Virginia Regulatory Town Hall
Department of Health Professions
Board of Medicine
Regulations Governing the Practice of Physician Assistants [18 VAC 85 ‑ 50]
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6/5/23  9:19 pm
Commenter: Phillip Davis, MHA, MPAS, PA-C


Each PA is required to have a written Practice Agreement with their team physician.  My understanding is that unless the physician is directly involved in the patient's care, they are not liable for that patient's outcome.  

As a physician assistant who is licensed by the Commonwealth of Virginia and credentialed to practice medicine, I understand my own limitations and in all cases ensure I have a practice agreement in place to protect patient safety and ensure I am practice within my scope of care.   As a collaborating member of the healthcare team, each PA has the responsibility and accountability to the patient.   

If a patient fails to improve as expected, it is incumbent upon the PA (or any health practitioner for that matter) to ensure the patient is referred in a timely matter.  I have issues with "fails to improve as expected".  Who determines "improve as expected".   PAs and all medical professionals have a duty to the patient and this petition to change the wording in 18VAC85-50-110 will in no way affect patient outcomes and will ensure physicians are available for complex cases.   

I would reiterate that PAs are licensed medical professionals who by training and education are aware, as should any provider, of their scope of practice and limitations.   In my mind, the Practice Agreement should determine the conditions for which a patient is re-evaluated.  

To provide the best and safest possible care, PAs are trained and educated to practice within their scope of practice and in accordance with their Practice Agreement.  Standard of Care does not change regardless of the level of care and it is incumbent upon each practitioner to ensure they are meeting the standard of care.   

Changing the wording to remove ambiguity will serve to ensure PAs continue to practice within their scope of care and ensure the standard of care is provided to provide the best possible outcomes for patients entrusted to their care. 

CommentID: 217062