Protocol · PA · Arizona
Practice Protocol for Physician Assistants in Arizona
Required. Arizona law names the instrument a Written Supervision Agreement, and the clinical protocol is the content that instrument carries. Below: the board that governs it, what it must contain, and the terms it has to carry.
HB 2043 (2023, eff. Jan. 1, 2024) recodified PA law at A.R.S. Title 32, Ch. 25 and removed the written supervision agreement at 8,000 hours, but a 'collaborating physician or entity' with designated responsible physician(s) is still required even past that threshold — this is not textbook full independence despite some secondary sources describing it that way.
Independent practice requires: ≥8,000 hours of board-certified clinical PA practice (qualifying out-of-state hours may count toward the threshold).
What an Arizona Written Supervision Agreement must contain
Governed by the Arizona Medical Board and the Arizona State Board of Pharmacy. Each numbered item is a statutory requirement the Written Supervision Agreement must satisfy.
If the Physician Assistant ("PA") has fewer than eight thousand (8,000) Arizona-certified clinical practice hours, the Physician Assistant shall practice under a written supervision agreement with the Physician describing the Physician Assistant's scope of practice, kept on file at the Physician Assistant's main practice location and produced to the Arizona Regulatory Board of Physician Assistants upon request, as provided under A.R.S. § 32-2531. If the Physician Assistant has at least eight thousand (8,000) such hours, no supervision agreement is required, though the Physician Assistant shall continue to collaborate with, consult with, or refer to appropriate healthcare professionals as clinical need requires.
Arizona law does not fix a numerical limit on the number of Physician Assistants with whom a physician may enter into a supervision agreement.
- The Written Supervision Agreement also carries 1 scope, 1 education and 1 registration clauses, authored in the document itself.
Terms it has to carry
Ratio, proximity, chart review, meeting and prescribing terms the Written Supervision Agreement has to carry, from Arizona's supervision rules.
Proximity
No proximity requirement
A.R.S. § 32-2531: supervision/collaboration 'may occur through electronic means and does not require the physical presence of the supervising physician at the time or place' the PA provides services — an explicit statutory rejection of any proximity standard, below or above the 8,000-hour threshold.
Supervision ratio
Not codified — no cap on file
Chart review
Not codified — left to the agreement
Meeting cadence
Not codified — left to the agreement
Prescriptive authority
Covered by the practice agreement · controlled substances permitted
No AZ-specific DEA-registration detail beyond standard federal requirements was found in the sections reviewed.
Written agreement
Required
Required only below the 8,000-hour threshold. At/above 8,000 hours no written supervision agreement is required, but the PA must still collaborate with, consult, or refer to an appropriate professional under a designated collaborating physician/entity (A.R.S. § 32-2531).
Practice ownership (corporate practice of medicine)
Non-licensee ownership permitted — Corporation may practice medicine through Arizona-licensed individuals (A.R.S. § 10-3301)
Business-formation guidance commonly cites a rule that non-licensed owners may hold no more than 49% of an Arizona professional corporation or PLLC, with licensed directors holding at least half; check the professional-corporation article (Title 10, Ch. 20) before relying on that figure.
Sources for the supervision rules (3)
- A.R.S. § 32-2501 — Definitions (Physician Assistants, Title 32 Ch. 25)
- A.R.S. § 32-2531 — Scope of Practice; Supervision/Collaboration
- HB 2043 (2023) — PA practice modernization, eff. Jan. 1, 2024
About Arizona's rules
Arizona has no explicit statutory CPOM ban; existing doctrine comes only from two optometry cases never applied to physician/PA ownership, making MSO tolerance a reasonable inference rather than a confirmed rule. NP/CNM/PMHNP have FULL practice authority with no collaborative agreement. PA's 2024 reform (A.R.S. Title 32 Ch. 25) removes the written agreement at 8,000 hours but still requires a designated collaborating physician/entity.
Other clinicians in Arizona: see the state overview.