MedicaidAdministrativeHigh impact
Physician Assistants Can Bill as Separate Providers
Wisconsin Medicaid (ForwardHealth)·WI·Medical Policy
Effective date
Jun 1, 2025
We identified it
Aug 26, 2026
Summary
Effective June 1, 2025, Physician Assistants (PAs) in Wisconsin can bill ForwardHealth (Medicaid/BadgerCare Plus) as separate providers instead of only rendering-only providers. Currently enrolled PAs must upload tax information to the demographic maintenance tool; new PAs must follow standard enrollment. PAs must have either physician oversight or a formal collaborative practice agreement to bill, and all claims must use valid diagnosis, revenue, and procedure codes.
Action Required
REQUIREMENTS:
Before June 1, 2025:
- Billing team must identify all Physician Assistants currently employed or contracted who plan to bill ForwardHealth independently
- Ensure each PA has either: (1) a physician providing primary oversight of their professional activities, OR (2) a completed collaborative practice agreement signed by both the PA and collaborating physician
- Verify collaborative practice agreements include all required elements: provider names/license numbers, PA scope of practice, physician availability clause, alternative collaborator arrangement, consultation timeframe, agreement duration, and signatures
- Upload tax information to ForwardHealth demographic maintenance tool for all currently enrolled PAs via the Portal (call Provider Services at 800-947-9627 for assistance)
- New PAs or those re-enrolling must complete full enrollment through the Provider Enrollment Information page on the ForwardHealth Portal
- Update billing system to recognize PA provider IDs as separate billing providers (not rendering-only)
- Train billing staff that PAs can now bill independently for all services within their legal scope under Wis. Stat. § 448.975
- Establish process to verify and maintain current demographic information for all billing PAs using the Portal's demographic maintenance tool
- Implement documentation retention procedures per Wis. Admin. Code § DHS 106.02(9) for all PA claims
On or After June 1, 2025:
- Billing team must ensure all PA claims include valid diagnosis codes, revenue codes, HCPCS/HIPPS/CPT codes before submission
- Flag and correct any claims with invalid codes before submission (ForwardHealth will deny claims with invalid codes)
- Monitor that each PA has a current collaborative practice agreement on file; if agreement expires, stop billing until new agreement is executed
- Maintain records for all PA services for potential audit by Wisconsin DHS
Consequences of Inaction:
- Claims without valid codes will be denied
- Claims from PAs without collaborative practice agreements or physician oversight will be recouped by ForwardHealth
- Failure to produce documentation upon request may result in claim denials, recoupment, intermediate sanctions, or program termination