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The Texas Medical Board proposed rule would cripple orthopedic PA practice in Texas

Posted By Sam Dyer, Saturday, February 23, 2019
Updated: Saturday, February 23, 2019

I am writing this today to post a letter written by Ben Kocher, PAOS vice president, to the Texas Medical Board. Our orthopedic colleagues in Texas are being faced with a rule change that would significantly impact their ability to practice. Please take time to read about it on the TAPA site and respectfully respond to the TMB with your comments and concerns.



From the Physician Assistants in Orthopaedic Surgery (PAOS) Board of Directors:


It has come to our attention that the Texas Medical Board (TMB) has proposed a rule change regarding Physician Assistant (PA) practice that we believe would be significantly detrimental to PAs in the state of Texas, especially to our orthopaedic colleagues.  As the primary constituent organization for PAs in Orthopaedic Surgery within the American Academy of Physician Assistants (AAPA), representing over  2,000 specialty-practice PAs nationwide, the organization opposes TAC 193.21(d) and supports the Texas Academy of Physician Assistants (TAPA) position on the rule. 


Texas Occupational Code 204 requirements for PA scope of practice are reliant on radiologic procedures to perform diagnosis, develop treatment plans, oversee progression of care, and determine treatment efficacy and endpoints.  These processes are extensively required to practice orthopaedic care and practiced daily by PAs throughout the United States and in Texas.  Patients currently treated for fracture management or palliative joint therapies would be delayed from appropriate care if orthopaedic surgeons were required to supervise at bedside for every reduction or injection. Further, NCCPA-derived PA student curriculum requires initial radiologic didactic and clinical training under physician supervision prior to graduation and certification. AAPA and the American Society of Radiologic Technologists (ASRT) further identify a framework for training in ionizing radiation/fluoroscopy that has been published since 2009. Intentionally broad or vague language contained within Texas Administrative Code for radiologic procedures performed by physician assistants contributes to this continuum of misunderstanding. Texas Occupation Code Section 601.056 regarding Medical Radiologic Technologists incorporates licensed physician assistant authority for performance of radiologic procedures, including those deemed dangerous or hazardous. The key component to updated language is the need to act inherent as a privileged provider that interim evaluation of radiologic imaging provides. Delaying care for the final/formal read by a qualified physician in all cases is not in the best interests of injured patients seen by PAs working in orthopaedic services.  


PAOS is unaware of any evidence that reading or interpreting radiologic studies in the delivery of care by a PA, while working within practice agreement and granted organizational privileges, is harmful to patients.  Across the U.S., PAs in Orthopaedic Surgery rely heavily on ordering and interpreting radiologic modalities to provide comprehensive musculoskeletal healthcare, as well as emergent stabilization of musculoskeletal injuries.  Restricting the ability of PAs to leverage and interpret radiologic modalities may prevent stabilizing treatment of musculoskeletal injuries and could lead to harmful outcomes.  These roles are imperative in rendering life and limb saving measures to musculoskeletal injuries and conditions.      


PAOS stands with TAPA in its request to reject Rule 193.21(d) of the Texas Administrative Code.  Rejecting this code ensures that PAs are able to order and interpret radiologic studies during management of musculoskeletal injuries and conditions.  It furthermore prevents disruption of treatment and prevents potential endangerment of the patients they PAs serve.


Comments and questions for this email may be directed to Benjamin K. Kocher, Vice President, PAOS and can be reached via phone at (443) 910-4489 or by email at bkkocher@gmail.





 Board of Directors



Physician Assistants in Orthopaedic Surgery, Inc.

PO Box 10781

Glendale, AZ 85318

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