Allied Health | Physician Assistants (2023)

What are the requirements for licensure?

The applicant shall complete an applicationAllied Health | Physician Assistants (1)supplied by the Board:

  1. Be of good moral character.
  2. Be at least 18 years old.
  3. Pay the application fee.
  4. Graduation from a physician assistant educational program accredited by the Accreditation Review Commission on Education for the Physician Assistant (ARC-PA) or its successor.
  5. Applicants who graduate from an accredited physician assistant educational program after October 1, 2003, must have a baccalaureate degree or the equivalent education to a baccalaureate degree.
  6. Current certification by the National Commission on Licensure of Physician Assistants (NCCPA).
  7. Demonstrate oral and written competency in English as required by the Board.
  8. Meet any other requirements established by the Board.
  9. Submit to a criminal history records check.

The Board may accept the Federation Credential Verification Service (FCVS) for primary source verification of a physician assistant's core credentials. For more information about the FCVS, contact them at 817-868-4000; fcvs@fsmb.org or go to their website at https://www.fsmb.org/licensure/fcvs/.

What is a delegation agreement?

A delegation agreement is a document that is executed by a primary supervising physician (PSP) and a PA (PA) containing the requirements of Health Occupations Article, § 15-302, Annotated Code of Maryland.

Applicants are also required to meet additional qualifications.

What are core duties?

Core duties are medical acts that are included in the standard curricula of accredited PA education programs.

How long does it take to be licensed?

The application process, on average, could take 3 – 6 weeks. However, theprocess may take longer depending on the individual applicant'scircumstance or if the individual does not provide the requireddocumentation on a timely basis.


Processing of an application for licensure is only one part of the process. In addition, all Physician Assistants (PAs) and their Primary Supervising Physician (PSP) must complete and submit an Online DA with the Board. The PA may begin working once the Board has received and acknowledges receipt of the completed DA in writing.

What are the requirements for reinstatement?

  1. Completion of a reinstatement application Allied Health | Physician Assistants (2)approved by the Board.
  2. Payment of a reinstatement fee.
  3. Satisfactory evidence of compliance with the continuing educationrequirements.
  4. Verification from the Maryland Office of the Comptroller that theapplicant has paid all undisputed taxes and unemploymentinsurance contributions payable to the Comptroller or the Secretaryof Labor, Licensing, and Regulation or that the applicant hasprovided for payment in a manner satisfactory to the unitresponsible for collection. (Maryland Health Occupations CodeAnnotated, § 1-213).

The continuing education requirement does not apply to the first renewal after initial certification or reinstatement of certification.

What are the continuing education requirements?

  1. Fifty hours (50) of Category I continuing education earned within the 2 years preceding the date of the application for renewal or reinstatement. A minimum of eight (8) must relate to pharmacology topics; OR
  2. Current certification by the National Commission on Certification of Physician Assistants (NCCPA).

The Board may request a PA to submit evidence of having met the continuing education requirements specified in this regulation. If a PA cannot demonstrate completion of the required continuing education credit hours, the Board may impose a civil penalty of up to $100 per missing continuing education credit hour.

What is the delegation agreement process for core duties?

PAs and PSPs must complete and submit the Online delegation agreement and the required fee to the Board. The PA begins the process and forwards the online delegation agreement to the PSP to complete and submit to the Board.

The PA may begin working once the Board has received the completed online delegation agreement and acknowledges its receipt in writing. PAs and PSPs will receive acknowledgment letters via email.

How long will it take the Board to acknowledge its receipt of the completed delegation agreement in writing?

The Board will send an email to the PA and PSP acknowledging its receipt of the completed delegation agreement upon its receipt of the completed delegation agreement.

When and how must a PA and/or PSP report the termination of an approved delegation agreement to the Board?

A PA and/or PSP must log into his/her practitioner profile on the Board's website to report the termination of an approved delegation agreement to the Board within 5 days of the effective date of termination.

What are advanced duties?

Advanced duties are medical acts that require additional training beyond the basic PA education program required for licensure. Click here for a listing of Advanced Procedures by SpecialtyAllied Health | Physician Assistants (3).

What is the delegation agreement addendum process for advanced duties in accredited healthcare facilities?

PAs and PSPs must file the completed delegation agreement with the Board. Delegation agreements with advanced duties will not require prior Board approval if the advanced duty listed in the delegation agreement will be performed in a hospital or an ambulatory surgical facility that:

  1. Is accredited by an accrediting agency recognized by the Board.
  2. Credentials supervising physician as a condition of employment, as an independent contractor or as a member of the medical staff before the supervising physician begins practicing in the facility;
  3. Credentials PA as a condition of employment, as an independent contractor or as a member of the medical staff before the PA begins practicing in the facility; and
  4. Through its governing body has already reviewed and approved the PA to perform each requested advanced duty before the delegation agreement with advanced duties is filed with the Board.

A PA may begin working after the Board receives the delegation agreement for advanced duties and acknowledges receipt in writing. Board staff will email acknowledgment letters to the PA and the PSP.

Note: Pursuant to §15-302.1(e), the Board is authorized to disapprove any delegation agreement not meeting the requirements of the law or if the Board believes that a PA is unable to perform the delegated duties safely.

What does the Board consider an accredited facility?

An accredited facility is a hospital or ambulatory surgical facility accredited by The Joint Commission, the American Association for Accreditation of Ambulatory Surgical Facilities, the Accreditation Association for Ambulatory Health Care, is certified to participate in the Medicare program, as enacted by Title XVIII of the Social Security Act or meets the criteria in Health Occupations Article, §15-302(c)(1).

What does the Board consider a non-accredited facility?

Non-accredited facilities are facilities that do not meet the criteria in Health Occupations Article, §15-302(c)(1). For example:

  1. Non-accredited hospitals;
  2. Non-accredited ambulatory surgical centers;
  3. Private practices
  4. Detention centers
  5. Public health facilities
  6. Correctional facilities
  7. Hospitals or ambulatory surgical facilities whose governing body has not approved the PA to perform the requested procedure prior to submitting the advanced duties request to the Board.

What is the delegation agreement process for advanced duties in non-accredited facilities?

PAs and PSPs must obtain prior Board approval before the PA may begin practicing any advanced duty. PAs in these practice settings are required to submit training and education documentation. The criteria for Board approval is as follows:

  1. Completion of the Delegation Agreement Addendum for Advanced DutiesAllied Health | Physician Assistants (4).
  2. Documentation, including but not limited to:
    1. Procedure logs showing at least 10 – 25 successful procedures (200 for stress testing);
    2. Advanced education/training, including training certificates indicating training completion or a delineation of hospital privileges for the PA;
    3. Consent forms;

(Please note that the PAAC or the Board may require a PA or SP to meet additional requirements before approving a request to perform advanced duties. The requirements will depend upon the type of advanced duty.)
Note:A PSP is required to obtain the Board's approval of a delegation agreement before the PA may administer, monitor or maintain general anesthesia or neuroaxial anesthesia, including spinal and epidural techniques.

Is there a way to expedite the process?

Yes. For delegation agreements with advanced duties that require prior Board approval, the PA and PSP may apply for a temporary practice letter. The Board may approve a temporary practice letter if:

  1. The Board previously approved the PSP to supervise one or more PAs in the performance of the requested advanced duty; AND
  2. The Board previously approved the PA to perform the advanced duty.

The temporary practice letter will allow a PA to practice while the delegation agreement is pending Board approval. The temporary practice letter request must be submitted with the delegation agreement.
A PA and PSP will not qualify for a temporary practice letter if:

  1. The PSP has never been approved by the Board to supervise a PA in the performance of the requested advanced duty; OR
  2. The Board never approved the PA to perform the requested advanced duty.

What is an alternate supervising physician?

An alternate supervising physician (ASP) is a physician designated by a PSP to supervise a PA in accordance with the delegation agreement on file with the Board. As of March 26, 2018, PSPs of PAs do not need to file documentation about ASPs with the Board (in any practice setting). Instead, PSPs must ensure that documentation, with signed confirmation, that each alternate understands and accepts the role as an ASP, is readily available, accessible, and provided to the Board upon request. See COMAR 10.32.03.07A(3)(d).

When may a PA practice under the supervision of an ASP?

PAs may practice under an ASP if the:

  • ASP supervises in accordance with the delegation agreement on file with the Board;
  • ASP supervises no more than four PAs at any one time, except in a hospital, correctional facility, detention center or public health facility;
  • Period of supervision does not exceed the time specified in the delegation agreement;
  • ASP's period of supervision does not exceed 45 days at any one time; and
  • PAs perform only those medical acts that have been delegated under the delegation agreement filed with the Board and are within the scope of practice of the alternate supervising physician.

When should a PA notify the Board that he/she will no longer be working under the supervision of the PSP whose name appears on the approved delegation agreement on file with the Board?

PAs should notify the Board as soon as they know that their PSP will no longer be with the practice by completing and submitting an Online delegation agreement. Once the PSP's last date of supervision is known, the PSP or PA must log into his/her Practitioner Profile and terminate the delegation agreement.

What happens if my license expires?

If your license expires, your delegation agreement (DA) becomes invalid. You must reinstate your license and complete and submit a new Online DA with a Maryland licensed physician to the Board. You may begin working once the Board has received and acknowledged its receipt of the completed Online delegation agreement in writing. The written acknowledgment will be sent to the PA and PSP via email.

What happens if my primary supervising physician's license expires?

If your primary supervising physician's license expires, your delegation agreement (DA) becomes invalid. You must complete and submit a new Online DA with a Maryland licensed physician to the Board. You may begin working once the Board has received and acknowledged its receipt of the completed Online delegation agreement in writing. The written acknowledgment will be sent to the PA and PSP via email.

May a PA practice under an ASP if the PSP is no longer with the practice?

In the event of a sudden departure, incapacity, or death of PSP, a designated ASP may assume the role of the PSP by completing and submitting a new Online delegation agreement to the Board within 15 days.

What are the requirements for prescriptive authority?

Before PSPs delegate prescriptive authority to PAs, the PSP must attest that the PA has:

  1. Passage of the NCCPA Exam within the previous 2 years of submitting the delegation agreement; OR
  2. Provide documentation of successful completion of 8 Category I hours of pharmacology education within the previous 2 years of submitting the delegation agreement; AND
  3. A Bachelor's degree or its equivalent (120 credit hours); OR
  4. Two years of work experience as a physician assistant.

PSPs may delegate the authority to prescribe prescription drugs, controlled dangerous substances and/or medical devices. PAs who have been delegated the authority to prescribe controlled dangerous substances must have a valid:

  1. Maryland Controlled Dangerous Substance (MCDS) license from the Office of Controlled Substances Administration (OCSA); and
  2. Federal Drug Enforcement Agency (DEA) registration.

For more information about Maryland controlled dangerous substance registration, contact the Office of Controlled Substances Administration.
For more information about DEA registration, contact the Drug Enforcement Agency.

What is the Scope of Practice?

Click to view the Regulations.

Is there a scope of practice that a PA may not practice?

A PA may not practice within the scope of practice of any of the following health occupations:

  1. Radiography
  2. Nuclear Medicine Technology
  3. Nursing
  4. Optometry
  5. Physical Therapy
  6. Psychology
  7. Radiation Therapy; or
  8. Psychotherapy

Under certain circumstances, a PA may operate a mini C-arm or similar low-level radiation machine to perform non-fluoroscopic procedures. See Health Occupations Article, §14-306e(3)(iii)B for more information.

What are the reporting requirements?

Hospitals, related institutions, alternative health care systems, or employers are required to report to the Board any termination of employment of the PA for any reason, including quality of care issues, within 10 days of the termination.
Hospitals, related institutions, alternative health care systems, or employers are also required to report to the Board within 10 days any limitation, reductions or other changes of employment that might be grounds for disciplinary action under Health Occupations Article, §15-314.

May a PA take x-rays or inject radiopharmaceuticals?

No. A PA must be a licensed radiographer to take x-rays and a licensed nuclear medicine technologist to inject radiopharmaceuticals. (Maryland Health Occupations Code Annotated, § 14-306e).

May a PA pronounce a patient dead?

There is no statute that specifically prohibits a PA from pronouncing death. However, hospitals may have their own policy on who may pronounce death and under what circumstances. Please check your hospital's policy.

May a PA sign an emergency medical services (EMS) do not resuscitate (DNR) orders form?

Yes, a PA may sign EMS/DNR orders in accordance with Health General Article, §5-601(i).

May a PA sign a "regular" DNR in an inpatient facility or hospital?

A PA may sign a non-emergency DNR based on the patient's treatment preferences if this duty is delegated to the PA by the supervising physician.

May a PA sign a death certificate?

Yes, a PA may sign a death certificate.

May a Maryland licensed physician with a Board-approved delegation agreement with a physician assistant (PA) delegate the ordering of restraints?

The Maryland Physician Assistants Act is silent about whether restraints are authorized to be delegated. The Board, however, does not authorize PAs to order restraints when it is otherwise prohibited by law.

Below the Board has included several citations to statutes and regulations that appear to require physicians to order restraints. Any authorization by the Board for PAs ordering restraints does not override these statutory requirements to the extent that they limit the ordering of restraints to physicians. The following statutes and regulations are not the entirety of statutes and regulations governing ordering restraints.

  • Health-General §§ 10-101(g), 10-701(a)(3), 10-701(c)(3)
  • COMAR 10.21.12.02B(10)
  • COMAR 10.21.12.05
  • Health-General § 19-343(b)(2)(vi)
  • COMAR 10.07.09.14A(3)
  • COMAR 10.07.02.22B(2)(b)
  • COMAR 10.07.14.37D and E
  • COMAR 10.07.22.18G
  • Health-General § 7-1002(b)(4) and (5)
  • 42 C.F.R. 482.13(e)(5)

(Note: Physicians and PAs must have a Board-approved delegation agreement on file with the Board.)

Are supervising physicians required to co-sign medical charts?

No. In place of the co-signature, the supervising physician will be required to describe a process, on the delegation agreement, by which the PA's practice is reviewed appropriate to the practice setting and consistent with current standards of acceptable medical practice.

For existing delegation agreements, supervising physicians may wish to keep a written description by which the physician assistant's practice is reviewed on file at the healthcare facility.

May a physician assistant practice psychotherapy?

A physician assistant (PA) may practice psychotherapy if the PA has the required additional education, training and experience to practice psychotherapy. Performing psychotherapy would be considered an advanced duty and therefore would require documentation of additional education, training and experience. When the Board licensed psychiatrist assistants, the minimum requirements were:

  1. Master's degree from an accredited college or university; AND
  2. Completion of a graduate program accepted by the Board in a behavioral science that included 1, 000 hours of supervised clinical psychotherapy; OR
  3. Bachelor's degree from an accredited college or university; AND
  4. 4,000 hours of supervised clinical experience that is approved by the Board.

A PA should have similar education, training and experience before seeking Board approval to practice psychotherapy.

If a PA does not have the required education, training and experience to practice psychotherapy, what type of treatment may a PA provide for a psychiatric patient?

A PA may provide treatment for a psychiatric patient's physical problems.

Is a Maryland licensed Physician Assistant permitted to order home health services in Maryland?

Yes, however, a Physician Assistant is authorized to perform medical acts customary to the practice of the primary or alternate supervising physician and consistent with the delegation agreement filed with the Board. Statutory provisions regarding the required contents of delegation agreements can be found in §15-302 of the H.O. Article, Annotated Code of Maryland. Title 15 of the H.O. Article and other relevant statutes are located at the Board's website. The COMAR regulations also have similar provisions, please see COMAR 10.32.03.05C(6) Delegation Agreements-Contents.

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