AAPA Shares Update on State Medicaid Policies Pertaining to PAs

More States Say They’re Enrolling PAs as Billing Providers

December 20, 2021

By Trevor Simon

AAPA periodically issues a questionnaire to all 50 states and D.C. Medicaid agencies to clarify and update policies pertaining to PAs. This year, 84% of the Medicaid programs returned the survey. One key takeaway is that more states say they enroll PAs as billing providers – indicating that PAs are authorized to receive direct payment – than we were previously aware.

AAPA finds numerous benefits in surveying state Medicaid policies. First, it helps AAPA promote proper compliance with Medicaid policies for PAs and their employers. Second, written responses help us counter misinformation about what a PA can or can’t do under a state’s Medicaid program. Finally, by identifying state Medicaid policies that restrict PAs, it allows us to focus on what needs to be addressed through advocacy activities in conjunction with state chapters.

Currently, of the 51 surveys disseminated, 43 (84%) Medicaid programs have returned a survey, four have declined to participate, and four have yet to respond. AAPA will continue to seek responses from the remaining four states.

AAPA initially sent the survey by email and followed up through subsequent emails and telephone calls. AAPA attempted to limit the number of questions as to not overwhelm potential respondents or deter them from completing and returning the survey. The 2021 survey included 14 questions regarding issues such as whether:

• the state Medicaid program implements any practice restrictions or supervisory requirements beyond what’s already required in state law;
• the Medicaid agency authorizes PAs to perform certain services such as seeing a patient on an initial visit, first assisting at surgery, ordering DME, ordering home health, and providing psychiatric services;
• PAs can be considered primary care providers;
• these policies differ for PAs who work in a private practice versus a hospital/facility;
• there are differences in policy with NPs;
• the state has a provider directory, and if PAs are included;
• at what level PAs are enrolled (ordering and referring, rendering, or billing provider) under the state’s fee-for-service Medicaid program;
• and, the rate at which services provided by PAs are reimbursed as compared to the physician’s rate.

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We reviewed all responses and identified any instances in which a state reported a restriction. We then compared them to survey responses from previous years and language contained in state Medicaid provider manuals to validate information. AAPA has found a limited number of discrepancies between survey responses and other written policies, and is actively seeking to reconcile the information. Once review and analysis are complete, AAPA will make each state chapter aware of any problematic responses for advocacy purposes.

Preliminary review of data received from the surveys has resulted in a few takeaways:

• More states are replying that they enroll PAs as billing providers – indicating that PAs are authorized to receive direct payment – than we were previously aware. This is an issue that will require further follow-up as there tends to be confusion around delineating levels of enrollment.
• There doesn’t appear to be any pattern (such as geographic, political leadership, etc.) as to what restrictions (e.g., lack of coverage for PA first assisting at surgery) states may have in place.
• Not all the prohibitions communicated to us can be sourced to a written or publicly available policy. This is important because if the restriction is not written, then there’s the risk that someone invented the obstacle without having an official policy.

The wealth of information we’re collecting will help us identify policies that still need to be changed and allow us to map out where we should concentrate our advocacy efforts. AAPA is also encouraged by the fact that most states have been highly responsive and have communicated an interest in getting PAs this information. AAPA hopes that contacts made through the survey process can be the beginning of constructive dialogues in advocacy efforts going forward.

Trevor Simon is a director with AAPA’s Reimbursement Department. Contact him at [email protected].

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