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Five States’ Laws: Physician Assistant Scope of Practice and Collaboration

Many states where MICA provides coverage have passed laws eliminating supervision mandates and expanding physician assistant autonomy.

Jeanne Varner Powell, JD | MICA

Jeanne Varner Powell, JD

02/11/2025

Regulatory restrictions on physician assistant scope of practice are loosening nationwide. Many states where MICA provides coverage have passed laws eliminating supervision mandates and expanding physician assistant autonomy. To assist you in complying with state licensing requirements, in this article we summarize laws governing physician assistant scope of practice and collaboration/supervision in Arizona, Utah, Montana, Colorado, and Nevada.

Arizona

In 2023, Arizona enacted new legislation governing physician assistant (PA) practice. The 2023 laws removed the supervision requirement for PAs with more than 8,000 hours of clinical practice who are certified by the licensing board to practice collaboratively. In place of a supervision agreement, these PAs must have a collaborating physician.

Scope of Practice Law in Arizona

An Arizona-licensed PA may provide any legally permissible medical service that he/she is competent to perform, based on education, training, and experience. This includes:

    • Obtaining health histories and performing physical exams;

    • Evaluating and diagnosing patients;

    • Managing and providing medical treatment and therapeutic interventions;

    • Ordering, performing, and interpreting diagnostic studies and therapeutic procedures;

    • Counseling and educating patients about healthy habits and disease prevention;

    • Providing consultations on request;

    • Writing orders;

    • Obtaining informed consent;

    • Assisting in surgeries;

    • Making appropriate referrals;

    • Delegating to and supervising licensed and unlicensed personnel as permitted by the PA’s licensing board;

    • Ordering, prescribing, dispensing, and administering drugs and medical devices in accordance with state and federal laws including R.S. 32-2532 (restrictions on PA prescribing and dispensing practices);

    • Prescribing controlled substances according to state and federal law;

    • Performing minor surgery;1

    • Performing nonsurgical health care tasks consistent with the PA’s education, training, and experience;

    • Certifying health or disability as required by any local, state, or federal program; and

    • Ordering home health services.2

Arizona PAs with 8,000+ Hours – Collaborative Agreement Requirements

PAs with greater than 8,000 clinical practice hours can apply to the Arizona licensing board for certification to practice collaboratively.3 To qualify, PAs must provide evidence  that they completed at least 8,000 hours in the 5 years preceding application, or at least 2,000 hours in the last 10 years and are currently certified by the National Commission on Certification of Physician Assistants.4 Once certified to practice collaboratively, the following legal requirements apply:

    • A PA must continue to collaborate or consult with, or refer to, the appropriate health care professional as indicated by the patient's condition and by the PA's education, experience, and competencies.

    • The required level of collaboration will be determined between the collaborating physician or the group or facility that employs the PA;
    • Collaboration, consultation, or referral may occur through electronic means;
    • A collaborating physician does not need to be physically present at the time or place the PA provides care;
    • PAs practicing according to collaborative agreements are legally responsible for the care they provide; and
    • A PA may have more than one collaborating physician.5

Arizona Physicians Obligations When Collaborating with PAs

Regulations issued in 2024 require physicians or entities collaborating with PAs to:

    • Verify at the start of the relationship that the PA is certified by the licensing board as eligible to collaborate;

    • Maintain evidence that the physician or entity completed this verification; and

    • If a group or entity, designate one or more physician by name or position as responsible for oversight of the PA and provide names of such individuals to the board on request.6

Collaborating physicians or entities also are obligated to ensure a PA’s competence to practice in any new area, not “substantially similar” to the area in which the PA is certified to practice collaboratively. In these situations, if the physician or entity determines the PA needs additional training or oversight to achieve competency in the new area, the physician or entity must provide both. Collaborating physicians or entities should also determine whether a supervisory agreement is necessary until the PA gains the necessary experience in a new area. These decisions must be documented and made in collaboration with the PA.7

Arizona PAs with Less than 8,000 Hours – Supervision Agreement Requirements

Arizona-licensed PAs who have not been certified by their licensing board as having more than 8,000 clinical hours must practice according to a Supervision Agreement.

    • A Supervision Agreement is a written, signed agreement between a PA and the PA’s Arizona-licensed supervising physician.

    • Alternatively, the agreement may be between the PA and the PA’s employer which may be a physician group, physician private practice, or a licensed health care institution that employs or has on staff at least one Arizona-licensed physician who will provide oversight.

    • "Supervision” means a physician's “opportunity or ability to provide or exercise direction and control” over the care and treatment a PA provides.

    • The supervising physician and the PA are legally responsible for the PA’s care.8

A PA is prohibited from providing care and treatment until a Supervision Agreement is finalized and signed. The Supervision Agreement:

    • Describes the PA’s scope of practice;

    • Specifies the PA’s ability to prescribe, dispense, or administer controlled substances under the PA’s DEA registration number;

    • Specifies the PA’s ability to prescribe, dispense, or administer prescription-only medication under the PA’s DEA registration number;

    • Must be kept on file at the main location of the PA’s practice and provided to the licensing board upon request; and

    • May permit electronic supervision. “Supervision does not require a physician's constant physical presence if the supervising physician is or can be easily in contact with the physician assistant by telecommunication.”9

Supervising physicians must comply with various requirements including:

    • May not supervise more than six PAs working at the same time;

    • Conduct performance evaluations; and

    • Record and review all instances when the PA prescribes schedule II or III controlled substances.10

Physicians seeking more information about their obligations when supervising PAs should read MICA’s Physician Assistant Supervision Requirements in Arizona.

Utah 

In 2021, Utah also moved to a collaborative practice regulatory scheme for PAs, removing previous requirements for direct physician supervision and delegation of services agreements. Under the new law, Utah imposes “collaboration” requirements on PAs with less than 10,000 clinical practice hours. “Collaboration” means the interaction and relationship a PA has with one or more physicians in which:

    • the PA and physician are cognizant of the PA’s qualifications and limitations in providing patient care,

    • the PA, while consulting with the physician regarding care, also remains responsible for the care provided, and

    • the physician(s) give direction and guidance to the PA.11

Utah PAs in a Non-Mental Health Specialty with Less Than 10,000 Clinical Hours – Collaboration Requirements

PAs practicing in a non-mental health setting with less than 4,000 clinical hours must collaborate with a physician according to written policies and procedures established at the practice level that describe:

    • how collaboration will occur and

    • the methods that will be used to evaluate the PA’s competency, knowledge, and skills.12

After the 4,000-hour mark, PAs in a non-mental health setting must enter into a written collaborative agreement that describes how collaboration will occur. The collaborative provider may be either:

    • a PA with more than 10,000 hours of practice experience in the same specialty as the PA or

    • a physician.13

The required written policies and procedures and collaboration agreement must remain on file at the PA’s practice location and be available to the licensing board upon request.14 After 10,000 hours of practice experience, collaborative agreements are no longer required unless the PA changes practice specialties. In that case, a PA with less than 4,000 hours in the new specialty must engage in collaboration for a minimum of 4,000 hours with a physician who is trained and experienced in that specialty.15

Utah PAs Specializing in Mental Health - Education and Training Requirements

Utah has separate requirements for PAs specializing in mental health care. Besides being licensed in Utah, a PA that provides mental health treatment must:

    • Maintain a current Certification of Added Qualification in psychiatry issued by the National Commission on Certification of Physician Assistants;

    • Complete an accredited doctorate level academic program for PAs approved by DOPL and the licensing board;

    • Complete a post-graduate certificate program for PAs to practice in psychiatric and mental health care approved by DOPL and the licensing board;

    • Complete a post-graduate residency in psychiatry and additional clinical practice or coursework approved by DOPL and the licensing board; and

    • Complete 10,000 hours of clinical practice requirements as described in the following section.16

Utah PAs Specializing in Mental Health with Less than 10,000 Clinical Hours - Supervision and Collaboration Requirements

PAs specializing in mental health care with less than 10,000 hours of practice experience must comply with the following clinical practice requirements:

    • Complete 10,000 clinical practice hours after passing the Physician Assistant National Certifying Exam administered by the National Commission on Certification of Physician Assistants.

    • The first 4,000 hours must be supervised by a psychiatrist.

    • Complete at least 2,000 hours in psychotherapy supervised by a mental health therapist or a psychiatrist trained in, and with at least 2 years of experience in, psychotherapy.

    • Complete additional hours to reach 10,000 in “collaboration” with a psychiatrist.

    • Up to 1,000 of these 10,000 hours may be completed as part of an approved education program in mental health.17

Utah PA Scope of Practice Regardless of Specialty

Regardless of specialty, PAs licensed in Utah may provide any medical services:

    • Not specifically prohibited by Utah law;

    • That are within the PA’s skills, scope of competence, and practice specialty; and

    • For which the PA has been trained and is credentialed or authorized to perform.18

All Utah-licensed PAs are legally responsible for the care they provide.19 When providing care, they must identify themselves as PAs, both verbally and via identification badges.20 They must consult, collaborate with, and refer to appropriate members of the health care team:

    • As appropriate for a patient’s condition;

    • Based on the PA’s education, experience, and competencies;

    • According to the applicable standard of care; and

    • When required by law.21

Utah law prohibits PAs from performing or inducing abortions22 and restricts their ability to administer anesthesia or perform rapid sequence intubation.23

Utah Scope of Practice - PAs Specializing in Mental Health With Less Than 10,000 Clinical Practice Hours

PAs working towards completion of 10,000 hours of clinical training may provide mental health therapy if they comply with the licensing board’s supervision rules and are supervised by:

    • a mental health therapist with training and more than two years practice experience in psychotherapy or

    • a board-certified psychiatrist.24

Utah Scope of Practice for PAs Specializing in Mental Health Who Satisfy the 10,000 Hours Requirement

PAs with more than 10,000 hours clinical experience in mental health care may:

  • Provide mental health therapy consistent with the PA’s education, experience, and competence and

  • Administer behavioral health screening instruments.25

They may not:

    • Perform psychological or neurological assessments or evaluations, including intellectual or forensic assessments or evaluations, or administration of psychological or neuropsychological tests or instruments requiring qualification level B or C under the Standards for Educational and Psychological Testing approved by the American Psychological Association; or
    • Administer neurostimulation or neuromodulation unless in a health care facility or under the supervision of a physician whose usual scope of practice includes these modalities.26

Montana

Like Arizona and Utah, Montana adopted a collaborative practice model in 2023, modifying its laws to permit increased autonomy for PAs.

Scope of Practice Law in Montana

In Montana, PAs may provide care and treatment for which they have been educationally prepared and have achieved and maintained competency.27 Montana law allows PAs to:

    • Diagnose, examine, and treat ailments, diseases, injuries, or infirmities, using any “means, method, device, or instrumentality;”

    • Obtain informed consent;

    • Supervise, delegate, and assign therapeutic and diagnostic measures;

    • Certify a patient’s health or disability for purposes of any state, local, or federal program; and

    • Authenticate any document, just as a physician would.28

PAs may also prescribe, dispense, and administer drugs in compliance with state and federal laws. This includes certain Schedule III, IV, and V controlled substances. Montana law says PAs may be authorized to prescribe, dispense, or administer certain Schedule II drugs as well, but only for periods of less than 34 days.29

PAs licensed in Montana are professionally and legally responsible for the care and treatment they provide.30

Montana Collaboration Requirements

PAs with fewer than 8,000 hours of “postgraduate clinical experience” must practice according to a written collaborative agreement between the PA and one or more collaborating providers.31 “Postgraduate clinical experience” means the delivery of health care directly to patients, after licensure as a PA and pursuant to a collaborative agreement.32

Collaborating providers may be:

    • Licensed physicians or

    • Licensed PAs with 8,000 or more hours of postgraduate clinical experience.33

Montana law defines “collaborative agreement” as “the interaction and relationship that a PA has with a collaborating provider.” Required elements of a collaborative agreement include:

    • The PA and collaborating provider are cognizant of the PA’s qualifications and limitations in providing patient care;

    • The PA consults with the collaborating provider but the PA remains responsible for his/her own care; and

    • The collaborating provider gives direction and guidance to the PA.34

In addition, collaborating providers must review a PA’s medical record documentation “with frequency and amount to be determined at the practice level and as described in the collaboration agreement.”35

Montana law requires collaborative providers and PAs to develop written policies and procedures governing the collaborative relationship. At a minimum, these policies and procedures must specify:

    • how collaboration will occur between the PA and the collaborating provider, and

    • methods the collaborating provider will use to evaluate the PA’s competency, knowledge, and skills.36

PAs and collaborating providers must submit a copy of the policies and procedures and/or the collaborative agreement to the licensing board upon request.37

Colorado

Colorado also moved to a collaborative practice model in 2023, repealing existing laws that had required physician supervision for all PAs.

Colorado Scope of Practice

Colorado PAs must work according to a written collaborative agreement with a Colorado licensed physician (or physician group).38 PAs remain liable for the care they provide.39

With a collaborative agreement in place, Colorado-licensed PAs are permitted to engage in the “practice of medicine” (defined by statute), which includes, among other things, diagnosing, treating, prescribing, and interpreting diagnostic tests and images.40 Scope of practice conditions and limitations include:

    • PAs may only provide care they are competent to provide, based on education, training and experience.

    • Care and treatment must be in accordance with generally accepted standards of medical practice.

    • When a PA consults with any physician about a patient, the PA must include the physician’s name in the PA’s dated chart note.41

    • When providing care, PAs must verbally and visually (name tags) identify themselves to patients as a PA.

    • PAs are prohibited from owning a majority share in a medical practice.42

Requirements for All Collaborative Relationships and Agreements in Colorado

Colorado law defines a “collaborative agreement” as a document that describes how a PA “collaborates” with a physician or physician group.43  “Collaboration” means:

    • Consultation between the PA and the physician or group; or

    • Referral by the PA to a physician or, if the referral is to a physician practicing in a different practice area than the PA, a physician’s practice group;

    • As indicated by the patient’s condition, community standards of care, and a PA’s education, training, and experience.44

A collaborating physician or group must:

    • Be licensed in good standing and “actively practicing medicine in Colorado,” and

    • Maintain a “regular and reliable physical presence in Colorado.” If a physician’s practice is “based primarily on telecommunication devices or other telehealth technologies [this] does not constitute ‘actively practicing medicine in Colorado.’”45

All collaborative agreements between PAs and physicians must:

    • Include the PA’s name, license number, and primary location of practice;

    • Be signed by the PA and the physician or group;

    • Be available at the main practice location;46

    • Contain a description of collaboration process, “the degree of which must be based on the PA’s primary location and area of practice and may include decisions made by the physician or physician group with whom the PA has entered into a collaborative agreement; and the credentialing or privileging requirements of the PA’s primary location of practice”;

    • Describe the physician’s or group’s performance evaluation process for PAs; and

    • Specify any additional requirements the collaborative physician or group imposes on the PA’s practice including additional levels of oversight, limitations on autonomous judgment, and/or a primary contact designated for collaboration.47

PAs with Less Experience or PAs in Emergency Departments – Additional Colorado Supervision Requirements

Less experienced PAs in Colorado must work under a “supervisory agreement” that contains all the elements outlined in the previous section of this article, plus additional oversight provisions.48 A supervisory agreement is required for:

    • PAs with less than 5,000 practice hours or

    • PAs changing practice areas who have fewer than 3,000 practice hours in the new practice area.49

Supervisory agreements must contain the following additional oversight provisions:

    • During the first 160 practice hours, collaboration must be completed in person or through technology, as determined by the collaborating physician or group.

    • After 6 months and 12 months of practice, the employer or collaborative physician shall complete a performance evaluation and discuss the results with the PA. After the 12-month mark, the employer or collaborative physician has discretion to determine the frequency of additional performance evaluations.50

In addition, the supervisory agreement must define the “expected nature of collaboration,” by specifying:

    • PA’s expected area of practice;

    • How the collaborating physician/group will support and consult with the PA;

    • Methods and modes of communication and collaboration; and

    • Any other pertinent elements of collaborative, team-based practice applicable to the relationship.51

In non-emergency department settings, once the PA exceeds 5,000 practice hours (or 3,000 if changing practice areas), additional oversight provisions are no longer required. At that point, the agreement becomes collaborative, not supervisory.52

For PAs practicing in a hospital emergency department that is a level I or II trauma center, a supervisory agreement (meeting all requirements outlined above) must remain in place indefinitely.53 In addition, if a PA is changing practice areas to provide care in a hospital emergency department that is not level I or II, then the supervising physician/group has discretion to require additional practice hours (above 3,000) before the agreement becomes collaborative.54

More About Performance Evaluation Requirements in Colorado Collaborative and Supervisory Agreements

Colorado law defines “performance evaluation” to mean a document that:

    • addresses and evaluates areas of competency relevant to PA scope of practice;

    • uses more than one type of assessment modality to evaluate competency; and

    • considers the PA’s education, training, experience, competency, and knowledge of the PA’s practice area.55

Collaborative physicians or groups are obligated under the law to develop and conduct performance evaluations of PAs, regardless of a PA’s level of experience. Physicians must also maintain accurate records of all initial and subsequent evaluations and provide these to the Board upon request.56 Colorado regulations state:

The statutory relationship between the physician or physician group and PA is by its nature a team relationship. The purpose of the Performance Evaluation is to enhance the collaborative nature of the team relationship, promote public safety, clarify expectations, and facilitate the professional development of an individual PA.57

Assessment modalities may include but are not limited to:

    • Co-management of patients;

    • Direct observation;

    • Patient and provider feedback (must identify patients/providers); or

    • Chart review (must identify charts reviewed).58

Competencies evaluated may be tailored according to the type of practice. They may include but are not limited to:

    • Medical knowledge;

    • Ability to perform an appropriate history and physical exam;

    • Ability to manage, integrate, and understand objective data, such as lab or radiographic studies and consultations;

    • Clinical judgment, decision-making and assessment of patients;

    • Accurate and appropriate patient management;

    • PA-patient and PA-provider communication skills;

    • Documentation and record-keeping;

    • Collaborative practice and professionalism; and

    • Procedural and technical skills appropriate to the practice.59

Nevada

Unlike other states discussed in this article, physicians in Nevada must supervise PAs and delegate the care they provide. A physician who supervises a PA is responsible for care provided by the PA.60 PAs may apply for licensing under statutes governing MDs, DOs, or both.

Nevada Scope of Practice

Except in emergencies, all care provided by PAs must be authorized by a supervising physician.61 Supervising physicians must be licensed in good standing and practicing medicine in Nevada.62 Care and treatment that a supervising physician authorizes a PA to perform must be:

  • Consistent with the PA’s education, training, experience, and level of competence;

  • Within the supervising physician’s scope of practice; and

  • For prescribing of controlled substances, limited to those schedules the supervising physician is authorized to prescribe under federal and state law.63

When providing care, a PA must wear identification indicating he/she is a PA.64

Responsibilities of Nevada Supervising Physicians

Statutes governing MDs and DOs specify supervising physicians’ obligations. Although there are important differences between the two sets of statutes, in general, both DOs and MDs are required to:

    • Ensure that PAs clearly identify themselves as PAs when providing care;65

    • Ensure that PAs perform only those services the physician authorizes;66

    • Ensure that PAs prescribe medications only as authorized by the physician and allowed by state and federal laws;67

    • Review and initial selected medical records of patients for whom the PA provided care;68

    • Be available for supervision/consultation, in-person or via electronic communication, whenever the PA is providing care and, for supervising osteopathic physicians, supervise the PA in person at all times during the first 30 days;69 and

    • At least once a month, provide in-person supervision/consultation while the PA is providing care.70

In addition, a supervising physician must develop and implement a program to ensure the PA’s quality of care. The physician must maintain accurate documentation of these evaluations which must include, at a minimum:

    • Medical competency assessment;

    • Review and initialing of selected patient medical records;

    • Assessment of a representative sample of the PA’s referrals/consultations to/with other health care professionals according to the patient’s condition; and

    • Direct observation of the PA’s performance of medical history taking and physical exams.71

Allopathic physicians supervising PAs should carefully review their obligations set forth at NAC 630.370. Similarly, osteopathic physicians should review their obligations listed at NAC 633.288 and NAC 633.289.

 

[1] Minor surgery is legally defined as those invasive procedures that may be performed by a PA, that are consistent with the training and experience of the PA, that are normally taught in courses of training approved by the licensing board, that have been approved by the board as falling within the scope of practice of a PA, and that are consistent with the practice setting requirements of the PA. Minor surgery does not include, and PAs in Arizona may not perform, a surgical abortion. ARS 32-2501(12) & 32-2531(E). PAs also are prohibited from prescribing medication to perform or induce an abortion. Id. at 32-2532(A)(3).

[2] ARS 32-2531(A)(1)-(18)

[3] ARS 32-2531(B); AAC R4-17-401. A PA with more than 8,000 hours is also permitted to practice according to a Supervision Agreement.

[4] AAC R4-17-401(B)(1)-(2)

[5] ARS 32-2531(B) & (D); 32-2501(6) (definition of “collaborating physician or entity”) & (13)

[6] AAC R4-17-402(A)-(B)

[7] AAC R4-17-402(C)-(E)

[8] ARS 32-2501(17)

[9] Id. at 32-2501(18); 32-2531(C); 32-2532(B) & (C)

[10] Id. at 32-2533(B)(4), (C), & (D)

[11] UT Code 58-70a-307(1)(a)-(c)

[12] Id. at 58-70a-307(2)(1)-(c)

[13] Id. at 58-70a-307(3)(a)-(b)

[14] Id. at 58-70a-307(2)(b) & (3)(b)(ii)-(iii)

[15] Id. at 58-70a-307(4)

[16] Id. at 58-70a-501.1(1)(a)-(d)

[17] Id. at 58-70a-501.2(4)(a)-(d)

[18] Id. at 58-70-501(1) & (4)

[19] Id. at 58-70-501(6)

[20] Id. at 58-70-501(11)(a)-(c)

[21] Id. at 58-70-501(2)

[22] Id. at 58-70-501(9)

[23] Id. at 58-70-501(7)(a)-(e)

[24] Id. at 58-70a-501.2(6)(a)-(c)

[25] Id. at 58-70a-501.2(1)(a) & (3)(a)

[26] Id. at 58-70a-501.2(3)(b) & (4)(a)-(b)

[27] MCA 37-20-301(3).

[28] MCA 37-20-403(1)-(2)

[29] MCA 37-20-404(1)-(3)

[30] MCA 37-20-403(1)

[31] MCA 37-20-203(2) & (4)(b)

[32] ARM 24-156-403(j)

[33] MCA 37-20-203(2)(a) & (b)

[34] Id. at (3)(a)-(c)

[35] ARM 24-156-1623

[36] MCA 37-20-203(4)(a)(i)-(ii)

[37] Id. 37-20-203(4)(b)

[38] CRS 12-240-107(6)(a)

[39] Id. at 12-240-107(6)(j)

[40] Id. at 12-240-107(1)(a)-(g)

[41] 3 CCR 713-1.15(C)(2)(e)

[42] CRS 12-240-107(6)

[43] Id. at 12-240-114.5(1)(b)

[44] Id. at 12-240-114.5(1)(a)

[45] Id. at 12-240-114.5(1)(d) & (2)(a)

[46] 3 CCR 713-1.15(E)(1) & (2)

[47] CRS 12-240-114.5(2)(a)(I)-(V)

[48] Id. at 12-240-114.5(2)(b)(I)

[49] Id.

[50] Id. at (2)(b)(I)(C)

[51] Id. at (2)(b)(I)(B)

[52] Id. at (2)(b)(III)

[53] Id. at (2)(b)(IV)(A)

[54] Id. at (2)(b)(IV)(B)

[55] Id. at (1)(c)

[56] 3 CCR 713-1.15(C)(3)(b)(6)-(7)

[57] 3 CCR 713-1.15(C)(3)(b)(2)

[58] Id. at (C)(3)(b)(4)

[59] Id. at (C)(3)(b)(3)

[60] NAC 630.370 & 633.289(1)

[61] NAC 630.370(1)(b); 630.271(1); 633.432(1)

[62] NRS 633.123 & 630.025; NAC 630.370(6)

[63] NAC 630.360(1)(a)&(b);NRS 630.271(2); NRS 633.432(2); NRS 633.469(5)

[64] NAC 630.360(2); NRS 633.432

[65] NAC 630.370(a) & (c) & 633.289(2)(a)

[66] NAC 630.370(1)(b) & 633.289(2)(b)

[67] NAC 630.370(d)(1)-(2) & 633.289(c)(1)&(2)

[68] NAC 630.370(2) & 633.289(3)(c)

[69] NAC 630.370(2) & 633.289(3)(b); NRS 633.469(2)&(3)

[70] NAC 630.370(3) & 633.289(3)(a)

[71] NAC 630.370(5)(a)-(e) & 633.289(3)(d)(1)-(5)