Back to dashboard
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
Days to comply
—

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

Action needed
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