Written Protocol · PA
Florida Written Protocol for Physician Assistants
Required. The Written Protocol is the written instrument Florida law names for a Physician Assistant working with a physician. Below: the board that governs it, what it must contain, and the terms it has to carry.
Florida has never created an independent-practice pathway for PAs; the most recent attempt (S.B. 668, 2026) died in Senate Health Policy Committee March 13, 2026. Unlike NP/CNM, there is no experience-based or scope-limited route to autonomy at any tenure.
What a Florida Written Protocol must contain
Governed by the Florida Board of Medicine and the Florida Board of Pharmacy. Each numbered item is a statutory requirement the agreement must satisfy.
The Physician Assistant ("PA") shall practice pursuant to a written protocol with the Physician identifying each supervising physician, as required by Section 458.347, Florida Statutes (or Section 459.022, Florida Statutes, if the supervising physician is licensed under Chapter 459). Prescriptions written under this Agreement shall identify the Physician Assistant and name the Physician. Florida law does not require the Physician to review and co-sign the Physician Assistant's charts or medical records, though this Agreement or Practice policy may impose additional review requirements.
A supervising physician may not supervise more than ten (10) Physician Assistants at any one time, as provided under Florida law. The Physician shall notify the Department of Health in writing within thirty (30) days of the commencement of supervision, and of any subsequent change in supervising physician, using the Board-approved supervision notification form. A Physician on probation may not serve as primary or alternate supervising physician during the term of that probation.
- The Written Protocol on file also carries 1 scope, 1 education, 1 registration clauses, generated in the document itself.
Statutes and rules cited
- Section 465.1865, Florida Statutesstatute
Collaborative pharmacy practice for chronic health conditions -- certification, required agreement contents, Board filing, and professional liability insurance requirements.
- Section 458.347, Florida Statutesstatute
Caps the number of Physician Assistants a supervising physician may supervise at one time (raised from four to ten by 2021 c. 2021-118, Laws of Fla.).
Terms it has to carry
Ratio, proximity, chart review, meeting and prescribing terms the agreement has to carry, from the state's supervision rules.
Proximity
Available remotely (no on-site requirement)
§458.347/§459.022 define supervision as requiring the physician's 'easy availability or physical presence... for consultation and direction,' and expressly include the ability to communicate by telecommunication within 'easy availability' — no mileage/radius standard is codified.
Supervision ratio
Up to 10 at a time
'A physician may not supervise more than 10 currently licensed physician assistants at any one time' (§458.347/§459.022) — raised from 4 to 10 by H.B. 431 (2021), effective July 1, 2021. PA-specific; no statutory cap governs how many APRNs the same physician may separately supervise.
Chart review
0% of charts · As needed
Coded as 0%/as-needed to distinguish an affirmative statutory exemption from silence: §458.347/§459.022 state the supervising physician 'may not be required to review and cosign charts or medical records prepared by' the PA. All delegated tasks/procedures must still be documented in the medical record (Fla. Admin. Code R. 64B8-30.012), but no review percentage or cosignature mandate exists.
Meeting cadence
Not codified — left to the agreement
Prescriptive authority
Covered by the practice agreement · controlled substances permitted
PAs with prescriptive privileges must complete 10 CME hours per renewal, 3 of which must specifically address safe/effective controlled-substance prescribing. A 2026 bill (H.B. 683) that would have raised the pediatric psychiatric limit to 30 days and removed DOH delegation-notification requirements passed the House 112-4 but died in Senate Rules March 13, 2026 — not current law.
Written agreement
Required
Unconditional — PA practice is a physician-delegation model under §458.347 (MD) / §459.022 (DO), not a filed 'collaborative practice agreement' the way some states use the term; the delegation relationship is mandatory for the life of the PA's practice.
Practice ownership (corporate practice of medicine)
Non-licensee ownership permitted — Florida has no judicially-recognized corporate-practice-of-medicine doctrine (secondary-source consensus across multiple health-law firms — no single statute states this affirmatively). The operative constraints are fee-splitting prohibitions (§458.331(1)(i)/§459.015(1)(j)) and the Health Care Clinic Act (Fla. Stat. Ch. 400, Part X): §400.9905(4)(g) exempts entities wholly owned by licensed health care practitioners under Ch. 457-491 (PA licensure lives within Ch. 458/459 itself) from clinic-licensure/medical-director mandates, provided the owner-practitioner supervises within their own scope — a materially more permissive framework than Texas's physician-majority-ownership mandate.
PA clinical services still require physician delegation regardless of entity ownership, so payer/credentialing practicalities often keep a physician involved in the entity even though Florida law itself doesn't mandate it.
Legal sources for these rules (8)
- Fla. Stat. § 458.347 — Physician assistants (MD supervision)
- Fla. Stat. § 459.022 — Physician assistants (DO supervision)
- Fla. Stat. § 458.331(1)(i) / § 459.015(1)(j) — Fee-splitting prohibitions
- Fla. Stat. § 456.44 — Controlled substance prescribing standards (acute pain)
- Fla. Stat. § 400.9905 — Health Care Clinic Act definitions/exemptions
- Fla. Admin. Code R. 64B8-30.012 — Physician Assistant Performancesecondary
- S.B. 668 (2026) — PA independent practice, died in committee March 13, 2026
- H.B. 683 (2026) — PA prescribing changes, passed House, died in Senate Rules
About Florida's rules
Florida's 2020 autonomous-practice law (§464.0123, ≥3,000 supervised hours + coursework) creates a real independence pathway for NP and CNM — but excludes PMHNP, CRNA, and CNS entirely; CRNA autonomy bills have died three sessions running (2024-2026). Florida has no corporate-practice-of-medicine doctrine (secondary-source consensus) — entity ownership instead turns on the Health Care Clinic Act's §400.9905 exemption mechanics. Supervision ratio/chart-review/meeting-cadence are largely uncodified; PA's 10-supervisee cap is the exception.
Other clinicians in Florida: see the state overview.