May 22, 2014

The Honorable Governor Jay H. Nixon
Post Office Box 720
Jefferson City, MO 65102

Subject:  Senate Bill 716

PAs for Tomorrow (PAFT), a special interest group of the American Academy of PAs (AAPA), urges you to veto Senate Bill 716 establishing a new class of healthcare provider, an assistant physician. PAFT represents the national interests of our PA members. We believe that enactment of this law with provisions “authorizing the Board of Healing Arts to license physicians, unable to find a residency match, as assistant physicians, practicing within the confines of a collaboration agreement with a physician, and restricted to providing primary care services in rural and underserved areas”. Further, the language within SB 716 contains a provision that states “An assistant physician shall be considered a physician assistant for purposes of regulations of the Centers for Medicare and Medicaid Services (CMS).” Signing this into law would be a mistake.

We believe that these provisions violate both federal and state laws and regulations.
The Centers for Medicare Services states under US Department of Health and Human Services rules “A PA must be licensed by the State to practice as a PA and either:

-Have graduated from a PA educational program accredited by the Accreditation Review Commission on Education for the Physician Assistant (its predecessor agencies, the Commission on Accreditation of Allied Health Education Programs, and the Committee on Allied Health Education and Accreditation); or

-Have passed the national certification examination administered by the National Commission on Certification of Physician Assistants.”

A collaborating physician or assistant physician requesting CMS reimbursement for PA fees may constitute Medicare fraud and also potentially defames the reputation of the entire PA profession. Your own state statutes (Chapter 334, Section 334.775, section 6) defines a “PA as a person who has graduated from a physician assistant program accredited by the American Medical Association's Committee on Allied Health Education and Accreditation or by its successor agency, who has passed the certifying examination administered by the National Commission on Certification of Physician Assistants (NCCPA) and has active certification by the NCCPA who provides health care services delegated by a licensed physician. A person who has been employed as a physician assistant for three years prior to August 28, 1989, who has passed the NCCPA examination, and has active certification of the NCCPA.”

The NCCPA qualification rules are clear as to who may sit for the national certification and recertification examinations, these individuals masquerading as PAs with the protection of this law, are not eligible to sit for our examination. The Frequently Asked Questions section of the official NCCPA Web site, states that graduates of medical schools cannot be certified unless they graduate from an accredited PA program. The Web site also states, “NCCPA will not waive any eligibility requirements.”

Ethically, use of the untrained providers is misleading to patients. As graduates of medical schools, they are entitled to introduce themselves to patients as “doctor,” thereby implying full qualifications as a practicing physician. This law does not require full disclosure of their legal status, which neither fits that of physician nor that of a PA.

Our board is comprised of many veterans with over a half century of experience caring for our troops and their dependents as PA medical care providers. We believe implementation of this law will diminish the quality of medical care you seek to provide to the citizens of your great state; therefore, we urge you to veto Senate Bill 716.


David Mittman, PA, DFAAPA

PAs for Tomorrow is a  professional organization for all PAs of all specialties.  It represents the future interests of all PAs, providing a vocal core group of PAs committed to seeing the PA profession reach its deserved place among America's health care providers and advocating for their role as providers of high-quality, cost-effective, comprehensive and patient-centered health care. 

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