As the Interim Program Director of the Shenandoah University Physician Assistant (PA) Program, I strongly support the petition to remove the requirement that a patient care team physician review the clinical course and treatment plan when a patient presents for the same acute complaint twice in a single episode of care.

This regulation imposes an unnecessary administrative burden without clear benefits to patient safety or clinical outcomes. PAs are highly trained, licensed medical professionals who practice within a defined scope of practice and in collaboration with physicians. They are fully capable of evaluating and managing patients who return with the same acute complaint, using their medical expertise to adjust treatment plans as needed. Mandating a physician review in these cases undermines the trust in PA clinical decision-making and contributes to inefficiencies in patient care.

Removing this requirement would improve workflow, reduce unnecessary delays, and allow PAs to practice more effectively within their scope while maintaining high standards of patient care. I urge the Virginia Board of Medicine to approve this petition and modernize regulations to reflect the essential role of PAs in Virginia’s healthcare system.

Sincerely,

Erika Francis, DMS, PA-C

Interim Program Director

Shenandoah University PA Program

In specialty practices, emergency departments, and hospitals, patients are often seen for in subsequent visits for the same chief complaint. This rule only increases the burdens on physicians. Removing it would expand access and lessen the physician workload.

Please help up remove the language that an MD review clinical course and treatment for patients that present for acute complaint twice in a single episode of care.  This adds to burden for providers, especially physicians and no proven benefit to patients.  I work psychiatry and often need to try multiple medications before finding the one that works best.  How is contacting a physician who is often not on site and not familiar with my patient and interrupting the MD's patient care helpful? We all benefit from team approach in medical care and PAs are trained to ask for help and involve the MD when needed. Please trust us to do this and help prevent provider burnout by removing antiquated rules that just don't make any sense when thoughtfully considered. Thank you for your consideration.

Please remove this antiquated language - it unnecessarily increases everyone's workload without improving patient care.  

As a practicing PA and PA Medicine program director, I strongly support the petition to remove the requirement that a patient care team physician must review the clinical course and treatment plan when a patient presents twice for the same acute complaint in a single episode of care.

This requirement creates unnecessary administrative burdens without improving patient outcomes. PAs are highly trained, licensed professionals who evaluate, diagnose, and manage acute complaints within their scope of practice. Requiring a physician to review every repeated acute visit does not add clinical value but instead introduces delays, increases workload inefficiencies, and disrupts the continuity of care.

Patients often return for follow-up due to the natural progression of illness or to assess treatment effectiveness. PAs are fully capable of managing these cases and determining when physician consultation is necessary based on clinical judgment—not outdated regulatory mandates. Many states have already recognized the autonomy of PAs in similar situations, streamlining care without compromising safety.

Updating this regulation would allow PAs to focus more on patient care and less on redundant administrative requirements. It would improve workflow efficiency, reduce delays in treatment, and ultimately enhance the patient experience. I encourage the regulatory board to support this petition and help modernize healthcare delivery in Virginia.

I support the proposed regulatory change to language regarding physician/PA appropriate consultation rather than required review after the same complaint twice.

PAs provide professional, team-based medical care. When a consultation or referral is needed, it will be sought, if the patient is there for the first, second or third visit. As a team member, the PA will assess the patient and provide the best care, including consultation as needed. The second visit rule is too restrictive.

There are many patients that may require an expected second, or subsequent, visit with the same complaint. I work in pediatrics. I do not often prescribe medication for the initial visit runny nose and cough and recommend follow up-for the ‘same acute complaint’ if there is not improvement. Then the patient returns with the same complaint in three weeks. Do I need to have this case reviewed by a physician when seeing this patient? Right now, by regulation, I do. Is this a waste of time and resources for the physician? Absolutely! Does this patient truly need to be seen by a physician? Not likely, but if I thought they did, I would for best patient care.

PAs will make the best use of time for their time, the physician and the patient.

Physician Assistants practice collaboratively with physicians just as physicians practice collaboratively with other physicians, meaning, the care team which consists of physicians, PAs, NPs, and other providers are all trained to seek assistance whenever needed.  Access is a major issue for patients everywhere, including the commonwealth.  Language like this creates additional access issues that patients should not be subject to.  We should be doing everything we can to increase access and not place requirements like this in the way of providing care.  There is absolutely no data to suggest this provides any safer care, in fact, there are many studies that show PAs provide care that is at least equal to the quality of care that is provided by our physician colleagues.  

Support proposed change to patient care team review requirements

Good morning,

Please remove requirement/legislation that requires physicians on the care team to review patient/chart after 2 visits.   It is not helpful and does not improve patient care.  Patient care teams coordinated consistently after one , two or five visits.  Regulations like this become simply "sign offs" and check a box for rules and regulations.  Let the providers treat the patient not treat the chart.

Even with my 26 years of experience, my teams coordinate care on multiple fronts and multiple times.   Help us to clean up the regulations to allow for our time to be spent with the patient. 

Thank you

Mark Ford

PAs receive rigorous training, and having this language in the law unnecessarily restricts patient access to care. The practice of medicine is a collaborative effort, and PAs know when to seek input, much like other healthcare providers do when consulting one another. I fully support eliminating the requirement for a physician to review the clinical course and treatment plan when a patient presents with the same acute complaint twice within a single episode of care. 

Good evening,

As an experienced PA, I ask that you remove the language requiring MD evaluation after repeated complaints and no improvement. We already collaborate and utilize colleagues to consult on our patients and having such wording creates unneeded hardship for patient care.

I am writing to support this legislation to improve the patient care process by removing unnecessary and burdensome regulations for Physician assistant practice. PA's have proven more than competent to manage their patient's care plan under such circumstances as this regulation addresses. When patient's access to care increases by streamlining processes and removing unnecessary burdens, all the people of Virginia benefit.  

As a practicing PA in the acute care setting (ICU), this regulation is both unnecessary and will delay patient care. PAs are highly trained and skilled individuals who work collaboratively with physicians to provide comprehensive care to patients. They are qualified to assess, diagnose, treat, and manage a wide variety of medical conditions within the scope of their practice. The current requirement for physician oversight and signature on every treatment plan places unnecessary administrative burdens on both the physician and the PA, reducing the efficiency of care delivery and delaying timely treatment for patients. In my own practice caring for the sickest patients in the hospital, delivery of safe and effective patient care can be a matter of life and death. Amending this requirement will not only streamline workflows but will also empower PAs to practice to the full extent of their training, allowing them to make more immediate decisions that are in the best interest of patients while prioritizing patient safety.

I support removing this practice regulation.  As PAs, we collaborate and utilize colleagues to offer our patients optimal care and having such wording creates unneeded hardship for patients.  As a surgical PA, I am often much more readily available to manage postoperative concerns immediately and having such wording limits access to timely care.  

I support removing this requirement, and reducing barriers to care and improving collaboration between PAs and physicians without increased logistic barriers 

This is another barrier to care, PAs are skilled and knowlegeable providers and this slows down access to care.

I support these proposed regulatory changes because they reflect the modern realities of PA practice and foster a more efficient, team-based approach to care. Removing outdated supervisory language aligns with current standards in many other states and empowers PAs to practice at the top of their license.

A patient who presents the second time deserves a physician to ensure nothing was missed and give a second opinion. Just the same as often for a second visit, even a primary care physicians might want a second opinion from a consultant. Patient care isn’t about the ego of the provider- it is about giving the best patient care. 

I support this change

I support this language to remove restrictions on physician review 

I support this  language to remove restrictions on physician review.  It limits access to care and places unnecessary burdens on the healthcare team.