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Registered Nurses Prescribing Non-Controlled Substances

posted on Wed, Jun 25 2014 3:02 pm by Mid-States Region

The Network was recently contacted by a local health department in Michigan about whether registered nurses can prescribe non-controlled substances under a delegation by a physician and in accordance with the physician’s standing order. The health department also asked if physicians need to personally countersign written prescriptions. Current common practice is for a registered nurse to sign and include the delegating physician’s name, without the physician’s signature, on the prescription.

This practice, where allowed by state and federal law, can be advantageous to local health care providers and their patients. Such practices can expedite the process of filling routine prescriptions and allow providers to more effectively utilize registered nurses and physicians. It can also be crucial in emergency situations where resources are limited.

The Network consulted with experts in Michigan’s licensing department. Although more stringent standards could be adopted by Medicare, Medicaid or private insurance carriers, delegation arrangements are generally controlled by Michigan statutes and the regulations adopted by the Department of Licensing and Regulatory Affairs. The Michigan Attorney General has advised that these authorities permit a registered nurse to prescribe non-controlled substances if delegated by a physician and in accordance with the physician’s standing orders. Pursuant to this authority, the physician does not need to see the patient or be present in the office at the time of service, and no direct supervision of the registered nurse is needed. 

Thus, under this interpretation of the Michigan code, physicians are generally required to:

  1. Establish a written delegation authorization (which should be kept at each site of practice) containing the physician's and nurse's signatures and respective license numbers;
  2. Record limitations or exceptions to the delegation, if any;
  3. Document the effective date of the delegation; and
  4. Review and update the authorization annually and record amendments, if any.


Further, other limitations apply to the power of delegation, including:

  1. The physician may delegate prescribing authorization to the registered nurse only with respect to those medications which fall within the physician’s scope of practice;
  2. Delegation of prescribing authority is limited to licensed professional nurses (RNs) who meet the applicable education, training, and experience requirements;  and
  3. RNs may not be authorized to prescribe non-controlled substances which require a physician’s level of education, skill and judgment.

The Nurses Association website contains a summary of these rules. Of course, all providers, including local health departments, must assure that any delegation arrangements they might establish are fully consistent with the applicable legal standards promulgated by the state licensing agency. Therefore, as these types of delegation orders are developed and modified over time, it is always useful to seek clarification from the state licensing authority as questions arise. 

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