A physician assistant's practice depends on three things being in order at the same time: a license in each state where patients are seen, the supervision or collaboration arrangement that state requires, and payer enrollment that lets the PA, or the practice, bill for the work. Doctor Rebrand keeps all three aligned. We prepare state license applications and PA Compact privileges, draft and maintain supervision and collaboration agreements from attorney-drafted templates, register PAs with DEA and the state for prescribing, credential each PA with payers, and bill PA services under Medicare's direct billing, incident-to and assignment rules.
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Supervision and Collaboration Rules by State
Each state sets the working relationship a physician assistant must have with physicians. Some states require a written supervision agreement, some require a collaborative agreement, and some leave the relationship to be defined at the practice level. The details vary too: who can serve as the supervising or collaborating physician, what has to be in writing, what has to be filed with the board, and what changes when the physician leaves.
Medicare follows the state. CMS covers PA services only when they are furnished under the state's law and scope of practice rules for PAs, and it treats any state requirement for supervision or collaboration as the supervision Medicare requires. In a state with no explicit rule, Medicare expects the practice to document the PA's scope of practice and the PA's working relationships with the supervising physicians. Under the Medicare benefit itself, PA services are furnished under the general supervision of an MD or DO.
We confirm your state's current rule with the board, prepare the agreement from our attorney-drafted templates, file it where the board requires filing, and update it when a physician joins or leaves. Doctor Rebrand is not a law firm; questions about your own arrangement are handled alongside your attorney.
- Supervision and collaborative agreements drafted for your state and practice.
- Board filings and notices when a supervising or collaborating physician changes.
- Practice-level documentation of scope and working relationships where the state has no explicit rule.
PA Licenses and the PA Licensure Compact
Physician assistants are licensed by each state, and a PA who sees patients in more than one state needs authority in each. The PA Licensure Compact is the newer route. It does not issue a separate license: it lets member states recognize a valid, unencumbered license from another member state through a compact privilege to practice. The compact's current status is shown below.
A compact privilege does not change what you may do in the remote state. You follow the scope of practice of each state where you hold a privilege, meet any supervision or collaboration requirement there before you practice, and follow the rules of the state where the patient is located at the time of care. Each member state needs its own privilege, and a state may require a jurisprudence exam.
Where the compact does not reach a state you need, we file a traditional application with that state's board: education, NCCPA certification and prior licenses verified, fingerprints coordinated, and follow-up until the license is issued.
- Current NCCPA certification and the continuing medical education required by the state of your qualifying license.
- A separate compact privilege, and any jurisprudence exam, for each member state.
- Every license, privilege and renewal tracked in one place.
PA Licensure Compact
Not Yet IssuingPhysician assistants (PAs)
The compact will let a PA licensed in a member state obtain a privilege to practice in each other member state. No state is issuing privileges yet; the commission projects that it will begin granting them in early 2027, depending on its data system. About 30 states have joined.
Official Compact SiteCompact status current as of October 27, 2026.
Prescribing, DEA and State Registrations
DEA registers physician assistants as mid-level practitioners when the state where they practice authorizes them to dispense controlled substances, and it requires every one of that state's licensing requirements to be met first. A PA who prescribes in more than one state needs a separate DEA registration in each. The PA Compact does not change this: for each remote state, a PA must meet that state's requirements for controlled substance authority.
State prescribing rules for PAs differ, and in some states the supervision or collaboration agreement itself defines what a PA may prescribe. We read your agreement and your state's rules together, file any state controlled substance registration, and then file the DEA registration. Telemedicine prescribing of controlled substances follows separate federal rules, shown below.
Credentialing Physician Assistants
To bill Medicare, a PA must enroll. To furnish covered services, a PA must have graduated from a PA program accredited by the Accreditation Review Commission on Education for the Physician Assistant or passed the NCCPA national certification exam, and be licensed by the state. Since January 1, 2022, each PA must also have an individual NPI for Medicare billing.
Commercial payers and Medicare Advantage plans credential PAs on their own terms, and some ask for the supervising or collaborating physician's details as part of the file. We keep that information current with every payer, so a change in physicians does not leave a PA out of network.
For practices that employ PAs, each PA is enrolled individually and then linked to the group, so claims for the PA's services are paid to the practice.
- Medicare, Medicaid, Medicare Advantage and commercial enrollment.
- CAQH profile completed and re-attested on schedule.
- Each PA linked to the group with every payer.
- Hospital and surgery center privileges, including for PAs who first assist.
Medicare Payment, Direct Billing and Incident-To
Medicare pays for PA services at 80 percent of the lesser of the actual charge or 85 percent of what a physician is paid under the Medicare Physician Fee Schedule, and claims must be submitted on assignment. When a PA assists at surgery, the assistant-at-surgery rate applies, which works out to 13.6 percent of the physician's surgical payment, with the AS modifier on the claim.
Since January 1, 2022, Medicare can pay PAs directly. Before then, payment for PA services went only to the PA's employer or to the entity the PA contracted with. A PA can now bill under their own enrollment or reassign payment to the practice, and we set up whichever arrangement you choose.
Incident-to billing lets a PA's service be billed under a physician at the full rate, but only when every requirement is met: the physician personally started the course of treatment, stays actively involved in managing it, and provides direct supervision, or general supervision for behavioral health services. New patients and new problems do not qualify. Our billers apply those rules claim by claim and bill under the PA's own NPI whenever incident-to does not fit.
- Claims billed at the PA rate under the PA's NPI, or incident-to only when the rules are met.
- Assistant-at-surgery claims billed with the AS modifier.
- Global surgical periods and split or shared visits coded to Medicare's rules.
- Commercial payer PA policies applied, since they can differ from Medicare's.
| Billing Path | Who Is Paid | Medicare Rate |
|---|---|---|
| PA bills under own enrollment | The PA, directly (since January 1, 2022) | 80% of the lesser of the charge or 85% of the physician fee schedule |
| PA reassigns payment to the practice | The employing or contracting practice | Same PA rate, billed under the PA's NPI |
| Incident-to a physician | The physician or practice, under the physician's NPI | The physician fee schedule rate, only when every incident-to requirement is met |
| Assistant at surgery | The PA or the practice, with the AS modifier | 13.6% of the physician's surgical payment amount |
HIPAA Compliance for PA Practices
Every practice that bills electronically is a covered entity under HIPAA and needs a documented program: a security risk analysis, a designated security official, written policies, workforce training and business associate agreements. PAs are part of the workforce the program covers, from training at hire to access controls in the EHR.
We run the risk analysis, write the policies, train your staff, collect BAAs and repeat the cycle every year. Where PAs see patients in more than one state, we also track each state's telehealth and prescribing rules.
- Security risk analysis repeated every year and whenever systems or locations change.
- Role-based EHR access set up for each new PA, and removed the day someone leaves.
- HIPAA training at hire and every year, with completion records.
- Website forms, analytics and ad pixels reviewed so patient information never reaches an ad platform.
For Practices That Employ PAs
Adding a PA is a sequence: confirm the state license, draft the supervision or collaboration agreement, file the DEA and state registrations, enroll the PA with each payer and link them to the group, and only then schedule insured patients. Starting credentialing early matters most, because it usually takes longest.
We run that onboarding for every new PA, track each license, agreement, registration and enrollment date, and alert you well before anything lapses. When a supervising physician leaves, we update the agreement, the board filings and the payer records together. When the PA leaves, we end the group linkage with each payer and close out the agreement, so no claim goes out under a provider who is no longer with you.
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