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Colorado Enacts Sweeping Changes to Physician Assistant Supervision Requirements

By Caroline Gecker

Caroline Gecker headshotIn April, Colorado Gov. Jared Polis signed SB23-083 into law. The bill amends the Medical Practice Act (“the Act”) to give physician assistants (“PAs”) the ability to practice, in most settings, without a physician supervisory agreement after meeting certain requirements. With its enactment, Colorado joins 17 other states that require collaborative agreements between PAs and physicians or physician groups instead of supervisory agreements.  

The law makes several significant changes to the Act. Most notably, PAs in most practice areas are no longer required to be “supervised” by physicians after completing a specified number of practice hours. Instead, they are required to have an ongoing collaborative agreement with a physician or physician group.   

Among other information, the collaborative agreement must include a description of the physician assistant’s process for collaboration, a description of the performance evaluation process, and “[a]ny additional requirements specific to the physician assistant’s practice required by the physician entering into the collaborative agreement, including additional levels of oversight, limitations on autonomous judgment, and the designation of a primary contact for collaboration.”   

PAs with fewer than five thousand practice hours, or PAs with fewer than three thousand practice hours in a new practice area, however, must still practice under a supervisory agreement until their practice hours requirement is met. In addition, PAs practicing in the emergency department of a hospital with a Level I or Level II trauma center will always require a supervisory agreement.  

The law further provides that with a collaborative agreement in place, a licensed PA “may perform acts within the physician assistant’s education, experience, and competency” (emphasis added). This is a departure from the current supervision requirements, which tie a PA’s scope of care to their physician supervisor’s scope of care.   

Under existing law, when a supervising physician is replaced by another physician with a different scope of care, unless different supervision arrangements are made, the PA is prohibited from providing the former skillset. The new law allows PAs to practice skills they have learned over the course of their career.   

Supporters of the new law contend that it will increase access to care for patients, particularly those in rural and medically underserved communities. In addition, proponents believe the increased autonomy will incentivize Colorado-trained PAs to remain in the state and make Colorado a more desirable place for PAs to practice.   

The Colorado Medical Board is in the process of promulgating the bill’s implementing regulations. A rulemaking hearing is scheduled for August 17, 2023. Our Health Law attorneys are closely following the rulemaking process and the impacts the bill will have on PAs, physicians, and healthcare entities. 



Please do not hesitate to contact one of our Health Law attorneys at Caplan & Earnest for more information about the changes to the Medical Practice Act or its impact on your organization. 

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