A provision in HB1622 creates new financial penalties for medical practices that employ or contract with certain physician assistants—and most business owners haven't heard about it yet.
Most North Dakota business owners don't realize that a new state law tucked into HB1622 has created a compliance obligation that could cost their medical practice or clinic thousands of dollars if they miss a deadline.
Here's what happened: HB1622, signed into law and effective upon filing with the Secretary of State, amended North Dakota's physician assistant licensure rules. Buried in Section 4 (which amends 43-17-46, subsection 2) is a requirement that physician assistants practicing under interstate compact privilege must complete board-mandated addendum questionnaires on time. If they don't, the employing practice faces a penalty.
If your medical practice, clinic, or urgent care employs or contracts with a PA operating under the interstate compact privilege, you now have an indirect compliance obligation. The PA must submit required questionnaires to the state board by specified deadlines. If that questionnaire is late or incomplete, your practice could be assessed a penalty fee up to three times the normal PA licensure fee.
That's significant. A missed deadline doesn't just mean paperwork—it means a financial hit that can disrupt staffing decisions and impose unexpected costs on a small business already managing thin margins.
Why does this matter to you as a business owner? Because you likely don't control whether your PA submits that questionnaire on time. Your PA does. Yet your practice absorbs the penalty. This creates a new risk category you probably haven't budgeted for and may not even know exists.
If you employ or contract with a PA operating under interstate compact privilege, take three steps:
First, confirm whether any of your PAs are licensed under the interstate compact. Not all PAs are; some hold traditional North Dakota licenses. Only those under compact privilege trigger this requirement.
Second, contact your PA directly and ask about the board-mandated addendum questionnaire requirement. Make sure they understand the deadline and the penalty structure. Consider adding a reminder system to your compliance calendar.
Third, review your employment or contractor agreements with PAs to clarify responsibility for timely questionnaire submission. You may want to document that the PA is responsible for meeting state board deadlines, and that missed deadlines could affect the working relationship.
HB1622's interstate compact provision is now law. The penalty is real. And unlike many regulatory changes that come with a transition period, this one is effective immediately upon filing with the Secretary of State. There's no grace period to learn about it or adjust operations.
Small medical practices shouldn't have to hire a compliance consultant to understand a buried provision in state law. But until you confirm your PA's licensing status and their questionnaire obligations, you're exposed to a penalty you didn't know existed.
For a free, detailed guide specific to medical practices and clinics, contact your state trade association or local chamber of commerce—many have prepared plain-language summaries of HB1622's compliance requirements.