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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6/28/23  10:20 pm
Commenter: Evan Turnbull, MPAS, PA-C, UVA Health

Support proposed amendments

I agree with the proposed amendment as written, and I second the opinions of my colleagues below. Additionally, I am in favor of removing unnecessarily restrictive language like what we have now that hinders patient care and access to care,  language that shows a profound misunderstanding of the training of a PA and the patient care delivered by a PA, a profound misunderstanding of the dynamic PA-MD collaborative relationship, and poorly worded language with legal bias. As written,  a prosecuting attorney is handed a clear and objective timetable of two visits to pin against a medical team, yet leaves the medical team with vague and subjective language to try and interpret in every patient encounter. A PA could also misinterpret the two visit rule and delay appropriate consultation on the first visit believing the standard of care only requires escalation of care if needed after a second visit. I would argue that standard of care for PAs is a national requirement of practice since a PA’s training is nationally accredited, and nationally certified by one certification body. The definition of two visits with a patient regardless of circumstance, chief complaint and practice setting is not standard of care. What IS standard of care, as my colleagues have already mentioned, is that the PA would use his or her clinical judgement to determine when care needs to be brought to a physician, or a referral to a specialist made, at ANY point in the management of that patient, regardless of which visit it is. Thank you. 

CommentID: 217524