- Is the supervising physician's name required to be on a prescription written by a PA?
- Can a PA telephone a prescription to a pharmacist?
- Is it legal for a PA to prescribe controlled substances using a supervising physician's DEA number?
- Is a PA required to have written practice guidelines or protocols?
- Is it within the scope of practice for a physician assistant to administer conscious sedation (IVCS)? If so, does the Board have an IVSC policy?
- Can physician assistants pronounce deaths?
- How many Physician Assistants can a Registered Physician supervise at one time?
1. Is the supervising physician's name required to be on a prescription written by a PA?
Yes. M.G. L. Chapter 112, section 9E specifically states the following: "Any prescription of medication made by a physician assistant must include the name of the supervising physician."
Department of Public Health regulations at 105 CMR 721, Prescription Format and Security in Massachusetts, (721.020 (B)) state that "Prescriptions for … physician assistants shall also contain the name of the supervising physician."
Physician assistant regulations at 263 CMR 5.07 state that prescribing is to be done in accordance with all applicable federal and state statutes and regulations.
The statue and regulations apply to both hard copy/paper prescriptions and electronic prescriptions.
2. Can a PA telephone a prescription to a pharmacist?
Pharmacy Board and DPH regulations permit pharmacists to accept oral prescriptions from a Physician Assistant.
Pharmacists may only accept oral prescriptions for Schedule II drugs in an "emergency" as defined in DPH regulations at 105 CMR 701.003 (PDF).
3. Is it legal for a PA to prescribe controlled substances using a supervising physician's DEA number?
No. In order to write legal prescriptions in MA, a PA must have, at a minimum, a State Controlled Substance Registration (CSR) number. In addition, to order controlled substances in Schedules II - V, a PA must have his/her own DEA registration number. ( MGL, c. 112, s. 9E; MGL, c. 94C, ss. 7, 9 & 20; 105 CMR 700.004 (PDF); and 263 CMR 5.07 (1))
4. Is a PA required to have written practice guidelines or protocols?
The Board regulations require specific written protocols for the PA's performance of major invasive procedures. The protocols, developed between a supervising physician and PA, must specify the level of supervision the service requires. ( 263 CMR 5.04(4))
PAs must have written prescription guidelines that are mutually developed and agreed to by the supervising physician and PA. The Board's regulations, at 263 CMR 5.07, define the requirements for the written prescription guidelines. Guidelines must to be reviewed annually and signed by both the PA and the supervising physician. Please see Prescription Practice Guidelines.
5. Is it within the scope of practice for a physician assistant to administer conscious sedation (IVCS)? If so, does the Board have an IVSC policy?
Under the Board of Registration in Medicine (BORM) Policy 94-004, adopted May 11, 1994, Patient Care Assessment Guidelines for Intravenous Conscious Sedation, PAs are not prohibited from administering intravenous conscious sedation (IVCS). The Medicine Board's IVCS guidelines advise, however, that "individuals who administer IVCS should be competent in airway management and resuscitation measures (i.e., at least BLS certified; ACLS certified or equivalent is strongly suggested) and should be educated regarding and demonstrate knowledge in the use, side effects and complications of the medication to be given." In addition, the IVCS guidelines recommend that hospitals' and clinics' policies and procedures should specifically address various situations in which certain types of practitioners (for example, anesthesiologists) must administer [IVCS]. Using these parameters, and abiding by all relevant statutes, regulations, and standards of practice, it is then up to each health care facility to develop its own policies and procedures governing the administration of [IVCS].
6. Can physician assistants pronounce deaths?
Yes. A registered physician assistant, after the death of a person who was a patient under the care of such physician assistant, may declare such person dead, provided, however, that said physician assistant first makes a reasonable effort to contact the attending physician or medical examiner before making such determination or pronouncement; provided further that such determination or pronouncement be made in writing on a form approved by the commissioner of public health and subscribed under pains and penalties of perjury; and, provided further, that the medical examiner be notified forthwith of the exact location to which the decedent has been removed. (MGL, ch.46, s.9)
7. How many Physician Assistants can a Registered Physician supervise at one time?
Effective November 4, 2012, M.G.L. c. 112, § 9E was amended to eliminate the limitation on the number of physician assistants who could be supervised by a supervising physician. Board regulation 263 CMR 5.05(2) containing the same limitation was deleted by emergency regulation effective May 29, 2013. Physician assistants must continue compliance with 263 CMR 5.05, Scope of Supervision Required, and supervising physicians must continue compliance with 243 CMR 2.08, Physician Assistants.