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Physician Assistant Collaboration Requirements in Colorado

A summary of Colorado’s collaboration, agreement, filing, supervision, prescribing, and specialty rules for PAs and the physicians who collaborate with them.

colorado np/pa collaboration laws
State Overview
Colorado PA Collaboration Laws Overview
collaborating physician required

Collaborating Physician Required? Yes

physician involvement

Physician Involvement: High until the PA transitions at 5,000 practice hours, then standard

NP collaborative agreement

Agreement Name: Collaborative agreement

proximity requirements

On-Site Requirements: None

chart reviews

Chart Review: No fixed count

controlled substances

Controlled Substances: Allowed

transition requirements

Reduced Supervision / Transition Requirements: 5,000 practice hours, or 3,000 hours in a new practice area. PAs licensed in Colorado before August 7, 2023 are exempt from the pre-transition requirements; PAs in the emergency department of a Level I or II trauma center do not transition.

State Requirements Summary

Colorado PA Collaboration Requirements Summary

 

Yes — every licensed PA in Colorado must enter into a collaborative agreement with a physician or a physician group. Physician involvement starts high and eases once the PA reaches 5,000 practice hours (or 3,000 hours in a new practice area), at which point the agreement shifts from a supervisory agreement to a standard collaborative agreement. Colorado is unusually light on paperwork: the agreement is never filed with the board, but it must be signed by both parties and kept on file at the PA’s primary practice location. Ongoing compliance runs through periodic performance evaluations rather than a set number of chart reviews or meetings. This page covers Colorado’s rules on the collaborative relationship, the agreement, board filing, ongoing compliance, prescribing, and specialty and telehealth requirements.

 

Source: C.R.S. 12-240-114.5(2)(a)

Collaboration Type

Type of Collaborative Relationship

 

Colorado requires every PA to work under a collaborative agreement with a physician or physician group, with the level of involvement tied to the PA’s experience. PAs with fewer than 5,000 practice hours — or fewer than 3,000 hours in a new practice area — work under a supervisory agreement with heightened requirements; after that, they move to a standard collaborative agreement. There is no fully independent practice option for PAs, and no cap on how many PAs a physician may collaborate with.

 

Source: 3 Colo. Code Regs. 713:1-1.15(C)(3)(a)

 

What is a PA’s scope of practice in Colorado?

 

A PA’s practice is shaped by their collaborative agreement, which is built around the PA’s primary practice location and area of practice. The agreement can add requirements specific to that practice, including extra levels of oversight, limits on independent judgment, and a designated primary contact for collaboration. Colorado law holds the PA liable for the care the PA provides.

 

Do PAs need a collaborating physician in Colorado?

 

Yes. Every PA licensed in Colorado must enter into a collaborative agreement with a physician or a physician group.

 

Can PAs practice independently in Colorado?

 

No. A collaborative agreement with a physician or physician group is required throughout a PA’s career, though the relationship becomes less hands-on once the PA reaches 5,000 practice hours.

 

How many PAs can a physician collaborate with in Colorado?

 

Colorado sets no limit. There is no cap on the number of PAs a physician or physician group may enter into collaborative agreements with.

 

Who can be a collaborating physician in Colorado?

 

The physician must be actively practicing in Colorado with a regular and reliable physical presence in the state. A physician who practices medicine primarily through telecommunication devices or other telehealth technologies does not meet that standard. A physician group, rather than a single named physician, can also be the party to the agreement.

 

Are there proximity or in-person requirements in Colorado?

 

No — Colorado does not require the physician to be on-site with the PA. The requirement falls on the physician’s presence in the state: a regular and reliable physical presence in Colorado. Separately, for a PA still under a supervisory agreement, collaboration during the first 160 practice hours must be completed in person or through technology, as permitted by the physician or physician group.

Agreements

Collaboration Agreement Requirements

 

Colorado’s written document is called a collaborative agreement, and it must be signed by the PA and the physician or physician group and kept on file at the PA’s primary practice location. The required content covers the PA’s identifying details, how collaboration will work, and how performance will be evaluated, plus anything else the physician or group adds. Colorado does not provide a template and sets no review or renewal schedule.

 

Source: C.R.S. 12-240-114.5(2)(a),(b)(I)

 

What must be included in a PA collaborative agreement in Colorado?

 

The agreement must include the PA’s name, license number, and primary practice location; the signatures of the PA and the physician or physician group; a description of the PA’s collaboration process; a description of the performance evaluation process; and any additional requirements the physician or group imposes. A PA still under a supervisory agreement needs three additional items: collaboration completed in person or through technology during the first 160 practice hours, elements defining the expected nature of the collaboration (practice area, consultation expectations, and methods and modes of communication), and performance evaluations at 6 months, 12 months, and as agreed thereafter. Colorado does not offer a state template.

 

What is the collaborative agreement called in Colorado?

 

It is called a collaborative agreement. For a PA with fewer than 5,000 practice hours — or fewer than 3,000 hours in a new practice area — that same document is a supervisory agreement and carries the additional requirements above.

 

Who has to sign the collaborative agreement in Colorado?


Both the PA and the physician or physician group must sign.

 

How often must the agreement be reviewed or renewed in Colorado?

 

Colorado sets no specific requirement. The rules are silent on review or renewal frequency. The agreement must be kept on file at the PA’s primary practice location and made available to the board on request.

 

Is a backup physician required in Colorado?

 

No — Colorado sets no backup physician requirement. The agreement may be entered into with a physician group rather than a single physician.

Board Filing

Board Filing Requirements

 

Colorado does not require the collaborative agreement to be filed with the board. Instead, the agreement must be kept on file at the PA’s primary practice location and made available to the board on request. There are no additional documents to file, no recurring filings, and no termination notice.

 

Source: C.R.S. 12-240-107(6)(c)

 

Do you have to file the collaborative agreement with the board in Colorado?

 

No. Colorado does not require the collaborative agreement to be filed with the board, and no additional documents must be filed. The signed agreement must be kept at the PA’s primary practice location and produced to the board on request.

 

Can a PA start practicing as soon as they file in Colorado?

 

Filing does not apply in Colorado, because there is nothing to file. What a PA needs is a signed collaborative agreement in place and on file at their primary practice location.

 

What are the termination and notice requirements in Colorado?

 

Colorado sets no specific requirement. No termination notice must be sent to the board, and the state provides no grace period for an unexpected loss of a collaborating physician.

Compliance

Collaboration Compliance

 

Colorado’s ongoing obligation is periodic performance evaluation rather than a set number of chart reviews or meetings. The physician or physician group must develop and carry out periodic performance evaluations covering competency areas relevant to the practice, using more than one method of assessment, and must keep accurate records of those evaluations. A PA still under a supervisory agreement must be evaluated at 6 months, 12 months, and as agreed thereafter.

 

Source: 3 Colo. Code Regs. 713:1-1.15(C)(3)(b)(1),(4)

 

How many charts must a collaborating physician review in Colorado?

 

There is no fixed chart count. Chart review, with the reviewed charts identified, is one accepted method of performance evaluation — alongside co-management of patients, direct observation, and feedback from patients and other identified providers — and more than one method must be used. Colorado does not require the physician to co-sign charts, and it adds no heightened review for controlled substances.

 

How often must a PA and collaborating physician meet in Colorado?

 

Colorado sets no fixed meeting cadence and no availability standard; it requires periodic performance evaluations instead. A PA still under a supervisory agreement must receive a performance evaluation, and a discussion of that evaluation, at 6 months, at 12 months, and as agreed thereafter.

 

How long must collaboration records be kept in Colorado?

 

Colorado sets no retention period. The physician or physician group must maintain accurate records and documentation of the performance evaluations — the initial evaluation and each periodic one — for every PA they have a collaborative agreement with, but no length of time is specified.

Prescribing

Prescribing Rules

 

PAs in Colorado may prescribe controlled substances, and the one stated condition is a registration from the U.S. Drug Enforcement Administration. Colorado adds no state-level prescriptive authority credential, no additional controlled-substance credential, and no prescription pad requirements.

 

Source: 3 Colo. Code Regs. 713:1-1.15(D)(3)

 

Can a PA prescribe controlled substances in Colorado?

 

Yes, provided the PA holds a registration from the U.S. Drug Enforcement Administration. A PA may not issue a prescription order for any controlled substance without that DEA registration.

 

Can a PA prescribe Schedule II drugs in Colorado?

 

Colorado’s PA rules do not single out Schedule II or set schedule-by-schedule limits. The stated condition on controlled-substance prescribing is DEA registration, and Colorado imposes no additional requirements for controlled-substance prescriptive authority.

 

What schedule drugs can a PA prescribe in Colorado?

 

Colorado does not restrict PA prescribing by schedule. Controlled-substance prescribing turns on the PA holding a DEA registration rather than on which schedule the medication falls into.

 

Does a PA need a DEA license in Colorado?

 

Yes — a federal DEA registration is required to prescribe controlled substances. Colorado does not require a separate state controlled-substance registration on top of it.

 

Can a PA prescribe independently (without physician sign-off) in Colorado?

 

Colorado does not require a physician to co-sign a PA’s charts or prescriptions. Prescribing still happens within the PA’s collaborative agreement, which can add extra levels of oversight or limits on independent judgment.

Specialty & Telehealth

Specialty & Telehealth Requirements

 

Colorado sets no telehealth requirements specific to PA practice, though telehealth does affect who can serve as a collaborating physician. On specialty, Colorado has one significant rule: a PA in the emergency department of a hospital with a Level I or Level II trauma center stays under a supervisory agreement indefinitely and never transitions to a standard collaborative agreement.

 

Source: C.R.S. 12-240-114.5(2)(b)(IV)

 

Are there telehealth or telemedicine requirements for PAs in Colorado?

 

No — Colorado sets no telehealth or telemedicine requirements specific to PAs. Telehealth does matter on the physician side: a physician who practices medicine primarily through telecommunication devices or other telehealth technologies is not considered to be actively practicing medicine in Colorado and so cannot serve as a collaborating physician. Technology may, however, be used to complete collaboration during a PA’s first 160 practice hours.

 

Are there specialty-specific requirements for PAs in Colorado?

 

Yes, in emergency medicine. A PA who enters into an agreement with a physician or physician group in the emergency department of a hospital with a Level I or Level II trauma center remains under a supervisory agreement indefinitely, keeping the heightened requirements permanently. A PA changing practice areas to work in an emergency department that is not a Level I or II trauma center may have that supervisory period extended by the physician or physician group.

 

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