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November 27, 2006

Pierce Wilson

Professional Licensure Division

Department of Public Health

Lucas State Office Building

Des Moines, Iowa 50319–0075

Dear Mr. Wilson:

In a letter dated October 13, 2006, the American Academy of Physician Assistants provided comments on proposed changes to Iowa Administrative Code section 645-326.  The Academy continues to support this update of the rules.  However, AAPA wishes to amend its comments to reflect the most recent version of these changes, as published in the November 8, 2006 Iowa Administrative Bulletin.   

Certificate of Completion 

Like all other states, Iowa requires graduation from an accredited physician assistant program for licensure.  Iowa’s administrative rules reasonably require verification of this educational attainment.  Iowa’s laws, though, do not require the Board of Physician Assistant Examiners to evaluate the coursework of each physician assistant applicant.  In Iowa Code section 148C.3, the statute references “Academic qualifications, including evidence of graduation from an approved program.”  It does not mention transcripts.  Therefore, a certificate of completion from an accredited program should suffice to verify program completion.  Allowing certificates of completion for temporary licensure is a step in the right direction, as it will allow new physician assistants to start working and to meet the health care needs of Iowans more quickly.  However, accepting certificates of completion for full licensure would simplify the application process and meet all of the requirements of the statute.  The Academy urges the Board to reconsider this change, either as part of the current update or in the future.

Board Notification of Supervising Physician Change 

It is vital for physician-physician assistant teams to have a clear definition of the supervisory relationship, particularly in larger practices or hospital settings, where it must be clear which physician supervises which physician assistant at which time.  In large practices and hospitals, these relationships may shift frequently depending on the schedules of multiple professionals.  Practices and hospitals maintain careful records of their employees and the supervisory relationships between them, but notifying an external party (i.e., the Board) of each change adds an unnecessary level of paperwork.  The Board can determine a physician assistant’s supervising physician at any point in the past by checking the records of the practice or facility, while updates at the time of renewal give the Board current information.  AAPA supports the proposed rule as currently written.

 

 

Professional Responsibilities

Iowa statute requires adequate supervision and communication between physicians and physician assistants and bestows on both parties the responsibility to ensure that this happens.  Rather than limiting the rule to notification of supervisory status and the coordination of schedules, the proposed amendment requires that each party in the physician-PA team is informed of their respective professional responsibilities.  This change would impose a more general duty on physicians and physician assistants to be aware of the requirements of each of their professions and the special relationship between them.  It avoids regulatory micromanagement of the communication between physicians and PAs.

New Procedures

Iowa rules appropriately recognize that physician assistants add to their skill sets throughout their careers by learning new medical procedures.  PAs should be able to take advantage of the new opportunities for learning and skill development presented by new technologies, including internet-based training modules.  It is reasonable to require supervision for such training, since all PA practice requires supervision.  A requirement for direct, personal supervision, though, can get in the way of these new technologies and is not a requirement for standard PA practice.  As reiterated by the proposed rule, a supervising physician must always be satisfied with the quality of a PA’s training before he or she delegates responsibilities to the PA.  The proposed change would both allow new avenues for training and reinforce the responsibility of both the physician and the PA to assure that the PA’s practice is within the PA’s skill set.  As with all PA training, the supervising physician would need to evaluate the PA’s competence before the new skill is put into practice whether or not the physician was personally present for the training.

The Academy appreciates the opportunity to provide comments on this proposal.  Thank you for your consideration and please do not hesitate to contact me at ann@aapa.org if I can provide any further clarification.

Sincerely,

  

Ann Davis, PA-C

Director, State Government Affairs