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Prescribing & DEA Roadmap

Pennsylvania Nurse Practitioner Prescriptive authority

Separate professional authority, state registration and federal DEA steps.

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Showing findings with official source evidence. Check the conditions for each requirement and confirm your circumstances with the board.

Use the boxes to track your preparation. Checking an item does not verify compliance.

Who may prescribe

  • A CRNP in Pennsylvania may perform medical diagnosis or prescribe medical therapeutic or corrective measures in collaboration with a physician, within the act and subchapter.

    Applies when: For CRNPs certified by the Board and functioning in the expanded role.

    Source evidence
    1. 1. pacodeandbulletin.gov ↗
      *CRNP—Certified Registered Nurse Practitioner*—A professional nurse licensed in this Commonwealth who is certified by the Board in a specialty and who, while functioning in the expanded role as a professional nurse, performs acts of medical diagnosis or prescription of medical therapeutic or corrective measures in collaboration with a physician licensed to practice in this Commonwealth and in accordance with the act and this subchapter
    2. 2. pacodeandbulletin.gov ↗
      *CRNP—Certified Registered Nurse Practitioner*—A professional nurse licensed in this Commonwealth who is certified by the Board in a specialty and who, while functioning in the expanded role as a professional nurse, performs acts of medical diagnosis or prescription of medical therapeutic or corrective measures in collaboration with a physician licensed to practice in this Commonwealth and in accordance with the act and this subchapter
  • A CRNP with current prescriptive authority approval from the Board may prescribe, dispense and administer drugs and therapeutic or corrective measures consistent with the collaborative agreement and the CRNP specialty.

    Applies when: For drug-related authority, not CRNP certification alone.

    Source evidence
    1. 1. pacodeandbulletin.gov ↗
      Prescribing and dispensing parameters. (b) A CRNP with current prescriptive authority approval from the Board may prescribe, dispense and administer drugs and therapeutic or corrective measures consistent with the prescriptive authority collaborative agreement and relevant to the CRNP’s specialty from the following categories: (1) Antihistamines.

License and education prerequisites

  • Applicants for CRNP certification must hold a current, unrestricted Pennsylvania single state or multistate registered nurse license, or a multistate registered nurse license issued by another Compact state.

    Applies when: For CRNP certification applicants.

    Source evidence
    1. 1. pa.gov ↗
      As a condition for obtaining Certified Registered Nurse Practitioner certification applicants must hold either a current, unrestricted Pennsylvania single state or multistate registered nurse license or a multistate registered nurse license issued by another Compact state
  • The Board certifies a licensed registered nurse as a CRNP in a particular clinical specialty area, and national certification means passing a nurse practitioner national certifying examination in a specialty.

    Applies when: For CRNP certification and specialty credentialing.

    Source evidence
    1. 1. pa.gov ↗
      Certified Registered Nurse Practitioners; Qualifications.--(a) The board may certify a licensed registered nurse as a certified registered nurse practitioner in a particular clinical specialty area if the nurse satisfies the requirements established by this act and regulations promulgated by the board.
    2. 2. pacodeandbulletin.gov ↗
      *National certification*—Certification by a Board-recognized National certification organization which required passing a nurse practitioner National certifying examination in a specialty.
  • To obtain prescriptive authority approval, a CRNP shall complete at least 45 hours of course work specific to advanced pharmacology, completed within 5 years immediately preceding the application for initial prescriptive authority approval.

    Applies when: For initial prescriptive authority approval.

    Source evidence
    1. 1. pacodeandbulletin.gov ↗
      Authority and qualifications for prescribing, dispensing and ordering drugs. (b) To obtain prescriptive authority approval, a CRNP shall: (1) Successfully complete at least 45 hours of course work specific to advanced pharmacology in accordance with the following:
    2. 2. pacodeandbulletin.gov ↗
      (ii) The course work shall be at an advanced level above a pharmacology course required by a professional nursing (RN) education program. (iii) The course work shall have been completed within 5 years immediately preceding the date the applicant applies for initial prescriptive authority approval.

Collaboration and supervision

  • The prescriptive authority collaborative agreement is the written and signed agreement between a CRNP with prescriptive authority and a collaborating physician that sets out the details of their collaboration.

    Applies when: For CRNPs with prescriptive authority.

    Source evidence
    1. 1. pacodeandbulletin.gov ↗
      *Prescriptive authority collaborative agreement*—The written and signed agreement between a CRNP with prescriptive authority and a collaborating physician in which they agree to the details of their collaboration
  • A CRNP may collaborate only with physicians who hold a current license to practice in Pennsylvania.

    Applies when: For CRNP collaboration under the subchapter.

    Source evidence
    1. 1. pacodeandbulletin.gov ↗
      CRNP Practice. (a) A CRNP may collaborate only with physicians who hold a current license to practice in this Commonwealth. (b) When acting in collaboration with a physician as set forth in a collaborative agreement and within the CRNP’s specialty, a CRNP may: (1) Perform comprehensive assessments of patients and establish medical diagnoses
  • When acting in collaboration with a physician as set forth in a collaborative agreement and within the CRNP specialty, the CRNP may prescribe only as allowed by the agreement and subchapter.

    Applies when: For CRNPs acting in collaboration.

    Source evidence
    1. 1. pacodeandbulletin.gov ↗
      CRNP Practice. (a) A CRNP may collaborate only with physicians who hold a current license to practice in this Commonwealth. (b) When acting in collaboration with a physician as set forth in a collaborative agreement and within the CRNP’s specialty, a CRNP may: (1) Perform comprehensive assessments of patients and establish medical diagnoses
    2. 2. pacodeandbulletin.gov ↗
      Prescribing and dispensing parameters. (b) A CRNP with current prescriptive authority approval from the Board may prescribe, dispense and administer drugs and therapeutic or corrective measures consistent with the prescriptive authority collaborative agreement and relevant to the CRNP’s specialty from the following categories: (1) Antihistamines.

State controlled-substance authority

  • A CRNP may prescribe a Schedule III or IV controlled substance for up to a 90 day supply as identified in the collaborative agreement.

    Applies when: For CRNP controlled-substance prescribing under state rules.

    Source evidence
    1. 1. pacodeandbulletin.gov ↗
      (2) A CRNP may prescribe a Schedule III or IV controlled substance for up to a 90 day supply as identified in the collaborative agreement. (e) A CRNP may not delegate prescriptive authority.
  • A CRNP may not delegate prescriptive authority.

    Applies when: For CRNP prescriptive authority.

    Source evidence
    1. 1. pacodeandbulletin.gov ↗
      (2) A CRNP may prescribe a Schedule III or IV controlled substance for up to a 90 day supply as identified in the collaborative agreement. (e) A CRNP may not delegate prescriptive authority.
  • Pennsylvania nurse practitioner authority is exercised solely by the State Board of Nursing.

    Applies when: For Pennsylvania CRNP authority.

    Source evidence
    1. 1. pa.gov ↗
      nurse practitioners, by or pursuant to law or regulation shall, after the effective date of this subsection, be exercised solely by the State Board of Nursing.

Federal DEA requirements

  • DEA registration is contingent in part on the applicant's authorization in the state where the practitioner practices, and controlled-substance privileges and limits are determined by that state.

    Applies when: For practitioners seeking DEA registration.

    Source evidence
    1. 1. deadiversion.usdoj.gov ↗
      Since DEA's authority to register practitioners to dispense (including to prescribe) controlled substances is contingent, in part, upon the applicant's authorization in the state in which he or she practices, his or her controlled substance privileges and limits are determined by that specific state.
    2. 2. deadiversion.usdoj.gov ↗
      DEA relies on State licensing boards to determine whether a practitioner is qualified to dispense, prescribe, or administer controlled substances and to determine which schedules he/she may dispense, prescribe, or administer.
  • DEA regulations require a separate registration for each principal place of business or professional practice at one general physical location where controlled substances are dispensed.

    Applies when: For a practitioner with more than one practice location.

    Source evidence
    1. 1. deadiversion.usdoj.gov ↗
      DEA regulations require a separate registration for each principal place of business or professional practice at one general physical location where controlled substances are manufactured, distributed, imported, exported, or dispensed by a person.
    2. 2. deadiversion.usdoj.gov ↗
      21 CFR 1301.12(a), "A separate registration is required for each principal place of business or professional practice at one general physical location where controlled substances are manufactured, distributed, imported, exported, or dispensed by a person."
  • DEA's examples of mid-level practitioners include nurse practitioners authorized by the state in which they practice.

    Applies when: For DEA scope as applied to nurse practitioners.

    Source evidence
    1. 1. deadiversion.usdoj.gov ↗
      A mid-level practitioner means an individual practitioner, other than a physician, dentist, veterinarian, or podiatrist, who is licensed, registered, or otherwise permitted by the United States or the jurisdiction in which he/she practices, to dispense a controlled substance in the course of professional practice.
    2. 2. deadiversion.usdoj.gov ↗
      Examples of mid-level practitioners include, but are not limited to, health care providers such as nurse practitioners, nurse midwives, nurse anesthetists, clinical nurse specialists and physician assistants who are authorized to dispense controlled substances by the State in which they practice.

Training and monitoring

  • As a condition of biennial renewal of prescriptive authority approval, a CRNP shall complete a minimum of 16 of the 30 hours of Board-approved continuing education in pharmacology in the 2 years prior to renewal.

    Applies when: For CRNPs renewing prescriptive authority approval.

    Source evidence
    1. 1. pacodeandbulletin.gov ↗
      As a condition of biennial renewal of prescriptive authority approval, a CRNP shall complete a minimum of 16 of the 30 hours of Board-approved continuing education in pharmacology in the 2 years prior to renewal
    2. 2. pa.gov ↗
      If licensee has prescriptive authority approval, a minimum of 16 of the 30 hours of continuing education must be completed in pharmacology every two years
  • To renew certification every two years, a licensee must complete 30 hours of continuing education applicable to the CRNP specialty, including 2 hours of approved training in how to recognize and report child abuse.

    Applies when: For CRNP biennial renewal.

    Source evidence
    1. 1. pa.gov ↗
      ### Education Required for Biennial Renewal: To renew certification every two years, a licensee must complete 30 hours of continuing education applicable to the licensee's CRNP specialty, which must include 2 hours of approved training in how to recognize and report child abuse
  • For all DEA-registered practitioners except solely veterinarians, the CAA training attestation is one-time and applies on the first applicable DEA registration submission on or after June 27, 2023.

    Applies when: For DEA-registered practitioners, including nurse practitioners where DEA registration is sought.

    Source evidence
    1. 1. deadiversion.usdoj.gov ↗
      Answer: All DEA-registered practitioners, with the exception of practitioners that are solely veterinarians.
    2. 2. deadiversion.usdoj.gov ↗
      Answer: Beginning on June 27, 2023, practitioners will be required to check a box on their online DEA registration form—regardless of whether a registrant is completing their initial registration application or renewing their registration—affirming that they have completed the new training requirement.
    3. 3. deadiversion.usdoj.gov ↗
      Answer: The deadline for satisfying this new training requirement is the date of a practitioner's next scheduled DEA registration submission—regardless of whether it is an initial registration or a renewal registration—on or after June 27, 2023.
    4. 4. deadiversion.usdoj.gov ↗
      This one-time training requirement affirmation will not be a part of future registration renewals.
    5. 5. deadiversion.usdoj.gov ↗
      It should be noted that this is a one-time attestation and trainings can occur in classroom settings, seminars at professional society meetings, or virtual offerings.

Fees and renewals

  • The Board charges $95 for an application for prescriptive authority.

    Applies when: For CRNP prescriptive authority applications.

    Source evidence
    1. 1. pacodeandbulletin.gov ↗
      Fees. (a) The following application fees are charged by the Board for services to licensees and applicants: CRNP Certification—Board-approved nursing education program graduates $100 CRNP Certification—graduates of out-of-State nursing education programs $140 Verification of certification $45 Verification of certification with history $50 Application for prescriptive authority $95
  • The Board charges $81 for biennial renewal of CRNP certification and $41 for biennial renewal of prescriptive authority approval.

    Applies when: For CRNP renewal.

    Source evidence
    1. 1. pacodeandbulletin.gov ↗
      Fees. Each additional application for prescriptive authority $45 Restoration of CRNP certification after suspension or revocation $60 Restoration of CRNP prescriptive authority after suspension or revocation $60 (b) The following renewal fees are charged by the Board to support its operations: Biennial renewal of CRNP certification $81 Biennial renewal of prescriptive authority approval $41
  • Each additional application for prescriptive authority is $45.

    Applies when: For additional prescriptive authority applications.

    Source evidence
    1. 1. pacodeandbulletin.gov ↗
      Each additional application for prescriptive authority $45 Restoration of CRNP certification after suspension or revocation $60 Restoration of CRNP prescriptive authority after suspension or revocation $60 (b) The following renewal fees are charged by the Board to support its operations: Biennial renewal of CRNP certification $81 Biennial renewal of prescriptive authority approval $41

Applications and documents

  • Applicants for certification shall pay the fee and submit an application form provided by the Board for review and approval.

    Applies when: For CRNP certification applicants.

    Source evidence
    1. 1. pacodeandbulletin.gov ↗
      Application for certification. (a) Applicants for certification shall pay a fee set forth in § 21.253 (relating to fees), and submit an application form provided by the Board to the Board for its review and approval.
  • To obtain prescriptive authority approval, a CRNP must complete the 45-hour advanced pharmacology coursework and submit an application for prescriptive authority approval to the Board.

    Applies when: For initial prescriptive authority approval.

    Source evidence
    1. 1. pacodeandbulletin.gov ↗
      Authority and qualifications for prescribing, dispensing and ordering drugs. (b) To obtain prescriptive authority approval, a CRNP shall: (1) Successfully complete at least 45 hours of course work specific to advanced pharmacology in accordance with the following:
    2. 2. pacodeandbulletin.gov ↗
      (2) Submit an application for prescriptive authority approval to the Board
  • CRNPs with prescriptive authority are required to submit their prescriptive authority collaborative agreements on a form provided by the Board.

    Applies when: For CRNPs with prescriptive authority.

    Source evidence
    1. 1. pacodeandbulletin.gov ↗
      The Board does not believe it is necessary to repeat these statutory provisions because CRNPs are required to submit their prescriptive authority collaborative agreements on a form provided by the Board and the form includes the three provisions found in section 8.3(a)(2)(i)—(iii) of the act, as well as additional information that must be submitted to the Board

Authorities and sources

  • Pennsylvania State Board of Nursing.

    Applies when: Primary state authority for CRNP certification and prescriptive authority.

    Source evidence
    1. 1. pa.gov ↗
      nurse practitioners, by or pursuant to law or regulation shall, after the effective date of this subsection, be exercised solely by the State Board of Nursing.
    2. 2. pa.gov ↗
      Certified Registered Nurse Practitioners; Qualifications.--(a) The board may certify a licensed registered nurse as a certified registered nurse practitioner in a particular clinical specialty area if the nurse satisfies the requirements established by this act and regulations promulgated by the board.
  • DEA registration FAQs and the MATE Act FAQ are official DEA sources for federal registration and training issues.

    Applies when: For federal DEA topics.

    Source evidence
    1. 1. deadiversion.usdoj.gov ↗
      Since DEA's authority to register practitioners to dispense (including to prescribe) controlled substances is contingent, in part, upon the applicant's authorization in the state in which he or she practices, his or her controlled substance privileges and limits are determined by that specific state.
    2. 2. deadiversion.usdoj.gov ↗
      Answer: As a condition of registration, the new training requirement in section 1263(a) of the CAA went into effect on June 27, 2023, and applies to all qualified practitioners when they apply for a new registration or a renewal of registration on or after that date.
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