Information Bulletin

DRUG ORDERS by PHYSICIAN ASSISTANTS

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Current law authorizes physician assistants to write and sign drug orders when authorized to do so by a supervising physician. If the supervising physician authorizes the physician assistant to issue drug orders for controlled substances, the physician assistant must obtain a federal DEA number with the federal Drug Enforcement Agency. The Pharmacy Law authorizes pharmacists to dispense drugs or medical devices, including controlled drugs, based on a physician assistant's written drug order.

The following describes the primary provisions of the laws that relate to drug orders by physician assistants:

1. Drug Orders

Section 3502.1 of the Business and Professions Code permits physicians to grant authority to PAs to issue written "drug orders" for medication and medical devices that can be filled by pharmacists. When transmitting a supervising physician's prescription via a drug order, "the physician assistant is acting on behalf of and as an agent for a supervising physician and surgeon." A drug order means an order for medication which is dispensed to or for a patient and the order is issued and signed by a PA.

Any prescription transmitted or carried out by a PA, whether by dispensing prepackaged drugs or with an oral or written drug order, is subject to a reasonable quantitative limitation consistent with customary medical practice in the supervising physician's practice.

Basis for Drug Order

The physician's prescription when transmitted by a PA, or issued as a drug order by the PA, for any patient cared for by the PA, must be based either on a written, practice specific formulary and protocols adopted by the supervising physician, or shall be approved by the supervising physician before it is filled or carried out.

A drug order for drugs not listed in the practice's protocols and formulary may only be issued by the PA with advance authorization from the supervising physician for the specific patient. (A record of the physician's oral authorization for a drug order should be entered into the patient's medical record by the PA.)

A physician assistant may only administer, provide or transmit a drug order for Schedule II through Schedule V controlled substances with the advance approval by supervising physician for the specific patient unless a physician assistant completes an approved education course in controlled substances, and if delegated by the supervising physician. If a physician assistant chooses not to take the educational course, the requirements for patient-specific authority remain unchanged.

2. Form

A "drug order" issued by a PA must contain "the printed name, address, and telephone number of the supervising physician and surgeon, the printed or stamped name and license number of the physician assistant, and the signature of the physician assistant." It must also contain the physician assistant's federal controlled substances registration number (i.e., DEA number) if the drug order is for a controlled substance (i.e., schedule drugs).

The physician's signature is not required on the physician assistant's drug order. However, the written drug order must be signed by the PA. As with all tasks delegated to a PA, the supervising physician may limit the PAs authority to issue oral, electronic, or written drug orders as the supervising physician deems appropriate.

3. DEA Number

Every physician assistant who is authorized by a supervising physician to issue drug orders for controlled substances must register with the United States Drug Enforcement Administration (DEA). Telephone numbers for DEA offices are as follows:

San Francisco Field Division 888-304-3251
Los Angeles Field Division 888-415-9822 or 213-621-6960
San Diego Field Division 858-616-4542
Web site: www.deadiversion.usdoj.gov

4. Physician Supervision

A supervising physician and surgeon who delegates authority to issue drug orders to a physician assistant may limit this authority by specifying the manner in which the physician assistant may issue the drug order.

Protocol and Formulary

Each supervising physician and surgeon who delegates the authority to a physician assistant to issue a drug order shall first prepare and adopt a written, practice specific, formulary and protocols that specify all criteria for use of a particular drug or device, and any contraindications for this selection. The drugs listed shall constitute the formulary and shall include only drugs that are appropriate for use in the type of practice engaged in by the supervising physician and surgeon. (Protocols adopted by the supervising physician and surgeon may incorporate by reference specific portions of particular editions of texts, and other sources.)

Medical Record

The medical record of any patient cared for by a PA for whom the supervising physician's Schedule II drug order has been issued or carried out must be reviewed, countersigned, and dated by a supervising physician and surgeon within seven days.

5. Prepackaged Medications

A physician assistant acting at the direction of a supervising physician may hand to a patient of the supervising physician a properly labeled prescription drug prepackaged by a physician, a manufacturer as defined in the Pharmacy Law, or a pharmacist.

6. Relating to Pharmacists

California Pharmacy Law, in part, authorizes a licensed pharmacist to dispense drugs or devices upon receipt of a written drug order signed by a PA. A drug order issued by a PA for a controlled drug must contain the physician assistant's DEA number.

7. Tamper-Resistant Forms

All written controlled substance drug orders must be on tamper-resistant prescription forms. The tamper-resistant prescription pads are available from private printing companies that have been approved by the Board of Pharmacy and the Department of Justice. Oral and fax orders for Schedules III-V are still permitted.

For further information on this topic, contact the Board of Pharmacy at (916) 574-7900 or their web site at www.pharmacy.ca.gov.

Note: This document does not purport to be an exhaustive analysis of laws relating to drug orders. This is not a declaratory opinion of the Physician Assistant Board.