Summary of State Laws and Regulations Requiring Physicians to Review Or Co-Sign PA Medical Record Entries
Alabama
For hospitalized patients, physician assistants may enter verbal admission orders and verbal subsequent orders for medications from the physician. All such orders must be validated by the ordering physician within 24 hours or within the time period specified in the hospital bylaws or policies.Countersignature by supervising physician must conform to established policy and/or applicable legal regulations and accreditation standards.
Alaska
No co-signature requirement.Arizona
A supervising physician shall develop a system for recordation and review of all instances in which the physician assistant prescribes 14-day prescriptions of schedule II or schedule III controlled substances. The board shall approve this system.Arkansas
California
(1) same day examination of patient by physician
(2) countersignature and dating of all medical records within 30 days
(3) adoption of protocols to govern a physician assistant's performance
(4) other mechanisms approved by PAC
The supervising physician must review, countersign and date at least 10% of medical records within 30 days for patients treated by physician assistants working under protocols.
*Regulatory change to implement 2007 statute change has not yet been adopted.
Colorado
"Reviewing the medical records" means review and signature by the primary physician supervisor or a secondary physician supervisor.
New physician assistant graduates:
For the first 6 months of employment and a minimum of 500 patient encounters, a physician supervisor shall review the chart for every patient seen by the physician assistant no later than 7 days after the physician assistant has performed an act defined as the practice of medicine. The physician supervisor shall document the performance of such review by signing the chart in a legible manner. In lieu of signing the chart, the physician supervisor may document the performance of such review by the use of an electronically generated signature provided that reasonable measures have been taken to prevent the unauthorized use of the electronically generated signature.
Experienced Physician Assistants New to a Practice Setting:
For the first 3 months of employment and a minimum of 500 patient encounters, a physician supervisor shall review the chart for every patient seen by an experienced physician assistant new to a practice setting no later than 14 days after the physician assistant has performed an act defined as the practice of medicine. The physician supervisor shall document the performance of such review by signing the chart in a legible manner. In lieu of signing the chart, the physician supervisor may document the performance of such review by the use of an electronically generated signature provided that reasonable measures have been taken to prevent the unauthorized use of the electronically generated signature.
All other PAs must meet with supervising physician twice yearly and physician must conduct performance assessment (to include review and initialing of selected charts).
Connecticut
Supervision includes, but is not limited to:
(i) Continuous availability of direct communication either in person or by radio, telephone or telecommunications between the physician assistant and the supervising physician;
(ii) active and continuing overview of the physician assistant's activities to ensure that the supervising physician's directions are being implemented and to support the physician assistant in the performance of his or her services;
(iii) personal review by the supervising physician of the physician assistant's services through a face-to-face meeting with the physician assistant, at least weekly or more frequently as necessary to ensure quality patient care, at a facility or practice location where the physician assistant or supervising physician performs services;
(iv) review of the charts and records of the physician assistant on a regular basis as necessary to ensure quality patient care and written documentation by the supervising physician of such review at the facility or practice location where the physician assistant or supervising physician performs services
Delaware
District of Columbia
Physician assistants may write orders and progress notes in outpatient settings. Countersignature by the supervising physician shall not be required prior to the execution, but shall be accomplished within 10 days of the execution of the order and within 10 days of any progress note.
Florida
Georgia
A copy of the prescription is maintained in the patient's medical file and the supervising physician must countersign the prescription or medical record entry for prescription within 7 working days.
In a remote site (physician is present at least 25% of the time) in an area with a shortage and maldistribution of health care services a supervising physician must be physically present at least twice a week and review patient records daily and all entries made by a physician assistant in patient medical records must be co-signed by a supervising physician within 7 days.
Hawaii
Idaho
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iii. Periodic review of a representative sample of records and a periodic review of the patient services being provided by the licensee. This review shall also include an evaluation of adherence to the delegation of services.
Illinois
It is the responsibility of the supervising physician to direct and review the work, records and practice of the physician assistant on a timely basis.
Indiana
Direction and supervision must be personally rendered by supervising physician, who must be physically present or immediately available at all times. Supervising physician shall review medical services provided by a physician assistant within a reasonable time, not to exceed 24 hours.
Iowa
Patient care provided by the physician assistant may be reviewed with a supervising physician in person, by telephone or by other telecommunicative means.
When signatures are required, electronic signatures are allowed if: (1) The signature is transcribed by the signer into an electronic record and is not the result of electronic regeneration; and (2) A mechanism exists allowing confirmation of the signature and protection from unauthorized reproduction.
A physician assistant may provide medical services in a remote medical site if one of the following three conditions is met:
(a) The physician assistant has a permanent license and at least one year of practice as a physician assistant; or
(b) The physician assistant with less than one year of practice has a permanent license and meets the following criteria:
(1) The physician assistant has practiced as a physician assistant for at least six months; and
(2) The physician assistant and supervising physician have worked together at the same location for a period of at least three months; and
(3) The supervising physician reviews patient care provided by the physician assistant at least weekly; and
(4) The supervising physician signs all patient charts unless the medical record documents that direct consultation with the supervising physician occurred; or
(c) The physician assistant and supervising physician provide a written statement sent directly to the board that the physician assistant is qualified to provide the needed medical services and that the medical care will be unavailable at the remote site unless the physician assistant is allowed to practice there. In addition, for three months the supervising physician must review patient care provided by the
physician assistant at least weekly and must sign all patient charts unless the medical record documents that direct consultation with the supervising physician occurred.
Kansas
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(g) at least every 14 days, reviews all records of patients treated by the physician assistant and authenticates this review in the patient record;
(h) reviews patient records and authenticates the review in each patient record within 48 hours of treatment provided by the physician assistant if the treatment provided in an emergency exceeded the authority granted to the physician assistant by the responsible physician request form required
Kentucky
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(10) Sign all records of service rendered by a physician assistant in a timely manner as certification that the physician assistant performed the services as delegated.
Louisiana
The physician assistant and supervising physician shall:
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(4) insure that, with respect to each direct patient encounter, all activities, functions, services, treatment measures, medical devices or medication prescribed or delivered to the patient by the physician assistant are properly documented in written form in the patient's record by the physician assistant and that each such entry is countersigned by the supervising physician within 24 hours with respect to inpatients in an acute care setting and patients in a hospital emergency department; within 48 hours with respect to patients of nursing homes and other sub-acute settings and within 72 hours in an office, clinic and all other practice settings
Maine
Maryland
Massachusetts
Any prescription or medication order issued by a physician assistant for a Schedule II controlled substance, as defined in 105 CMR 700.002, shall be reviewed by his or her supervising physician, or by a temporary supervising physician designated pursuant to 263 CMR 5.05(4)(g), within 96 hours after its issuance.Michigan
*identical language appears in laws governing the practice of osteopathic medicine
Minnesota
Mississippi
Missouri
It is the responsibility of the supervising physician and licensed physician assistant to jointly review and document the work, records, and practice activities of the licensed physician assistant at least once every two (2) weeks. The supervising physician must review a minimum of ten percent (10%) of the physician assistant’s patients’ records every two (2) weeks and have documentation supporting the review. For nursing home practice, such review shall occur at least once a month. The documentation of this review shall be available to the Board of Registration for the Healing Arts for review upon request.
Montana
(2) Chart review for a physician assistant having less than one year of full time practice experience from the date of initial licensure must be 100 percent for the first three months of practice, and then may be reduced to not less than 25 percent for the next three months, on a monthly basis, for each supervision agreement.
(3) The supervising physician shall countersign and date all written entries that have been chart reviewed and shall document any amendments, modifications, or guidance provided.
(4) Chart review for a physician assistant who has been issued a probationary license must be 100 percent on a monthly basis, unless the board terminates the probationary period.
Nebraska
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(4) The supervising physician, as a method of regular reporting, must review 100% of the charts of the patients seen by the physician assistant. A systematic documentation of these reviews must be established and maintained by the supervising physician.
Nevada
(b) A review and initialing of selected charts
New Hampshire
A physician assistant may write orders for patients as delegated by the supervising physician or alternate. Such orders shall be countersigned by the RSP or ARSP as required by institutional policy, however, such countersignature shall not be required prior to the order being executed.New Jersey
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(3) personal review by a physician of all charts and records of patients and countersignature by a physician of all medical orders, including prescribing and administering medication, within 24 hours of their entry by the physician assistant.
In an outpatient setting, direct supervision of a physician assistant shall include, but not be limited to:
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(3) personal review by a physician of the charts and records of patients and countersignature by a physician of all medical orders, within seven days of their entry by the physician assistant, except that in the case of any medical order prescribing or administering medication, a physician shall review and countersign the order within 48 hours of its entry by the physician assistant.
New Mexico*
The supervising physician will review and countersign each patient's chart in which the physician assistant has prescribed more than 72 hours of Schedule II drugs in a 30 day period for that patient.
*These regulations apply only to PAs licensed by the NM Board of Osteopathic Medical Examiners
New York
North Carolina
North Dakota
Ohio
(1) During the first five hundred hours of the provisional period, the review and evaluation shall be completed and documented on every chart by each supervising physician who provided supervision within a reasonable period of time after the physician assistant rendered service to a patient.
(2) During the remainder of the provisional period, the review and evaluation shall be completed and documented on at least fifty percent of the patient charts by each supervising physician who provided supervision within a reasonable period of time after the physician assistant rendered service to a patient.
Oklahoma
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(b) regularly reviewing the health care services provided by the physician assistant and any problems or complications encountered
Physician supervision shall be conducted in accordance with the following standards:
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(2) The supervising physician regularly reviews the health care services provided by the physician assistant and any problems or complications encountered.
(a) Office setting
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(2) It is assumed that the physician regularly and systematically checks the charts and notes of the patients seen by the physician assistant, checking for accuracy and completeness of such records, and in particular, the suitability of the plan of management. It is assumed that this type of review is conducted within 48 hours of the care being delivered.
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(b) Hospital setting
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(3) Initial workup of patients upon admission is often delegated to the physician assistant. This is an appropriate function if checked and countersigned by the supervising physician on his/her next visit to the hospital, which should usually occur within 24 hours.
(4) Initial orders may be delegated to a physician assistant. These activities are very important in that they involve the function of others, such as the R.N. and L.P.N. assigned to the ward. Copies of all standing orders that the physician has delegated to the physician assistant to order on his/her behalf should be on file in the hospital and available to the nurse accepting such orders as a means of assurance that these orders are emanating from the responsible physician and that they are within the authority which the physician has delegated to the physician assistant. All orders should be checked and countersigned by the responsible physician at his/ her next visit to the hospital, which should usually occur within 24 hours.
Oregon
Pennsylvania
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(4) The supervising physician will visit the satellite location at least once every 10 days and devote enough time onsite to provide supervision and personally review the records of selected patients seen by the physician assistant in this setting. The supervising physician shall notate those patient records as reviewed.
Recordkeeping requirements are as follows:
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(3) The physician assistant shall report, orally or in writing, to the supervising physician within 36 hours, a drug prescribed or medication dispensed by the physician assistant while the supervising physician was not physically present, and the basis for each decision to prescribe or dispense in accordance with the written agreement.
(4) The supervising physician shall countersign the patient record within 10 days.
An appropriate degree of supervision includes:
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(C) Personal and regular review within 10 days by the supervising physician of the patient records upon which entries are made by the physician assistant.
(a) A physician assistant may execute a written or oral order for a medical regimen or may relay a written or oral order for a medical regimen to be executed by a health care practitioner subject to the requirements of this section.
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(iii) Personal and regular - at least weekly - review by the supervising physician of the patient records upon which entries are made by the physician assistant.
*This provision applies only to PAs licensed by the State Board of Osteopathic Medicine
No physician assistant may be permitted to be utilized in an office or clinic separate and apart from the supervising physician's primary place for meeting patients unless the supervising physician has obtained specific approval from the Board. ... The criteria for granting approval is that the supervising physician demonstrate the following to the satisfaction of the Board:
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(4) That the supervising physician will visit the remote office at least weekly and spend enough time on-site to provide supervision and personally review the records of each patient seen by the physician assistant in this setting.
*This provision applies only to PAs licensed by the State Board of Osteopathic Medicine
Rhode Island
South Carolina
South Dakota
Tennessee
(7) Within ten (10) business days after the physician assistant has examined a patient who falls in one of the following categories, the supervising physician shall make a personal review of the historical, physical, and therapeutic data gathered by the physician assistant on that patient and shall so certify in the patient's chart within thirty (30) days:
(a) when medically indicated;
(b) when requested by the patient;
(c) when prescriptions written by the physician assistant fall outside the protocols;
(d) when prescriptions are written by a physician assistant who possesses a temporary license; and
(e) when a controlled drug has been prescribed.
(8) In any event, a supervising physician shall personally review at least twenty percent (20%) of charts monitored or written by the physician assistant every thirty (30) days.
Texas
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(B) visits the clinic in person at least once every ten business days during regular business hours during which the advanced practice nurse or physician assistant is on site providing care, in order to observe and provide medical direction and consultation to include, but not be limited to:
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(iii) verifying that patient care is provided by the clinic in accordance with a written quality assurance plan on file at the clinic, which includes a random review and countersignature of at least 10% of the patient charts by the physician
Utah
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(c) the supervising physician cosigns any medical chart record of a prescription of a Schedule 2 or Schedule 3 controlled substance made by the physician assistant.
The [delegation of services] agreement defines the working relationship and delegation of duties between the supervising physician and the physician assistant as specified by division rule and shall include:
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(iii) the frequency and mechanism of chart review
The supervising physician shall review and co-sign sufficient numbers of patient charts and medical records to ensure that the patient's health, safety, and welfare will not be adversely compromised. The Delegation of Services Agreement, maintained at the site of practice, shall outline specific parameters for review that are appropriate for the working relationship.
Vermont
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(b) Supervision:
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(5) Provisions for retrospective review of PA charts:
(A) the frequency with which these reviews will be conducted
(B) the methods to be used to document this review
Virginia
Washington
*This provision applies only to PAs who are not certified
It shall be the responsibility of the certified physician assistant and the sponsoring physician to ensure that appropriate consultation and review of work are provided.
*This provision applies only to PAs who are certified (PA-C)
(5) The osteopathic physician assistant and supervising osteopathic physician shall ensure that:
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(d) The supervising osteopathic physician provides adequate supervision and review of the osteopathic physician assistant's practice. The supervising osteopathic physician or designated alternate physician shall review and countersign:
(i) All charts of the licensed osteopathic physician assistant within seven working days for the first thirty days of practice and thereafter ten percent of their charts, including clinic, emergency room, and hospital patients within seven working days.
(ii) Every chart entry of an interim permit holder within two working days
*This provision applies to PAs who are supervised by osteopathic physicians, whether the PA is certified or not.
West Virginia
No physician assistant may be utilized in an office or clinic separate and apart from the supervising physician's primary place for meeting patients unless the supervising physician has obtained specific approval from the Board. ... The criteria for granting the approval is that the supervising physician demonstrate the following to the satisfaction of the Board:
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(d) That the supervising physician visits the remote office at least once every fourteen (14) days and demonstrate that he or she spends enough time on site to provide supervision and personal and regular review of the selected records upon which entries are made by the physician assistant. Patient records shall be selected on the basis of written criteria established by the supervising physician and the physician assistant and shall be of sufficient number to assure adequate review of the physician assistant's scope of practice.
An appropriate degree of supervision includes:
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(3) Personal and regular (at least monthly) review by the supervising physician of selected patient records upon which entries are made by the physician assistant. The supervising physician shall select patient records for review on the basis of written criteria established by the supervising physician and the physician assistant and shall be of sufficient number to assure adequate review of the physician assistant's scope of practice
Supervision requires the availability of the supervising osteopathic physician. An appropriate degree of supervision includes:
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c. Personal and regular (at least monthly) review by the supervising osteopathic physician of selected patient records upon which entries are made by the osteopathic physician assistant. The supervising osteopathic physician shall select patient records for review on the basis of written criteria established by the supervising osteopathic physician and the osteopathic physician assistant and these records shall be of sufficient number to assure adequate review of the osteopathic physician assistant's scope of practice
*This provision applies only to PAs supervised by osteopathic physicians
Wisconsin
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(e) The supervising physician either:
1. Reviews and countersigns the prescription order prepared by the physician assistant, or
2. Reviews and countersigns within 72 hours the patient record prepared by the physician assistant practicing in the office of the supervising physician or at a facility or a hospital in which the supervising physician has staff privileges, or
3. Reviews by telephone or other means, as soon as practicable but within a 72-hour period, and countersigns within one week, the patient record prepared by the physician assistant who practices in an office facility other than the supervising physician's main office of a facility or hospital in which the supervising physician has staff privileges.
Wyoming
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