practitioner, but a corresponding responsibility rest with the pharmacist who fills the prescription (DEA, 2010b). Laws and regulations vary from state to state; thus, the prescribing clinician must ensure that the prescription follows all requirements. Prescriptions for controlled substances must be written in indelible ink or typewritten. The controlled substance prescription must be dated and signed on the date issued. Additional requirements for a controlled substance prescription include the following: ● Patient’s full name and address. ● Prescriber’s full name, address, and DEA registration number. ● Drug name. ● Strength. ● Dosage form. ● Quantity prescribed. ● Directions for use. ● Number of refills authorized (not applicable for Schedule II drugs). ● Prescriber’s signature. ● Date issued. practitioners may prescribe Schedules III, IV, and V controlled substances in all states. However, state laws to determine NPs’ prescriptive authority differ considerably. Some states allow full practice for NPs where they may prescribe medications with a level of autonomy comparable to physicians. On the other hand, many states restrict NP prescriptive authority and require physician supervision. The American Association of Nurse Practitioners categorizes state practices into restricted, reduced, and complete practice authority (AANP, 2022). Twenty -two states allow the full practice, where NPs have similar prescriptive authority to physicians. In 16 states, NPs have reduced authority and work alongside physicians in joint practice agreements. States with reduced prescriptive authority have varying limitations on medications that NPs can prescribe to patients. NPs are categorized as restricted in the remaining 12 states and require physician supervision or delegation when prescribing controlled substances. Each healthcare provider should verify their state’s legal requirements and regulations for prescribing and dispensing controlled substances. There are a variety of restrictions imposed on NPs, including (DEA, 2022): ● Limits to the allowed controlled substance schedules prescribed. ● Required controlled drug substance registration or licensure. ● Required written agreement between physician and nurse practitioner. ● Limits on the number of controlled substances prescribed. ● Limits on the daily supply of a prescribed controlled substance. ● Limits on controlled substances prescribed in the healthcare setting.
The regulations provide that “the secretary or agent may prepare [a] prescription for the signature of a practitioner, but the prescribing practitioner is responsible in case the prescription does not conform in all essential respects to the law and regulations” (DEA, 2010b). The CSA does not permit a prescribing practitioner to delegate to an agent or any other person the practitioner’s authority to issue a prescription for a controlled substance. A practitioner acting in the usual professional practice must determine a legitimate medical purpose for a controlled substance prescription; an agent may not make this determination. Dental Considerations: T he American Dental Association (2018). became the only major health professional organization to support mandatory continuing education on safe prescribing of controlled substances https://www.ada. org/-/media/project/ada- organization/ada/ada-org/files/ resources/practice/legal-and-regulatory/faq_mate-act.pdf?rev =2d62d028e6cf49869624d1cfa4e442c3&hash=A7D5EB01BC1 9DA0ADC5968E336996DA5 ● Required number of controlled substances–oriented continuing education hours. Self-Assessment Quiz Question #2 Interns, residents, staff physicians, and advanced practice providers may prescribe controlled substances under the registration of the hospital, provided that: a. The dispensing, administering, or prescribing is in the ordinary course of practice. b. Practitioners are authorized to do so by the state in which they practice. c. The hospital or institution has verified that the practitioner is permitted to dispense, administer, or prescribe controlled substances within the state. d. The practitioner acts only within the scope of employment in the hospital or other institution. e. All of the above. The John S. McCain Opioid Addiction Prevention Act (S.724, 116) established a new registration requirement for licensed clinicians to prescribe controlled substances in Schedules II, III, or IV. Specifically, a practitioner must agree to limit the supply of opioids prescribed for the initial treatment of acute pain as a condition of obtaining or renewing a registration through the DEA. An opioid approved and prescribed for addiction treatment is not subject to the limit https://www.govtrack.us/ congress/bills/116/s724/summary. Evidence-based strategies can assist in the prevention of substance use disorder. 911 good Samaritan laws aim to reduce barriers for individuals who notify authorities about overdoses through limited immunity and other drug charges (CDC, 2022). Syringe programs are community-based programs that provide links to access medical, mental health, and social services; treatment; and drug injection equipment (CDC, 2022). “conform[s] in all essential respects to the law and regulations” rests upon the prescribing practitioner. As noted, however, a pharmacist is responsible for dispensing controlled substances. Further, “A corresponding liability rests upon the pharmacist, including a pharmacist employed by a central fill pharmacy, who fills a prescription not prepared in the form prescribed by DEA regulations” (DEA, 2018c). Therefore, the pharmacist must carefully review all controlled substance prescriptions to ensure the drug meets all legal requirements for a valid prescription. In addition, pharmacists must inquire about the satisfaction of any or all of the legal requirements for a valid prescription
Prescribing controlled substances: Nurse practitioner requirements While the CSA allows NPs to prescribe controlled substances, each state has different regulations (DEA, 2022). Nurse
Considerations for healthcare practitioners prescribing controlled substances While the laws vary from state to state, no prescribers, including nurse practitioners, should prescribe controlled substances
for themselves or a family member. Prescribing for family members may have legal and ethical implications. Pharmacists will likely question a prescription written for an individual with the same name as the prescriber who signed the prescription. Patients may attempt to fill prescriptions in a different state for various reasons. Regardless of the method of transmission of a controlled substance prescription—by hand delivery, facsimile, phone call, or electronically—DEA regulations make it clear that the legal responsibility for issuing a valid prescription that
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