Practice Resources

Resources You Need for Collaborative Agreements with Physician Assistants

Important changes have occurred to the scope of practice for physician assistants (PA). After two years of fiercely fought and failed legislative attempts, SB23-83 passed the legislature and was signed into law by Governor Polis earlier this spring. COS in collaboration with CMS secured important amendments to the bill. The new law changes how PAs practice. Instead of practicing medicine under the direct supervision of a physician, a physician assistant must now enter a “collaborative agreement” with a physician.

In addition, the legislature included the requirement for a “collaborative agreement that is a supervisory agreement” in the following circumstances:

• All PAs practicing in Level I & II trauma designated emergency departments.
• New PAs for their first 5,000 hours regardless of practice area (specialty).
• PAs changing practice area (specialty) must complete an additional 3,000 hours in that new practice area.

The Colorado Board of Medicine (CMB) recently finalized regulations to operationalize the law (changing what was Rule 400 to the new Rule 1.15 [starting on page 21]). If you work with PAs, then COS encourages you to review COPIC’s excellent analysis that explains exactly how the new agreements work. COS also encourages you to utilize the collaborative practice agreement template and the performance evaluation form template that COPIC developed and is supported by both COS and CMS.

PA’s Operating a Fluoroscope

PA’s Operating a FluoroscopeA question was asked of COS about a new requirement by some facilities that PAs hold an additional registration before they may operate a fluoroscope within such facility. We have researched the issue and want to provide you with the answer to this question as it likely impacts your practice.

Approximately three years ago the Colorado Department of Public Health and Environment adopted new regulations which determined that the utilization of a fluoroscope does not fall within the scope of practice of a PA therefore is a PA (and NPs) must obtain the additional registration. 

When asked about the delayed implementation by facilities, we were told that CDPHE had offered a grace period to facilities to come into compliance. That grace period has expired, and all facilities will now require this registration. A facility’s failure to ensure PAs have appropriate registration will result in monetary penalties, more frequent inspections (at the facility’s cost) and ultimately the facility’s license.

COS also asked if there was a grandfather clause for those PAs that have been operating fluoroscopes as part of their practice. There was a short time frame during which a PA could have their credentials reviewed and be granted the registration without going through the registration process. That window closed quite some time ago (2021). 

In short, PAs must now obtain registration as a Fluoroscopy Operator.

Here is the process:

• Complete an application: https://fs20.formsite.com/HMWMD/fluoroscopy/index
• Must have completed a course that includes at least 40 hours of in-person or online education on topics that include radiation physics, radiation biology, radiation safety and radiation management applicable to fluoroscopy. Such hours must be completed in a structured and documented training program that meets the requirements of American Registry of Radiologic Technologists. (ARRT)
• Must have completed 40 hours of clinical experience in the use of fluoroscopy for guidance in diagnostic and therapeutic procedures under the personal supervision of a Colorado licensed physician.
• Submit a non-refundable check for $60 made out to CDPHE, or payment can be made online once the form has been submitted.
• Instructions for further details are included in the form.
• If accepted, this will allow the PA to take the American Registry of Radiologic Technologists fluoroscopy operator exam. (Additional testing fees apply.)
• The applicant must receive a score of 75% or greater on the ARRT fluoroscopy examination. If the applicant fails to achieve at 75% or greater within three attempts, that applicant must start the 40 educational and 40 supervised hours over again.
• Upon approval, CDPHE will send the PA a letter with payment and testing instructions.
• If the PAs are using a fluoroscopy operator registration from another state, or need to retake the registration/certification exam, complete and resubmit the R-50 form.
• Current fluoroscopy operators are required to renew their registration every 2 years by submitting the R-52 application for renewal form along with the $60 application fee and evidence of current state licensure.

A fluoroscopy operator registration is valid for a two-year period.

To renew the fluoroscopy operator registration your PA must submit the R-52 application with the $60 application fee and evidence of current state licensure and national PA certification. Should the PA let their registration lapse, they are required to begin the original process over again.

The complete regulation can be found here. (6 CCR 1007-1 Part 02 Section 2.4.5.5)

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