What a Physician Assistant Practice Agreement Has to Contain

Answer first: the document is where the scope lives

California Business and Professions Code section 3502 states four requirements that must all be met before a physician assistant may perform medical services as authorized by the chapter. The assistant renders the services under the supervision of a licensed physician and surgeon who is not subject to a disciplinary condition prohibiting that supervision or prohibiting the employment of a physician assistant. The assistant renders the services pursuant to a practice agreement that meets the requirements of the following section. The assistant is competent to perform the services. And the assistant's education, training, and experience have prepared the assistant to render the services.

Two of those four are about the individual and two are about paperwork and about the supervising physician's own standing. A physician assistant's authority in California is therefore not readable from the credential alone; it depends on a document and on the disciplinary status of somebody else.

Washington reaches the same place through a different phrase. RCW 18.71A.030 states that a physician assistant may practice medicine in Washington to the extent permitted by the collaboration agreement, and that a physician assistant shall be subject to discipline under the state's Uniform Disciplinary Act.

Virginia frames it as a team. Code of Virginia section 54.1-2952 provides that a patient care team physician or patient care team podiatrist licensed under the chapter may serve on a patient care team with physician assistants and shall provide collaboration and consultation to those physician assistants, and that physician assistants may practice medicine to the extent and in the manner authorized by the Board.

California lists the provisions the agreement must address

Business and Professions Code section 3502.3 states that a practice agreement shall include provisions that address a named list of subjects.

The types of medical services a physician assistant is authorized to perform. Policies and procedures to ensure adequate supervision of the physician assistant, including, but not limited to, appropriate communication, availability, consultations, and referrals between a physician and surgeon and the physician assistant in the provision of medical services. The methods for the continuing evaluation of the competency and qualifications of the physician assistant. The furnishing or ordering of drugs or devices by a physician assistant pursuant to the cited section. And any additional provisions agreed to by the physician assistant and the physician and surgeon.

The signature requirement is stated separately. A practice agreement shall be signed by the physician assistant, and by one or more physicians and surgeons, or by a physician and surgeon who is authorized to approve the practice agreement on behalf of the staff of the physicians and surgeons on the staff of an organized health care system.

Two further sentences change how the document should be read. A practice agreement may designate a physician assistant as an agent of a supervising physician and surgeon. And nothing in the section shall be construed to require approval of a practice agreement by the board.

That last point is worth pausing on. The document is required, its contents are specified, and it is signed — but the statute expressly does not route it through the board for approval. It is a private instrument with statutory contents.

Section 3502 adds a provision about records that cuts against a common assumption. Nothing in regulations shall require that a physician and surgeon review or countersign a medical record of a patient treated by a physician assistant, unless required by the practice agreement. The board may, as a condition of probation or reinstatement, require review or countersignature of records for a specified duration.

California also states where the chapter does not reach: it does not authorize the performance of medical services in the determination of the refractive states of the human eye or the fitting or adaptation of lenses or frames; the prescribing or directing the use of optical devices in connection with ocular exercises, visual training, or orthoptics; the prescribing or fitting of contact lenses; or the practice of dentistry or dental hygiene or the work of a dental auxiliary. And within a general acute care hospital, a physician assistant shall be supervised by a physician and surgeon with privileges to practice in that hospital, with the practice agreement establishing policies and procedures to identify the supervising physician.

Washington measures autonomy in postgraduate hours

Washington is the only one of the three read here that puts a number of hours in the statute, and the number decides whether the relationship is supervision or collaboration.

RCW 18.71A.030 provides that a physician assistant who has completed fewer than four thousand hours of postgraduate clinical practice must work under the supervision of a participating physician, as described in the collaboration agreement and determined at the practice site. A physician assistant with four thousand or more hours of postgraduate clinical practice may work in collaboration with a participating physician, if the physician assistant has completed two thousand or more supervised hours in the physician assistant's chosen specialty.

Changing specialties resets part of that. If a physician assistant chooses to change specialties after completing four thousand hours of postgraduate clinical practice, the first two thousand hours of postgraduate clinical practice in the new specialty must be completed under the supervision of a participating physician, as described in the collaboration agreement and determined at the practice site.

As in California, supervision is defined by what it does not require: supervision shall not be construed to necessarily require the personal presence of the participating physician or physicians at the place where services are rendered.

On scope, Washington places the decision with named parties rather than in a regulation. Physician assistants may provide services that they are competent to perform based on their education, training, and experience and that are consistent with their collaboration agreement. The participating physician or physicians, or the physician assistant's employer, and the physician assistant shall determine which procedures may be performed and the degree of autonomy under which the procedure is performed.

There is an outer boundary. Physician assistants may practice in any area of medicine or surgery as long as the practice is not beyond the scope of expertise and clinical practice of the participating physician or physicians, or the group of physicians within the department or specialty areas in which the physician assistant practices.

Washington then writes a narrow exception to that boundary for long-experienced assistants in underserved settings. A physician assistant with at least ten years or twenty thousand hours of postgraduate clinical experience in a specialty may continue to provide those specialty services where employed in a practice setting in which the services are outside the specialty of the participating physician, as outlined in the collaboration agreement, if the practice is located in a rural area as identified by the department under the cited section or in an area designated by the federal health resources and services administration as a medically underserved area or as having a medically underserved population. The assistant must complete continuing education related to that specialty while performing services outside the participating physician's specialty.

Virginia caps the number and requires availability at all times

Virginia's section 54.1-2952 is published in two versions with contingent effective and expiration dates tied to a 2026 chapter. The language quoted here appears identically in both, so it does not depend on which version is in force.

The cap is stated in one sentence. No patient care team physician or patient care team podiatrist shall be allowed to collaborate or consult with more than six physician assistants on a patient care team at any one time.

The availability requirement is stated in another. A patient care team physician or patient care team podiatrist shall be available at all times to collaborate and consult with physician assistants. Each patient care team shall identify the relevant physician assistant's scope of practice and an evaluation process for the physician assistant's performance.

Virginia also addresses liability directly, which the other two texts do not. Service as part of a patient care team by a patient care team physician or patient care team podiatrist shall not, by the existence of such service alone, establish or create vicarious liability for the actions or inactions of other team members.

The employment provision is the part most relevant to a company structure. Any professional corporation or partnership of any licensee, any hospital, and any commercial enterprise having medical facilities for its employees that are supervised by one or more physicians or podiatrists may employ one or more physician assistants in accordance with the section. Activities shall be performed in a manner consistent with sound medical practice and the protection of the health and safety of the patient. Those activities shall be set forth in a practice agreement or by the credentialing and privileging practice arrangement requirements of a facility described in the cited subsection, and may include health care services that are educational, diagnostic, therapeutic, or preventive, including establishing a diagnosis, providing treatment, and performing procedures. Prescribing or dispensing of drugs may be permitted as provided in a separate section.

And one sentence closes the loop on responsibility: no person shall have responsibility for any physician assistant who is not employed by the person or the person's business entity.

What this means for reading a program's description of its clinicians

The three statutes together explain why the phrase physician assistant on a website does not answer the question a reader is usually asking.

In California, the services a given assistant is authorized to perform are named in a signed practice agreement that the board does not approve, and a physician's countersignature of records is not required by regulation unless that agreement requires it.

In Washington, whether the relationship is supervision or collaboration turns on hour counts — fewer than four thousand postgraduate hours means supervision; four thousand or more, with two thousand or more in the chosen specialty, permits collaboration — and which procedures may be performed is determined by the participating physician or the employer together with the assistant.

In Virginia, the patient care team identifies the scope of practice and the evaluation process, the physician must be available at all times, and no physician may collaborate or consult with more than six assistants at once.

Three consequences follow for a reader. The answer is written in a document, not printed on a credential. The document's contents are specified by statute but its terms are set by the parties. And the numbers that bound it — four thousand hours in Washington, six assistants in Virginia — are state-specific and do not travel.

None of this evaluates any clinician or program, and none of it describes any state other than the three named here.