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Mid-Level Practitioner Controlled Substance
Originally published in the February 2012 Missouri Board of Pharmacy Newsletter.
The Bureau of Narcotics and Dangerous Drugs (BNDD) is now issuing controlled substance registrations to advanced practice registered nurses (APRNs) and physician assistants (mid-level practitioners). As of December 1, 2011, these mid-level practitioners are authorized to prescribe controlled substances, as authorized by Missouri law. To assist in compliance, BNDD has issued the following general guidance:
- Mid-level practitioners must be in a collaborative or supervision agreement with a physician who also has a current BNDD and Drug Enforcement Administration (DEA) registration. Mid-level practitioners may not purchase, stock, dispense, or administer controlled substances independently.
- Mid-level practitioners may prescribe controlled drugs in Schedules III, IV, and V only. There is no authority for Schedule II drugs.
- Like other prescribers, mid-level practitioners may not prescribe, administer, or dispense controlled drugs to themselves.
- Mid-level practitioners may not prescribe controlled drugs to family members. “Family” is defined in the state medical board’s Rule 20 CSR 2150-5.100(3)(G)(10) as a spouse, parent, grandparent, greatgrandparent, child, grandchild, great-grandchild, brother, sister, aunt, uncle, nephew, niece, mother-in-law, father-in-law, brotherin-law, sister-in-law, daughter-in-law, or son-in-law. Adopted and step family members are also included in the definition of “family.”
- Out-of-State Practitioners: Pursuant to Section 195.060.1, RSMo, Missouri pharmacies may in good faith dispense controlled drug prescriptions from out-of-state practitioners, as long as the prescriptions were written in compliance with the laws of the applicable state.
Difference in Schedule III Prescribing Quantities
- APRNs: When prescribing a Schedule III opiate/narcotic, APRNs are limited to a 120-hour (five-day) supply with no refills on the prescription. Section 334.104.2, RSMo, gives APRNs normal prescribing authority for non-opiate/narcotic Schedule III drugs.
- Physician Assistants: Physician assistants are limited to a 120-hour (five-day) supply for all Schedule III drugs, with no refill. These practitioners may, however, issue an entirely new prescription after five days that would generate a new prescription and new prescription number. According to BNDD, these would be considered new prescriptions and not refills.
Change in Labeling Requirements
Section 195.100, RSMo, contains amended labeling requirements for controlled drug prescriptions issued by mid-level practitioners.
Generally:
- The label on the prescription must document both the names of the prescribing mid-level practitioner and his or her supervising or collaborating physician. If the physician’s name is not provided, the pharmacy may call the prescriber and document the name. Note: This pertains to “prescriptions” and not to internal drug “orders” for inpatients of a licensed hospital.
- Physician assistants must document both their Missouri BNDD number and DEA number on prescriptions. The revised statutory requirements can be found in §334.104 (APRNs) and §334.747, RSMo (physician assistants). Additional compliance information can be found on BNDD’s Web site.
