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Pennsylvania Society of Physician Assistants

Member Login Join or Renew
  • Home
  • About
    • Our Purpose
    • Officer Directory
    • Officer’s Responsibilities
      • President
      • President Elect
      • Immediate Past President
      • Treasurer
      • Secretary
      • Directors at Large
      • Student Directors at Large
  • News
    • Blog
    • Newsletters
    • PSPA News Brief
  • Contact
  • Why PSPA
    • Overview
    • For Practicing PAs
    • For Students
    • For Employers
  • Membership
    • Reasons to Join PSPA
    • Join PSPA
    • Membership Levels
    • Benefits of Membership
      • Insurance Benefits
    • Member Directory
    • Renew Membership
    • Keystone Cash
    • Gift Memberships
  • Career Center
    • Overview
    • Job Seekers
      • Find a Job
      • Interviewing Tips
      • Pre-Employment Checklist
      • Anatomy of a Contract
      • New Graduate Info Sheet
      • Obtaining State License
      • Employment Exit Checklist
    • Employers/Recruiters
      • Employer Career Center
      • How to Find a PA
      • Benefits of Hiring a PA
      • Reimbursement for Services
      • Advertising and Fees
    • Resources
      • Salary and Demographics
      • Physician PA Team
      • Summary of PA Regulations
      • Amending Hospital Bylaws
      • Research Grant
  • Student Affairs
    • Overview
    • Potential Students
    • Active Students
    • Graduating Students
    • Pennsylvania PA Programs
    • Challenge Bowl
      • General Info/Rules
      • Challenge Bowl FAQs
    • Student Leader Philanthropic Endowment
    • Student Awards/Scholarships
      • Nathaniel Alston Student Achievement Scholarship Award
      • Thomas J. Lemley Award for Health Disparities Competition
    • Links
  • Advocacy
    • Overview
    • Governmental Affairs
      • Action Center
      • State Boards of Medicine and Osteopathic Medicine
      • Online Written Agreement Information
      • Regulatory Activity
      • Legislative Activity
      • Political Action Committee
      • About PSPA PAC
      • Tools
      • SBM Regulations**
      • SBOM Regulations**
      • Archives
    • Workplace
      • Leadership
      • PSPA Annual Awards
        • How it Works
        • Fellow Awards
        • PSPA Award Winners
    • Community
      • Health Disparities
      • Annual Charity
      • 10 Ways to Make a Difference
    • Committees
      • Committee Information
      • Committee Annual Reports
      • AAPA House Delegates
      • Awards Committee
      • Conference Planning Committee
      • Election Committee
      • Finance Committee
      • Governmental Affairs Committee
      • Health Disparities Committee
      • Historian
      • Leadership & Mentoring Committee
      • Membership Committee
      • Newsletter Committee
      • PSPA Liaison
      • Public Relations & Education Committee
      • Regional Affairs Committee
      • Reimbursement Committee
      • Social Media
      • Standing Rules & Policy Committee
      • Student & Faculty Affairs Committee
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      • Website Committee
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      • Spread the Word
      • Addressing Specific Audiences
      • Concepts to Convey
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      • 2023 CME Conference Rates & Registration
      • General Information
      • Schedule
      • Thank you to our 2022 speakers!
      • Hotel Information
      • CME Workshops
      • Professional Sessions
      • Current Exhibitors
      • Special Events
      • Conference Faculty
      • Committee Interest Form
      • Exhibitor and Sponsor Information
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      • Future Conference Locations
      • Posting of Conference Lectures
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News

Implementing Act 101 and 101 Countersignatures

Posted on March 10, 2014 by Susan DeSantis

The State Board of Medicine / State Board of Osteopathic Medicine are implementing changes to effectuate Act 100 /101 of 2013 (related to physician requirements for countersigning patient records completed by a physician assistant). Physicians who currently have a written agreement with a physician assistant, and who wish to change their current countersigning practice, must submit a written agreement change form and have the change approved by the Board. Physicians who are entering into a new written agreement will see the statutory amendment reflected in the new application form.

Prior to the enactment of Act 100/101 of 2013, a supervising physician was required to countersign 100% of the patient records completed by the physician assistant within a reasonable time, not to exceed ten days. Under the new rules, 100% countersignature within 10 days will be required only during each of the following time periods:

  • The first 12 months of the physician assistant’s practice post-graduation and after obtaining licensure.
  • The first 12 months of the physician assistant’s practice in a new specialty.
  • The first 6 months of the physician assistant’s practice in the same specialty under a new primary supervisor (unless, the new primary supervisor was registered as a substitute supervisor for at least six months under another written agreement).

If after the required time frames listed above, the supervising physician wishes to deviate from the 100% chart review, the supervising physician must complete and submit a written agreement change form, including specific details regarding how patient records will be selected for review and how often patient records will be reviewed.

This information should include specifics such as type or percentage of patient charts that will be reviewed, specific types or categories of patient cases that will be reviewed, and the review schedule, etc. In addition, the supervising physician must affirm that the review plan is sufficient to assure adequate review of the physician assistant’s practice.

Deviation from 100% review of patient records within 10 days will require Board approval.

The supervising physician will need to continue to perform 100% review of patient records within 10 days until the Board approves the amended written agreement.

Countersignature requirements in a facility are under the jurisdiction of the facility bylaws, the Pennsylvania Department of Health’s Health Care Facility Act, and The Joint Commission. Maintenance of 100% countersignature may still be required in your setting. The medical staff office, facility compliance office or the lead PA would be your resource for those details. A facility’s bylaws can be more restrictive than the state regulations for PA practice.

The written agreement change form can be found on the Medical Board’s website at www.dos.state.pa.us/med or the Osteopathic Board’s website at www.dos.state.pa.us/ost within the list of Board applications.

Acts 100 / 101 formalize the temporary authorization practice provision process as well.

The Acts approved a temporary authorization for Physician Assistants to practice pending formal approval of the “Application for Registration as a Supervising Physician.”

Upon submission of the application, Board staff will review the application only for completeness and issue a letter to the supervising physician providing the temporary authorization for the physician assistant to begin practice. If the application is not “complete” (i.e., required signatures are not provided, information is missing, fee is not included, etc.), a temporary authorization for the physician assistant to begin practicing will not be issued.

The temporary authorization, when issued, will provide a period of 120 days during which the physician assistant may practice, under the terms set forth in the written agreement as submitted to the Board. While practicing under the temporary authorization, the supervising physician shall countersign 100% of the patient records completed by the physician assistant within a reasonable time, which shall not exceed ten days. Within 120 days, the Board will notify the supervising physician of the final approval or disapproval of the application. If approved, a final approval of the written agreement will be issued to the Supervising Physician. If there are discrepancies that have not been corrected within the 120 day period, the temporary authorization to practice will expire.

Please note: The primary supervisor’s responsibilities also include:

• Providing a copy of the final Board approved written agreement to all substitute

supervisors.

  • Maintaining a current list of all locations where the physician assistant will perform duties.
  • Maintaining a current list of all substitute supervisors under which the physician assistant will work.
  • Notifying the Board of changes to the primary practice location utilizing a written agreement change form.
  • Ensuring that the physician assistant will not practice without supervision by either the primary supervisor or an authorized substitute supervisor.

The complete language for Act 100 / 101 can be found on the PSPA website, www.pspa.net under the Governmental Affairs tab legislative section. A reference table describing the implementation of Act 100 and 101 can also be found in the same section of the PSPA website. It is highly recommended that all PA’s confirm receipt of the temporary and final approvals from the Board(s) and retain a copy for your own file.

Sincerely,

Mark DeSantis, PA-C Gerry Grega, PA-C

PSPA Governmental Affairs Committee Chair PSPA President

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