So what is an “organized health care system”? It’s a new term that Section 3501 defines broadly to include, among other settings, licensed clinics, health care facilities (such as hospitals and nursing facilities), home health agencies, physician’s offices, professional medical corporations, medical partnerships, and medical foundations – essentially, any setting where medical care is lawfully provided. Like standardized procedures, practice agreements apply to the organized health care system as a whole and allow any physician within the system to supervise any PA subject to the practice agreement. In other words, whereas delegation of services agreements were like contracts directly between each PA and his or her own supervising physician or physicians, the new practice agreement is more like a standardized procedure, which is the supervisory document that applies to advanced practice registered nurses (APRNs).
However, in a striking break from past requirements, the practice agreements, while “developed through collaboration” with one or more physicians, grants approval for all the physicians on the staff of an “organized health care system” to supervise one or more PAs in the organized health care system. One significant change is the replacement of “delegation of services agreements” with “practice agreements.” Like the old delegation of services agreements, practice agreements are required for the PA to practice, must be developed with at least one physician, and must define the medical services the PA is authorized to perform. Delegation of Services Agreements Replaced With Practice Agreements The changes to the law remove some of the more onerous requirements, streamlining the supervisory process in a way that better reflects current industry practice. The law also detailed specific, limited ways in which physicians could perform their supervisory tasks these included chart reviews, countersigning records, the creation of patient-specific protocols, and medical record review meetings. If multiple physicians were supervising the PA – such as in a group practice or at a hospital – each had to either sign the delegation of services agreement or create their own. Prior to these changes, physicians and PAs had to enter into “delegation of services agreements,” specifically delegating the medical services a PA could perform.