Frequently Asked Questions

LICENSURE

Q. What are the requirements to obtain a PA license in the state of Texas?
A. To practice medicine in Texas, a PA must obtain a Texas PA license from the Texas Medical Board(TMB). Eligibility requirements include graduation from an accredited PA program, passing the PA National Certifying Exam(PANCE), and passing the Texas Jurisprudence exam. After passing the qualifying exams, fingerprinting must be completed at a registered center. Texas PAs must renew their license every 2 years through the TMB. While the state does not require NCCPA certification to renew a license in Texas, many hospital systems require NCCPA certification to remain credentialed at the practice site.
Source: Tx Occupations Code Section 204.151, Section 204.152, Section 204.153

Q. What are the requirements to obtain a temporary license in the state of Texas?
A. If a PA meets all qualifications for licensure and graduated from a program six months prior to applying, one is eligible to submit for a temporary license. A temporary license is valid for not more than one year after the date issued.
Source: Tx Occupations Code Section 204.155

Q. How many CME hours is a PA required to complete? Who registers the CME?
A. The National Commission on Certification for PAs (NCCPA) requires PAs log 100 CME hours, at least 50 category I, every two years and pay a certification maintenance fee. However, the state of Texas only requires 40 CME hours every 2 years with at least half of those hours being at the Category I and the rest Category II. Although PAs do not have to log these hours with the Texas Medical Board, they must verify completion on the state renewal application and be able to produce documentation if audited. The Texas PA board adopts, monitors, and enforces a reporting program for CME for license holders.
Source: Tx Occupations Code Section 204.1562
Source: TMB Board Rule 185.6
Source: NCCPA - "About CME Requirements"

SCOPE OF PRACTICE

Q. What is a PA’s scope of practice in Texas?
A. If the service is within the education, training, and experience, A PA can provide an array of medical services delegated by the supervising physician in any place authorized by the supervising physician. These acts may include, but are not limited to, obtaining histories and physical exams, ordering and performing diagnostic and therapeutic procedures, formulating a working diagnosis, developing and implementing a treatment plan. Additionally, many PAs assist in surgery, counsel and educate patients to meet their needs, and prescribe or order a drug or device as provided by the medical practice act. Depending on the work setting or specialty, a PA will have a more specific scope of practice defined in the practice agreement between a PA and a supervising physician.
Source: Tx Occupations Code 204.202 “Scope of Practice” and 204.205 “Requirements for Supervising Physician”

PRESCRIPTIVE AUTHORITY

Q. Can a PA prescribe medication?
A. A physician may delegate to a PA the act of prescribing or ordering a drug (or device) as authorized through a prescriptive authority agreement. The PA must hold an active license in good standing, is not prohibited by the board, and prior disciplinary action by the Texas medical board is disclosed.
A physician may delegate prescribing or ordering a drug or device that is nonprescription drugs, dangerous drugs, and controlled substances listed in schedules III, IV, or V. While the term is not used frequently in PA education, dangerous drug refers to any drug that is unscheduled and requires a prescription for use. Texas State law defines a dangerous drug as a device or drug that is unsafe for self-medication, and not included in Schedules I - V or Penalty Groups 1 through 4 of Chapter 481 in the Texas Controlled Substances Act.

Q. What should be included in a prescriptive authority agreement?
A. There is a list of minimum requirements that must be included into a prescriptive authority agreement executed on or after September 1st, 2019. To read the minimum requirements, the rule can be found here.
Source: Tx Occupations Code, Title 3. Health Professions, Subtitle B, Chapter 157, Sec. 157.0511 Delegation of Prescribing and Ordering Drugs
Source: Tx Health and Safety Code, Title 6, Food, Drugs, Alcohol and Hazardous Substances, Subtitle C, Chapter 483, Dangerous Drugs, Subchapter A

CONTROLLED SUBSTANCES

Q. Can a PA prescribe schedule II drugs?
A. PAs may prescribe schedule II drugs in the following situations:
A hospital facility-based practice approved by the hospital medical committee staff. The patient receiving schedule II medication has been admitted to the hospital for an intended length of stay of 24 hours or greater, or is receiving services in the emergency department of the hospital. Schedule II medication may also be part of the treatment plan for a patient with terminal illness, elected to receive hospice care, and is receiving hospice treatment from a qualified provider. Source: Tx Occupations Code, Title 3. Health Professions, Subtitle B, Chapter 157, Sec. 157.0511 Delegation of Prescribing and Ordering Drugs
Source: Texas Occupations Code 157.051

Q. How many charts must be reviewed by a supervising physician?
A. The law does not provide a specific number. The details are determined by the practice authority agreement at the practice site.
Source: Texas Occupations Code 157.051

Q. What is the difference between a medication order and a prescription?
A. A medication order is an order for administration of a drug or device to a patient in a hospital for administration while the patient is in the hospital or for emergency use on the patient’s release from the hospital, as defined by §551.003, Occupations Code and §481.002, Health and Safety Code. A prescription is an order to dispense a drug or device to a patient for self-administration as defined by §551.003, Occupations Code.
Source: Texas Occupations Code 551.003
Source: Health and Safety Code 481.002

SUPERVISION REQUIREMENTS

Q. How many PAs can a physician supervise?
A. Texas is unique as the law differentiates delegating general scope of practice and prescriptive authority. There is no limit to the number of PAs that a physician may delegate the ability to practice. However, there is a limit to the number of PAs a physician can delegate prescriptive authority. This number depends upon the practice setting of a PA; broadly speaking, whether the practice is considered outpatient or facility-based practice. A physician can delegate to a maximum of 7 full time PAs for an outpatient practice A physician may delegate to an unlimited number of PAs for a facility-based practice or in an area with medically underserved populations.
Source: Texas Occupations Code 157.051

Q. How often do I have to meet with my supervising physician?
A. If prescriptive authority has been delegated to a PA, then the physician and PA must meet once a month in a manner determined between the physician and the PA. These meetings should entail a sharing of information relating to patient treatment and care, changes in patient care plans, chart review and issues relating to referrals. If a PA works in a group practice, the PA may appoint one or more alternate supervising physicians to conduct the meetings. These meetings must be documented, but do not have requirements on percentage of chart review or meeting quality assurance metrics; these are left to be determined at the practice site between the physician and the PA.
Source: Tx Occupations Code, Title 3. Health Professions, Subtitle B, Chapter 157, Prescriptive Authority Agreement
Source: Texas Occupations Code Sec. 157.0512

Q. What are the requirements for a supervising physician?
A. The supervising physician delegating medical practice must be licensed as a physician by the state medical board, and the license must be unrestricted and active. The physician must notify the board of the intent to supervise, and retain professional and legal responsibility for the care rendered by the PA. Logging a supervising physician on the TMB website is required before a PA begins practice. A DEA license is required to prescribe scheduled medication which also requires registering a supervising physician on your TMB profile.
Source: Texas Occupations Code Sec. 204.201

Q. How many miles from my delegating physician can my practice site be?
A. SB 406, passed in 2013, eliminated site based prescriptive authority. Currently, there is no defined maximum distance a PA or NP must be when working with a supervising physician; however, there is no change in the law requiring adequate supervision of delegates.
Source: SB 406, 83rd Legislature
Source: Texas Occupations Code 157.051

Q. Does a physician have to co-sign my charts?
A. There is no law mandating physician co-signature of a PA’s charts. However, the manner in which a PA’s charts are reviewed is “determined by the physician and advanced practice registered nurse or PA”, and must be part of the prescriptive authority agreement.
Source: Tx Occupations Code, Title 3. Health Professions, Subtitle B, Chapter 157, Section 157.0512(e)(9)(A), Prescriptive Authority Agreement

REIMBURSEMENT

Q. Can a PA independently bill for medical services rendered?
A. Yes and no, a PA may not independently bill patients for services provided by the PA except where provided by law.
Medicare (national program) allows PA to submit claims under their own NPI number, however a PA cannot directly bill and receive payment directly. This payment is made out to the PAs employer. Typically, reimbursement for services is 85% of the physician fee schedule. 100% reimbursement may be obtained only when billing ‘incident-to’ which has many requirements. In this circumstance, services are billed under the physician’s NPI number. Shared Visits where PAs and Physicians share responsibility are billed at 100% under the physicians NPI number. exas Medicaid (state program) reimburses PAs for 92% of the rate paid to a physician for the same professional service. 100% percent of the rate paid to physicians for laboratory services, X-ray services, and injections performed by PAs.
Q. What is the medicare reimbursement for a PA acting as first assist in surgery?
A. Medicare reimbursement for assisting in surgery is made under the PAs NPI and is 13.6% of the surgeons fee. There are certain procedures that are restricted from first assistant fees that apply to all health care providers.

Q. Is there one place where PAs can learn more regarding the rules and practices of reimbursement?
A. No, but TAPA has created a consolidated list of hyperlinks and contacts where an individual can read more regarding common billing and reimbursement inquiries.
Source: TAC §355.8093
Source: TAC Title 22, Part 9, Chapter 185, Rule 185.16 (Employment Guidelines)
Source: AAPA summary of third party reimbursement

REGULATION

Q. Who regulates the PA profession in Texas?
A. The Texas PA Board licenses and regulates all PAs practicing in Texas, with the exception of those working directly for the federal government The Texas PA Board serves as an advisory board to the Texas Medical Board The Texas PA Board writes rules to regulate the PA profession, as directed by laws passed by the Texas Legislature. All rules passed by the Texas PA Board must then also be approved by the Texas Medical Board.

Q. Who is a part of the Texas PA Board?
A. A total of 13 members comprise the Texas PA Board 7 licensed PAs, including a presiding officer who must be a PA; all must have at least 5 years of clinical experience 3 licensed physicians who also supervise PAs 3 members of the public who are not affiliated with the PA profession All members are appointed by the Governor of Texas, and serve a term of 6 years.
Source: Texas Occupations Code 204

VOLUNTEERISM AND DISASTER SERVICES

Q. Can a PA participate in medical volunteer work without the need for physician supervision?
A. Yes, PAs may volunteer their services at any public or private event without the specific need for physician supervision or delegation.

Q. Does a PA require supervision if providing medical volunteer work during a disaster declared by the state?
A. No, PAs may also provide medical services on a volunteer basis during a disaster declared by the state without the need of supervision or delegation requirements.

Q. How does volunteer care affect a PA’s liability for services rendered?
A. In delivering medical services within their scope of practice, PAs are entitled to immunity from liability provided by the Civil Practice and Remedies Code.
Source: Texas Occupations Code 204.2045 (Volunteer Care and Services Performed During Disaster
Source: HB 1978, 85th legislature

TELEMEDICINE

Q. Can PA provide telemedicine services in the state of Texas?
A. Yes, if a PA is acting under the delegation and supervision of a physician licensed in Texas.

Q. How is telemedicine defined in the state of Texas?
A. Telemedicine involves healthcare delivered with telecommunications or information technology to patients physically located at sites away from where the provider is located. For more information regarding the types of telemedicine services please refer to TMB Rule, Chapter 174 - telemedicine.
Source: Texas Occupations Code 111.001

PRACTIVE OWNERSHIP AND MANAGEMENT

Q. Can a PA own a medical practice in Texas?
A. PAs are permitted by law to open and own a medical practice along with a physician, organized as a corporation, partnership, professional association or professional LLC. However, many restrictions apply:
PAs cannot be officers in the practice or serve on the corporate board. PAs cannot employ or contract a supervising physician. PAs may only have minority ownership and percentage ownership of an individual PA cannot exceed any individual physician owner. PAs cannot be a partner and cannot participate in the management of partners. PAs must report annually to the board of ownership interest (fee for report is $18.00 per year). PAs may not interfere with or direct the practice of physicians or supervision of other PAs. Source: Texas Business Organizations Codes 22.0561, 152.0551, 301.012 and Texas Occupations Codes 162.053 and 204.209.

DNR

Q. Can an inpatient PA place inpatient DNR orders?
A. The answer will likely be determined by the practice site or inpatient facility. Senate bill 11, introduced in the 85th legislature, provided a framework for in-facility DNR orders. While the PA may act as a representative of the hospital, the DNR order is only valid if the patient’s attending physician issues the order.
Source: Texas Health and Safety Code sec. 166.203
Source: Senate Bill 11, 85th legislature

Q. Can an outpatient PA complete an out-of-hospital DNR?
A. An out-of-hospital DNR contains a physician statement that may only be signed by the patient’s attending physician.
Source: Texas Health and Safety Code Sec 166.081

DEATH PRONOUNCEMENT AND SIGNING DEATH CERTIFICATE

Q. Can a PA pronounce death?
A. PAs in the state of Texas are able to pronounce death.

Q. Can a PA sign a death certificate?
A. In most circumstances, no. A PA may sign a death certificate for their patients only if the patient is under hospice or palliative care.
Source: Tx Health and Safety Code sections 193.005 and 671.001
Source: TX SB 919, 85th Legislature

ADVOCACY

Q. What is a political action committee (PAC), and what is its role with TAPA
A. Political Action Committees, or “PACs”, are tax-exempt organizations that pool campaign contributions from their members for the purpose of donation to political campaigns. Any individual may donate to a PAC.
The TAPA Political Action Committee’s mission is to allow for individual PAs and those supportive of the PA profession to financially support lawmakers and candidates for the Texas Legislature who also are supportive of the PA profession.
The TAPA PAC is a bipartisan organization that is a separate but affiliated entity of TAPA. Activities of the TAPA PAC are carried out by the Board of Trustees and TAPA PAC members with general policy and operational supervision by the TAPA Board of Directors. Members of the TAPA PAC consist of those who have donated to the PAC. All state PACs, including the TAPA PAC, are governed by the Texas Ethics Commission, and laws pertaining to PACs are found in the Texas Elections Code. PAC funds may only be used for campaign contributions; they may not be used for any other purpose with the associated organization.
Q. How does TAPA arrive at legislative topics to address?
A.By soliciting feedback from TAPA members and PAs across the state, TAPA creates an agenda for each legislative session. The agenda contains proposed bills that would further the practice of all PAs across the state and align with the AAPA's key elements for modern PA practice. The previous 2019 agenda is available online. Read TAPA’s position regarding OTP here. For more information regarding how you can advocate for the profession, see our legislative toolkit, where you can see links to find your representative and learn more about the Texas legislative process.

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Frequently Asked Questions