Rules for prescribing controlled substances / Register your DEA number
Because a DEA number costs $731 (for 3 years), I know several of you have been convinced by your employers that you don't need your own number, you can just "use the doctor's." This is not legal. An MD's DEA number should only be used for patients the MD examined themselves. That means you can not see a patient, then just have the physician sign the prescription and sign off your note afterwards to make it look like the MD did the evaluation. I have seen this done even with level II controlled substances like Adderall, and it is fraud. Do not put your license in danger just to save your employer some money and time! If they find they law inconvenient, then MDs will be motivated to change it...but if we enable them to skirt the very regulations they insisted on, we do our profession a disservice. This is a reminder from the latest Board of Medical Examiners newsletter:
Practitioners may not issue pre-signed prescriptions to anyone, including physician assistants or nurse practitioners. Practitioners may not post-date prescriptions. All prescriptions must be dated with the date they were issued. It is permissible to write "Do not fill until ____." Practitioners may not authorize anyone, including physicians, PAs, and APRNs to use his or her DEA number. OCGA 16-13-41, 4-5.
With a DEA number, the APRN may prescribe Schedule III-V drugs, but not Schedule II. (Under Georgia law, only physicians can prescribe Schedule II drugs.) Without a DEA number, the APRN may not prescribe any scheduled drugs, but may only write prescriptions for dangerous drugs (such as antibiotics, etc.), but only if their protocol listing the top 20 most prescribed drugs in their practice has been accepted by the Board of Medical Examiners. If you are going to apply for a DEA number, you will need to submit your GCMB protocol number, which will be in the letter you receive from the BME accepting your protocol. This number is issued only for tracking purposes for the DEA.
If you have a DEA number, PLEASE register it! After many months of delay, NPs have been added to the registration form for the Georgia PDMP (Prescription Drug Monitoring Program) set up by the Georgia Drugs and Narcotics Agency. This is the website to tell you how to use the program, and a form to request an account: http://www.hidinc.com/gapdmp/practitioner-pharmacist.html
Click on the "Training Guide" link and read over it. Then click on "Registration Site" to request and account. Enter "newacct" under username and "welcome" under password the first time. If you have any questions, email the help desk at firstname.lastname@example.org. Registering allows you to catch when your patients are abusing the system by seeing multiple doctors and filling multiple narcotic prescriptions at different pharmacies, or if someone else is using your DEA number. It also proves to regulatory agencies that NPs are safely prescribing narcotics, by giving them the data to track our prescribing practices. This will be invaluable information to present if we decide to pursue the right to prescribe level II substances, or to increase our independence of practice in the future. If you have experience related to this post, feel free to comment.