Kentucky PA Collaboration Requirements Summary

Kentucky requires every PA to practice under a supervising physician, and the physician must be approved by the Board of Medical Licensure separately for each PA before that PA can begin working. Physician involvement is high: the physician accepts responsibility for the PA’s medical services, must be continuously available by phone or other telecommunication, and must countersign a sufficient number of the PA’s notes to assure quality of care. Kentucky ties oversight to where the PA works — a physician needs separate board approval to have a PA practice at an office or clinic away from the physician’s primary office. There is no route to independent or reduced-supervision practice for PAs in Kentucky. This page covers Kentucky’s rules on supervision, the collaborative agreement, board filing, ongoing compliance, prescribing, and specialty and telehealth requirements.

Source: KRS 311.854(1)

Type of Collaborative Relationship

Kentucky requires PAs to practice under a supervising physician who has been approved by the Board of Medical Licensure for that specific PA. Physician involvement is high — the physician oversees the PA’s activities and accepts responsibility for the medical services the PA provides — and there is no path to reduced supervision or independent practice. A PA’s authority is bounded by what the supervising physician delegates and by the scope of services described in the physician’s board application.

Source: KRS 311.840(6)

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

A PA’s scope of practice is set by the supervising physician and cannot exceed the physician’s own normal scope of practice. The specific medical services and procedures the PA will perform are described in the physician’s application to the board, and the PA must have been trained for them in an approved program. Delegated tasks must be appropriate to the PA’s level of training and experience.

Do PAs need a collaborating physician in Kentucky?

Yes. A physician cannot supervise a PA without board approval, and that approval must be obtained individually for each PA.

Can PAs practice independently in Kentucky?

No. Kentucky requires an approved supervising physician at all times and sets no hours- or years-based pathway to reduced supervision or independent practice.

How many PAs can a physician collaborate with in Kentucky?

Four. A physician may enter into supervision agreements with no more than four PAs and may not supervise more than four PAs at any one time.

Who can be a collaborating physician in Kentucky?

A supervising physician must be currently licensed and in good standing with the Kentucky Board of Medical Licensure and must maintain a practice primarily within Kentucky. The board has discretion to modify or waive the in-state practice requirement. The physician must also apply for and receive board approval for each PA they intend to supervise.

Are there proximity or in-person requirements in Kentucky?

Kentucky does not routinely require the physician to be on-site, but the physician must be continuously available by telecommunication whenever the PA works in a separate location. If a PA will work in an office or clinic separate from the physician’s primary office, the physician must first obtain board approval for that location, or a board waiver. This separate-location approval does not apply to hospitals, nursing homes, patient-home care, or school health events.

Collaboration Agreement Requirements

Kentucky does not require a separate written collaborative agreement between the PA and the physician. Instead, the terms that other states put in an agreement are captured in the physician’s application for supervisory authority, which the board must approve. Kentucky sets no signature, on-site storage, or review-and-renewal requirement for an agreement document.

Source: KRS 311.854(2)

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

No standalone agreement is required, but the physician’s supervisory application must describe the nature of the physician’s practice, assure that the PA’s scope will not exceed the physician’s normal scope of practice, explain how the two will communicate when they are not in the same location, list the medical services and procedures the PA will perform, and outline the specific parameters for reviewing countersignatures. A process for evaluating the PA’s performance must also be established.

What is the collaborative agreement called in Kentucky?

Kentucky law refers to “supervision agreements,” but there is no separate agreement document to draft. In practice the collaboration is documented through the physician’s application for supervisory authority, and the state provides that application rather than an agreement template.

Who has to sign the collaborative agreement in Kentucky?

Kentucky sets no signature requirement, because no separate agreement is required. Signatures do come up elsewhere: if the PA seeks controlled substance prescriptive authority, the supervising physician must sign that application.

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

Kentucky sets no fixed review or renewal schedule. The physician must, however, submit amendments to the board for approval before the PA performs any service or procedure beyond what the original application described.

Is a backup physician required in Kentucky?

No — Kentucky sets no backup physician requirement.

Board Filing Requirements

Yes, a filing is required: the supervising physician must apply to the Board of Medical Licensure and be approved before supervising a PA, and that approval must be obtained separately for each PA. Filing alone is not enough — practice cannot begin until the board approves. Amendments must be filed and approved before the PA takes on new services, and the physician must notify the board promptly when the relationship ends.

Source: KRS 311.854(1)

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

Yes, in effect. There is no separate agreement to file, but the physician must submit an application for supervisory authority to the board, and that application contains the collaboration details.

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

No. A physician cannot supervise a PA without board approval, and approval must be obtained individually for each PA — so the PA must wait for the board to act.

What are the termination and notice requirements in Kentucky?

The supervising physician must notify the board within three business days of ceasing to supervise or employ the PA. The same three-business-day notice applies if the physician believes in good faith that the PA has violated a disciplinary rule. Kentucky provides no grace period for an unanticipated termination.

Collaboration Compliance

Once the supervision is approved, the physician must review and countersign a sufficient number of the PA’s medical notes, stay continuously available by telecommunication, and reevaluate the PA every two years. Kentucky does not set a required meeting cadence or a fixed chart count — but a process for evaluating the PA’s performance must be in place, and the countersignature parameters must be spelled out in the physician’s board application.

Source: KRS 311.846(11)

How many charts must a collaborating physician review in Kentucky?

There is no fixed chart count — the physician must review and countersign a “sufficient number” of the PA’s overall medical notes to assure quality of care. The specific countersignature requirements are determined by the supervising physician, practice, or institution, and must be outlined in the physician’s supervisory application.

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

Kentucky sets no required meeting cadence. A process for evaluating the PA’s performance must be established, and the physician must be continuously available by telecommunication when the PA works in a separate location. Separately, the physician must reevaluate the PA’s reliability, accountability, and professional knowledge two years after the PA’s original Kentucky licensure and every two years after that, then recommend approval or disapproval of renewal to the board.

How long must collaboration records be kept in Kentucky?

Kentucky sets no specific retention period for collaboration records.

Prescribing Rules

PAs in Kentucky may prescribe, but controlled substance authority is limited to Schedules III, IV, and V — Schedule II is off limits — and requires separate board approval before the PA can prescribe or administer any controlled substance. All prescribing flows from what the supervising physician delegates. Kentucky also caps the supply length on several controlled substance categories.

Source: KRS 311.858(5)

Can a PA prescribe controlled substances in Kentucky?

Yes, Schedules III, IV, and V only, and only after the board approves the PA for controlled substance prescriptive authority. Before prescribing or administering controlled substances, the PA must have at least one year of experience as a licensed, practicing PA, submit an application signed by the supervising physician, receive board approval, obtain a federal DEA Controlled Substance Registration Certificate, and register with Kentucky’s controlled substance monitoring system.

Can a PA prescribe Schedule II drugs in Kentucky?

No. PAs in Kentucky cannot prescribe Schedule II medications.

What schedule drugs can a PA prescribe in Kentucky?

PAs may prescribe Schedules III, IV, and V controlled substances, plus all nonscheduled legend drugs and medical devices, to the extent the supervising physician delegates. Supply limits apply: Schedule III prescriptions are limited to a 30-day supply with no refills; Schedule IV and V prescriptions are limited to the original prescription plus refills not exceeding a six-month supply; and benzodiazepines and Carisoprodol are limited to a 30-day supply with no refills. Restrictions on specific controlled substances that apply to all practitioners also apply.

Does a PA need a DEA license in Kentucky?

Yes, a federal DEA Controlled Substance Registration Certificate is required before a PA prescribes or administers controlled substances. The PA must also register with Kentucky’s controlled substance monitoring system and any other applicable state controlled substance regulatory authority. Kentucky does not explicitly require a separate state DEA registration.

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

No. A PA’s prescribing authority exists only to the extent the supervising physician delegates it, and controlled substance authority additionally requires an application signed by that physician plus board approval. Kentucky does not require the physician to co-sign every prescription, but it does require countersignature of a sufficient number of the PA’s medical notes.

Specialty & Telehealth Requirements

Kentucky sets no PA-specific telehealth or telemedicine requirement in its master rules, but it does impose a stricter supervision standard on PAs practicing as anesthesiology assistants. The general supervision, filing, and prescribing rules apply otherwise.

Source: KRS 311.862(3)

Are there telehealth or telemedicine requirements for PAs in Kentucky?

No, Kentucky sets no PA-specific telehealth or telemedicine requirement. The general rules still apply, including board approval for practice at a separate location and the physician’s duty to stay continuously available by telecommunication.

Are there specialty-specific requirements for PAs in Kentucky?

Yes — a PA practicing as an anesthesiology assistant requires direct supervision. A PA cannot administer or monitor general or regional anesthesia unless the supervising physician in anesthesia is physically present in the room during induction and emergence, is not concurrently performing any other anesthesiology procedure, and is available to provide immediate physical presence in the room.