Rules and Regulations regarding a Physician's role in Prescriptive Authority for Advanced Practice Nurses
Effective July 1, 2010: Physician preceptors and mentors must comply with the full rules on Prescriptive Authority adopted by the Colorado Medical Board. Failure to comply may constitute grounds for disciplinary action as set forth in section 12-36-117, C.R.S.
- Changes for APNs who currently have prescriptive authority
- Requirements for the 1800-hour Mentorship and Physician Mentor
- Requirements of the Physician Mentor
- Articulated Plan for Safe Prescribing
A Collaborative Agreement between an advanced practice nurse with prescriptive authority ("RXN") and a physician is no longer required.
- An "Articulated Plan for Safe Prescribing" ("Articulated Plan") is required.
- An Articulated Plan does not require an ongoing involvement of a physician, as a Collaborative Agreement did.
- APNs who wish to obtain prescriptive authority are required to:
- Have national certification (new)
- Hold a graduate or post-graduate nursing degree (unchanged)
- Complete an 1800-hour preceptorship (unchanged)
- Complete an 1800-hour mentorship (new)
- Develop an Articulated Plan for safe prescribing (new)
Changes for APNs who currently have prescriptive authority
- Collaborative Agreements are no longer required.
- All APNs with prescriptive authority will be considered "Provisional" (RXN-P) as of July 1, 2010. This does not change their prescribing authority.
- An RXN-P's designation will change to "Full Prescriptive Authority" when they have created an Articulated Plan that has been signed by a physician and the RXN and submitted an Attestation of such to the State Board of Nursing.
- The Attestation must be signed by the physician who signed the Articulated Plan. It does not need to be the same physician with whom the RXN had his or her Collaborative Agreement.
- The attestation is due by July 1, 2011 (one year from the implementation of the rules).
- There is not a limit on the number of Articulated Plans a physician may sign.
Summary of Requirements for the 1800-hour Mentorship and Physician Mentor
- Completed within five years of Provisional Prescriptive Authority being granted.
- Documented in writing and signed by the mentor(s).
- Outlines a process and frequency for ongoing interaction and discussion of prescriptive practice throughout the mentorship.
- The document will be retained for three years after the completion of the mentorship by the APN and the physician.
- The mentor shall not require payment or employment as a condition of entering into the mentor relationship.
- In recognition of the mentor's time and expertise, reasonable fair market expenses may be paid. Compensation will be mutually agreed upon and shall not be onerous or represent a barrier to completion of the mentorship.
- At the conclusion of the mentorship, the physician will sign an Attestation that the mentorship was completed.
Requirements of the Physician Mentor
- A Colorado medical license in good standing or otherwise be exempt from licensure as set forth in 12-36-106 of the Medical Practice Act.
- Actively practicing medicine in Colorado.
- Education, training, experience, and practice that corresponds to the Role/Specialty and population focus of the APN.
- An unrestricted DEA registration for the same controlled substance schedules as the APN.
- Interacts with the mentee about prescribing issues as mutually agreed upon and documented.
Articulated Plan for Safe Prescribing
The Articulated Plan must contain the following four elements:
- A mechanism for consultation, collaboration, and referrals to physicians and other health care providers,
- A quality assurance plan,
- Identification of Decision Support Tools, and
- Documentation of continuing education.
The Articulated Plan must be signed by the physician mentor(s) as the development of the Articulated Plan is part of the mentorship requirements. There is no limit on the number of Articulated Plans a physician may approve and sign.
After a mentorship and Articulated Plan is completed, the APN is eligible for Full Prescriptive Authority.