Wiki ARNP/PA cosignature requirements

[jgoehring]

As I am reviewing our rules and regs for our hospital, I am trying to make sure i can find supporting evidence for why we do things the way we do. Does anyone have any links where CMS states we do or do not need a cosignature on a mid-level provider in the ED/Hospitalist program?

 

[csperoni]

I don't think CMS has guidelines on this. I believe state law determines the scope of practice and signature requirements by supervising physician of mid-level providers. Many hospitals do have an internal policy regarding signatures, but I don't believe this is legally required by CMS unless your state law does.
From https://www.cms.gov/files/document/r10639bp.pdf (my emphasis added)
"CMS finalized for Calendar Year (CY) 2020 the "Physician Supervision for Physician Assistant (PA) Services" proposal implementing our reinterpretation of Medicare law that requires physician supervision for the professional services of PAs. Accordingly, Federal Regulations at 42 CFR 410.74 (a)(2) require that a PA must furnish their professional services in accordance with State law and State scope of practice rules for PAs in the State in which the services are furnished to the extent that those rules describe the required relationship between physicians and PAs, including its collaborative nature, describe a form of supervision for Medicare’s purposes. For States with no explicit State law and guidance regarding physician supervisions of PAs, physician supervision is a process with one or more physicians to supervise the delivery of their healthcare services. Such physician supervision is evidenced by documenting the PA’s scope of practice and indicating the working relationships the PA has with the supervising physicians when furnishing professional services, with any required documentation of PA supervision maintained at the practice level, instead of in the medical record for each patient."