Last Updated: Apr 2, 2020
Due to the current COVID-19 emergency, Governor Wolf and the Pennsylvania Department of State (DOS) have announced certain statutory and regulatory suspensions related to physician assistant, certified registered nurse practitioner (CRNP), and certified registered nurse anesthetist (CRNA) licensure and practice. These suspensions are for the duration of the current COVID-19 emergency.
Physician Assistant Suspensions
In order to allow physician assistants practicing under the State Board of Osteopathic Medicine to more easily and effectively assist with emergency response efforts to COVID-19, Governor Wolf granted the Department of State’s request to suspend requirements pertaining to written agreements and several other items.
These suspensions specifically include, but are not limited to, the following:
- The Osteopathic Medical Practice Act provides that physicians may not supervise more than four physician assistants, physicians can apply for a waiver from the Board to supervise more, both the supervisory ratio and waiver are suspended.
- The requirement that written agreements are approved by the Board, agreements will be effective upon submission to the Board.
- The requirement that the Board must approve use of a physician assistant at “satellite operations” is suspended.
- Board regulations that require countersignature from a physician within 10 days and at least weekly review by a physician of medical records prepared by a physician assistant are suspended.
- Countersignature requirements outlined in the Osteopathic Medical Practice Act will be suspended, provided that the number of patient records reviewed is sufficient to assure adequate review of the physician assistant’s scope of practice.
DOS determined that no such list of suspensions pertaining to written agreements are required for physician assistants practicing under the State Board of Medicine. This allowance is due to an emergency medical services clause, see 49 Pa. Code §18.162, in the Medical Board’s regulations that permits licensed physician assistants to respond to a need for medical care created by a declared state of emergency by rendering care consistent with relevant standards of care. This clause applies to physician assistants licensed in Pennsylvania and physician assistants licensed or authorized to practice in any other state. The State Board of Osteopathic Medicine does not have a similar emergency services clause.
To review the full announcement by DOS and full list of suspensions pertaining to physician assistants, please click here.
Nursing Board Suspensions
Several suspensions pertaining to licensees practicing under the State Board of Nursing, including CRNPs and CRNAs, have also been announced.
Licensing suspensions and waivers related to CRNP practice and licensing include, but are not limited, to the following:
- Licenses currently "in renewal" and set to expire on April 30, 2020. These licenses will be extended for an additional three months until July 31, 2020.
- On a CRNP's initial application for prescription-writing authority, the State Board of Nursing will require only one collaborative physician and one substitute physician, rather than the entire list of substitutes.
- CRNPs can practice without the usual requirement that they practice within a specific clinical specialty and are allowed to prescribe drugs outside the established formulary.
- Out-of-state applicants for certification as a CRNP by endorsement in Pennsylvania, who are active licensees of other states and have national certification, will not have to meet the educational equivalence requirement.
- Board approval of certain changes to an existing Prescriptive Authority Collaborative Agreement (PACA) not required to enact changes. However, CRNPs must submit the changes to the PACA to the Nursing Board within 60 days of the change.
- For an additional PACA, if a CRNP has one active Pennsylvania prescriptive authority with a physician, the CRNP, upon submittal of the prescriptive authority authorization to the Nursing Board, will be permitted to practice with a new collaborating physician for up to 6 months provided the CRNP and the new collaborating physician hold current unrestricted licenses. Board approval may still be required depending on the physician’s licensure status.
- CRNPs must still have a collaborative agreement with all physicians with whom they collaborate throughout an emergency declaration. However, CRNPs who have a collaborative agreement with a physician in a hospital or health system are now permitted to collaborate with other physician(s) within the same hospital or health system, without written and signed collaborative agreements. Unless there is a PACA, CRNPs may not prescribe and dispense under the additional collaboration.
- Requirements are waived that CRNPs may only collaborate with physicians who hold current Pennsylvania licensure. This waiver will enable CRNPs to collaborate with physicians from other states. Unless there is a PACA, CRNPs again may not prescribe and dispense under the additional collaboration.
Suspensions related to CRNA practice have also been announced. Currently, CRNAs must administer anesthesia in cooperation with a surgeon or dentist. The requirement to administer anesthesia in cooperation with a surgeon is temporarily waived and replaced with any physician.
Also, since there are no CRNA certification examinations available during the emergency, the requirement that CRNA graduates need to ask the Board for authority to continue to practice prior to taking the first available examination has been waived. CRNA graduates who avail themselves of this waiver must practice under the direction of, and in the presence of, a chief or director of anesthesia services or a board-certified anesthesiologist.
A full list of suspensions and waivers enacted by DOS and the Nursing Board in response to the COVID-19 emergency can be accessed here.
Where Can I Find Additional Information?
Due to the COVID-19 emergency, additional statutory and regulatory suspensions are expected to be forth coming, the Pennsylvania Medical Society (PAMED) will continue to provide updates as these suspensions are announced. When announced, licensing suspensions will be posted by DOS here.
PAMED has established a COVID-19 resource page where you will find additional information and resources on the COVID-19 outbreak.