What Is a Physician Assistant (PA)?
A Physician Assistant (PA) is a nationally certified and state-licensed medical professional who provides diagnostic, therapeutic, and preventive care under the supervision or collaboration of a physician. PAs are trained to perform many of the same clinical functions as physicians, including conducting physical exams, diagnosing conditions, ordering tests, prescribing medications, and managing treatment plans.
In CMS-recognized care management programs like Chronic Care Management (CCM), Principal Care Management (PCM), and Collaborative Care Model (CoCM), PAs often serve as the billing provider, supervising clinician, or both. They are considered Qualified Health Professionals (QHPs) and are eligible to bill Medicare directly for time-based and service-based care models, provided they are properly credentialed.
Key Functions of a PA in Care Management
Physician Assistants play a central role in delivering and overseeing care management services in both primary care and specialty settings. Their medical training allows them to function independently in many scenarios, making them well-suited to coordinate, supervise, and document activities required for CMS program billing.
Common functions of a PA in care management include:
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Acting as the billing provider for CCM, PCM, TCM, or CoCM services
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Supervising clinical staff such as RNs or care coordinators performing time-based activities
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Creating and approving care plans for patients with chronic or high-risk conditions
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Conducting required face-to-face visits (or reviewing staff notes) to meet eligibility thresholds
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Collaborating with behavioral health managers in CoCM while serving as the billing clinician
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Signing attestations, documentation, and time logs for Medicare compliance
Because PAs are eligible to independently bill Medicare when properly enrolled, they are often used to expand clinical capacity and revenue potential in practices with limited physician availability.
The Role of a PA in Care Delivery
Physician Assistants are highly adaptable clinicians who help extend a practice’s capacity to manage complex, high-risk, and chronic care populations. Because they are trained in medical diagnosis, treatment, and coordination, PAs are commonly used in care management models where billing authority and supervision are both required.
In day-to-day care delivery, PAs may:
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Lead care management programs as the primary billing provider
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Supervise time-based services performed by RNs or medical assistants
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Manage patients enrolled in multiple care models simultaneously (e.g., CCM + CoCM)
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Bridge the gap between specialty and primary care in transitional care situations
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Conduct follow-ups and reassessments for patients with chronic or behavioral health needs
For many practices — particularly those with limited access to physicians — PAs provide the regulatory and clinical backbone needed to run compliant, revenue-generating care management workflows.
Billing and Supervision Rules for Physician Assistants
Physician Assistants are recognized by CMS as billing-eligible providers under multiple care management programs. As long as they are enrolled and credentialed with Medicare, PAs may bill directly or serve as supervising clinicians in time-based and collaborative care models.
Programs where PAs may serve as billing providers include:
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Chronic Care Management (CCM): CPT 99490, 99439, 99491
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Principal Care Management (PCM): CPT 99424–99427
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Transitional Care Management (TCM): CPT 99495, 99496
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Collaborative Care Model (CoCM): CPT 99492–99494
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Remote Physiologic Monitoring (RPM): When applicable and clinically appropriate
Supervision Flexibility:
PAs may supervise clinical staff performing non-face-to-face care management services (e.g., nurses or care coordinators), as long as they are the designated supervising provider in the medical record and meet CMS’s documentation requirements.
State laws and employer policies may still affect scope of practice. While CMS rules determine billing eligibility, each state determines how independently a PA may practice or prescribe. In most care management scenarios, the PA’s ability to supervise and attest to time is sufficient to meet CMS billing standards — without requiring direct physician oversight.
Frequently Asked Questions about QHPs
1. What is a Physician Assistant (PA)?
A Physician Assistant is a licensed medical professional who provides diagnostic, therapeutic, and preventive care under a physician’s supervision or collaboration. PAs are authorized to evaluate patients, prescribe medications, and manage treatment plans.
2. Can a PA bill Medicare for care management services?
Yes. PAs are considered Qualified Health Professionals (QHPs) by CMS and may bill directly for Chronic Care Management (CCM), Principal Care Management (PCM), Transitional Care Management (TCM), and the Collaborative Care Model (CoCM), as long as they are properly credentialed.
3. Is a PA allowed to supervise clinical staff for billing purposes?
Yes. PAs may supervise care team members—such as nurses or care coordinators—when those staff deliver non-face-to-face services. The PA must be listed as the supervising provider in documentation and meet CMS program requirements.
4. How does a PA compare to a Nurse Practitioner (NP)?
Both PAs and NPs can diagnose, treat, and prescribe medications. NPs are trained in the nursing model, often focusing on patient education and holistic care, while PAs are trained in a medical model similar to physicians. Scope of practice is similar in many states, but supervisory requirements and credentialing paths differ. Both roles can bill for CMS care management programs.
5. What codes can a PA bill for under CMS care management programs?
Common codes include 99490 (CCM), 99424 (PCM), 99495 (TCM), and 99492 (CoCM). PAs must meet all documentation and eligibility criteria to bill Medicare for these services.
6. Can a PA be the billing provider in the Collaborative Care Model (CoCM)?
Yes. PAs may serve as the billing provider in CoCM and coordinate with a Behavioral Health Care Manager (e.g., LCSW), as long as they meet CMS’s billing and documentation guidelines.