I’ve been sharing my insights into the ten most commonly cited ARC-PA Standards for many months. Today, we’ve finally reached the last of the ten, Standard B3.06, which pertains to the qualifications of the preceptors who grade our PA students during the clinical year.

Standard B3.06 states as follows:

Supervised clinical practice experiences should occur with:

a) physicians who are specialty board certified in their area of instruction,

b) NCCPA-certified PAs, or

c) other licensed health care providers qualified in their area of instruction.

25 out of 98 programs between March 2022 and June 2023 received a citation for standard B3.06a.

Why are citations so common?

Much of the trouble happens specifically because of its wording, “should occur,” and the qualifications of physicians under part (a) of the Standard, that they should be specialty board certified “in their area of instruction.”

What we have found in the recent past is that when the Standard begins, “Supervised clinical practice experiences should occur with…”  the phrase “should occur” really means “must occur.” ARC-PA will issue a citation if physician preceptors are not specialty board certified in their area of instruction. They will do so unless you expend considerable effort showing them that your program is genuinely not in a position to have a physician of said qualifications. And I’ll be honest with you, it’s tough to prove.

In a recent PAEA ARC-PA presentation about the ten most common citations, ARC-PA Executive Director Sharon Luke shared this information with us: there are virtually no circumstances in which they will accept a non-board certified physician for supervised clinical experiences. This includes using board-certified physicians in other specialties to supervise a different specialty. For example, a family medicine board-certified physician supervising PA students for pediatrics is unacceptable. Even though the standard says “should,” this condition is considered an absolute necessity.

The modern ARC-PA rarely considers physicians not board-certified in that discipline as appropriate preceptors. This paradigm has shifted significantly even since 2020. They focus sharply on this with the 5th Standards with ever-increasing rigidity.

Finally, there is no clear roadmap for validating physicians who work in primary care who would supervise students in a similar discipline.

Those of us who strive to achieve and maintain compliance with the Standards have been concerned and frustrated by this. In the following blogs, I’ll take a relatively deep dive into this because I have some potential solutions or strategies that may be helpful. 

B3.06 citations cascade into more trouble

A citation in B3.06 can result in citations in other standards, specifically Standard B3.07. If your program is deemed out of compliance with B3.06a, then you could have a multiplication of citations in B3.07, among others. 

B3.07 states:

Supervised clinical practice experiences must occur with preceptors who enable students to meet program-defined learning outcomes for:

a) family medicine,

b) emergency medicine,

c) internal medicine,

d) surgery,

e) pediatrics,

f) women’s health including prenatal and gynecologic care, and

g) behavioral and mental health care. 

For example, if you have non-board-certified providers in any of the specialty areas that B3.07 lists, the Commission has a right to cite you in those areas, too! PA Programs face this serious issue often.

Nuances of Compliance to B3.06a

Using physicians as preceptors in areas where they are not board-certified has historically been fairly common practice. For example, using specialists in family medicine instead of specialists in pediatrics or women’s health has been accepted. There’s a clear logic: family medicine always takes care of both specialties in many areas of the country. This is how it has always been, so PA programs assume that a family practice specialist is sufficient.

However, if your program does this currently, start transitioning away from doing so as soon as possible. Fortunately, if you are a year or two ahead of your committee site visit, you have time to rearrange your preceptors.

The simplest solution is to designate PAs (or NPs) as the preceptors of record within alternative learning environments whenever possible. This is an acceptable alternative, and I have heard about it many times from individuals from the Commission. 

Using a certified PA who provides pediatric care in a family medicine setting is acceptable, whereas using a board-certified family medicine doctor, even with extensive experience in pediatric care, is not sufficient. To be honest, I cannot explain the logic behind this; I can only say that this is how it works now. Using PA preceptors is a solution.

In our next blog:

In discussing Standard B3.06a over the next two blogs, I intend to achieve these objectives:

1. Articulate how to troubleshoot the current level of compliance in your program and apply risk mitigation methods to avoid your receiving observations. This aspect is all about preventing issues from arising. 

2. Demonstrate how to ensure your program presents sufficient evidence to show compliance through comprehensive vetting and regional analysis. I will present a helpful vetting process. 

We’ll look at some examples of typical citations and discuss where things went wrong.

I’ll see you next week!