The Massachusetts Department of Public Health Drug Control Program has updated the Massachusetts Controlled Substance Registration (MCSR) website so that Nurse Practitioners who are eligible for independent practice authority may NOW submit an attestation that they have satisfied the required 2 years of supervised practice and amend their MCSR to remove their supervising physician(s). Pending any processes that may be implemented by the Board of Registration in Nursing, this is the only way to do this at this time.

Per section  244 CMR 4.07(2)(a) of the Emergency APRN regulations that remain in effect until final Full Practice regulations are promulgated, CRNAs, CNPs or PNMHCSs with a minimum of two years of supervised practice may engage in prescriptive practice without supervision upon submission of an attestation to the Board that the CRNA, CNP or PNMHCS has completed a minimum of two years of supervised practice by a Qualified Healthcare Professional.

Regarding APRN eligibility to serve as a Qualified Healthcare professional for other APRNs, this is defined in section 4.07(1)(d) of the emergency regulations as a person who meets the following criteria:

A CRNA, CNP or PNMHCS who holds:

    1. valid Registered Nurse license in good standing issued by the Board, and
    2. advanced practice authorization issued by the Board that it is in the same clinical category as the person being supervised; and
    3. a controlled substance registration issued by the U.S. Drug Enforcement Administration, or the Department of Public Health, or both, for a minimum of one year; and
    4. either:
      a. a combination of supervised practice for a minimum of two years plus independent practice authority for a minimum of one year; or
      b. three years of independent practice authority.

The MCNP submitted public comments at a 7/16/21 hearing before the BORN with a request that this definition be changed to less restrictive language, but It is not clear at this point if the minimum 1-year of independent practice requirement will remain in the final regulations.

For this reason, we encourage any APRNs who are eager to serve as a QHPs to update their MCSR as soon as possible so this 1-year waiting period can commence.

However, if you are employed by a group medical practice or larger healthcare institution, we recommend that you to FIRST check with your employer to make sure they have addressed any internal policies or EMR changes that will need to be implemented to support your change to independent practice authority.

Steps to amend your current MCSR to take advantage of Independent Prescribing Practice as authorized by Chapter 260 of the Acts of 2020 and 244 CMR 4.00 are outlined below.

1.  Go to the MA DPH Massachusetts Controlled Substances Registration (MCSR) website and follow the instructions to amend your MCSR by mail, online  or by fax:

https://www.mass.gov/how-to/amend-a-physician-dentist-advanced-practice-nurse-practitioners-physician-assistants-or-cdtm-pharmacist-mcsr

You will need to complete a:

Attestation for Advanced Practice Providers

MCSR Add/Remove Supervising Physician Form

Mail, Fax or email completed forms as directed on the MCSR website.

Please note, the process will take as long as 10 days and DPH will not send a follow-up communication that your MCSR has been changed to independent practice authority. You can confirm the change has been made by logging into your online DPH License account or look up your MCSR on the DPH Check a License page. Once the change has been made, you will no longer see the name of your supervising physician listed with your MCSR.

If you have questions, you can contact the Massachusetts Department of Public Health Drug Control Program at: MCSR@Massmail.State.MA.US

To look up your MCSR and verify the status/expirations dates of all of your licenses, go to:  https://madph.mylicense.com/verification/

To log into the Mass Department of Public Health Online Licensing Portal, go to:

https://madph.mylicense.com/eGov/Login.aspx?ReturnUrl=%2FeGov%2F

To read the emergency APRN regulations in full go to:

https://www.mass.gov/doc/244-cmr-4-advanced-practice-registered-nursing/download