Administrative Practice Issue References
Important to Your Practice

NEWLY UPDATED!!!

Joseph Streff, PA-C
Webmaster, 1995-present

————————————————————————
READY REFERENCE FOR THE VA PHYSICIAN ASSISTANT

A CANADIAN VIEW OF THE PHYSICIAN ASSISTANT

http://www.nationalreviewofmedicine.com/issue/2007/12_15/4_patients_practice05_20.html

GRANDFATHERED PAs:
by Denni Woodmansee, PA Advisor to the USH

With the assistance of the VISN CMOs, I finally have accurate data on VHA non-certified "grandfathered" PAs.

There are currently 62 non-NCCPA certified PAs in the system.

15 have indicated that they will retire prior to 1/1/2010.

14 have indicated that they will participate in the Grandfathered PAs Assistance Program and attempt to regain NCCPA Certification. This program will fund non-certified VA PAs to attend a comprehensive certification review course

33 have not responded. Webmaster's note: if you are one of the 33, why didn't you respond to Mr. Woodmansee?

I would like present some demographic info. You may find the following information helpful. The trend clearly shows that the PA profession is shifting with a majority of PAs in general being women and the VA rapidly heading in that direction. - DW

As of November 30, 2007:

1672 PAs were employed by VHA. 55% male, 45% female. AAPA 2007 census shows 64% of all current PAs are female.

Of all PAs hired in the last 5 years, 21% were veterans, 79% were non-vets. Of all current, VHA PAs, 36% are veterans.

43% of all VHA PAs hold Bachelor's degrees, 40% with Master's Degrees, 5 PhDs, actually 24 PAs with nursing degrees.

3,504 NPs are employed by VHA. 10% male, 90% female. 15% of all NPs are veterans

Source: VA PAID Data File

I have received the FY 2007 2nd QTR stats for VHA PAs and NPs. These numbers DO NOT include NP positions in VACO. It also does not include NP/PAs under contract of fee basis. If the VA is hiring to prepare for the multiple new initiatives, it isn't PAs or NPs. -dw

April 11, 2007

Draft 2008 GS Pay Scales:

The draft of the 2008 Pay Scales has been posted on the OPM Website. Here is the link:

http://www.opm.gov/oca/08tables/indexGS.asp

VA Pay information can be found at: http://vaww.appc1.va.gov/ohrm/PAY/PAYRATE1.htm

(1) Receipt by an employee, or for group authorizations, a significant number of employees, of one or more bona fide offers of employment, as evidenced by a formal written job offer or affidavit signed by the employee or employees providing the position and salary being offered, the name and location of the organization, and the prospective date of employment; or

(2) Evidence of high demand in the private sector for the knowledge and skills possessed by the employee or group of employees and significant pay disparities between Federal and non-Federal salaries; or

(3) A discussion with the employee of the employee’s career plans.

This Directive was just released. I have posted sections that may pertain to Physician Assistants.
<<VHA Directive 2007-015 Inter-Facility Transfer Policy.DOC>>

(4) No patient is transferred to the VA facility or from the VA facility to a non-VA facility, without the prior approval by an appropriately-credentialed, privileged, and responsible VA staff physician, or designee.

(a) No patient may be transferred from a VA facility to a non-VA facility without the prior approval from an accepting physician, or designee, at the receiving non-VA facility.

(b) The accepting physician, or designee, must speak directly with the referring physician, or designee, regarding the care of the patient. NOTE: A nurse to nurse contact is essential. These verbal communications need to allow for questions and answers from both transferring and receiving facilities. This is irrespective of whether the transferring facility is VA or non-VA.

) An assigned designee, involved in any decisions or actions related to transfers, is a credentialed provider.

(a) The designee cannot be an individual who is at the VA as a post graduate trainee (intern, resident, or fellow). If the designee is not a physician, the designee must be a qualified medical person as determined by the facility’s by-laws or rules and regulations.

(b) Transfer-related decisions by a non-physician designee may be made only after a physician is consulted and agrees with the action. Signatures of any transfer-related documentation by the non-physician designee must subsequently be counter signed by the physician consulted.

(6) Only the Emergency Department or Urgent Care Unit physician, or designee on duty and in charge, accepts patients for evaluation in the Emergency Department or Urgent Care Unit. NOTE: Responsibility for accepting direct admissions to inpatient units is determined by local policy.

VHA Directives Links: (Posted 20 May 2007) Special Awards

Some confusion exists about the difference between Special Awards for Achievement versus those for Performance. Here are the latest copies of the regs for you to download and keep in your files:

Physician_Assistant_Criteria_for_Special_Advancement_for_Performance.doc (30k)

Physician_Assistant_Criteria_of_Special_Advancement_for_Achievment.doc (33k)

Special Advancements (Originally Posted 25 Feb 2007)
Q. What are the rules on Special Advancements?
A: VA Handbook 5017, Part V authorizes Special Advancement for Performance and Special Advancement for Achievement. These provisions may be used to recognize a PA who exhibits superior performance or sustains professional achievements. Requests for SAPs and SAAs must be submitted to the PA Professional Standards Board for review and approved by the Director. Step increases awarded under SAP and SAA do not take the place of the regular periodic step increase and does not reset the waiting period for the next step increase. They also do not effect eligibility for grade promotion. One could receive a step increase for SAP, a regular periodic within grade step increase, followed by a grade promotion in the same year. SAP are limited to one occurrence in 52 weeks. Step increases may not exceed the maximum step in the grade.

Special Advancement for Performance (SAP) - Allows for a one step increase.Criteria
d. Physician Assistants. The employee must have demonstrated a sustained high level of performance and ability over and above that normally expected of employees in the particular grade and profession or there must have been noted contributions in some aspect of health care. Criteria for one-step advancement will be demonstrated superior performance as evidenced by:

(1) Assumption of a major responsibility in administering a major patient care program.

(2) Significant accomplishments associated with an academic program conducted in affiliation with the facility where the physician assistant is employed.

Special Advancement for Achievement (SAA) - Allows for one to five step increase. The number of steps awarded will depend on the level of achievement. The average award is a 2-3 step increase. A 5 step increase is extremely rare and usually involves significant achievements that are national in scope. Note: Those holding faculty appointments with a university based PA training program may be eligible for a SAA.

d. Physician Assistants. Full-time, part-time and intermittent physician assistants may be advanced within the grade from one to five steps on the basis of professional achievement above that expected for the grade level or assignment provided they have demonstrated excellence in performance and potential for assumption of greater responsibility. Examples of such achievements include, but are not limited to:

(1) A graduate level degree in a field related to the Department’s health care mission;

(2) Appointment to a university faculty position;

(3) Significant contributions to the Department’s health care mission. Such accomplishments may result from leadership or exceptional efforts on facility, regional or national task forces or committees, or by serving as a consultant on matters relating to education research, health care management, or quality of care issues;

(4) Recognition of outstanding and exceptional achievement by a professional or academic organization;

Election to office in a professional organization at the State or national level
Independently producing or serving as a principal assistant or major contributing member on research producing publishable results that advance patient care or medical science; or

(7) Attainment of specialty certification within the occupation. This does not include certification as a physician assistant by the National Commission on Certification of Physician’s Assistants, which is a condition of employment as a physician assistant in VHA.

----- -----

All the MP-5s were converted to Handbooks. I have found the links listed below to be very helpful. That last one on the list includes any updates or changes.

http://www1.va.gov/vapubs/

http://www1.va.gov/vhapublications/

http://vaww.appc1.va.gov/ohrm/Directives-Handbooks/Direct_Hand.htm

VHA Directives Links: (Posted 13 May 2007)

As discussed at the VAPAA Conference, the link to most of the relevant VHA Directives effecting PAs is provided below. This site incorporates changes to the directives as they occur so this reference is the most up to date. (These are VA Intranet links and not available from outside the VA realm.)

http://vaww.appc1.va.gov/ohrm/Directives-Handbooks/Direct_Hand.htm

Also included is a index of VA Handbooks 5001 - 5027 (HRMS Directives) that enables you to more easily find which handbook addresses a particular topic.

http://vaww.appc1.va.gov/ohrm/Directives-Handbooks/Documents/TerryKguide.doc

Denni J. Woodmansee, PA-C
PA Advisor to the Under Secretary for Health
Department of Veterans Affairs
(774) 826-2035

AAPA Reimbursement Policy Template Available (posted 01May2007)

The AAPA’s Reimbursement Policy Staff developed a template of reimbursement policy information to add to your organization’s website. The link below will take you to information on Medicare, Private Payer, Medicaid, and Workers’ Compensation reimbursement policy that will help your members answer their reimbursement questions and will direct them to the AAPA’s reimbursement policy staff members to solve more difficult reimbursement problems.

http://www.aapa.org/cor/WebResources.htm

The web page can also be located by going through the Constituent Organization Services section of our website at: http://www.aapa.org/cor/index.html

We encourage you to review this information and add it to your organization’s website. If you have additional questions about reimbursement policy, or need assistance customizing the Medicaid and Workers’ Compensation sections for your state, please contact Gwen Gordon (ggordon@aapa.org) in the AAPA’s Reimbursement Policy Department at 703/836-2272 ext. 3219.

Sincerely,

Gwen Gordon
Manager, Reimbursement Policy
American Academy of Physician Assistants
950 N. Washington Street
Alexandria, VA 22314-1552

The following message was sent on behalf of the AAPA Reimbursement Department. All e-mail replies should be directed toward ggordon@aapa.org. All constituent organization leaders were blind copied on this message.

Travel Policy Changes (Posted 01 Feb 2007)
From: Travel Policy Division (047E3)
Subject: Travel Notice 07-07 – Mileage Rate Reimbursement Change
To: All VA Administrations and Staff Offices
This is Travel Notice 07-07 to inform all VA Administrations and Staff Offices of a change to the reimbursement rate for the use of a privately owned vehicle (POV) for official travel. This change in the POV rate is effective for travel on and after February 1, 2007.
1. Reimbursement rates when the use of a POV is authorized as advantageous to the government:
· privately owned automobile rate increases from 44.5 cents per mile to 48.5 cents per mile.
2. Reimbursement rate for the use of a POV when a government vehicle is authorized as the mode of transportation:
· rate for use of POV remains at the same at 28.5 cents per mile.
3. Reimbursement rate for the use of a POV when traveler has signed a commitment statement to use a GOV:
· rate for use of POV remains the same at 12.5 cents per mile.
Again, please note these changes are effective February 1, 2007.

Questions or concerns regarding this Travel Notice should be directed to the Travel Policy office on 202-273-9375, or at travelpolicy@va.gov.

-- Colleen Kelley, president of the National Treasury Employees Union, in support of a call for civilian-military pay parity in 2008.

Overtime Pay (Posted 29 Jan 2007)

Q: What is the policy on overtime pay? A: Physician Assistants were re-classified by the FLSA as a "learned profession" which meets the criteria of "exempted" profession. You may find that the FLSA designation in your service record in VISTA is Exempt. FLSA, as administered by the Department of Labor, sets standards for overtime payment for all employers (public and private) which is at least 1 1/2 times the basic rate of pay. There is a complicated formula use to determine which occupations are exempt from these provisions which means the employer does not have to pay OT rates. VA addresses this issue in VA Handbook 5007 where FLSA exempt employees have OT pay rates capped at GS-10 levels.

HOWEVER, VA has a separate policy provision for Nurses, PAs, and EFDAs concerning OT and OT pay rates. Therefore, it does not matter if PAs are FLSA exempt or non-exempt. OT pay rates for VA PAs are not capped. If someone tries to tell you this, give them a copy of the reference below.

VHA Handbook 5007/21 - Pay Administration, Part V., Chapter 2, 2. Overtime and Compensatory Time off for Employees Appointed Under 38 U.S.C 7306, 7401, and 7405
b. Overtime Pay for Nurses, PAs, and EFDAs
(1) Except as provided in paragraph 3a of this chapter, probational and permanent full-time nurses, PAs, and EFDAs are employed on the basis of a 40-hour basic workweek, unless on an alternate work schedule, as indicated in VA Handbook 5011, Hours of Duty and Leave. Computation of regular pay for employees on the 40-hour basic workweek shall be based on a basic hourly rate, derived by dividing the employee’s annual rate of basic pay by 2,080.
(2) General provisions for the payment of overtime pay for nurses, PAs, and EFDAs
(a) Leave without pay is not included when computing hours of work for overtime purposes.
(b) Overtime must be at least 15 minutes duration in a calendar day to be creditable for overtime purposes.
(c) Overtime is payable for service performed in excess of 40 hours in an administrative workweek, or in excess of 8 hours in a day, whichever is greater, at a rate of one and one-half times the employee’s basic hourly rate of pay. NOTE: [For a full-time employee on a compressed work schedule, overtime is pay-able for hours of work in excess of the basic work requirement. For a part-time employee on a compressed work schedule, overtime is payable for hours of work in excess of the basic work requirement for a day (but must be in excess of 8 hours) or for a week (but must be in excess of 40 hours)].

Rating Benefits By Karen Rutzick

How do your 1.8 million federal co-workers feel about their pay and benefits? The Office of Personnel Management surveyed 220,000 of them to get an idea. Some of the results released last week could have been expected. But there were some surprises, too.
This column is published at http://www.govexec.com/dailyfed/0107/012507pb.htm

DEA Exemption Letter
December 8, 2006
A recent email discussed that the VA will need to require DEA registration for all PAs. After further discussion, it was clarified that a PA may be licensed in any state. However, personal DEA registration requires licensure in the state in which the facility of employment is located. Those not licensed in their state of practice may use the facilities DEA number. This may seem to avoid a problem but VA Pharmacy is pushing to implement a new tracking system that requires every practitioner have their own DEA number. So… we may have a reprieve for now but there will be problems down the road. The best permanent solution is to exempt VA practitioners from DEA registration in the first place.

21 CFR 1300.01(b)(28) - "The term mid-level practitioner means an individual practitioner, other than a physician, dentist, veterinarian, or podiatrist, who is licensed, registered, or otherwise permitted by the United States or the jurisdiction in which he/she practices to dispense a controlled substance in the course of professional practice."

Since VA practitioners are "agents" of the United States and states recognize they do not have jurisdiction over federal facilities, VA should use it's authority and authorize ALL prescribing authority irrespective of state licensure status. DOD did it. We just need someone with enough chutzpa in the VA to override VA General Counsel to make it happen.

Based on data from every agency that awarded retention bonuses in 2005, OPM calculated that five of the top 10 occupations to receive retention incentives were in health care: nurse, medical officer, pharmacology, physician's assistant and practical nurse.

One reason for the health care emphasis is the disproportionate use of retention incentives by the Health and Human Services Department. HHS, which employs less than 70,000 people, doled out more than a third of the 3,000 retention bonuses throughout government 2005. The agency spent about $12 million on the incentives to keep high-performing employees at risk of leaving the agency.

Full story: http://www.govexec.com/story_page.cfm?articleid=35110&dcn=e_gvet

Military PAs - Recently Mobilized National Guard PAs Need To Read This:
You have been identified as a Soldier that has served on Title 10 Mobilization orders on or after September 11, 2001. You may be eligible for educational benefits under the Reserve Educational Assistance Program (REAP), Chapter 1607, Title 10, U.S. Code, as established by the Ronald Reagan National Defense Authorization Act of 2005.

In accordance with this provision of the law, it is a requirement that you be notified of these benefits.
To obtain your Eligibility for Mobilized Soldier (EMS), or receive further instructions, please click on the following link.
https://www.nationalguardbenefits.com/MGIBWeb/CH_1607_Notification.aspx?SessionID=bd9332fa-bc8f-4365-be0e-efcd21ec8a5f

Alternatively you can follow these steps to obtain your Eligibility for Mobilized Soldier (EMS) notification -

Go to https://www.nationalguardbenefits.com/
Logon using your AKO username and password
Review and print your Eligibility for Mobilized Soldier (EMS) notification

POC for this email message is the ARNG GI Bill Support Team.

ARNG GI Bill Support Team
Email.: esc@PEC.NGB.army.mil
Phone: 1-866-628-5999
————————————————————————

PA Utilization Directive: Directive 2004-029
Utilization of Physician Assistants (PAs)
(http://www1.va.gov/vhapublications/ViewPublication.asp?pub_ID=1107)

Proficiency Guidelines for Physician Assistant Rating / Evaluation
     HTML Document PA-Rate Document

Proficiency Rating System: (MP-5, Part II, Chapter 6)
http://www1.va.gov/vhapublications/ViewPublication.asp?pub_ID=1042

ANNUAL LEAVE ACCRUAL FOR PAs:
Handbook 5011 (Moved to OHRM Web Site)

Creditable Service for Annual Leave:
http://www1.va.gov/ohrm/WorkLife/Leave/Flyer06-15.doc

Provider Credential Information: 
PAs are included in the VHA Directive 2001-013, Maintaining Provider Credential Information in the VistA NewPerson File has been approved for distribution; it may be found on the following web sites:
     Internet http://www.va.gov/publ/direc/health/
     Intranet http://vaww.va.gov/publ/direc/health/

Assignments, Staff Adjustments, and Furloughs:
http://www1.va.gov/vhapublications/ViewPublication.asp?pub_ID=1428

Comp Time for Travel:
Compensation Time For Travel - VA Handbook 5007, Part VIII, Chapter 15.doc
(2) Under the authority of 38 U.S.C. 7421(a), the Secretary has extended provisions of 5 U.S.C. 5550b, Compensatory Time Off for Travel, to nurses, physician assistants, expanded function dental auxiliaries and title 38 hybrid employees entitled to overtime under 38 U.S.C. 7453 and to part-time physicians, dentists, podiatrists, chiropractors and optometrists appointed under 38 U.S.C 7306, 7401 or 7405. [Latest complete version is on VA website dated July 20, 2005]
http://www1.va.gov/ohrm/Directives-Handbooks/Documents/5007-19.DOC

Other Directives (some with Handbooks attached):
http://www1.va.gov/vhapublications/publications.
or http://www1.va.gov/ohrm/Directives-Handbooks/Direct_Hand.htm (Human Resources HBs)

Other Handbooks:
http://www1.va.gov/vhapublications/publications

(a) Full-Time Physicians, Dentists, Podiatrists , Chiropractors, or Optometrists. A full-time physician, dentist, podiatrist or optometrist may carry forward not more than [86] days of accumulated annual leave at the end of any leave year.

(b) Full-Time Nurses, PAs or EFDAs. A full-time nurse, PA, or EFDA may carry forward not more than 685 hours of accumulated annual leave at the end of any leave year.

(c) Part-Time Employees. A part-time employee may carry forward not more than 240 hours of accumulated annual leave at the end of any leave year except that an employee converted to part-time from full-time may carry forward more hours of unused annual leave as indicated in subparagraphs 1 and 2.

http://vaww.appc1.va.gov/ohrm/Directives-Handbooks/Direct_Hand.htm

————————————————————————
Code of Federal Regulations

Follow this link for all the DEA topics:
http://www.deadiversion.usdoj.gov/21cfr/index.html

————————————————————————
July 1, 2006 Urgent Information from AAPA
About FOR-PROFIT Specialty Exam Company

House of Delegates policies concerning specialty certification
(http://www.aapa.org/policy/against-spec-cert.html).

————————————————————————
June 6, 2002
Texas Allows PAs to Submit for Reimbursement Without License!

Texas now has a law that allows PAs without licensure to submit for insurance reimbursement for services if they use the hospital or clinic's provider number. It is hoped that more states will follow suit, so that federally employed PAs, who due to their unique relationship with their supervising physician in the federal system, cannot qualify for licensure in most states, can have their services reimbursed. This will help PAs become more widely acceptable, within the federal system, we hope.