Scope of Practice

Kansas Medical Assistants Performing Sonography

Donald Balasa

I recently received the following question from a manager in Kansas:

We have a new sports medicine physician joining us, [who] will be doing procedures with platelet-rich plasma. He [wants] his medical assistant to draw the blood from the patient and for [the medical assistant] to be trained to use an ultrasound if needed to find a vein.

My perception is that using the ultrasound would be outside of [medical assistants’] scope of practice.

Would you be able to provide any guidance on this?

Please see my legal opinion letter for Kansas. Kansas law does not answer your question.

Also, it appears that Kansas does not license diagnostic medical sonographers. In other words, Kansas law does not require diagnostic medical sonographers to have specified education or a diagnostic medical sonography credential to work as a sonographer.

I suggest that you ask your employer’s malpractice carrier whether it would cover any negligence by medical assistants in performing this task. This opinion should be in writing.

continuing education, The AAMA

Identifying and Responding to Human Trafficking: The Medical Assistant’s Role

Donald Balasa

In January 2026, the American Association of Medical Assistants (AAMA) will release a comprehensive and current self-study course called “Identifying and Responding to Human Trafficking: The Medical Assistant’s Role.” This course was created in anticipation of the enactment of Texas legislation that will require medical assistants to successfully complete a training course on identifying, assisting, and reporting victims of human trafficking.

The following is an excerpt from Module 5, “Appropriate Documentation and Reporting Protocols: Human Trafficking Laws, Information in the Electronic Health Record, and Protecting Patient Privacy,” which I authored:

There is a strong consensus in the United States that trafficked persons should be protected to the fullest extent of the law. Researchers and policymakers, however, have pointed out the potential conflict between mandatory human trafficking (HT) reporting laws and laws that safeguard patient privacy (e.g., the Health Insurance Portability and Accountability Act, or HIPAA). In addition, the health care field continues to wrestle with the question of how much information should be included in the electronic health record (EHR) of those patients who may be trafficked. 

These issues confront medical assistants interacting with patients who are (or may be) ensnared in the insidious web of human trafficking.  

Scope of Practice

Limitations to Tasks Delegable to Medical Assistants

Donald Balasa

Occasionally I receive questions from medical assistants who have been told by a provider or another superior that the law in their state allows medical assistants to perform any task that is delegated to them by the overseeing/delegating licensed provider. This is not correct.

There are limitations on tasks that may be assigned to unlicensed health professionals such as medical assistants, even if these limitations are not stated directly in a statute or regulation:

  • Medical assistants must not perform any task in which they are not knowledgeable and competent. A medical assistant should inform the overseeing/delegating provider, or another appropriate superior, that they are not competent in a certain task and therefore are not able to perform it safely. The medical assistant should also state that they are willing to learn the task.
  • Medical assistants must not perform tasks and procedures that are restricted in state law to other health professionals. Examples include the full range of physical therapy and acupuncture, as well as tasks and procedures limited in law to certain licensed professions.
  • Medical assistants are not permitted to undertake tasks that require the exercise of independent clinical judgment or the making of clinical assessments, evaluations, or interpretations.
Scope of Practice

Medical Assisting Scope of Practice for Vaccine Administration in Arkansas

Donald Balasa

I recently received the following inquiry from Arkansas:

We have a laboratory that is asking if medical assistants are permitted to administer vaccines to patients who have come into the facility for the purpose of lab tests [and] decide to get an immunization while they are at the facility.

No physicians, PAs [physician assistants,] or APRNs [advanced practice registered nurses] are on site.

To answer this question, see the Arkansas statute and rule that permit physicians to delegate to unlicensed personnel such as medical assistants the administration of certain types of medications, including by certain types of injections. Note that the administration of injectable substances (including vaccines) may only be done under a physician’s authority and supervision and in the delegating physician’s practice (or other delivery setting).

Also see the advanced practice registered nurse and the physician assistant bills that were enacted in 2025. Note that unlicensed personnel such as medical assistants may be delegated the administration of injections (including vaccines) only under the supervision of an APRN (such as a nurse practitioner) or a PA and only in the clinical setting in which the nurse practitioner and the PA are practicing.

Based on these documents, my legal opinion is that Arkansas law does not permit unlicensed personnel such as medical assistants to administer vaccines in the setting described. Medical assistants are not permitted to assess a patient who has come to the facility for phlebotomy and determine whether the patient should receive a vaccine.

Scope of Practice

Legality of California Medical Assistants as Physical Therapy Aides

Donald Balasa

I recently received the following question:

Can a medical assistant in California provide physical therapy exercises to patients in an ambulatory clinic [if they are] assisting a licensed physical therapist?

Medical assistants who are assisting a physical therapist are functioning as physician therapy assistants or aides. I have found in California law that a physical therapy aide is unlicensed.

So, another way to phrase the original question is by asking whether a physical therapy aide can provide physical therapy exercises under the authority and supervision of a physical therapist. If the answer is yes, then the medical assistant would be functioning as an unlicensed physical therapy aide.

This kind of question is best directed to the Physical Therapy Board of California: 

Main Line: 916/561-8200

California Toll Free Line: 800/832-2251

Contact Us Form: https://www.ptbc.ca.gov/about_us/contact_us/

The AAMA reached out to the board to ask whether an unlicensed health worker is permitted to provide physical therapy exercises to a patient under the authority of a licensed physical therapist. Notably, we did not use the phrase “medical assistant.”

The board responded in the affirmative as long as there’s supervision:

Yes, [an unlicensed health worker (e.g., an unlicensed physical therapy aide) is permitted to provide physical therapy exercises to a patient under the authority and supervision of a licensed physical therapist], as long as the aide is at all times under the supervision of the physical therapist.

See California Laws and Regulations Related to the Practice of Physical Therapy:

2630.4. Physical therapy aide

(a) A “physical therapy aide” is an unlicensed person, at least 18 years of age, who aids a licensed physical therapist consistent with subdivision (b).

(b) The aide shall at all times be under the supervision of the physical therapist. An aide shall not independently perform physical therapy or any physical therapy procedure. The board shall adopt regulations that set forth the standards and requirements for the supervision of an aide by a physical therapist.

(c) Physical therapy aides shall not be independently supervised by a physical therapist license applicant, as defined in Section 2639, or a physical therapist student, as defined in Section 2633.7.

(d) This section does not prohibit the administration by a physical therapy aide of massage, external baths, or normal exercise not a part of a physical therapy treatment.