COVID-19: Frequently Asked Questions

Below are some of the most frequently asked questions CMA has received during the COVID-19 outbreak. By default, the most recent answers will appear up top. You can also filter the FAQ by category. We will update this resource regularly.

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Have state and federal waivers removed California’s requirement for physician supervision for advanced practice nurses and physician assistants during the declared emergency?

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On April 9, 2020, the Centers for Medicare and Medicaid Services (CMS) temporarily suspended a number of rules pertaining to scope of practice and physician supervision of non-physicians. These waivers supplement, rather than replace, state scope of practice and licensure laws for health care workers in cases where federal requirements may be more stringent than state laws and requirements.

CMS also waived requirements under 42 CFR §482.12(c)(1)–(2) and §482.12(c)(4), which require that Medicare patients be under the care of a physician. In general, California laws related to scope of practice for advanced practice nurses and physician assistants are not impacted by these temporary federal rule waivers, as California's laws are more stringent than federal law. In California, physician supervision continues to be required for these non-physicians.

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