Key Advocacy Issues

PAEA’s Government Relations Team has composed the following briefs describing key issues in PA education as well as innovative policy solutions.

Clinical Training Site Shortage

FAQ: Precepting PA Students as a MIPS Improvement Activity

Certain preceptors of PA students are eligible to claim credit towards a positive payment adjustment to their annual Medicare Part B reimbursements. In 2017, the Centers for Medicare and Medicaid Services (CMS) finalized a rule that made precepting students a “practice improvement activity” under the Merit-Based Incentive Payment System (MIPS) for Medicare Part B providers. For more information on improvement activities, read this CMS fact sheet. Clinical coordinators are encouraged to inform all preceptors about this incentive.

In the final regulation, CMS elected to restrict eligibility to “community practices in small, underserved, or rural areas” and specifically excluded providers in metropolitan areas. PAEA continues to advocate for eligibility to be expanded to all practice settings in future regulations.

All MIPS-eligible clinicians, including physicians, PAs, and NPs, are eligible to claim credit under this improvement activity. Please note, however, the restriction mentioned above, regarding the need to be practicing in “small, underserved, or rural areas” to be eligible for the credit. For a full list of eligible providers, click here.

To receive full credit towards a positive Part B payment adjustment, providers in practices with fewer than 15 clinicians and those located in a rural area or a designated Health Professions Shortage Area are required to complete two “high-weighted” or four “medium-weighted” improvement activities. The preceptor improvement activity is considered high-weighted, meaning eligible clinicians would only have to complete this activity to earn full credit.

MIPS-eligible clinicians who meet the criteria regarding practice area are eligible to claim credit for precepting PA students.

MIPS-eligible clinicians may submit improvement activity data via attestation, Qualified Clinical Data Registry or other qualified registry or through electronic health records systems. For more information on the data submission process, visit the CMS Quality Payment Program Resource Library.


For more information or additional questions, please contact Senior Director of Government Relations Tyler Smith at

FAQ: CMS Student Documentation

In 2019, the Centers for Medicare and Medicaid Services (CMS) issued a final rule amending the agency’s previous restrictions on the use of student medical record documentation during the provision of evaluation and management (E/M) services for billing purposes. As of 2020, all preceptors of PA students, including PAs, physicians, and nurse practitioners, are allowed to verify, rather than reperform, documentation provided by students. To learn more about this policy, please see the list of frequently asked questions below.

In the final rule, CMS removed restrictions on the use of student-provided documentation of evaluation and management services for billing purposes. As a result of the 2020 Physician Fee Schedule final rule, physician, PA, and APRN preceptors will be allowed to verify documentation provided by PA, medical, and APRN students.

January 1, 2020

Yes, there are no restrictions imposed by CMS on the verification of student documentation on the basis of profession.

No. Because a change to current physical presence requirements was not addressed in the proposed rule, the agency opted not to consider changes in the final rule.

Yes. In the 2020 Physician Fee Schedule proposed rule, CMS proposed to expand the use of student documentation generally without explicitly stating the types of students. Because of our belief that the new rule should be unambiguous, PAEA argued for an improvement to the proposed rule. CMS found this argument persuasive and edited the final rule to explicitly include PA and APRN students to eliminate the potential for future confusion among clinicians, practices, systems and compliance officers regarding the agency’s intentions.

Please refer them to §§ 410.20, 410.69, 410.74, 410.75, 410.76, and 410.77, which can be found in the final rule.

Yes. Please feel free to use the following messaging when communicating with preceptors about the CMS 2020 Physicial Fee Schedule Final Rule.

In 2019, the Centers for Medicare and Medicaid Services (CMS) finalized regulations regarding the use of PA student medical record documentation for billing purposes.

CMS no longer requires that clinicians serving as preceptors reperform student-provided documentation. Preceptors may verify (sign and date) student documentation after January 1, 2020. This makes the role of preceptors significantly easier as they will be able to spend more time teaching than redocumenting. Students will also benefit from increased experience with electronic health records, which will better prepare them for practice.

All physician, PA, and APRN preceptors will be allowed to verify medical record documentation provided by PA students. It is important to note that there are no restrictions on the verification of student-provided documentation on the basis of profession (i.e., a preceptor does not have to be a PA in order to verify the documentation of a PA student).

This change represents a significant reduction in the administrative burden associated with training PA students and will allow more time to be spent on student mentorship, direct patient care, and other clinical responsibilities.

For questions regarding this change in CMS policy, please contact PAEA Senior Director of Government Relations Tyler Smith at