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2013 PA Practice Act

Frequently Asked Questions

 

Controlled II Substance Prescriptive Authority

 

The 2013 PA Practice Act allows for a PA, with appropriate DEA authorization, who works in a hospital setting to write for a one-time parental dose of Category II medication within a 24 hour period. Can the PA write for an order to include multiple doses within the 24 hour period or just 1 dose.

 

The new law allows for 1 dose only, not 1 standing order.

 

The 2013 PA Practice Act specifies that a PA may write for a 30 day prescription of CII continuing therapy. Does the new law specify if the initial CII prescription has to be written by the PA’s supervising physician or just by a physician?

 

The new law specifies that a physician initiate the prescription if the PA is continuing therapy. It does not have to be written by the PA’s supervising physician.

 

If the PA initiates a prescription for a category II medication, at what point does their supervising physician need to evaluate the patient?

 

If a PA writes a 72 hour category II prescription and the patient needs to continue taking the same medication or the problem has not resolved, the patient must be seen by the supervising physician. A PA may not write another prescription for the same medication after they have written for a 72 hour time frame.

 

What is the definition of continuing drug therapy according to the new laws?

 

"Continuing drug therapy” is when the supervising physician has initiated chronic use of a category II prescription. A classic example of this would be Adderall or Ritalin. If the physician has started the patient on the one of these medications and the patient needs a renewal of the medication, a PA may write for the next 30 days supply. The supervising physician must be notified that the 30 day supply has been written.

 

Does the new law specify that the patient must see the physician again after the PA has started continuing drug therapy?

 

No. The new law does not state that the patient must return to the physician after a certain amount of time.

 

What should I do if a pharmacy rejects dispensing a duly authorized PA signed CN II prescription?

 

A pharmacist has the right to refuse to fill a prescription if they are unaware of the current PA practice act or if their corporate headquarters has not updated company policies in terms of accepting CN II prescriptions from SC PAs. If the pharmacist works for a chain of pharmacies and the corporate headquarters has not updated company policies and procedures, please notify the SCAPA office (803)356-6809 of which pharmacy chain is involved and the Legislative Committee will communicate with the company involved.

 

A PA should communicate directly with the pharmacist and recommend that the pharmacist call either SC DHEC (Ms. Dianne Grainger who can be reached by phone at (803)896-0634 and/or the SC BME at (803)896-4500 to verify the change to the PA practice act.

 

Another option is to suggest the pharmacist log on to the SC DHEC drug control verification web site to confirm that the PA is authorized to write for Category II prescriptions: (http://www.scdhec.gov/administration/drugcontrol/registration-verification.aspx). This searchable database has the names of all authorized prescribers of controlled substances and details which controlled substance they can prescribe.

 

Do you have to register separately for scheduled II prescriptive authority?

 

Yes. If you are ALREADY registered (and paid to date) with BME, SC-DHEC, and DEA for schedule 3-5, follow the steps on our website under the CONTROLLED SUBSTANCE tab to add schedule II prescriptive authority.

 

In regards to the prescribing ongoing therapy of schedule II medications, is the number of prescriptions a year limited (for example: only 1 prescription per year per patient)?

 

There are no limitations on the number of prescriptions you can write if it is for continuing current drug therapy. These are not called medication renewals, but are instead referred to as ongoing therapy. Remember, as a PA you can NOT change the dose, frequency, or quantity to be dispensed.

 

Is there any time period that the physician must re-examine the patient while the PA is prescribing ongoing schedule II medication therapy?

 

No, there is nothing specifying that the physician must re-examine the patient if the PA is continuing drug therapy. However, if the dose or frequency requires modification, the PA should consult with the physician. The physician will need to write the prescription with the changes.

 

Can you provide a patient with 3 different schedule II prescriptions of the same prescription and write "do not fill for 30 days” on 1 of the 3 and "do not fill for 60 days” on another of the 3 the prescriptions?

 

The practice act does not specify this. However, we strongly advise against doing this as may draw attention and get push back from the BME that would limit our laws.

 

What is the length of time that is considered continuation of therapy?

 

The physician must write the initial prescription. The PA can then prescribe ongoing therapy for a 30 day supply. The PA CANNOT adjust the medication dose, frequency, or quantity.

 

If a patient is prescribed Hydrocodone in the hospital and you want to give them Oxycodone at discharge, can the PA prescribe this?

 

Yes. The PA can write a prescription for a 3 day supply. The patient must be re-evaluated by the supervising physician to receive ongoing therapy.

 

Is a script given at the time of discharge from the hospital considered continuation therapy if the patient was initially given the prescription in the hospital? 

 

Yes. The PA can write for this prescription as long as a MID initiated the prescription in the hospital.

Are PAs allowed to prescribe anabolic steroids, such as testosterone?

Yes. There are no restrictions to prescribing these medications in the new PA Practice Act. You can prescribe these medications as long as your current Scope of Practice does not state any restrictions about prescribing them.

Are PAs allowed to dispense medications from their offices?

PAs are able to to prescribe and dispense drugs and medical devices that are lawfully delegated by their supervising physicians. However, only physician assistants holding a permanent license may prescribe drug therapy in this manner.

 

Does my supervising physician's information need to be included on a prescription that I write for a CII medication?

 

The law says the "physician assistant’s and physician’s name, address, and phone number" should be including on the prescription. Therefore, the supervising physician's name is required on the prescription. The practice name is not a substitute for the physicians name. The DEA number of the actual provider should be on the prescription.

Licensure Requirements

 

Can you explain the process for a new graduate who does not yet have a supervising physician who wishes to begin the licensing process prior to hire?

 

Licensure is a separate process from the approval to work with a specific supervising physician. You do not need to have a supervising physician identified to obtain your license. You can apply for a limited license or a full-license (the difference is having passed the PANCE). The BME will want you to submit the application and provide all of the documentation that you have graduated from an approved program. You can begin the process now before getting your diploma, but they will not give you a limited license until you have the diploma. If you are given a limited license, it will be converted to a full license upon the BME receiving confirmation from NCCPA of a passing PANCE score. Once you have a license, you can then find a potential employer. You and your employer must submit and receive approval of your Scope of Practice (SOP) Guidelines from the BME before you can begin seeing patients. The law gives the BME 10 business days to approve the SOP.

 

Does the new law address whether or not a supervising physician who has not had a PA before would have to have a formal meeting with the BME and the PA?

 

Licensure requires the interview with only the PA.

 

What do I need to do if I change my supervising physician?

 

Approval to work with a specific physician requires submission of the Change/Additional Primary Supervisor form with an attached Scope of Practice. The BME has 10 business days to approve. BME will verify that the physician has an unrestricted license.

 

Can a new graduate work in an office without the supervising physician present?

 

If the new graduate is fully licensed, not provisional or limited, then the graduate can work in the office without the supervising physician present.

 

Are there any restrictions or limitations to work under the direction of my supervising physician in the following facilities: Skilled Nursing Homes, Assisted Living Facilities, Hospice Agencies or Home Health Agencies?

 

With the recent changes in the PA practice act in SC, there should be no restrictions in your engagement in taking care of patients in these settings. As long as your supervising physician works in these settings, then you are allowed to provide care to patients in these settings. It should be spelled out in your practice guidelines that you will be evaluating and managing patients in these settings. However, Medicare does not pay for PAs to provide hospice care.

 

Is there anything I have to do in order to terminate my relationship with my current supervising physician?

 

When a PA and his/her supervising physician terminate their relationship, the BME requires notification. To simplify the process, there is now a 1 page form titled: "Primary Supervisor Termination Notification” that should be completed and mailed to the LLR.

 

Are PAs allowed to provide house calls?

 

The wording in the new PA practice act allows PAs to provide house calls. The BME specifically requested that PAs be able to provide this service. In addition, Medicare will compensate the practice for house call services provided by a PA.

Are there any requirements for PA onsite or offsite supervision of the PA by their physician?

The new law no longer specifies the percentage of time the physician must be physically present in either the onsite or offsite practice settings. An offsite practice can now be within a 60 mile radius from the primary practice setting. However, the physician must co-sign, at a minimum, 10% of the charts. If a physician/PA team wants the PA to work in an offsite practice site, they must work as a team for 6 months before requesting approval by the BME. The practice guidelines should stipulate the percent of charts to be co-signed; however, it should not be less than 10%.

How do I add new tasks to my current scope of practice?

The On the Job Training (OJT) requirement has been significantly modified. A PA no longer has to submit a request for OJT. Instead, a PA and supervising physician may work collaboratively and increase the skill set of the PA. PAs may be educated by the supervising physician and the PA may be engaged in learning new skills with the direct supervision of the physician. However, it they want to add an additional task to the practice guidelines so that PA can provide the task or service without supervision, they must acquire BME approval. This can be done by submitting a 1 page Additional Task Request FormThe PA and supervising physician should receive a response from the BME within 10 business days.  

 

Will my PA license remain active even if I take time off from the workforce and will therefore not be actively practicing as a PA?  Will my DEA and DHEC licenses remain active during this time?

Since our Practice Act change separated licensure from employment, you should be able to maintain your license without working.  Once you re-enter the work force, you will need to have an approved scope of practice specific to your discipline of choice.  You will also have to keep up with any licensing fees and certification requirements while you are not working in order to keep your license active.  With regards to your DEA and DHEC licenses, these are associated with your individual job, so these would expire and you would have to reapply for them once you have a new position.


Chart Co-Signature Requirements

 

What is the physician co-signature requirement for PAs who work in the hospital setting?

The state law does not require the physician to co-sign your hospital charts. The law does not specifically speak to the issue of chart co-signature in the hospital setting. The law addresses 2 settings: on-site practice and off-site practice. It’s written to address whether or not you and the physician work in the same site or on separate sites. The off-site practice must be within a 60 mile radius.

If the physician is on-site in the hospital then none of your charts have to be cosigned per the State Practice Act. However, if you are doing rounds while he/she is in the office, then the BME might consider that an off-site practice. Therefore, you could notify the BME through a modification of your scope of practice guidelines to specify 10% of your charts are to be co-signed. This would be in compliance with the PA practice act.


Miscellaneous

Can a PA share ownership of a medical practice?

Yes. As long as physician supervision requirements are met and maintained, a PA can share ownership of a medical practice. 

Can a PA write prescriptions for and sign for DMV Disability (Handicap) Placards?

No. At this time, Physician Assistants are not able to sign DMV forms and write prescriptions for handicap placards. SCAPA has this on a list of legislative topics to address during our next legislative session.

 

 


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