By: Chase Howard
In Florida, a licensed physician can provide supervision of healthcare providers that are not physicians under certain circumstances. Understanding who a physician can cover and under what circumstances can help protect your license and avoid receiving a complaint by the Florida Department of Health.
In every case, when a physician agrees to supervise another provider, Florida law requires certain documentation and notice to be filed.
First, a supervising physician must file a notice with the Florida Board of Medicine stating their name, license number, primary address, and how many providers they are supervising. This notice is required within thirty days of entering, or ending, a supervisory relationship.
Additionally, supervising physicians must develop jointly written protocols to establish the appropriate procedures that the physician will be supervising.
In Medical office settings, the following regulations apply to supervisory physicians:
- Primary Health Care Services: A physician providing primary health care services may not supervise more than five total offices, including the physician’s primary practice location. Primary health care means health care services that do not require referrals. Primary practice location means the address reflected on the physician’s Board of Medicine profile.
- Specialty Health Care Services: When a physician provides specialty health care services, such as dermatologic or aesthetic and cosmetic skin services, that physician may only supervise three total offices, including the physicians primary practice location.
- Additional Regulations in Specialty Health Care Offices: When a physician is supervising APRN and PA’s in specialty health care offices, the physician must report to the Board of Medicine each address that the physician supervises. The physician must be board certified or board eligible in dermatology or plastic surgery as well. Additionally, all of the offices that the physician supervises must be within 25 miles of the physician’s primary place of practice. Finally, the Physician may not supervise more than two total offices.
- Requirements: The physician must post, in each office they supervise, the physician’s schedule for each office.
- Supervision: Physician’s can generally supervise ARNP’s and PA’s indirectly and off-site. Electrologists, providing laser and light-based hair removal services, must operate under the direct supervision and responsibility of a physician. Additionally, that physician must be properly trained in hair removal techniques.
Entering into a supervisory relationship with a non-physician provider is a serious undertaking that carries with it implications on your medical license. Prior to agreeing to any such relationship, it is recommended that you seek legal counsel to determine the risks of the relationship for the provider and additionally the office location. Many medical types of businesses require medical directors in order to properly operate which puts physician licenses at risk of liability for violation of Florida law.
