Delegation of Schedule II Prescribing

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July 19, 2005

Mr. Edward Friedmann, PA, Chairman

Iowa Board of Physician Assistant Examiners

Lucas State Office Building

321 E. 13th Street

Des Moines, IA 50319

Dear Mr. Friedmann:

The American Academy of Physician Assistants (AAPA) is the national professional society for physician assistants (PAs). In this capacity, the Academy represents over 60,000 physician assistants in the United States. The Academy would like to comment on Iowa Code §147.107.5,.7, that prohibits physicians from delegating prescriptive authority to physician assistants for Schedule II controlled substances which are categorized as stimulants or depressants.

Physician assistants have been practicing with physician supervision in Iowa since 1974. A physician assistant’s scope of practice is that of providing medical services under the supervision of a physician. An integral component of providing medical services is the ability to prescribe medications, including stimulants or depressants. When first enacted the prohibition on stimulants and depressants may have been a cautious restriction placed on a relatively new profession with little or no track record. Over time the PA profession has established a track record for safe prescribing, and it has become apparent that this limitation hinders appropriate patient care.      

Forty-eight states have enacted laws or regulations that authorize supervising physicians to delegate prescriptive authority to physician assistants. No state has ever rescinded this authority. Twenty-nine states allow for Schedule II prescribing by physician assistants, including your neighboring states of Minnesota, Nebraska, Wisconsin, and South Dakota. In fact, this year Nebraska removed its restriction on Schedule II drugs for physician assistants. Nebraska is the latest among a host of states to embrace the recent trend of granting physicians the ability to delegate Schedule II prescriptive authority to PAs. For instance, Mississippi and Connecticut have recently repealed restrictions for physician assistants with regard to Schedule II drugs. There has been no record of increased liability or malpractice claims due to physician assistant prescribing of scheduled drugs. This is supported by data from the Federation of State Medical Boards, which conclusively shows that there is no increase in state disciplinary actions against physician assistants in states that allow controlled substances prescribing privileges versus those that do not.

While the Academy is in favor of eliminating the current restriction, we do agree that the board should have the authority to regulate physician assistant prescriptive authority. Physician assistants, like other professional licensed health care providers, should have in place measures that ensure accountability and patient safety when prescribing medications. It should be noted that physician assistants are eligible for DEA registration and are under the same federal and state scrutiny as physicians, pharmacists, and nurses. Physician assistant prescribing limitations will be delineated by the supervising physician. The Iowa State Board of Physician Assistant Examiners regulates PAs. The board should take disciplinary action against physician assistants who fail to appropriately prescribe medications to patients or do so outside their scope of practice. This should be the case irrespective of the level of prescriptive authority a physician assistant possesses.

Prescribing by physician assistants, as regulated by the state and by the supervising physician, can improve patient access to comprehensive care and provide for increased efficiency and cost-effectiveness. By permitting physician assistants the authority to prescribe stimulants and depressants medications, patient access to needed medications can be increased. Removing this restriction will enable those PAs who are delegated to do so to prescribe medications for attention deficit hyperactivity disorder, hospice care, and post surgical pain management. When the physician assistant can write the appropriate prescription, it allows the supervising physician to have decreased interruptions and to spend more time with patients who are more seriously ill and require physician-level care.  

We encourage the board to support the removal of the prohibition that prevents physicians from delegating prescriptive authority to physician assistants prescribing Schedule II controlled substances which are categorized as stimulants or depressants. We believe that this option would accomplish the board’s goals without placing unnecessary restrictions on providers or potentially decreasing access to care for patients.

The Academy appreciates the opportunity to address the board on this important issue.

Sincerely,

  

Ramon Gardenhire, J.D.

Assistant Director, State Government Affairs