North Dakota's HB1622 introduces a penalty fee structure that could affect small medical practices and clinics—and the staffing decisions they make.
Most North Dakota small business owners haven't heard of HB1622, and fewer still realize it contains a provision that could affect their bottom line if they employ or contract with physician assistants operating under interstate compact privilege.
Here's what changed: North Dakota's new law imposes a compliance obligation on physician assistants (PAs) who practice under the physician assistant licensure compact—an interstate agreement that lets PAs licensed in one state practice in another without obtaining a separate license in each state. While the compact itself isn't new, HB1622 adds teeth to North Dakota's oversight.
Under Section 4 of HB1622 (amending N.D.C.C. 43-17-46, subsection 2, pages 2–3), physician assistants privileged to practice under the interstate compact must now complete board-mandated addendum questionnaires by specified deadlines. Fail to submit on time, and the PA faces a penalty fee that can reach up to three times the normal PA licensure fee.
For small medical practices and clinics, this creates an indirect but real cost. If a PA on your staff misses a deadline—whether due to administrative oversight, unclear communication, or simple delay—your practice could face staffing disruptions while the PA resolves the penalty. In a small operation, losing a PA's availability, even temporarily, ripples through scheduling and patient care.
The penalty structure is designed to encourage compliance, but it shifts responsibility to employers and contractors to ensure their PA staff understand and meet these new deadlines. Practices that don't track these requirements risk unexpected complications.
If your medical practice, urgent care clinic, or small health service employs or contracts with a PA who holds privileges under the interstate compact, this applies to you. The provision is particularly relevant for practices in border areas or those that recruit talent from neighboring states.
Larger health systems may have compliance departments to manage this. Smaller practices often don't, which means owners need to build this into their HR and credentialing processes now.
HB1622 became effective upon filing with the Secretary of State (Section 6, Page 19). This means the compliance obligations are already in place. If you employ a PA under interstate compact privilege, you should verify that your staff understands the new questionnaire requirements and deadlines.
Review your current PA contracts and employment agreements. Confirm that any PA working under interstate compact privilege is aware of the board-mandated addendum questionnaire deadlines. Consider adding this to your compliance calendar and credentialing checklist.
Contact the North Dakota Medical Board or your PA's licensing authority in their home state for specific deadline information. The clearer your internal processes, the less likely you are to face penalties or staffing disruptions.
For a free, business-specific guide to HB1622 compliance requirements, contact your state medical association or local chamber of commerce.