Proposed Emergency Amendment to Appendix B

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February 3, 2006

Patricia E. Shaner, Esq.

Alabama Board of Medical Examiners

P.O. Box 946

Montgomery, AL36101-0946

Dear Ms. Shaner:

The American Academy of Physician Assistants (AAPA) is the national professional society for physician assistants (PAs). In this capacity, the Academy represents nearly 60,000 physician assistants across the country. The AAPA would like to provide comments on the proposed emergency amendment to 540-X-7 Appendix B.

The Academy would like to provide a general comment on the application approval process and subsequently comment on a specific section of the proposed rule.

We applaud the Alabama Board’s conscientious regulation of the PA profession and many of the progressive reforms that have been instituted by the board over the past decade. However, at some point in the future, we would like for your board to consider whether specific approval of specific tasks for individual PAs is efficacious and the best use of the board’s time and resources.

Most states have moved from a board-approval process for determining scope of practice to a system that licenses the physician assistant, requires physician supervision, and then authorizes the PA to perform those tasks and services delegated by the supervising physician. If the physician delegates the PA to practice in a facility, then the PA must also be authorized by the facility to perform delegated procedures.

 

Physician assistants seek and embrace a physician delegated scope of practice. This is unique. No other health profession sees itself as entirely complementary to the care provided by physicians. PAs have great respect for the depth of training received by physicians and acknowledge physicians as the best-educated and most comprehensive providers on the health care team.

Allowing a supervising physician to determine the specific elements of a PA’s scope of practice allows an on-site expert, the supervising physician, to evaluate the physician assistant’s specific abilities. The physician has the ability to observe the physician assistant’s competency and performance and to assure that the PA is performing tasks and procedures in the manner preferred by the supervising physician. Because the supervising physician is responsible for care provided by the PA (540-X-7-.25), the supervising physician has a vested interest assuring that delegated tasks are appropriate to the individual physician assistant.

It is our hope that sometime in the future the Alabama medical board will consider moving to a physician-delegated scope of practice for PAs, the method that is now utilized by the majority of PA regulatory authorities.

At this time we would like to comment on a specific element of the proposed regulation.

Sections one and two of the rule are somewhat difficult to interpret because Section one is written in the negative. (“However, the Physician Assistant may not perform any procedure not listed under #2 below without prior approval of the Alabama Board of Medical Examiners.) Subsection 2-i-7 says, “(7) Suturing-single layer closure of the face.” Coupled with the above language, this could be interpreted to mean that suturing by physician assistants is limited to single layer closures, and only of lacerations on the face.

If the board desires to retain this level of specificity, and intends to limit facial suturing to single layer closure only, the rule needs to be revised to reflect this intent. Adopted as drafted it is very likely to cause unnecessary confusion for physician-PA teams.

The American Academy appreciates the opportunity to comment on the proposed revised regulation.

Sincerely,

  

Ann Davis, PA-C

Director of State Government Affairs