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

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

Jim Anderson, PA-C, MPAS, DFAAPA, President
cell 206-371-9525