Colorado Physician Assistant Collaborative Agreements
During the 2023 legislative session, SB23-083 was passed by the General Assembly. The bill modified the relationship between a Physician Assistant and a Physician or a Podiatrist by removing the requirement that a Physician Assistant be supervised by a Physician or a Podiatrist. Instead, a Physician Assistant must enter into a Collaborative Agreement with a Physician, Podiatrist or a Physician Group. There are circumstances where the Collaborative Agreement must take the form of a Supervising Agreement. The Physician or Podiatrist must be licensed in good standing in Colorado and be actively practicing with a regular and reliable physical presence in the state.
For more specific information on requirements and answers to frequently asked questions, review the information in the tabs below.
PA Collaborative Agreement FAQ's
General Information About Collaborative Agreements
Q: What is a Collaborative Agreement?
A: A collaborative agreement is defined as a written agreement describing the manner in which a physician assistant collaborates with a physician or physician group.
Q: What must be included in a Collaborative Agreement?
A: Collaborative Agreements must include:
- The physician assistant's name, license number, and primary location of practice;
- The signature of the physician assistant and the physician or physician group with whom the physician assistant has entered into the collaborative agreement;
- A description of the physician assistant's process for collaboration;
- A description of the performance evaluation process, which may be completed by the physician assistant's employer in accordance with a performance evaluation and review process established by the employer; and,
- Any additional requirements specific to the physician assistant's practice required by the employer or by the physician or physician group entering into the collaborative agreement, including additional levels of oversight, limitations on autonomous judgment, and the designation of a primary contact for collaboration.
Q: Where must Collaborative Agreement records be stored?
A: Collaborative agreements must be kept on file at the Physician Assistant’s primary practice location and be made available to the board upon request. A primary supervisor registration form is no longer required.
Q: What location restrictions are there for physicians entering into these agreements?
A: Physicians must be actively practicing medicine in Colorado by means of a regular and reliable physical presence in Colorado. Practicing medicine based primarily on telecommunication devices or other telehealth technologies does not constitute “actively practicing medicine in Colorado".
General Information About Supervisory Agreements
Q: What are the requirements for supervisory agreements?
A: Physician Assistants falling shy of practice hour thresholds that require Supervisory Agreements must complete collaboration during the first 160 practice hours in person or through technology as permitted by the Physician or Physician Group with whom the Physician Assistant is collaborating. These practice hours need to incorporate elements defining the expected nature of collaboration along with a performance evaluation and discussion of the performance evaluation with the Physician Assistant.
Q: Will the Board require Supervising Physician Forms for Physician Assistants that require a supervisory agreement?
A: Supervising Physician Forms are not required. But it is important that the Physician Assistants that require a supervisory agreement follow all applicable laws.
Q: Do requirements differ for physician assistants with fewer than 5,000 practice hours or those Physician Assistants changing practice areas with fewer than 3,000 practice hours in the new practice area?
A: Yes. In the instances where Physician Assistants have fewer than 5,000 practice hours, or change practice areas with fewer than 3,000 practice hours in the new practice area, these Collaborative Agreements are instead Supervisory Agreements with required elements.
Q: What kind of agreements are applicable to Level I or Level II trauma center settings?
A: Collaborative Agreements entered into by Physician Assistants in emergency departments in hospitals with Level I or II trauma center settings shall take the form of a Supervisory Agreement as identified in section 12-240-114.5(2)(b)(IV)(A), C.R.S.
General Information About Evaluations
Q: What must be included within a performance evaluation?
A: Performance evaluations should include domains of competency relevant to the practice of a Physician Assistant, use more than one modality of assessment to evaluate the domains, and includes consideration of the Physician Assistant's education, training, experience, competency, and knowledge of the specialty practice area in which the Physician assistant is engaged.
Q: What modalities of assessment are applicable to evaluating competency?
A: Modalities of assessment to evaluate domains of competency may include but are not limited to: co-management of patients; direct observation; chart review with identification of charts reviewed; and, feedback from patients and other identified providers.
Q: Is fingerprint identification part of the compact application process?
A: Yes. A fingerprint background check is required.
Q: Can previous fingerprint results be used during the compact application process?
A: No. Federal law requires that you submit a background check specific to your Colorado application for a Compact Physician License. Previously submitted or completed background checks cannot be used to obtain a Compact Physician License.
Q: Would legal issues in an individual’s background prevent compact licensure?
A: Background checks are required for obtaining a license. Any items flagged during a criminal background check may prohibit eligibility for a compact physician license. Pursuant to 24-60-3602, Section 2(k)(6), requirements for licensure include individuals who have “never been convicted, received adjudication, deferred adjudication, community supervision, or deferred disposition for any offense by a court of appropriate jurisdiction.”
General Information About Collaborative/Supervisory Agreements
Q: Is the scope of practice for Physician Assistants impacted?
A: The new law does not expand scope of practice; it modifies the requirement for a supervisory relationship to a Collaborative Agreement.
Q: Can a Physician Assistant prescribe controlled substances?
A: Physician Assistants may issue prescription orders for any drug or controlled substance provided that each prescription and refill order is entered on the patient’s chart, along with the physician assistant’s name and the address of the health facility or specialty clinic in which he/she is practicing. The Physician Assistant must possess a valid DEA registration.
Q: What if someone needs help understanding or interpreting this law?
A: Board staff cannot provide legal advice, which can include interpretation of laws, rules or policies. Please consult with your attorney or liability carrier, who may have in-house legal counsel, and/or a professional association who may be able to provide valuable insights as to the generally accepted standard of practice regarding this Bill and Rule.