Physician Assistant Issues – National Certification

Like all medical professionals, physician assistants must pass an exam to demonstrate their medical knowledge and readiness to work with patients. For the PA profession, the national qualifying exam is the Physician Assistant National Certification Exam (PANCE). PAs who want to regain certification must take the Physician Assistant National Recertifying Exam (PANRE), and those who want to gain specialist qualifications must take exams for Specialty Certificates of Added Qualifications (CAQ).

The National Commission on Certification of Physician Assistants (NCCPA) is the body responsible for administering exams and overseeing physician assistant certification. If you come under suspicion for misconduct concerning your exam, the NCCPA can take disciplinary action against you.

Becoming a physician assistant takes years of studying and training. If you are accused of irregular behavior relating to the PANCE, it could disqualify you from certification. All of your hard work would be wasted. If the NCCPA suspects wrongdoing and formally investigates you, you should take every precaution necessary to protect yourself and your career.

Irregular Behavior Related to Certification Exams

The NCCPA has a Disciplinary Policy that covers actions relating to irregular behavior, fraudulent credentials, and legal or regulatory actions. This policy applies to:

  • Certified PAs
  • PAs seeking certification
  • PAs holding the PA-C Emeritus designation

If you are accused of wrongdoing related to PANCE, PANRE, or CAQ qualifications, the NCCPA can bring disciplinary action against you as long as you are a certified PA or working toward PA certification.

Under the NCCPA Disciplinary Policy, the following behaviors are “irregular” in connection with an exam:

  • Cheating or dishonest behavior
  • Compromising the security of an exam
  • Removing or attempting to remove test materials from a test center
  • Reproducing, distributing, displaying, or misusing a test question or part of a test question
  • Copying someone else's answers or allowing someone else to copy you
  • Making notes on anything other than materials provided by the test center
  • Memorizing and reproducing test items
  • Having unauthorized materials during a test, including recording devices, photographic materials, and other reference material
  • Having or seeking access to exam materials before the exam takes place
  • Impersonating someone who's supposed to take the exam or taking the exam for someone else
  • Altering or misrepresenting test scores
  • Any behavior that may cast doubt on exam results of an individual or another person

All PA exams take place at specific testing centers, administered by NCCPA personnel. Testing conditions are strict, and personnel will notify the NCCPA if they notice anything that resembles irregular behavior.

With such strict rules, behavior that seems harmless could actually result in an irregular behavior violation. For example, discussing the PANCE with any colleagues who've already taken it before you have could constitute seeking access to exam materials. If you fail the PANCE the first time and create a study guide based on the information you remember from the test, it may be memorizing and reproducing test items.

Small mistakes can easily be construed as dishonest behavior and land you in trouble. Always remember that the testing environment for PANCE, PANRE, and CAQ exams follows NCCPA rules closely. The NCCPA has sole discretion in determining if behavior undermines or threatens the integrity or validity of the application, assessment, or certification processes, whether the action happens before, during, or after an exam. If NCCPA personnel has reason to believe you acted dishonestly, you must be ready to defend yourself.

NCCPA Disciplinary Procedures

Anyone can complain to the NCCPA about suspected irregular behavior. The NCCPA has the authority to either investigate the claim further or to dismiss it. The organization may also make the complaint public.

Once disciplinary proceedings against you start, the NCCPA will send you formal notice. You must reply to this notice in writing within 30 days of receiving it. If you do not respond, the NCCPA can impose a temporary administrative suspension of your certification or eligibility for certification.

The suspension is not reportable to the Federation of State Medical Boards, but the NCCPA can report it to employers, state medical boards, and other interested parties. If you respond but don't provide the information the commission has asked for, you can still face administrative suspension. There is no appeal process for administrative suspension.

After the NCCPA investigates a claim of irregular behavior, they can make one of three decisions:

  1. No action: The NCCPA takes no action and closes the matter.
  2. Non-reportable disciplinary action: The NCCPA takes disciplinary action, and the matter is final.
  3. Reportable disciplinary action: The NCCPA takes disciplinary action, and you can ask for a Request for Review of the matter, launching the appeals procedure.

The only chances accused individuals have to participate directly in the disciplinary process are providing a written statement at the start of disciplinary proceedings and appealing at the end. Accused PAs do not get a hearing with the NCCPA or any further chances to defend themselves until they begin the appeal procedures.


If you request a review of the NCCPA's decision, it will go before the Review Committee. You'll have a hearing and can bring legal counsel to represent you at this hearing. Both you and the NCCPA can present information for the Committee's review, and the Committee can look at your NCCPA record. After the hearing, the Review Committee can decide to affirm, modify, or reverse the decision of the NCCPA.

Reestablishment of Eligibility for Certification

Before you can take the PANCE, PANRE, or CAQ exams to become a certified PA, you must be eligible to take the exams. Disciplinary action resulting from irregular behavior concerning an exam can make you ineligible for a certain period of time. If you want the opportunity to become certified again, you must apply for it with the NCCPA. You must submit a full statement with the following:

  • An acknowledgment of your actions
  • A statement as to why the NCCPA should reestablish your eligibility for certification
  • Attestation that you've committed no new violations of the Code of Conduct
  • Description of how you've met NCCPA stipulations
  • Attestation that a state licensing board or employer considering your credentials are aware of your certification revocation

The NCCPA may also ask for further documents, such as testaments to your character or written notice of support from a licensing board. They also have the authority to place other conditions on the reestablishment of eligibility, and failure to comply could lead to further disciplinary action.

Possible NCCPA Actions

If the NCCPA decides that your behavior violates the Disciplinary Policy, it can take any action it deems appropriate. The policy lists the following potential consequences:

  • Deny or revoke your eligibility, certification, recertification, Certificate of Added Qualification, or PA-C Emeritus designation permanently or a period of time determined by the NCCPA
  • Issue a reportable Letter of Censure
  • Issue a non-reportable Letter of Concern
  • Issue a non-reportable Letter of Suspension for failure to respond to an NCCPA request for information
  • Order you to retake an exam at a time and place and in a format decided by the NCCPA
  • Remove you from participation in the Alternative to PANRE Pilot program
  • Refuse to release the exam score, effectively denying your current application for certification, recertification, or Certificate of Added Qualification
  • Requiring you to wait a specified period of time before reapplying to take another NCCPA exam
  • Recommend legal action to the NCCPA Board of Directors

Code of Conduct for PAs

In addition to following the rules of the NCCPA's Disciplinary Policy, certified and certifying PAs must also follow the Code of Conduct. This code is to ensure that all PAs who are certified or seeking certification follow the organization's rules on professionalism and ethics. The NCCPA only issues PA credentials to those who have displayed the integrity necessary to earn them. As ethics also pertain to taking the PANCE, PANRE, or CAQ, the Code of Conduct applies to exam-taking procedures as well.

Examples of behavior prohibited by the Code of Conduct:

  • Cheating or other dishonest behavior that violates exam security before, during, or after an NCCPA exam
  • Irregular behavior
  • Submitting a document or testimony to the NCCPA containing misstatement or omission of facts in order to obtain or maintain a PA credential
  • Manufacturing, modifying, reproducing, distributing, or using fraudulent NCCPA certificates

How Should You Respond to an Allegation of Irregular Behavior?

When the NCCPA sends you notice of irregular behavior, you must provide a written response. What other steps should you take in this situation?

  1. Do not delete or throw away your test preparation materials. You may be tempted to simply get rid of anything that could prove your wrongdoing, but such an action will only hurt you later. Hang on to all your materials and let your student defense attorney-advisor review them.
  2. Contact an experienced student defense attorney. Even if you haven't made it to the appeals portion of the process yet—and your case may not get that far—you'll still need a qualified attorney to advise you. Your attorney can help you write your response letter at the start of the disciplinary proceedings, for example.
  3. Start gathering evidence attesting to your character. Good Hopeof your good character could include awards, certificates of achievement, reference letters from former employers/instructors, etc. If your student defense advisor has access to this kind of evidence, they can demonstrate that you're an honorable person.
  4. Comply with the NCCPA. Do not ignore their communications, letters, or requests for information. The problem will not just go away or resolve itself. Dealing with a charge of irregular behavior on a national certification exam can feel overwhelming. But if you contact a student defense attorney and seek advice on what to say, your chances of getting a favorable outcome are much higher.
  5. Do not try to represent yourself if you have an appeals hearing.CCPA takes irregular behavior concerning national exams as a grave matter. Simply going in front of the Review Committee, apologizing, and hoping for a dismissal of the case won't cut it. If they have reason to believe your behavior was irregular at all, they will not go easy on you. Hiring a student defense attorney to represent you shows that you're taking the matter seriously too.

Preparing for the Disciplinary Process

What should you keep in mind as the disciplinary process with the NCCPA unfolds?

  • Leave a paper trail: Write down everything and request everything in writing. Make copies of every document that might be relevant and keep your documents organized. If you have to mail or ship something, use certified mail and get a tracking number so you can ensure it arrives.
  • Don't lie: When the NCCPA initially contacts you, don't submit false information. The commission investigates you before making a decision, and if they find out you lied, they could inflict harsher penalties.
  • Sound professional: Remain professional and courteous in all your communication with the NCCPA, whether written or verbal. Your first statement is a crucial part of your defense, as it's the commission's first impression of you. Be clear and succinct. If you have trouble writing professionally, a student defense attorney can help you craft a statement.
  • Ask for your NCCPA record: The commission will review your record during their investigation, and the Review Committee will look at it during the appeals process.

There's a lot to take in after you've been notified of irregular behavior. You have to stay organized and act quickly—which isn't easy to do if you're worried. As a physician assistant student, you've poured time, money, and resources into your education and you don't want it all to get ripped away from you so easily. Attorney Joseph D. Lento has helped students across the country protect their rights during disciplinary action. If you want to protect your future medical career, contact the Lento Law Firm today at 888-535-3686.

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If you, or your student, are facing any kind of disciplinary action, or other negative academic sanction, and are having feelings of uncertainty and anxiety for what the future may hold, contact the Lento Law Firm today, and let us help secure your academic career.

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