Documentation necessary for practicing as a PA in North Carolina
North Carolina is a wonderful state for PA practice. There are currently over 5700 certified PAs living and/or practicing in North Carolina. Our laws make it possible for PAs to utilize the clinical skills and expertise they have developed through education and practice. North Carolina’s Rules and Regulations clearly state what is required for the physician-PA team to have documented in our practice. Usually, PAs only think (or more likely worry) about this when they are being visited by a Medical Board Investigator. Following these suggestions will ensure that you have the necessary documentation required. Remember, these documents need to be at your work and available for inspection.
1. Documentation of Continuing Medical Education
Documentation must be maintained of 100 hours of CME for every two-year period, at least 50 hours which must be AAPA Category 1 or equivalent.
2. Written instructions from the supervising physician for prescribing drugs
These instructions have no required format. They would vary according to the type of medical practice involved, and should be updated periodically as the MD-PA team matures in its working relationship.
3. Written policy for periodic review by the physician of the drugs prescribed
A statement detailing when and how the PA’s prescribing practice is reviewed to assure conformity to the previously documented written instructions for prescribing drugs.
4. A statement clearly describing supervisory arrangements
Access to the supervising physician is defined including adequate back-up supervision for any procedures performed by the PA in any practice setting. If the PA practices at multiple sites, the statement must include details on how the PA can access the supervising physician from various locations. A list of back-up supervisors must also be kept, dated, and signed by the PA and supervising MD and kept on site.
5. The scope of practice should be identified
This should include tasks delegated that are appropriate to the level of competence of the PA. A statement should be made in this section if the PA may order consults from others without approval by the supervising physician.
6. A copy of current licensure approval by the NC Medical Board
This should be kept for inspection. In addition, PAs must wear a name tag identifying themselves as a “Physician Assistant” or a “PA”.
7. A copy of your intent to practice must be kept on site
8. QI meetings
Minutes from your semiannual QI meetings must kept be on file for review.
Requirements to prescribe controlled substances
In order to prescribe controlled substances, both the PA and the supervising physician must have a valid DEA registration and the PA shall prescribe in accordance with information provided by the Medical Board and the DEA. All prescriptions for substances falling within schedules II, IIN, III, and IIIN, as defined in the federal Controlled Substances Act, shall not exceed a legitimate 30 day supply.
The above requirements need not be addressed in a “cookbook” format. General statements that detail specific plans, plus documentation of when the plans are reviewed, are necessary to ensure compliance. Remember though, if your written instructions detail quarterly meetings with your supervising physician, make sure you have quarterly meetings and that the outcome is documented. There is no one correct format that would fit everyone’s practice. If you have questions regarding your practice documentation, please contact the NCAPA Central Office who will then pass your question to the appropriate individual.
Important notice for PAs who dispense pharmaceuticals
The Board of Pharmacy promulgated rules as they relate to dispensing of medication. They state (paraphrased) that there must be written instructions to dispense drugs from the supervising physician. A current pharmacy permit must be obtained from the Board of Pharmacy. Drugs are to be prepackaged in safety-closure containers and the name of the patient and directions for use must be placed on the label.
There shall be a consulting pharmacist to prepare a plan to ensure proper ordering, storing, and packing of drugs. In addition, all drugs dispensed by the PA shall be reviewed by the pharmacist on a weekly basis for compliance with retrospective drug review, cost effectiveness, and optimal drug therapy. The law lists various factors the pharmacist shall consider in respect to the drug review. The Academy believes many of these requirements overstep the bounds of the consulting pharmacist and in essence makes it that the PA has a supervising physician and a supervising pharmacist.
Giving patients prepackaged pharmaceutical samples does not constitute dispensing.