Physician Assistant (PA)

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To furnish covered PA services, the PA must meet the conditions as follows:

  1. Have graduated from a physician assistant educational program that is accredited by the Accreditation Review Commission on Education for the Physician Assistant (its predecessor agencies, the Commission on Accreditation of Allied Health Education Programs (CAAHEP) and the Committee on Allied Health Education and Accreditation (CAHEA); or
  2. Have passed the national certification examination that is administered by the National Commission on Certification of Physician Assistants (NCCPA); and
  3. Be licensed by the State to practice as a physician assistant.

Covered Services

Coverage is limited to the services an NP is legally authorized to perform in accordance with State law (or State regulatory mechanism established by State law).

The services of a PA may be covered under Part B, if all of the following requirements are met:

  • They are the type that are considered physician's services if furnished by a doctor of medicine or osteopathy (MD/DO);
  • They are performed by a person who meets all the PA qualifications,
  • They are performed under the general supervision of an MD/DO;
  • The PA is legally authorized to perform the services in the state in which they are performed; and
  • They are not otherwise precluded from coverage because of one of the statutory exclusions.

Types of PA Services That May Be Covered

State law or regulation governing a PA's scope of practice in the State in which the services are performed applies. Carriers should consider developing lists of covered services. Also, if authorized under the scope of their State license, PAs may furnish services billed under all levels of CPT evaluation and management codes, and diagnostic tests if furnished under the general supervision of a physician.

Examples of the types of services that PAs may provide include services that traditionally have been reserved to physicians, such as physical examinations, minor surgery, setting casts for simple fractures, interpreting x-rays, and other activities that involve an independent evaluation or treatment of the patient's condition.

Services Otherwise Excluded From Coverage

The PA services may not be covered if they are otherwise excluded from coverage even though a PA may be authorized by State law to perform them. For example, the Medicare law excludes from coverage routine foot care, routine physical checkups, and services that are not reasonable and necessary for the diagnosis or treatment of an illness or injury or to improve the functioning of a malformed body member. Therefore, these services are precluded from coverage even though they may be within a PA's scope of practice under State law.

Physician Supervision

The PA's physician supervisor (or a physician designated by the supervising physician or employer as provided under State law or regulations) is primarily responsible for the overall direction and management of the PA's professional activities and for assuring that the services provided are medically appropriate for the patient. The physician supervisor (or physician designee) need not be physically present with the PA when a service is being furnished to a patient and may be contacted by telephone, if necessary, unless State law or regulations require otherwise.

Employment Relationship

  • The PA's employer can either be an individual or an organization. The PA can still be a stockholder of the organization if the state allows this, however the entity needs to be eligible to enroll as a provider or supplier in the Medicare program
    • This is also known as an establishing employment with an organization
  • PAs can own 100% of an organization
    • PAs can receive payments directly as either an individual or PA's organizing together to form their own organization, meaning they are unable to be a sole proprietor or a general partnership with another PA(s)

If the employer of the PA is a professional corporation or other duly qualified legal entity (such as a limited liability company or a limited liability partnership), properly formed, authorized and licensed under State laws and regulations, that permits PA ownership in such corporation nor entity as a stockholder or member, that corporation or entity as the employer may bill for PA services even if a PA is a stockholder or officer of the entity, as long as the entity is entitled to enroll as a "provider of services" or a supplier of services in the Medicare program.



Last Updated Dec 21 , 2022