Rhode Island Proposed Regulations for Licensure of PAs

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October 28, 2005

 

Charles Alexandre, MS, RN, Chief

Office of Health Professions Regulation

State of Rhode Island Department of Health

3 Capitol Hill

Room 205

Providence, RI  02908

 

Dear Mr. Alexandre:

The American Academy of Physician Assistants (AAPA) is the national professional society for physician assistants (PAs). In this capacity the Academy represents over 55,000 practicing physician assistants in the United States. The Academy would like to comment on proposed changes to the Rhode Island Rules and Regulations for the Licensure of Physician Assistants (R5-54-PA).

The majority of the proposed provisions will make important updates to Rhode Island’s regulation of the physician assistant profession. Elimination of the reference to the Formulary Committee to conform to recent statutory changes, creation of a non-disciplinary alternative program, and clarification of immunity from liability for gratuitous emergency assistance are important and progressive improvements. We also support elimination of the language that restricts a person who has been trained as a physician as being licensed as a PA, should the applicant meet all other licensing requirements. Recognition of the Federation Credentials Verification Service (FCVS) can streamline the licensure process for licensing staff and for PA license applicants.

We would like to offer the following comments on two specific sections of the proposed regulations:

Section 2.2 Exemptions

In a majority of states federally employed physician assistants are exempted from state licensure and from complying with state requirements. This is appropriate in day to day practice, and can be essential if PAs who are part of National Guard, military, or Disaster Management Assistance Teams (DMATS) are deployed to a state in times of a disaster. Therefore we would suggest addition of the following language:

 

• Physician assistants employed in the service of the federal government while performing duties incident to that employment.

 

Section 6.9 Place of Employment

This section requires the PA to inform the Board of the name of the supervising physician(s). It is our opinion that this is redundant and may cause supervised physician assistants who are providing high quality care with complete intention of complying with all aspects of the law and regulations to be in technical violation because of a change in supervising physician.

Section §5-54-2 of Rhode Island Code requires a physician or health care delivery organization to have on file at the practice site a copy of an agreement between the supervising physician and PA delineating the job description for the PA. Requiring a document such as this at the practice site is certainly reasonable, and could be echoed in rule. The value of requiring the document at the practice site rather than the Board is the ease of amendment. If a physician is added to the practice, amending the agreement is readily accomplished.

If an amendment to this section were to be considered, it could use the following language:

Section 6.9 Physician-Physician Assistant Agreement

Each practicing physician assistant must have an agreement with a supervising physician(s) as provided in §5-54-2. A copy of the agreement signed by the physician(s) and physician assistant must be kept on file at the primary practice location and be made available to the Board or its representative upon request.

The Academy appreciates this opportunity to comment on the proposed changes to the Rhode Island regulations governing the practice of physician assistants.

Sincerely,

 

Ann Davis, PA-C

Director of State Government Affairs