A summary of Massachusetts’s collaboration, agreement, filing, supervision, prescribing, and specialty rules for PAs and the physicians who collaborate with them.
Collaborating Physician Required? Yes
Physician Involvement: High
Agreement Name: Written prescriptive practice guidelines.
On-Site Requirements: None
Chart Review: No fixed chart count. The supervising physician must review the PA’s prescribing practice at least every three months, and every Schedule II prescription or medication order the PA issues must be reviewed within 96 hours.
Controlled Substances: Allowed, Schedules II through V. A PA needs a Massachusetts Controlled Substance Registration to write any prescription in the state, plus their own federal DEA registration to order Schedules II through V. The supervising physician must hold both Massachusetts Department of Public Health and federal DEA registrations.
Reduced Supervision / Transition Requirements: None
Massachusetts PA Collaboration Requirements Summary
Massachusetts requires every PA’s professional activities to be supervised by a Massachusetts-licensed physician, and that supervision must be continuous — though it never requires the physician to be physically present. The written agreement in Massachusetts is narrower than in most states: written guidelines are required for prescribing, major invasive procedures, and fluoroscopic procedures rather than for practice generally. Nothing is filed with the state; the guidelines stay between the parties. Oversight is concentrated on prescribing, with a review of the PA’s prescribing practice at least every three months and a 96-hour review requirement for every Schedule II prescription. This page covers Massachusetts’s rules on the supervising relationship, the written prescriptive practice guidelines, board filing, ongoing compliance, prescribing, and specialty and telehealth requirements.
Source: MGL c. 112, § 9E
Type of Collaborative Relationship
Massachusetts requires all of a PA’s professional activities to be supervised by a physician licensed by the Massachusetts Board of Registration in Medicine. That supervision must be continuous but does not require the physician’s personal presence. Physician involvement is high, concentrated on prescribing: the physician and the PA are jointly responsible for every prescription the PA issues, and the PA’s employer is legally responsible for the PA’s acts and omissions. There is no path to reduced supervision or independent practice for PAs in Massachusetts.
Source: 263 CMR 5.04(1)
What is a PA’s scope of practice in Massachusetts?
A PA’s professional activities in Massachusetts must all be supervised by a Massachusetts-licensed physician, with prescribing bounded by written guidelines the PA and physician develop together. Those guidelines set the types and classes of medications the PA may prescribe, quantity and refill limits, and how prescriptions outside the ordinary scope of that work setting are handled.
Do PAs need a collaborating physician in Massachusetts?
Yes. All professional activities of a PA must be supervised by a supervising physician licensed by the Massachusetts Board of Registration in Medicine.
Can PAs practice independently in Massachusetts?
No. Supervision is continuous, and Massachusetts sets no experience threshold that leads to reduced supervision or independence. A PA employed by a health care facility also may not be used as the sole medical personnel in charge of emergency services, outpatient services, or any other clinical service where a licensed physician is not regularly available.
How many PAs can a physician collaborate with in Massachusetts?
Massachusetts sets no limit on the number of PAs a physician may supervise. A 2012 amendment removed the statute’s reference to a maximum number. In practice, a physician may sign prescriptive practice guidelines only with PAs they are actually able to supervise.
Who can be a collaborating physician in Massachusetts?
A physician licensed by the Massachusetts Board of Registration in Medicine. For purposes of signing prescriptive practice guidelines, the physician must hold an unrestricted full Massachusetts license.
Are there proximity or in-person requirements in Massachusetts?
No, Massachusetts sets no distance, travel, or on-site presence requirement. Supervision must be continuous but does not require the supervising physician’s personal presence. Geographic proximity is still a factor a physician must weigh before signing prescriptive practice guidelines, alongside practice setting, patient volume and complexity, and the experience, training, and availability of both parties.
Collaboration Agreement Requirements
Massachusetts requires written guidelines rather than a general practice agreement, and they are required for prescribing, major invasive procedures, and fluoroscopic x-rays and procedures. The prescribing guidelines are mutually developed and agreed on by the PA and the supervising physician, must be in writing, and must be signed by both. They must be reviewed annually and dated and initialed by both parties at each review, and either party may change them at any time with both initialing and dating the change. The state provides no template but does publish a checklist.
Source: 263 CMR 5.06(4)(a)
What must be included in a PA collaborative agreement in Massachusetts?
Eight things at minimum: identification of the supervising physician for that work setting, how often the PA and physician will review medications, the types and classes of medications the PA may prescribe, how prescriptions outside the ordinary scope of that work setting are initiated or renewed, the quantity of any medication the PA may prescribe including initial dosage limits and refills, the types and quantities of Schedule VI medications the PA may order from a wholesaler, manufacturer, laboratory, or distributor for the practice setting, review of initial prescriptions or medication changes, and procedures for initiating intravenous solutions. Massachusetts provides no state template, though a checklist is available.
What is the collaborative agreement called in Massachusetts?
It is called written prescriptive practice guidelines, or written guidelines governing the prescription of medication. Separate written agreements apply to major invasive procedures and to fluoroscopic x-rays and procedures.
Who has to sign the collaborative agreement in Massachusetts?
Both the supervising physician and the PA. The guidelines must be in writing and carry both signatures.
How often must the agreement be reviewed or renewed in Massachusetts?
Annually. Both the supervising physician and the PA must date and initial the guidelines at each annual review. Either party may alter the guidelines at any time, and any change must be initialed and dated by both.
Is a backup physician required in Massachusetts?
No standing backup physician is required, but when the supervising physician is unable or unavailable to be the principal medical decision-maker, another licensed physician must be designated to take temporary supervisory responsibility. That physician’s name and scope of responsibility must be readily ascertainable from records kept in the ordinary course of business and available to patients. The supervising physician of record remains ultimately responsible for ensuring each task the PA performs is properly supervised.
Board Filing Requirements
Massachusetts requires no board filing for the supervising relationship. The written prescriptive practice guidelines expressly do not need to be filed with the state agencies, no additional documents are required, there is no recurring filing, and no notice is required when the relationship ends. The guidelines are kept between the PA and the supervising physician.
Source: 263 CMR 5.06(4)(b)
Do you have to file the collaborative agreement with the board in Massachusetts?
No. Copies of the written prescriptive practice guidelines do not need to be filed with the state agencies, and Massachusetts sets no on-site storage requirement for them either.
Can a PA start practicing as soon as they file in Massachusetts?
There is nothing to file for the supervising relationship, so no waiting period applies. A PA needs a Massachusetts license, a supervising physician, and signed written guidelines in place before prescribing.
What are the termination and notice requirements in Massachusetts?
Massachusetts sets no termination or notice requirement when a supervising relationship ends. There is also no grace period provision for an unexpected termination.
Collaboration Compliance
Massachusetts concentrates its ongoing obligations on prescribing. The supervising physician must review the PA’s prescribing practice at least every three months and provide ongoing direction, and every Schedule II prescription or medication order the PA issues must be reviewed within 96 hours. Massachusetts sets no general chart review count, no meeting cadence, no chart co-signature requirement, and no records retention period.
Source: 243 CMR 2.08(5)(a)(4)
How many charts must a collaborating physician review in Massachusetts?
Massachusetts sets no general chart count, but requires review of the PA’s prescribing practice at least every three months. Every Schedule II prescription or medication order the PA issues must be reviewed by the supervising physician, or by a designated temporary supervising physician, within 96 hours after it is issued. Chart co-signature is not required.
How often must a PA and collaborating physician meet in Massachusetts?
Massachusetts sets no required meeting cadence. The supervising physician must review and provide ongoing direction for the PA’s prescribing practice as necessary, accounting for the PA’s education, training, and experience, the nature of the PA’s practice, and the availability of clinical back-up from physicians.
How long must collaboration records be kept in Massachusetts?
Massachusetts sets no retention period for supervision records and no on-site storage requirement for the written guidelines. Where a temporary supervising physician is designated, that designation must be ascertainable from records kept in the ordinary course of business and available to patients.
Prescribing Rules
PAs in Massachusetts may prescribe controlled substances in Schedules II through V, but the credentialing requirements are specific. A PA needs a Massachusetts Controlled Substance Registration to write any prescription in the state, and their own federal DEA registration to order controlled substances in Schedules II through V. The supervising physician must separately hold valid registrations from both the Massachusetts Department of Public Health and the federal DEA. All prescribing runs through the written guidelines, and the physician and PA are jointly responsible for every prescription the PA issues.
Source: 243 CMR 2.08(5)(a)(2)
Can a PA prescribe controlled substances in Massachusetts?
Yes, in Schedules II through V, with a Massachusetts Controlled Substance Registration and the PA’s own federal DEA registration. The supervising physician must also hold valid Massachusetts Department of Public Health and federal DEA registrations to issue prescriptions or medication orders for controlled substances.
Can a PA prescribe Schedule II drugs in Massachusetts?
Yes, but every Schedule II prescription or medication order a PA issues must be reviewed by the supervising physician within 96 hours. A designated temporary supervising physician may perform that review when the supervising physician is unavailable.
What schedule drugs can a PA prescribe in Massachusetts?
Schedules II through V with DEA registration, plus other prescription medications as set out in the written guidelines. Those guidelines fix the types and classes of medications, quantity limits, and refills, and separately address the types and quantities of Schedule VI medications the PA may order from a wholesaler, manufacturer, laboratory, or distributor for the practice setting.
Does a PA need a DEA license in Massachusetts?
Yes for Schedules II through V — a PA must hold their own federal DEA registration number. A Massachusetts Controlled Substance Registration is the minimum needed to legally write any prescription in the state. There are no prescription form requirements; a 2012 amendment removed the requirement that a PA’s prescription include the supervising physician’s name.
Can a PA prescribe independently (without physician sign-off) in Massachusetts?
No. Prescribing runs through written guidelines developed and signed with the supervising physician, that physician must review the PA’s prescribing practice at least quarterly, Schedule II orders get a 96-hour review, and the physician and PA are jointly responsible for every prescription the PA issues.
Specialty & Telehealth Requirements
Massachusetts sets no telehealth-specific requirements for PAs but does regulate fluoroscopic x-rays and procedures separately, requiring a written agreement for that work. Major invasive procedures also require a written agreement. Standard supervision and prescribing rules apply otherwise.
Source: 263 CMR 5.07
Are there telehealth or telemedicine requirements for PAs in Massachusetts?
Massachusetts sets no telehealth-specific requirement for PAs in the master regulatory data. Supervision must be continuous but never requires the physician’s personal presence, so remote supervision is contemplated by the general rules.
Are there specialty-specific requirements for PAs in Massachusetts?
Yes, fluoroscopic x-rays and procedures are governed by their own rule and require a written agreement. Major invasive procedures also require a written agreement, and PAs employed by health care facilities may not be the sole medical personnel in charge of a clinical service where a licensed physician is not regularly available.
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