Administrative Practice Issue References
Important to Your Practice

NEWLY UPDATED!!!

Joseph Streff, PA-C
Webmaster, 1995-present

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

I am copying a posting by the VACO Office of Nursing Services regarding federal supremacy. Although the posting is focused on NP practice, it also applies to all other VA occupations, including PAs. This is the best description of state vs. federal authority and controlled substance prescribing I have found. I recommend you save this to your reference archives.

Licensure requirements for the employment of VA health care providers have been established by Federal law, not State law. Under 38 USC 7402(b), VA physicians, dentists, nurses, podiatrists, optometrists, pharmacists, psychologists, social workers, chiropractors, and certain other health care positions must be licensed or registered in “a” State to practice their profession. There is no requirement that they be licensed in the State of practice. Thus, a licensed VA health care practitioner may practice at any VA facility, regardless of its location or his or her State of licensure.

Under the Supremacy Clause of the Constitution, States are prohibited from regulating or controlling the activities of the Federal Government, absent Congressional consent. However, where required by a Federal law, VA practitioners must comply with State licensure or registration requirements. Through the Controlled Substances Act (CSA), 21 USC 801 et seq., and implementing regulations in 21 CFR Part 1300, Congress has subjected health care practitioners to the requirements of State licensure law for purposes of prescribing controlled substances. Under the CSA, a health care practitioner can prescribe controlled substances only if authorized to do so by his or her State of licensure and either registered or exempted from registration with the Drug Enforcement Administration (DEA). 21 CFR 1306.03(a)(1)-(2). Accordingly, VA health care practitioners must possess a State license that allows them to prescribe controlled substances, but can utilize the DEA registration number of the VA medical facility, with a suffix.

Where Federal law and State law conflict, the Federal law will govern the official actions of Federal employees. Thus, where VA rules or policy conflict with the requirements of a State licensure law, VA employees would be bound by the VA rules or policy. Generally, the scope of practice of a nurse is determined by VA, without regard to State Practice Acts. For example, VA permits NPs to prescribe non-controlled substances provided the NP is licensed, certified, and has completed an approved upper division or continuing education course in pharmacology. To do this, VA establishes a scope of practice that authorizes the NP to prescribe certain non-controlled substances. Thus, for aspects of clinical practice other than controlled substances prescribing, the NP would be required to comply with VA rules or policy, even if his or her State Practice Act were more restrictive. For controlled substances prescribing, however, the NP would be required to meet the licensure requirements for controlled substances prescribing authority of his or her State of licensure.

Links to: VHA Directive 2004-031 Guidance On Primary Care Panel Size.pdf
and
VHA Primary Care DPCT 2006-060.DOC

OPM chief: 'Cracks are showing' in the General Schedule
By Alyssa Rosenberg

Story talks about Options for reform that include extending bonuses to rank-and-file employees.

Full story: http://www.govexec.com/story_page.cfm?articleid=43957&dcn=e_gvet

Wednesday, October 28, 2009, the President signed into law the Defense Authorization Act of 2010. The Act provisions modifying sections of Title 5 of the US Code relating to retirement benefits. The following is a summary of the changes for FERS retirement :

1. Credit for Unused Sick Leave.

a. FERS employees will be eligible to receive credit for a percentage of unused sick leave (see below) when determining the total years of service. This time cannot be used in determining average pay or retirement eligibility.

b. Employees retiring on or before December 31, 2013 will receive credit on 50% of their ending sick leave balance.

c. Employees retiring after December 31, 2013 will receive credit on 100% of their ending sick leave balance.

d. Unused sick leave cannot be used for determining retirement eligibility. In other words, you must be eligible for retirement without unused sick leave credit. However, your sick leave can be credited to total federal service time.

2. FERS Retirement Refund Redeposit Upon Return to Federal Service.

a. This provision allows for re-deposit of refunds received for FERS retirement payroll deductions when an employee left federal service and subsequently returned. Previous to the enactment of this legislation, the time covered by the refund was not eligible to be considered in the total federal service time for retirement purposes and the refund could not be could not be re-deposited.

b. Payroll deduction is authorized for repayment of refunded retirement deposits.

c. Federal service time for the period covered by the retirement deposit refunds may be restored upon repayment of the total amount originally refunded plus interest.

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

Grade 13 October 6, 2009

Please see the link below. Save to your favorites for future reference.

http://vaww1.va.gov/ohrm/HRLibrary/Dir-Policy.htm (only available from a VA computer)

Current OPM regulations include a time-in-grade requirement for promotion. OPM has changed their regulations to eliminate this requirement and was supposed to be effective November 7, 2008. However, due to a White House Memorandum on regulatory review, agencies were requested to extend for 60 days the effective date of regulations published in the Federal Register but not yet taken effect. In response, OPM has effected an additional comment period before the new regulation takes effect. The new estimated effective date is May 18, 2009. VA is expected to revise VA Handbook 5005 to eliminate time-in grade requirements for Title 5 on that date and include Title 38 occupations as well.

This change will effect physician assistant eligibility for promotion. Under current policy, a PA must occupy a grade for two years before becoming eligible for promotion. With elimination of the time-in-grade requirements, a PA must only meet the grade qualifications as specified in the VA PA Qualification Standards. The PA Qualification Standards specifies certain experience requirements in each grade qualifications. The proposed revision of the PA Qualification Standards includes modifying the experience requirements to "at least 1 year experience in the previous grade or equivalent". These combined changes in regulation and policy will make it much easier for VHA PAs to be promoted in a much shorter time period.

UPDATE - October 2009
Question: I was wondering if anyone knew if the OPM did actually change the proposed “Time-in-Grade” requirements for Title 38’s? I was looking in the VA Handbook and did not see any new literature regarding this change. I am asking secondary to we have an excellent PA on our Staff Service who is 1 year out of school and with the current payscale, her salary is not even close to the national average for new grads. Thanks for your time and your assistance.

Answer: The time-in-grade elimination was pulled when OPM deliberated whether to include Title 5. They decided not to. VA will now go forward with elimination of Title 38 time-in-grade requirements and will include language to this effect in the forthcoming revision of VA Handbook 5005. It is in the concurrence process now and should be out in the next month or so.

I'm also trying to get language inserted into the revised policy that would establish time frames for acting on promotion and special advancement requests as well as eliminate HR from the processing of PSB Board Action Requests.

Legislation modifying federal retirement rules advances
By Alyssa Rosenberg

Legislation was reintroduced this year that would allow employees under the FERS retirement system have their unused sick leave added to their credited federal service time for retirement annuity computation. In the past this leave was lost if not used. Read the full story for details...

Provisions would make it easier for retirees to cash out unused sick leave and return to government service.
Full story: http://www.govexec.com/story_page.cfm?articleid=42297&dcn=e_gvet

FYI – PA demographics in VHA is changing. There are more female PAs coming on board every week. The past arguments about pay have centered around gender, however, this is rapidly becoming a non-issue. NPs are outpacing PAs in salary overall. These stats are taken from the VHA Pay files.

As of December 31, 2008, there were 1,826 PAs on the VHA payroll. 962 males – 52.7% and 864 females – 47.3%

NCCPA reports that for all first time PANCE takers in 2008, 26% were men and 74% were women.

Pay Disparity: PA Senior Grade (12), step 10 vs. NP Nurse III, top step (12-14)
Salary data for PAs and NPs as of December 31, 2008 show the following:

NPs < PAs 4 facilities Range: 1.1% - 3.1%

NPs = PAs 11 facilities (less than 4% discrepancy in NP favor)

NPs > PAs 104 facilities Range: 4.1% - 48.2%

NPs > PAs (> $10,000) 74 facilities

NPs >PAs ( > $25,000) 13 facilities

NPs > PAs ( > $30,000) 9 facilities

Maximum pay discrepancy is $44,000 or 48.2%. (San Diego VA)

PA and NP salaries will vary from facility to facility due to factors such as locality pay, PA special pay rates, Nursing Locality Pay, and existence of NP pay bands. Pay comparisons were between the full performance level grades for each profession – PA Senior Grade and NP Nurse III.

PA to MD article: Interesting thoughts from our "father", Dr. Eugene Stead, Jr.

This is directly from Dr Stead's own web site : http://easteadjr.org or http://easteadjr.org/thoughts.html
"Using Distance Learning to Provide a Medical Education to Non-traditional Students"

Go to “Mostly My thoughts” section then scroll down to “Breaking the Medical Monopoly on Manpower Production “. It is contained under that section.

The article goes into the concept of using distance learning to advance PAs to the status of MD using the PA concept as a stepping stone to a medical degree. Interesting argument that I actually used in a paper during my first semester of PA school in 1977. I argued that all MD or DO candidates should actually come "from the ranks" rather than "jumping" directly into being a physician from college. -jos

Q: Do you have any national or local VISN policies regarding P.A.'s performing after hours on call duty?

A: Yes: See VA HANDBOOK 5007, PART V CHAPTER 5 & CHAPTER 2
CHAPTER 5. ON-CALL PAY AND STANDBY PAY

1. ON-CALL PAY FOR NURSES, PAs, AND EFDAs APPOINTED UNDER 38 U.S.C. 7401(1) OR 7405(a)(1)(A)

a. A nurse, PA or EFDA officially scheduled to be on-call outside of his or her regular duty hours shall receive 10 percent of his or her applicable overtime rate for each hour of on-call duty. When called back to perform overtime work, such personnel shall receive overtime pay in accordance with chapter 2 or chapter 4 of this part, as appropriate. On-call pay shall be suspended during the period of actual overtime duty; when released from overtime duty, such personnel shall return to the remaining scheduled on-call duty, if any, and receive on-call pay accordingly.

b. While in an on-call status, such personnel shall be available for prompt response to perform service. In the event of incapacitation or unavailability during the period for which scheduled to be on-call, such unavailability shall be promptly reported by the employee to the authorizing official or other responsible official. An employee who is relieved from scheduled on-call duty as a result thereof shall not receive on-call pay during the period from which relieved.

c. An employee who is excused from duty on a holiday may receive on-call duty during such hours of excusal. Authorizing officials for on-call duty shall be the same officials authorized to order and approve overtime, as indicated in chapter 1 of this part

SEE ALSO: VA HANDBOOK 5007, PART V CHAPTER 2
2. OVERTIME PAY AND COMPENSATORY TIME OFF FOR EMPLOYEES APPOINTED UNDER 38 U.S.C. 7306, 7401 AND 7405

c. Call-Back Overtime

(1) Any overtime on a day when a nurse, PA or EFDA was not scheduled to work, or for which an employee is required to return to his or her place of employment, shall be deemed to be a minimum of 2 hours in duration, regardless of whether or not service is performed for a full 2 hours. When an employee is called back from an on-call status to perform overtime work, the callback overtime provisions shall be applied upon return to duty of the employee.

(2) To be eligible for the full 2 hours of overtime, employees must be called into work at a time which is outside of and unconnected with their basic workweek (45 Comp. Gen. 53).

FYI…http://physician-assistant.advanceweb.com/Article/More-PA-Doctorates.aspx

This will take you to the article.

AUTOMATIC PAY GRADE INCREASES

PA Q: Are there automatic increases in grade?

PA Advisor: There are no "automatic" increases in grade. Although you may meet the PA Qualification Standards for promotion to a higher grade, grade promotions must be requested by the Service Chief. Requests must be submitted to the facility PA PSB and, if recommended for approval by the Board, forwarded to the Director for approval. I am unclear on how you were promoted from a grade 9 to 11 if the promotion request by your supervisor was denied.

To be eligible for promotion, you must also meet an OPM time-in-grade requirement. PAs must be in their current grade for a period of 2 years before being eligible for promotion. Again, I'm not sure how you were promoted to Senior Grade (grade 12) since you only had a little over 1 year time-in-grade. Your promotion was not in compliance with technical requirements. I am surprised that HR did not block this. Be that as it may, it happened and I would not call it into question.

Periodic Within Grade Increases (automatic step increases) occur every two years. These are "automatic" unless the performance appraisal is unsatisfactory. Promotion to a higher grade "resets' the clock for these step increases. It is important to keep this in mind when going for a grade promotion. If you are eligible for a step increase and a promotion around the same time, it may be wise to hold off on your promotion request until after your step increase. Otherwise, you will "lose" your step increase if your promotion occurs first. You would then have to wait another 2 years from the date of promotion for another step increase.

PA: The PA Advisor's last point is good but also, going up a grade can not be less money than you are currently receiving, so getting the last step in will put you at a higher step within the next grade when it comes.

Step increases within a grade can also be for 'reward' your supervisor or cmo can request a step increase almost at any time, and this does not effect the q 2 yr automatic increases,
it a nice way to get the steps up, i don't think it can cross grade levels, sorry 12-10s,
and i think it is easer to get a step than a grade increase.

PA Advisor: The step placement when promoted must be the equivalent of at least a two step increase. For example, if are promoted to Senior Grade (12) and are at 11/10, multiply the step interval amount for Intermediate Grade X 2 and add to the 11/10 salary amount. Then find the corresponding step on the Senior Grade pay schedule that is equal to or greater than the calculated amount.

This PA is describing Special Advancement for Performance and Special Advancement for Achievement. There are criteria to meet for these step advancements. He is correct, SAPs and SAAs do not effect the waiting period for Periodic Within Grade Step Increases.

A CANADIAN VIEW OF THE PHYSICIAN ASSISTANT

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

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

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.