March 31, 2011


Dear Jennifer,

I have PA employees who see patients on a regular basis. Is there anything I should be worried about? How much supervision am I required to provide?


Dr. P


Under Medicare Regulations and New York State rules PAs may provide any service authorized under their license and relevant to their training as long as appropriately supervised by a physician. Today many practices utilize PAs and are increasing their role in patient care.

Medicare rules typically provide “General Supervision” as the level of supervision required when a PA is performing services. General Supervision means that the service is provided under the physician’s “overall direction and control”, but the physician’s presence is not required. New York State regulation contains similar supervision requirements, where a physician may supervise a PA as long as he is available to communicate.

With such seemingly lax supervision requirements it is easy to lose oversight of the PAs providing services for your practice, however, doing so can result in severe consequences – physicians are responsible for the training and oversight of PAs under their supervision, and will be held responsible (professionally and legally) for any lapses in the standard of care.

Further, New York State guidelines allow one physician to supervise only 2 PAs, and physicians may not supervise PAs who provide services outside of the physician’s scope of practice. For example, a general practitioner should not supervise a PA who is responsible for providing radiology services. These and other additional restraints will apply depending on the nature of the practice, which is why this answer is of a general nature, and if you have a specific question as to whether the PA in your practice is performing appropriate services, we will need additional specific information to opine. Remember, noncompliance from practicing outside your area of expertise, or allowing a PA in your practice to perform services outside their area of expertise may result in payment denials, recoupment demands, and licensure repercussions.

Additional compliance concerns may arise when billing PA services “incident to” physician services in order to obtain full reimbursement. Due to the various regulatory pitfalls, I strongly recommend that any practice utilizing PAs implement a PA supervision and control protocol through its compliance plan and employee policies to ensure that the practice maintains compliance with those services rendered by and billed by or on behalf of PAs.


For additional information on this topic, contact Jennifer Kirschenbaum at (516)-747-6700 ext. 302 or at


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