- within Strategy topic(s)
Massachusetts may soon join New Hampshire as the second New England state to grant experienced physician assistants (PAs) the authority to practice independently. Companion legislation currently being considered by the Massachusetts Legislature (H.2371 and S.1502), would permit PAs who meet certain criteria to practice and prescribe independent of a supervising physician. In light of this change, the proposed law also contains provisions that clarify the legal responsibility of PAs and their employers and regulate the relationship between PAs and payers.
Current Law
Current Massachusetts law requires PAs to practice under the supervision of a physician and limits their prescriptive authority by requiring adherence to guidelines "mutually developed and agreed upon" by the PA and supervising physician.1 Additionally, PAs must file the name and address of their supervising physician with the Board of Registration of Physician Assistants.2
Proposed Legislation
If passed, the legislation would require PAs, as a condition of registration or renewal, to complete 2,000 hours of experience working under a "collaborative agreement" with a supervising physician. The agreement must be with a physician practicing in the same specialty as the PA and define the working relationship and "scope of collaboration" between the two providers. After completing the 2,000-hour requirement, PAs would be permitted to practice and prescribe independently within their scope of practice.
The bills would also eliminate the requirement that PAs file a supervising physician with the Board of Registration of Physician Assistants and, because PAs would have full practice authority, clarify that they would be permitted to operate limited-service clinics in the Commonwealth.
Additionally, the bills would require that PAs be identified on claims as the rendering provider where appropriate, permit PAs to bill and receive payment directly from payers, and mandate that insurers cover services provided by PAs if those same services would have been covered if rendered by a physician. The bills would also protect the newly granted independence of PAs by prohibiting insurers from imposing more restrictive requirements than those set forth in the statutes and their implementing regulations.
Proposed Bills in Context
Similar legislation has been considered by the last two Massachusetts General Courts, but none has passed.3 If one of the bills passes, Massachusetts would join New Hampshire as the second New England state to grant independent practice authority to PAs.
New Hampshire's law permits PAs with more than 8,000 hours of experience working under a collaboration agreement to obtain a waiver from the Board of Medicine permitting independent practice through the end of 2026. Beginning January 1, 2027, PAs in New Hampshire with more than 8,000 hours of experience will no longer require a waiver, while PAs with fewer than 8,000 hours will still require a collaboration agreement.
Next Steps
The bills are pending review by the Joint Committee on Health Care Financing after being reported favorably to their respective chambers by the Joint Committee on Public Health.4 The Joint Committee on Health Care Financing has until March 18, 2026, to report back to the House on H.2371; no reporting date has been set for S.1502. Notably, the bills were discussed during a hearing of the Joint Committee on Public Health on July 14, 2025.
Footnotes
1.See Supervision requirements and prescriptive practice authority.
2. See Mass. Gen. Laws ch. 112, § 9I.
3. See H.2135, 193rd Gen. Ct., 1st Sess. (Mass. 2023); S.1354, 193rd Gen. Ct., 1st Sess. (Mass. 2023); and H.2229, 192nd Gen. Ct., 1st Sess. (Mass. 2021).
4. The authors note that the Massachusetts Legislature is concurrently considering a series of other proposed bills that would impact PAs. Holland & Knight will separately provide summaries of these bills and continue tracking their status.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
