Although supervising physicians are required to follow regulatory guidelines, it is also important that physician assistants (“PAs”) understand their role in the authority delegated to them and the specifics of regulatory compliance for supervision.

KRS 311.850 allows the Kentucky Board of Medical Licensure (“KBML”) to revoke, suspend, deny, decline to renew, limit, or restrict the license of a PA, or fine, reprimand or place a physician assistant on probation for up to five years for certain licensure violations, including exceeding the scope of medical services described by the supervising physician in the applications required under KRS 311.854; exceeding the scope of practice for which the physician assistant was credentialed under KRS 311.856 and 311.858; and/or aiding or assisting in the unlawful practice of medicine or osteopathy or any healing art, including the unlawful practice of physician assistants.

The actual scope of practice, including any locations where the PA would practice separately from the supervising physician, must be clearly explained in the physician’s application that must be approved by the KBML as well as the plan of supervision. It is important that the PA is aware of these requirements and know application process.

Further, PAs should understand the full gamut of “supervision”. Physician supervision means overseeing the activities of and accepting of responsibility for the medical services rendered by a PA. Both physicians and PAs are required to ensure that the delegation of medical tasks is appropriate to the PA’s level of training and experience, that how the PA is to access to the supervising physician is clearly defined, and that a process for evaluation of the PA’s performance is established. The KBML has established clear definitions and requirements for the different levels of supervision required: Direct, On-site, and Off-site. Due to these specific criteria for supervision, PAs and supervising physicians must understand what is expected of them to maintain compliance with regulatory requirements