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Prescriptive Authority FAQ

ARNP WITH OR WITHOUT PRESCRIPTIVE AUTHORITY APPLICATION PACKET

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PRESCRIPTIVE AUTHORITY FAQ: WASHINGTON CRNA'S

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Click here to view CRNA Controlled Substance Protocols.

PRESCRIPTIVE AUTHORITY FOR WA CRNA'S

Washington surely leads the nation in the ability of ARNPs and CRNAs to practice independently. This distinction often leads to some confusion about the requirements for Washington CRNAs to have prescriptive authority and DEA registration in order to practice. The FAQ's document provided below attempts to dispel some of the misconceptions regarding our practice and to direct the reader to the appropriate resources for policy development for their facilities.

Much of the confusion stems from definitions. Many people, physicians and hospital administrators included, do not understand the laws and regulations affecting selecting, ordering, administering, dispensing, and prescribing legend drugs and controlled substances. Each of these terms has a specific meaning in the law, and thus one must have a clear understanding of what it is one wishes to do with a medication before consulting the laws. Please review the definitions before consulting the questions as they will help you tremendously in figuring out where you are.

In addition, it is important to remember that both State and Federal laws and regulations impact our practice. In cases where one or the other is more restrictive, that law or regulation will apply.

CRNA & DEA NUMBER

July 30, 2012

Dear Colleagues,

As with other CRNA practice issues, definitions are scrutinized and reinterpreted. The most current issue is whether or not CRNAs need a personal DEA number to practice anesthesia. This question has come up recently in other states and CRNAs there are now required to have them.

This has happened abruptly, and the CRNAs have been unprepared.

In Washington State, we have previously been covered by RCW 18.79.240 to "select, order, and administer" under "facility based protocols." The DEA has specifically exempted CRNAs in the past from getting a personal DEA number or prescriptive authority while working under a facility DEA number according to a written protocol, unless writing prescriptions. Interpretation of this exemption could change.

Should you be required to obtain a personal DEA number, you will first need prescriptive authority (RxA). The state requirement for RxA requires an initial $92 application fee and 30 pharmacotherapeutic contact hours in the 24 months preceding application. These are in addition to the 30 contact hours required every two years, for ARNP relicensure.

Once you have RxA, only 15 additional pharmacotherapeutic credits are required in addition to the 30 for ARNP licensure every two years, and the renewal fee for ARNP licensure with prescriptive authority is the same as without prescriptive authority.

To qualify as a pharmacy credit, the course must be acceptable to the AANA as a general CE. AANA does not designate pharmaceutical contact. To meet the state requirement, if the title is not self-explanatory, include a brief description in your own words of how the course material addresses pharmacotherapeutics in your job.

The prudent and wise path recommended by the WANA Board of Directors is to immediately start the process to obtain both Washington State prescriptive authority and a Federal DEA number. Below is the link you will need to get started.

If you have questions, feel free to call any of the WANA Board members.

For more information, select from the links below: