PA Controlled Substance Prescribing Requirements (California)

🔑 Key Points

For a PA to legally write or transmit a controlled substance prescription in California, they must possess and maintain these four core credentials:

• Active California PA License: Issued by the Physician Assistant Board of California.
   
• Individual DEA Registration: Tied to their active CA license for Schedules II–V. PAs cannot "borrow" a physician's DEA number.
   
• Active Practice Agreement: A signed, written agreement on file at the practice location outlining their specific prescribing authority, protocols, and the supervising physician's details. (Note: California law no longer requires the supervising physician's name to be printed on the actual prescription pad, but the agreement must exist).
   
• CURES (PDMP) Account: Active registration with California's Prescription Drug Monitoring Program. Just like NPs and physicians, PAs must query CURES before prescribing a Schedule II–IV controlled substance for the first time, and at least once every 6 months thereafter for ongoing therapy.

⚠️ Mandate: The PA must query CURES prior to prescribing a Schedule II–IV controlled substance at every single visits
 

🚨 Important to Note

Schedule II (The "7-Day" Co-Signature Rule): * Unlike NPs, who do not require routine chart co-signatures under California law, PAs have a strict supervision requirement for Schedule II drugs:

• The Rule: If a PA orders a Schedule II controlled substance, the supervising physician must review, countersign, and date the patient’s medical record within seven (7) days of the order.

1️⃣ Steps Required   

To maintain clinical alignment and support oversight protocols for controlled substances (CS), BESA Health requires the following collaborative communication workflow:

1. Mandatory Notification for CS Prescribing: For every patient encounter where a Controlled Substance (CS) medication is newly prescribed, adjusted, or refilled, the prescribing Advanced Practice Provider (APP) must route a note comment or task notification directly to the Supervising Physician within the Electronic Health Record (EHR) on the same day as the encounter.
    
2. What to Include: The notification should briefly state the patient’s clinical status, confirmation of a completed Prescription Drug Monitoring Program (PDMP) query, and the rationale for the CS prescription.
    
3. Oversight Compliance: This collaborative documentation ensures seamless clinical transparency, supports the Supervising Physician's oversight requirements, and maintains our commitment to patient safety and quality care.

If you have any questions or would like more information, please reach out to the Delegating Physician.