A buried provision in North Dakota's new physician assistant compact law creates a surprise financial penalty for small medical and clinical practices.
Most North Dakota construction and trades business owners don't realize that a provision buried in HB1622 could affect their small medical or clinical operations—or those of their employees who run them.
Here's what happened: North Dakota passed HB1622 to align physician assistant (PA) licensing with a multi-state compact that lets PAs practice across state lines under a single license. That part is routine. But the bill includes a compliance penalty that many practice owners haven't heard about yet.
Under Section 4 of HB1622 (amending North Dakota Century Code 43-17-46, subsection 2), any small medical or clinical practice that employs a physician assistant working under the compact privilege faces a potential penalty fee. If the practice misses the North Dakota Medical Board's addendum questionnaire deadline, the board can charge a noncompliance fee of up to three times the standard PA licensure fee. On top of that, additional statutory penalties apply.
In plain terms: if you run a small clinic or medical practice and your PA misses a board filing deadline, you're not just late—you're looking at a recurring financial hit that's triple the normal cost, plus other penalties.
This applies directly to:
• Small medical practices and clinics in North Dakota with a PA on staff
• Occupational health clinics at construction sites or trade shops
• Any employer-sponsored medical facility using a compact-privileged PA
It's a compliance cost tied to each PA you employ, and it recurs if deadlines are missed.
For small business owners, compliance deadlines are easy to miss when you're focused on operations. This provision makes that mistake expensive. A tripled licensure fee isn't a warning—it's a direct operating cost. And because it applies to each PA on staff, practices with multiple PAs face multiplied exposure.
The penalty is automatic under the statute. There's no grace period mentioned in the bill language. The board sets the deadline for the addendum questionnaire, and missing it triggers the fee structure immediately.
HB1622 becomes effective upon filing with the North Dakota Secretary of State (Section 6, Page 19). That means the compliance requirements and penalty structure are now in force.
If you operate a medical or clinical practice in North Dakota with a PA working under compact privilege, review your administrative processes now. Make sure someone on your team is tracking the Medical Board's addendum questionnaire deadline and has a system to submit it on time. The cost of missing it—up to three times the standard fee, plus statutory penalties—makes this a line item worth protecting.
The full text of HB1622 is available through the North Dakota Legislative Assembly. For a free, business-specific summary of how this provision affects your practice, contact your state trade association or local chamber of commerce.