PRESCRIBING AUTHORITY

What is Controlled Substance Prescribing Authority?

• Neither the CSA nor the DEA regulations confer authority to prescribe controlled substances on a person who did not otherwise have the authority to do so under either state or federal law

• (Prescribing authority is federal but driven by PA law)

Who has Full Prescribing authority w/in scope of practice (no quantity limits)?

• Physicians

  • MD

  • DO

• Medical Interns, Residents, & Foreign-Trained Physicians

  • Caveat- limited by the scope of the facility where they are assigned

• Ophthalmologists

• Dentists

• Psychiatrists

• Podiatrists

• Veterinarians

• (Pharmacists in PA cannot prescribe) (These people must write w/in scope of practice)

Who has Limited Independent Prescribing authority?

• Optometrist

  • Must have a Therapeutic License

  • Max 6 week supply of CIII-V

  • No CIIs, except codeine & hydrocodone combination products limited to a 72-hour supply

Who has Limited Dependent Prescribing authority?

• Midlevel Prescribers

  • Physician Assistants

    • Must have a collaborative agreement w/ a physician (who oversees)

    • CII

      • May dispense up to a 72-hour dose (initial therapy)

      • Must notify the supervising physician w/in 24 hours from the issuance of the prescription

      • May write a prescription for a CII controlled substance for up to a 30-day supply if it was approved by the supervising physician for ongoing therapy

      • Prescription must clearly state on its face that it is for initial or ongoing therapy

    • CIII-V- full authority

• Certified Registered Nurse Practitioner

  • Must have a collaborative agreement w/ a physician

  • CII- 30 day supply

  • CIII-IV- 90 day supply

  • CV- full authority

• Nurse Midwife

  • Must have a collaborative agreement w/ a physician

  • CII- 72-hour supply

  • CIII-IV- 30 day supply

  • CV- full authority

Who has No Prescribing Authority?

• Psychologists

• EMTs

• Chiropractors

• Pharmacists in PA