SECTION IV. - BOARD POLICY Prescriptive Authority for ...
SECTION IV. - BOARD POLICY Prescriptive Authority for Physician Assistants
POLICY: It is the policy of the Board of Licensure in Medicine that the Board will not authorize blanket
prescribing of scheduled substances from hospital emergency departments by physician assistants.
It is the policy of the Board that Physician Assistants and Advanced Practice Nurses, working under delegation,
when working in a hospital setting, may order and dispense schedule II drugs as authorized in their written Plan of
Supervision, including emergency department analgesic starter packs (as defined by emergency department
BOARD OF LICENSURE IN MEDICINE
Guidelines for Granting PA Schedule II Prescription Authority
September 9, 2003
The Board of Licensure in Medicine has accepted, with modifications, the recommendations of the Physician
Assistant Advisory Committee dated June 3, 2003 regarding new guidelines which could be used in the evaluation
of Physician Assistant (PA) requests for authorization to prescribe schedule II drugs.
• The committee recommended that, following specific guidelines, the board should continue to judge
individual requests to prescribe schedule II drugs according to specific need rather than give “blanket”
authorization to all PA’s. It also concluded that application should be made using a proposed amendment
to the Plan of Supervision (POS), with that document including relevant detail regarding what types of
drugs may be prescribed, to whom, and in what circumstances.
• The committee felt that based on the required curriculum of modern PA training, every PA should be
presumed to be adequately trained and capable of managing schedule II pharmaceuticals within their
• Finally, the committee recommends that any PA and Primary Supervising Physician (PSP) who believe that
the ability to prescribe schedule II drugs is essential to their practice should apply to the Board for authority
to prescribe schedule II drugs according to details specified in the submitted POS.
PLAN OF SUPERVISION GUIDELINES
Guidelines for necessary detailed information to be included in the POS amendment submittal when schedule II
drug prescription authority is being sought include the following. The submittal should be on the form prescribed by
1. A detailed description of the practice setting which will clearly demonstrate the need for the PA to
prescribe schedule II drugs for the particular practice.
a. PA’s may prescribe schedule II drugs for the treatment of acute and/or chronic pain syndromes and or
behavioral/psychiatric conditions in which schedule II drugs are indicated. The POS should
implement the Board’s Rule Chapter 11: Use of Controlled Substances in the Treatment of Pain”.
b. This authority should exclude the use of narcotics for the treatment of narcotic addiction.
2. A specific list of the types of medication to indicate which drugs are commonly prescribed in the practice.
This list should include, by drug type, an approximate frequency of prescription of the drugs to show the
level of necessity of schedule II’s in the particular practice.
3. A detailed description of the PA’s current competence base derived from Continuing Medical Education
(CME), other formal training, and knowledge from work with the supervising physician; and a detailed
plan of education to maintain competence, to show knowledge of use and management of schedule II’s.
Category 1 CME specific to the drug types proposed in the POS should have been completed within six (6)
months prior to the application. The POS will also include a plan for future category 1 CME to maintain
4. A counter signature attesting to agreement and support of the POS by the PSP. An onsite copy of the POS
should include the signatures of all secondary supervising physicians with a clear delineation of schedule II
prescribing supervision responsibilities.
5. The request for authority to prescribe schedule II drugs shall be renewed every two years from the time
granted, unless interim changes are needed.
REQUEST ACTION PROCESS
The process for requesting, reviewing, and granting authority to prescribe schedule II drugs includes the following
1. Requests for authorization to prescribe schedule II drugs should be submitted by the PA and the PSP by a
letter of request, including a proposed POS detailing the need and practice structure to assure patient safety
and appropriate treatment.
2. Any PA and PSP who believes that the ability to prescribe schedule II drugs is essential to their practice
should be allowed authority to prescribe schedule II drugs according to details specified in the submitted
3. PA’s will be bound by specific criteria established by the board regarding their POS agreement. Within the
POS, specific guidelines will be documented in detail concerning when the prescribing of schedule II drugs
are considered necessary within the practice.
4. If the board finds the criteria are sufficiently met within the POS, the board may grant the PA limited
schedule II prescription authority as defined in the submitted POS.
5. Submit the application fee as specified in a published fee schedule.
ATTACHMENT TO PLAN OF SUPERVISION
Proposed Effective date: _________________
This proposed addition to our original Plan of Supervision intends to include the ability of the Physician Assistant
(PA) to prescribe certain schedule II drugs under the following conditions:
1. Practice setting description (in detail, why is schedule II needed)
a. acute or chronic pain
b. psychiatric conditions, including Attention Deficit Hyperactivity Disorder (ADHD)
2. List each medication to be used, by type, and the anticipated frequency of use.
2. Describe the training and knowledge base of the PA, the plan for continuing education related specifically
to the drugs being proposed for use, and the plan for supervision/monitoring:
4. Every situation in which schedule II drugs are prescribed must be fully supervised/monitored
Describe the plan for supervision/monitoring.
This proposal is jointly agreed to and submitted by:
PA-C Primary Supervising Physician
Agrees and Supports
Date: ______________________________ Date: ______________________________
(See also - SECTION I ADVISORY RULINGS PHYSICIAN ASSISTANTS ORDERING SCHEDULE II
Effective Date: November 9, 1999
Revision date: February 10, 2004
Revision date: October 6, 2005
HISTORY: In 1995 the board, responding to a letter of inquiry from Pen Bay Medical Center, stated in a letter
interpreting chapters 2 and 3 of the board rules, that Physician Assistants and Nurse Practitioners (then jointly
referred to as physician extenders) could order and administer schedule II narcotics to hospital inpatients under the
assumption that access to a qualified physician was readily at hand and that supervision of the Extender’s actions
were both supervised and carefully reviewed after the fact through quality assurance review processes. In 1999 the
Board responding to a letter of inquiry by Maine Coast Memorial Hospital, added that a PA working in the
Emergency Department could order and dispense schedule II analgesics, including the dispensing of medication
“starter packs” so long as the contents of medication starter packs were delineated in Emergency Department
protocols and included only enough medication to allow the patient sufficient time to seek a licensed physician for
further diagnosis, treatment plan, and prescription of appropriate medications by a licensed physician. An
increasing number of requests for special consideration by individual physician assistants and their supervising
physicians has lead to the need for clear guidelines when considering specific requests.
In October of 2003, The Board of Licensure in Medicine replaced its decision guidelines. The earlier version read:
Schedule II prescribing shall be reviewed and authorized on a case by case basis as called for in Board Rules. In
reviewing specific requests by Physicians Assistants and Advanced Practice Nurses working under delegation for
the authority to prescribe schedule II drugs, the Board shall consider the following criteria in assessing the
appropriateness of the request:
1. Travel distance or lack of access to a licensed physician by the patient or the PA.0.
2. Training and general competence of the Physician Assistant.
3. Specific training and supervision management by the supervising physician.
4. Clearly identified protocols in the written Plan of Supervision.
5. Other situation specific facts or particular needs that will improve patient access to critically needed
medications, while assuring the protection of the health and safety of the public.
On October 6, 2005 an editorial revision was made by staff. Item 5 under “Request Action Process” was added. It
was not submitted for Board approval since it was merely an instructional statement on a form of a current standing
expectation that a fee shall be submitted with the application.