, detention center, or public facility, primary supervising physicians must keep an ongoing list of all approved ASPs with the ASPs’ scope of practice, signed and dated by each ASP.  
   
   

18.

Question: When may a PA practice under the supervision of an ASP?(back to top)
 

Answer:

PAs may practice under an ASP if the:

 

  • ASP supervises in accordance with the delegation agreement on file with the Board;;
  • ASP supervises no more than four PAs at any one time, except in a hospital, correctional facility, detention center or public health facility;
  • Period of supervision does not exceed the time specified in the delegation agreement;
  • ASP’s period of supervision does not exceed 45 days at any one time; and
  • PAs perform only those medical acts that have been delegated under the delegation agreement filed with the Board and are within the scope of practice of the alternate supervising physician.
   

19.

Question: When should a PA notify the Board that he/she will no longer be working under the supervision of the PSP whose name appears on the approved delegation agreement on file with the Board?(back to top)
 

Answer:

PAs should notify the Board as soon as they know that their PSP will no longer be with the practice by filing a new delegation agreement.
   

20.

Question: May a PA practice under an ASP if the PSP supervising physician is no longer with the practice? (back to top)
 

Answer:

In the event of a sudden departure, incapacity, or death of PSP, a designated ASP may assume the role of the PSP by submitting a new delegation agreement to the Board within 15 days.
   
21. Question: What are the requirements for prescriptive authority? (back to top)
 

Answer: Before PSPs delegate prescriptive authority to PAs, the PSP must attest that the PA has:

    1. Passage of the NCCPA Exam within the previous 2 years of submitting the delegation agreement; OR
    2. Provide documentation of successful completion of 8 Category I hours of pharmacology education within the previous 2 years of submitting the delegation agreement; AND
    3. A Bachelor’s Degree or its equivalent (120 credit hours); OR
    4. Two years of work experience as a physician assistant.
PSPs may delegate the authority to prescribe prescription drugs, controlled dangerous substances and/or medical devices. PAs who have been delegated the authority to prescribe controlled dangerous substances must have a valid:

 

  • State controlled dangerous substance registration; and
  • Federal Drug Enforcement Agency (DEA) registration.

 

For more information about Maryland controlled dangerous substance registration, contact the Division of Drug control at: http://dhmh.maryland.gov/laboratories/drugcont/SitePages/Home.aspx

For more information about DEA registration, contact the DEA at: http://www.deadiversion.usdoj.gov/

   

22.

Question: May a PA dispense prescription drugs? (back to top)
  Answer: PAs who are delegated the authority to prescribe may dispense a starter dosage or dispense drug samples of any drug the PA is authorized to prescribe to a patient of the PA if:

 

  1. The starter dosage or drug sample complies with the labeling requirements of Health Occupations Article §12-505;
  2. No charge is made for either samples or starter dosages;
  3. The starter dosage does not exceed a 72 hour supply;
  4. The PA enters an appropriate record in the patient’s medical record; and
  5. The PA complies with the requirements under Title 12 and 14 of Health Occupations and applicable Federal law and regulations.

 

   

23.

Question: What is a PA scope of practice? (back to top)
 

Answer:

The scope of practice is defined by the Board approved delegation agreement. A physician assistant's scope of practice is limited to acts:

 

    1. Delegated by the primary or designated alternate supervising physician;
    2. Appropriate to the physician assistant's education, training and experience;
    3. Customary to the practice of the primary or alternate supervising physician; and
    4. Consistent with the delegation agreement submitted to the Board.
   

24.

Question: Is there a scope of practice that a PA may not practice? (back to top)
 

Answer:

A PA may not practice within the scope of practice of any of the following health occupations:

 

    1. Radiography;
    2. Nuclear Medicine Technology;
    3. Nursing;
    4. Optometry;
    5. Physical Therapy;
    6. Psychology;
    7. Radiation Therapy; or
    8. Psychotherapy

    Under certain circumstances, a PA may operate a mini C-arm or similar low-level radiation machine to perform non-fluoroscopic procedures. See Health Occupations Article, §14-306e(3)(iii)B for more information. http://mgaleg.maryland.gov/webmga/frmStatutesText.aspx?article=gho§ion=14-306&ext=html&session=2014RS&tab=subject5

   

25.

Question: What are the reporting requirements? (back to top)
 

Answer:

Hospitals, related institutions, alternative health care systems, or employers are required to report to the Board any termination of employment of the PA for any reason, including quality of care issues, within 5 days of the termination.

 



Hospitals, related institutions, alternative health care systems, or employers are also required to report to the Board within 5 days any limitation, reductions or other changes of employment of the change of employment that might be grounds for disciplinary actions under Health Occupations Article, §15-314.
   
   

26.

Question: May a PA take x-rays or inject radiopharmaceuticals? (back to top)
 

Answer:

No. A PA must be a licensed radiographer to take x-rays and a licensed nuclear medicine technologist to inject radiopharmaceuticals. (Maryland Health Occupations Code Annotated, § 14-306e).
   

27.

Question: May a PA pronounce a patient dead? (back to top)
 

Answer:

There is no statute that specifically prohibits a PA from pronouncing death. However, hospitals may have their own policy on who may pronounce death and under what circumstances. Please check your hospital's policy. 
   

28.

Question: May a PA sign an emergency medical services (EMS) do not resuscitate (DNR) orders form? (back to top)
 

Answer:

No, a PA may not sign EMS/DNR orders. 
   

29.

Question: May a PA sign a "regular" DNR in an inpatient facility or hospital? (back to top)
 

Answer:

A PA may sign a non-emergency DNR based on the patient's treatment preferences if this duty is delegated to the PA by the supervising physician. 
   

30.

Question: May a PA sign a death certificate? (back to top)
 

Answer:

Yes, a PA may sign a death certificate. 
   

31.

Question: May a PA write orders for restraints? (back to top)
 

Answer:

Yes, a PA may write orders for restraints. 
   

32.

Question: Are supervising physicians required to co-sign medical charts? (back to top)
 

Answer:

On October 1, 2006, the law repealed the requirement for supervising physicians to co-sign medical charts. In place of the co-signature, the supervising physician will be required to describe a process, on the delegation agreement, by which the physician assistant’s practice is reviewed appropriate to the practice setting and consistent with current standards of acceptable medical practice.

The supervising physician will be required to provide a description by which the physician assistant’s practice is reviewed on delegation agreements filed October 1, 2006 and later.

For existing delegation agreements, supervising physicians may wish to keep a written description by which the physician assistant’s practice is reviewed on file at the healthcare facility.  
   

33.

Question: May a physician assistant practice psychotherapy? (back to top)
 

Answer:

A physician assistant (PA) may practice psychotherapy if the PA has the required additional education, training and experience to practice psychotherapy. Performing psychotherapy would be considered an advanced duty and therefore would require documentation of additional education, training and experience. When the Board licensed psychiatrist assistants, the minimum requirements were:

  1. Master’s degree from an accredited college or university; AND
  2. Completion of a graduate program accepted by the Board in a behavioral science that included 1, 000 hours of supervised clinical psychotherapy; OR
  3. Bachelor’s degree from an accredited college or university; AND
  4. 4,000 hours of supervised clinical experience that is approved by the Board.

A PA should have similar education, training and experience before seeking Board approval to practice psychotherapy.

   

34.

Question: If a PA does not have the required education, training and experience to practice psychotherapy, what type of treatment may a PA provide for a psychiatric patient? (back to top)
  Answer: A PA may provide treatment for a psychiatric patient’s physical problems. 
   
35. Question: How can individuals verify a license / certification? (back to top)
  Answer: Online verification, verbal or written verifications.
   
Professional Contact Information
National Commission on Certification of Physician Assistants (NCCPA) www.nccpa.net
American Academy of Physician Assistants (AAPA) www.aapa.org
Maryland Academy of Physician Assistants (MAPA) www.mdapa.org
Federation Credential Verification Service (FCVS) www.fsmb.org/fcvs.html

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updated 1/30/2014