I'm interested in getting fellow PAs' perspectives on an issue involving the distinction between practicing as a PA and working in a nonclinical capacity that draws upon one's medical education and professional experience.
For context, I'm a PA-C with >5 years of clinical experience. I'm currently out of practice for personal health reasons, and participating in my state's professional monitoring program, thus my PA license is active with a non-disciplinary restriction.
My monitoring agreement includes the following language:
"Refrain from practice as a PA until this IRP is amended and their license status no longer states non-disciplinary restriction. The Licensee shall gain written approval from XXX Staff prior to starting employment that requires the respective license."
I fully acknowledge and have been compliant with this restriction. I have my next clinical job lined up for early 2027, when my license is scheduled to become "conditional practice" contingent on my ongoing compliance in this monitoring program. For the past several months I have been working an entry-level job to make ends meet.
In the meantime, I've established an independent medical-legal consulting business, primarily working with criminal defense attorneys. No civil cases/medmal/standard of care cases. My responsibilities would include reviewing medical records; developing chronologies and identifying clinically relevant information; explaining medical terminology, diagnoses, injuries, and clinical concepts to attorneys; assisting attorneys in understanding medical evidence and its potential relevance to their cases; potentially providing testimony explaining medical concepts or findings.
No clinical duties, patient care/interaction, period.
Importantly, I have received written confirmation from the organization engaging my services that PA licensure is not required for this work. My medical education and experience are relevant to my qualifications, but an active PA license is not a prerequisite for the position.
The question that has arisen is whether performing this type of nonclinical consulting, while identifying myself accurately as a PA-C, nevertheless constitutes "practicing as a PA" under my monitoring agreement.
My interpretation is that there is an important distinction between using the knowledge and experience acquired through PA training to work as an independent medical legal consultant, and actually practicing as a PA.
My questions are:
- Would you personally consider the nonclinical work I've described to constitute practicing as a PA?
- For those who have transitioned into nonclinical roles, how have your employers or state licensing boards distinguished those responsibilities from licensed PA practice?
- Are there aspects of medical-legal consulting, particularly expert testimony, that you believe could cross that distinction?
I'm aware that the ultimate interpretation of my agreement is a regulatory/legal question. But I'm genuinely interested in how my colleagues understand the professional boundaries of PA practice, especially as more PAs move into nontraditional roles.
Thanks in advance for your perspectives, including those who disagree with my interpretation.