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FAQ Controlled Substances Answers
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Category - Controlled Substances

 

QUESTION – Are there any restrictions for PAs ordering and administering controlled substances?

ANSWER – No.
PAs can order and administer a schedule II (through V). Schedule II - V drug.  Medications ordered for immediate administration are handled as any other order such as non-scheduled medications. Ordering schedule drug medications in the hospital or psychiatric setting does not require DEA registration but a state controlled substance license is required.

 

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QUESTION – Can a Physician Assistant prescribe controlled substances?

ANSWER – Yes.

Physician Assistants are now defined in Public Act 379 of 2016 as independent "Prescribers" (within a practice agreement).  This is an exclusive designation in law that, in addition to PAs, includes physicians, dentists, veterinarians, optometrists (limited to therapeutic pharmaceutical agents) and advance practice registered nurses (excluding schedule 2-5 which must be delegated by a physician according to Public Act 499 of 2016).  

Specific prescribing exclusions for PAs, however, may be detailed within the practice agreement between the PA and their participating physician

 

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QUESTION – Are there any restrictions for PAs prescribing Schedule II - V Drugs?

ANSWER – No* (See Suboxone/Buprenorphine and Medical Marijuana FAQs below) .  

 

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QUESTION - Does this mean that a PA must now obtain their own state Controlled Substance License (CSL) and DEA license?
 
ANSWER - Yes

A PA who intends to prescribe controlled substances must now purchase a State of Michigan Controlled Substance License (CSL) in addition to maintaining their DEA license.  Go to the links below to apply now for the State of Michigan Controlled Substance License and a DEA License. 

CSL forms are available at http://www.michigan.gov/documents/lara/lara_pharm_cs_app_0314_450189_7.pdf

DEA forms are available at www.deadiversion.usdoj.gov/drugreg/reg_apps/onlineforms_new.htm
 

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QUESTION - When do I need to renew my Controlled Substance License license?

ANSWER - A state controlled substance license expires after one, two or three years depending upon your application parameters (see CSL application form).

 

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QUESTION - Can I submit the renewal application for my controlled substance license before submitting the renewal for my professional license?

ANSWER - The professional license must be renewed first. If the Department receives the controlled substance renewal but not the professional license renewal, neither license will be renewed.

 

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QUESTION - Do I have to renew my controlled substance (CS) license if I am not currently living in Michigan and my professional license is active? Can I renew my CS license later if I move back to Michigan?

ANSWER - You do not have to renew your CS license unless you are currently prescribing controlled substances in Michigan under the practice agreement. You can get your CS license reinstated at a later time as long as your professional license is active in Michigan. You would do this by submitting a Controlled Substance Application to the Department. You can download the most current application at www.michigan.gov/bpl under Health Licensing (Apply & Renew) and select Pharmacy from the listed professions.

 

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QUESTION - Is a CSL transferrable to other locations?

ANSWER - Yes.

If you prescribe controlled substances at more than one location, you only need one controlled substance license.

 

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QUESTION - When do I need to renew my DEA license and is a DEA license transferrable to other locations?

ANSWER - The DEA license is renewable every three years and is transferable by a PA going from one practice to another.


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QUESTION – If a PA suspects that a new patient is “shopping around” for controlled substances, can a PA find out what prescriptions that patient has filled?

ANSWER – Yes.  

Michigan has a prescription/pharmacy database where most pharmacies report prescriptions that are filled. PAs are allowed to access the Michigan Automated Prescription System (MAPS) online, but a PA must first email the systems administrator to set up an account.

 

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Can PAs prescribe Suboxone (buprenorphine)?

ANSWER - Yes.

NPs and PAs who have completed the 24 hours of required training may seek to obtain a DATA 2000 waiver for up to 30 patients by completing the Waiver Notification Form....These waiver applications are forwarded to the Drug Enforcement Administration (DEA), which will assign the NP or PA a special identification number. DEA regulations require this number to be included on all buprenorphine prescriptions for opioid dependency treatment, along with the NP’s or PA’s regular DEA registration number."  (See link below).

http://www.asam.org/quality-practice/practice-resources/nurse-practitioners-and-physician-assistants-prescribing-buprenorphine

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QUESTION - Can PAs prescribe Medical Marijuana?

ANSWER - No

PAs were not included in Michigan law as prescribers for this drug.  
 

 

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