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Physician Assistant Collaboration Requirements in Washington, D.C.

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

d.c. np/pa collaboration laws
State Overview
Washington, D.C. PA Collaboration Laws Overview
collaborating physician required

Collaborating Physician Required? Yes

physician involvement

Physician Involvement: High

NP collaborative agreement

Agreement Name: Delegation agreement.

proximity requirements

On-Site Requirements: Yes, in inpatient settings

chart reviews

Chart Review: No chart review count

controlled substances

Controlled Substances: Allowed. A PA authorized to prescribe or dispense controlled substances must register with the federal DEA and include that DEA number on controlled-substance prescriptions.

transition requirements

Reduced Supervision / Transition Requirements: None

State Requirements Summary

Washington, D.C. PA Collaboration Requirements Summary

 

Washington, D.C. requires every PA to have a supervising physician under a written delegation agreement filed with the Board of Medicine, plus a copy to the Board of Pharmacy if the PA prescribes. Physician involvement is high: PAs are treated as agents of their supervising physicians, the supervising physician has ultimate responsibility for the care the PA provides, and the pair must complete a documented practice advisory review every quarter. Inpatient work carries a physical presence requirement that outpatient work does not. Filing deadlines are short throughout — changes to the supervising physician list and terminations both carry 10-day filing requirements, and any change to the agreement means signing and filing a new one. This page covers D.C.’s rules on the supervising relationship, the delegation agreement, board filing, ongoing compliance, prescribing, and specialty and telehealth requirements.

 

Source: 17 DCMR 4916.1

Collaboration Type

Type of Collaborative Relationship

 

Washington, D.C. requires a supervising physician who retains professional and legal responsibility for the care a PA renders. Physician involvement is high: PAs are considered agents of their supervising physicians in all practice-related activities, the supervising physician must be available by electronic communication or have designated a substitute, and the pair must complete a quarterly practice advisory review. Inpatient settings add a physical presence requirement. D.C. offers no path to reduced supervision or independent practice.

Source: 17 DCMR 4916.2

 

What is a PA’s scope of practice in Washington, D.C.?

 

A PA’s scope in D.C. is what the delegation agreement delegates — it must describe the PA’s role in the practice, list the delegated functions and practice sites, and identify the settings where the supervising physicians delegate authority to see patients. The physician-PA team is responsible for ensuring the PA’s scope is identified and that delegated medical tasks match the PA’s level of competence.

 

Do PAs need a collaborating physician in Washington, D.C.?

 

Yes. Before beginning practice, a PA must have a written delegation agreement on the Board’s form with a supervising physician, and that physician retains professional and legal responsibility for the PA’s care.

 

Can PAs practice independently in Washington, D.C.?

 

No. D.C. sets no hour count or experience threshold that leads to reduced supervision or independence, and the supervising physician holds ultimate responsibility for the medical care and treatment a PA provides.

 

How many PAs can a physician collaborate with in Washington, D.C.?

 

Four on-duty PAs at one time. A physician may not actively supervise more than that simultaneously.

 

Who can be a collaborating physician in Washington, D.C.?

 

A physician licensed in the District of Columbia who is free from any Board-imposed disciplinary restriction on their ability to supervise a PA. That physician must maintain a written delegation agreement with the PA stating they will exercise supervision under the Board’s rules and retain professional and legal responsibility for the PA’s care.

 

Are there proximity or in-person requirements in Washington, D.C.?

 

Yes, but only in inpatient settings. There, supervision includes continuing or intermittent physical presence of the supervising physician, with constant availability through electronic communications. In outpatient settings, supervision requires constant availability through electronic communications without any physical presence requirement.

Agreements

Collaboration Agreement Requirements

 

D.C.’s written agreement is called a delegation agreement, and the Board provides the required form. It must describe the PA’s role in the practice, list the delegated functions, practice sites, and supervisors, identify the settings where the supervising physicians delegate authority to see patients, and state that the physician will exercise supervision under Board rules and retain professional and legal responsibility for the PA’s care. The PA and the supervising physicians sign it. It must be filed with the Board, kept on file at the primary practice site, and updated at each of the PA’s license renewals or as needed.

 

Source: 17 DCMR 4915.1

 

What must be included in a PA collaborative agreement in Washington, D.C.?

 

The delegation agreement must describe the PA’s role in the practice, list the delegated functions, practice sites, and supervising physicians, identify the settings in which those physicians delegate authority to see patients, and state that the physician will exercise supervision in accordance with Board rules and retain professional and legal responsibility for the care the PA renders. D.C. provides a form, and using it satisfies the content requirements.

 

What is the collaborative agreement called in Washington, D.C.?

 

It is called a delegation agreement. The Board provides the form that must be used.

 

Who has to sign the collaborative agreement in Washington, D.C.?

 

The PA and the supervising physician or physicians listed on it. The signed form is then filed with the Board by the PA and kept at the primary practice site.

 

How often must the agreement be reviewed or renewed in Washington, D.C.?

 

At the time of each of the PA’s license renewals, or as needed. Any change to the delegation agreement requires a new form signed by the physician and the PA, filed with the Board and kept at the primary practice site.

 

Is a backup physician required in Washington, D.C.?

 

No separate backup physician is required, but coverage must come from the agreement itself. If a supervising physician cannot supervise because of a planned or unplanned absence, they must delegate that responsibility to another supervising physician whose signature appears on the delegation agreement. If they cannot, the PA may ask another supervising physician on the agreement to take it on, and that physician must consent.

Board Filing

Board Filing Requirements

 

Washington, D.C. requires the delegation agreement to be filed with the Board of Medicine, with a copy also going to the Board of Pharmacy if the PA has prescriptive authority. A duplicate is kept at the primary practice site. Filing does not stop there: any change to the agreement requires a newly signed form on file, changes to the supervising physician list must be filed within 10 days, and terminations carry their own 10-day deadline.

 

Source: 17 DCMR 4915.2

 

Do you have to file the collaborative agreement with the board in Washington, D.C.?

 

Yes, with the Board of Medicine — and with the Board of Pharmacy too if the PA has prescriptive authority. The PA files the signed form and keeps a duplicate copy at the primary place of practice. If the agreement changes, a new signed form must be filed and kept on site.

 

Can a PA start practicing as soon as they file in Washington, D.C.?

 

D.C.’s rules do not state whether a PA may begin practicing immediately on filing or must wait for Board action. What is clear is that a PA must have a written delegation agreement on the Board’s form before beginning practice.

 

What are the termination and notice requirements in Washington, D.C.?

 

Both changes and terminations carry 10-day deadlines. If the supervising physicians change, the PA must file the Board’s form for additions and deletions to the supervising physician list within 10 days of the effective date. If the PA’s employment status changes or the delegation agreement is otherwise terminated, the first supervising physician listed on the agreement must file a Board termination form within 10 days.

Compliance

Collaboration Compliance

 

D.C.’s central ongoing obligation is the quarterly practice advisory review: each PA and one of the supervising physicians listed on the delegation agreement must complete one every quarter and document it on a form kept in a personnel file at the PA’s practice location. Beyond that, the supervising physician must stay available by electronic communication or designate a substitute, and the physician-PA team must have a process in place for evaluating the PA’s performance. There is no required chart review count and no chart co-signature requirement, though every chart entry a PA makes must name the responsible supervising physician.

 

Source: 17 DCMR 4914.9

 

How many charts must a collaborating physician review in Washington, D.C.?

 

D.C. sets no chart review count. The physician-PA team must ensure the PA’s scope of practice is identified, that delegated tasks match the PA’s competence, that the relationship with and access to the supervising physicians is defined, and that a process for evaluating the PA’s performance is established. Where a PA practices in a licensed health care facility, that entity shares responsibility through its credentialing and privileging process.

 

How often must a PA and collaborating physician meet in Washington, D.C.?

 

Quarterly. Each PA and one of the supervising physicians listed on the delegation agreement must complete a practice advisory review every quarter, documented on a form kept in a personnel file at the location where the PA practices.

 

How long must collaboration records be kept in Washington, D.C.?

 

D.C. sets no retention period for supervision records. The quarterly practice advisory review form must be kept in a personnel file at the PA’s practice location, and a duplicate of the delegation agreement must be kept at the primary place of practice.

Prescribing

Prescribing Rules

 

PAs in Washington, D.C. may prescribe, and a PA authorized to prescribe or dispense controlled substances must register with the federal DEA. D.C. requires no separate local controlled-substance registration, but it does impose specific documentation and prescription format requirements: every prescription must carry the names of both the PA and the supervising physician, and the PA must chart every drug they prescribe, dispense, or administer.

 

Source: 17 DCMR 4912.2

 

Can a PA prescribe controlled substances in Washington, D.C.?

 

Yes, with federal DEA registration. A PA authorized to prescribe or dispense controlled substances must register with the DEA and must include that federal DEA registration number on prescriptions for controlled medications. D.C. adds no heightened supervision requirement specific to controlled substances.

 

Can a PA prescribe Schedule II drugs in Washington, D.C.?

 

D.C.’s master regulatory data does not address drug schedules individually. It treats controlled substances as a category, requiring federal DEA registration and the PA’s DEA number on the prescription.

 

What schedule drugs can a PA prescribe in Washington, D.C.?

 

D.C.’s master regulatory data sets no schedule-by-schedule limits on PA prescribing. What a PA may prescribe follows from what the supervising physician delegates in the delegation agreement.

 

Does a PA need a DEA license in Washington, D.C.?

 

Yes, a PA authorized to prescribe or dispense controlled substances must register with the federal DEA and put that registration number on controlled-substance prescriptions. D.C. requires no separate local controlled-substance registration. Every prescription must bear the names of the PA and the supervising physician, and written prescriptions must be issued on a pad printed with both names.

 

Can a PA prescribe independently (without physician sign-off) in Washington, D.C.?

 

No. Prescribing authority comes through delegation from the supervising physician, every prescription must carry that physician’s name, and the PA must enter a progress note in the patient’s chart on the date of each transaction recording each prescription ordered and the name, strength, and quantity of anything dispensed or administered.

Specialty & Telehealth

Specialty & Telehealth Requirements

 

Washington, D.C. sets no telehealth-specific and no specialty-specific requirements for PAs. The standard supervision, delegation agreement, filing, and prescribing rules apply across settings and specialties, including the inpatient physical presence requirement.

 

Are there telehealth or telemedicine requirements for PAs in Washington, D.C.?

 

No, D.C. sets no telehealth-specific requirement for PAs. Electronic communication is how the supervising physician satisfies the availability standard, and in outpatient settings constant availability by electronic communication is all that supervision requires.

 

Are there specialty-specific requirements for PAs in Washington, D.C.?

 

No, D.C. sets no specialty-specific requirements for PAs. Setting matters more than specialty here: inpatient supervision requires the physician’s continuing or intermittent physical presence, while outpatient supervision does not.

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