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Physician Assistant Supervision Requirements
  • Compliance

Physician Assistant Supervision Requirements in Arizona

Physicians must be aware of the physician assistant supervision requirements, to ensure they receive the supervision and support they need to deliver quality patient care.

Molly Adrian, JD


The Arizona legislature passed changes to the law governing physician assistant supervision requirements that go into effect on December 31, 2023. This article addresses the law until December 31, 2023. Please look out for an updated article this fall that will help your practice prepare for those statutory changes.

Understanding physician assistant supervisions requirements is important because, for many practices, physician assistants are an essential part of the patient continuum of care. Physicians in Arizona may delegate to licensed physician assistants (“PA”) any medical service that is (1) within the PA’s skills, (2) within the physician’s scope of practice, and (3) supervised by the physician.1

The physician can supervise up to six PAs working at the same time. However, it is crucial to understand that the physician is professionally and legally responsible for a PA’s care rendered under their supervision. Physicians must be aware of the supervisory responsibilities required of them by law, and ensure PAs receive the supervision and support they need to deliver quality patient care.

A Cautionary Tale: What could happen when PA supervision is inadequate?

Internist Dr. Philips opened a solo practice 7 years ago. Within 3 years, she found that her patient roster was full and decided to hire a physician assistant to help handle existing patient needs and take on new patients. Dr. Philips hired Mr. Stein, a PA with a few years of emergency room experience. Neither Dr. Philips nor Mr. Stein were aware that they were required to enter into a formal delegation agreement, and Dr. Philips only gave vague verbal direction that Mr. Stein was to see patients for routine matters and complaints. He was to consult Dr. Philips when he needed help with more complex matters.

Several months into working at the practice, 22-year-old Marissa arrived for an appointment with Mr. Stein for recent abdominal pain and spotting between periods. Mr. Stein went over her history and past medical records, and noted that she saw Dr. Phillips 6 months prior for an annual physical during which she had a full workup, including a normal pap test, and was in good health. At her visit with Mr. Stein, she mentioned she was dealing with family and work stress, so Mr. Stein advised her to work on reducing her stress through diet and exercise. She was to monitor her symptoms and come back if they did not improve or got worse. Physician Assistant with Patient

Marissa returned 3 months later complaining of worsening symptoms, but Mr. Stein still chalked it up to stress and referred her to a psychologist. Despite working in the same office and talking throughout the week, Mr. Stein did not seek Dr. Philips’ input. After seeing the psychologist weekly and making other changes to reduce her stress, Marissa returned after another 3 months with worsening symptoms. Mr. Stein offered a pap test at this visit, which revealed abnormal cervical cells. After additional testing, Marissa was diagnosed with terminal cervical cancer.

Marissa and her husband sued Mr. Stein for negligent diagnosis and treatment. They also sued Dr. Philips for vicarious liability and for negligent hiring, training, and supervision. Both parties quickly settled the case. Dr. Philips also faced a medical board investigation and likely licensure action.

How to Properly Supervise Physician Assistants In Your Practice

Dr. Philips and Mr. Stein’s supervisory arrangement fell short of what is required by law and dictated by best practice. The following guidelines will help you avoid their mistakes.

Initial Competency Review

The supervising physician should undertake a comprehensive evaluation of the PA’s competencies before delegating medical tasks. In the PA’s employment file, keep copies of their:

  • transcripts

  • resume detailing medical work history

  • detailed accounting of the PA’s proficiencies along with areas in which the PA needs additional training
  • any documentation of specialized training

  • documentation of continuing education courses

The Delegation Agreement

By law, physicians and PAs must enter into a delegation agreement prior to the PA beginning clinical work under the physician’s supervision.A sample delegation agreement is available on the Arizona Regulatory Board of Physician Assistants’ website here.

  • At a minimum, the delegation agreement must:

    • Include a statement that the physician will exercise supervision over the physician assistant and retain professional and legal responsibility for the care rendered by the PA.

    • Be updated annually.

    • Be signed by the supervising physician and the physician assistant.

    • Be kept on file at the physician assistant’s practice site.

    • Be available to the Arizona Regulatory Board of Physician Assistants on request.

      Scope of Work of Physician Assistant
  • The physician-physician assistant team is also required by law to do the following.3 The delegation agreement is a good place to memorialize that they have:

    • Defined the PA’s scope of practice.

    • Defined the supervisory relationship between the physician and PA.

    • Discussed the PA’s access to the supervising physician and the communication expectations between the PA and supervising physician.

      • If the supervising physician and physician assistant do not routinely practice at the same physical location, they must meet by telecommunication or in person at least once each week to ensure ongoing oversight of the PA’s work.4

    • Determined appropriate delegation of medical tasks according to the PA’s competency.

    • Established a process to review the PA’s performance. Consider:

      • Evaluating the PA’s competencies annually and documenting this review in the PA’s employment file.

      • Adjusting the PA’s scope of practice and delegated tasks in the written delegation agreement as appropriate.

      • Reviewing the delegation agreement together on an annual basis before both parties sign.

Other requirements

  • The PA must wear a name badge identifying them as a physician assistant.5

  • The supervising physician must maintain a system for recording and reviewing all instances in which the PA prescribes schedule II or schedule III controlled substances.6

  • The supervising physician must report in writing to the Arizona Regulatory Board of Physician Assistants and to the physician assistant if the PA exceeds the scope of delegated medical tasks.7

The Takeaway

It is possible that Dr. Philips would have recognized a need for earlier intervention had she been a more involved supervisor. Even if Marissa’s outcome would not have changed, though, Dr. Philips would undoubtedly fare better during a lawsuit and medical board investigation with documentation showing that she had a robust process to ensure her PA was competent in the tasks he was delegated, and that she complied with those things legally required of her when supervising a PA. A perceived lack of oversight and disregard for legal requirements would only inflame a jury and/or the medical board, while evidence of an appropriate supervisory relationship may be a mitigating factor in any legal or licensure action.


MICA’s Risk Management Consultants are ready to respond to your questions and provide more information. You can reach a Consultant Monday – Friday 8:30am – 5pm MST at 800-352-0402 x 2137, 602-808-2137, or

[1] A.R.S. § 32-2531(D)
[2] A.R.S. § 32-2531(H)(4)
[3] A.R.S. § 32-2533
[4] A.R.S. § 32-2531(J)
[5] A.R.S. § 32-2531(K)
[6] A.R.S. § 32-2533(D)
[7] A.R.S. § 32-2531(H)(3)

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