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Use of Unlicensed Healthcare Personnel

This Statement of Philosophy is offered as guidance for medical, osteopathic, and podiatric physicians and physician assistants.

With ever-increasing demands on the time and resources of physicians and physician assistants, the role of unregulated healthcare personnel is expanding.  As a result, high quality patient care depends on the contributions of a wide variety of personnel, including medical assistants.  When establishing expectations and limitations for medical assistants in a medical office, the OMB advises that patient safety should be the primary factor.

The physician or physician assistant is responsible for ensuring that the medical assistant is qualified and competent to perform any delegated services.  It is within the physician's or physician assistant's judgment to determine that the medical assistant's education, training, and experience is sufficient to ensure competence in performing the service at the appropriate standard of care.  Performance of delegated services is held to the same standard of care applied to the physician or physician assistant, and the physician or physician assistant is ultimately accountable for the actions of their supervised personnel. 

Unlicensed healthcare personnel must be adequately supervised by a licensed physician or physician assistant.  Examples of supervision include verifying the correct medication and dosage prior to administration of medicine by a medical assistant and being physically present in the facility when services are performed by a medical assistant.

The physician or physician assistant may not allow any unlicensed healthcare personnel to provide care or practice medicine as defined by the Oregon Medical Practice Act. Unlicensed healthcare personnel may not provide independent medical judgment.  It is the physician's or physician assistant's responsibility to determine what does not require medical judgment to perform.  For example, medical assistants should not provide assessments, interpretations, or diagnoses and should not perform invasive procedures.

Physicians and physician assistants should exercise caution when employing a person who has education and training as a healthcare professional but is working as an unlicensed medical assistant.  In this situation, it may be tempting for the physician or physician assistant to delegate (or the medical assistant to perform) duties beyond the scope of unlicensed healthcare personnel.

Medical assistants and other unlicensed healthcare personnel must maintain patient confidentiality to the same standards required of physicians and physician assistants.  Medical assistants must be clearly identified by title when performing duties.  This can be accomplished through wearing a name tag with the designation of “medical assistant" and clearly introducing oneself as a “medical assistant" in oral communications with patients and other professionals.

In order to fulfill its mission to protect the health, safety and wellbeing of Oregonians, the OMB recommends physicians and physician assistant to follow these guidelines and to be mindful of patient safety when delegating services to other healthcare personnel.


– Adopted October 2012

–  Amended July 7, 2022