CMS Clarifies Rule, Again Requires Preceptors to Redo Student Work

The PA education community received some disappointing news this week from the Centers for Medicare and Medicaid Services (CMS) in response to questions requesting clarification of the February 2 change in the CMS manual about expanded use of student health record documentation. PAEA’s Government Relations Team believed that the changes allowed preceptors to verify and include PA student (and NP and medical student) documentation in the medical record, rather than having to “redocument” it. An email received yesterday from CMS Hospital and Ambulatory Policy Group Director Carol Blackford states clearly that the February 2 change applies only to medical students and to physician preceptors.

The February 2 transmittal initially appeared to significantly ease the burden of precepting PA students by no longer requiring preceptors to redocument students’ work in the medical record, as we wrote in the Networker at that time. It also provided enhanced opportunities for students to practice their documentation skills. The longstanding interpretation of “student” to include both PA and NP students in this context, and the unchanged historical language of the rest of this section of the CMS manual, appeared to make this change a cause for celebration for our profession. PAEA had played a significant role in bringing about this apparent change through our collaboration and joint advocacy with the Society of Teachers of Family Medicine (STFM) and their Preceptor Expansion Initiative.

The clarification we received yesterday now makes clear that medical records written by PA and NP students must be rewritten by preceptors. Your institutional compliance officers will be receiving this same clarification through their channels and may be passing this along to PA program leaders, but we wanted to communicate with you directly as soon as we heard this news.

The Silver Lining

There is one piece of good news here for PA programs. This clarification now offers a clear opportunity to work with CMS to change the rule to apply to PA and NP students and their PA/NP preceptors, thereby cementing our position in clear policy language rather than longstanding interpretation. We believe we can make a compelling case that easing the burden of redocumentation on preceptors is important to tackling the preceptor and clinical site shortage faced by many health professions — and thus to growing the U.S. health workforce. This also offers a wonderful opportunity to work with our other health professions colleagues to advocate for PA and NP students and preceptors.

We will be exploring all options in the coming days, including seeking legal advice, and will continue to work with STFM on the Preceptor Expansion Initiative, for which both PAEA Chief Assessment Officer Olivia Ziegler, PA, and I sit on the Oversight Committee. Enhancing clinical education is always a high priority for PAEA, and we will continue to do everything we can to improve the regulatory environment. We’ll keep you informed as this situation unfolds. Please contact me at with any questions.