Seeking a SAMHSA PA/NP Exemption For Allowing PA/NPs to Write Orders in
Opiate Treatment Programs
Society of Physician Assistants in Addiction (SPAAM) FAQ
Society of Physician Assistants in Addiction (SPAAM) FAQ
SAMHSA=Substance
Abuse and Mental Health Services Administration
CSAT=Center
for Substance Abuse Treatment (part of SAMHSA)
1. If I am a PA, can I write orders for
admission and/or dose changes for patients in Opiate Treatment Programs (OTPs)?
The 2015 Federal
Guidelines for Opiate Treatment Programs state that only physicians
may admit or order medication changes in OTPs. In many settings, local regulatory bodies have interpreted this to mean that this order-writing may be delagated to PAs, consistent with state practice guildelines regarding delegation by MDs to PAs, but some settings have interpreted this to mean "physician only." PAs and NPs are grouped together in this process. NPs do not have separate standing from PAs in the SAMHSA guidelines.
2. Is there an exemption process that allows
PAs and NPs to write such orders ?
Yes. There is a
SAMHSA-approved process so that PAs and NPs can obtain an exemption to the
SAMHSA “physician only” rules regarding order -writing in OTPs. This was a
point of emphasis on a work group which was charged with revising
the SAMHSA rules, resulting in the 2015 revisions. There was an effort to
modify the rules to include PAs and NPs, but it failed. What emerged was the
new exemption process, where a facility or agency can request and receive
exemptions allowing PAs and NPs to write orders in OTPs.
3. What must be done to obtain this exemption?
1. The Opiate Treatment Program must be located in
a state which grants PAs and/or NPs Schedule 2 prescriptive authority.
2. The Opiate Treatment Program must be in a state
where there are no special state rules relating to the scope of practice in
OTPs.
3. The Opiate Treatment Program must have the
support of the agency OTP medical director regarding the seeking of the PA/NP
exemption.
4. The State Opioid Treatment Authority (SOTA) must
be willing to approve an OTPs request for exemption from those Guidelines for
42CFR Part 8.
Find Your State Opioid Treatment Authority (SOTA)
5. SAMHSA/CSAT will consider for approval the
exemption request.
6. For agencies wanting the authority to have PAs
and NPs conduct intake physicals, admit patients and order dose changes, the
agency must engage with the agency's program sponsor and medical director to
start the process for applying to CSAT for the exemption.
7. Providers may not seek this exemption
independent of their program sponsor, medical director, or their State
Opioid Treatment Authority. (SOTA)
For more information about the exemption, click here to see more detailed information about this process. Please feel free to contact the
Society of Physician Assistants in Addiction Medicine at
aapaspaam@gmail.com
Society of Physician Assistants in Addiction Medicine at
aapaspaam@gmail.com
Jim Anderson, PA-C, MPAS, DFAAPA, President
cell 206-371-9525
