Understanding the Role of Physician Assistants in the RFA Process
In California's workers' compensation system, the question of who can submit a Request for Authorization (RFA) and participate in peer-to-peer reviews has significant implications for claims management and treatment authorization. Today, we're clarifying the role of physician assistants (PAs) in this process.
Can Physician Assistants Submit Valid RFAs?
The short answer is yes, but with important qualifications.
Under [LC § 3209.10], physician assistants can provide medical treatment for industrial injuries when they are:
- Licensed by the state
- Acting under the review or supervision of a physician and surgeon
- Working within standardized procedures or protocols
- Operating within their lawfully authorized scope of practice
However, there's a critical distinction: while the PA may examine the patient and complete the RFA paperwork, the supervising physician is deemed to be the treating physician, not the PA. This means the supervising physician bears the ultimate responsibility for the treatment request.
RFA Signature Requirements: What's Acceptable?
The regulations specify that an RFA form must be "completed by a treating physician." Since PAs are not recognized as physicians under [LC § 3209.3], this raises questions about signature requirements.
Case law provides some flexibility here. The appeals board has rejected arguments that an RFA was invalid because it was signed by another physician in the same office rather than the primary treating physician. This suggests that an RFA completed by a PA but signed or authorized by the supervising physician would likely be considered valid.
Peer-to-Peer Reviews: Who Should Participate?
When it comes to peer-to-peer discussions for modified or denied treatment requests, the guidelines are clear:
- Decisions to modify or deny treatment must be made by a licensed physician who is competent to evaluate the clinical issues involved
- The physician reviewer must be appropriately licensed (MD, DO, psychologist, etc.)
- Since the supervising physician is legally the treating physician when a PA provides treatment, peer-to-peer reviews should be conducted with the supervising physician, not the PA
Best Practices for Claims Professionals
To ensure smooth processing of RFAs involving physician assistants:
- Verify supervision: Confirm that the PA is working under proper physician supervision
- Check signatures: Ensure the RFA has appropriate physician authorization or signature
- Direct peer-to-peer requests: Schedule peer-to-peer discussions with the supervising physician
- Document properly: Note in the file when treatment is provided by a PA under physician supervision
Key Takeaway
A request for authorization initiated by a physician assistant is valid when properly supervised by a physician, but peer-to-peer reviews should be conducted with the supervising physician, not the PA. Understanding these distinctions helps ensure proper claims handling and compliance with California workers' compensation regulations.
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This blog post is based on current interpretations of California workers' compensation law and regulations. For specific case guidance, please consult with your legal department.