Is a CRNA in Texas required to have prescriptive authority to order medications in the perioperative period?

A CRNA in Texas is not required to have prescriptive authority to order medications in the perioperative period.  In Texas, a CRNA is required to have an order for anesthesia or anesthesia related services from a physician.  The physician’s order delegates the ordering of drugs and devices to the CRNA.  The legal basis for this practice for CRNAs is established by the Board Rule 221.15221.16.  For physicians, the Texas Medical Board has established rule 193.13, which describes how physicians delegate the ordering of drugs and devices to nurse anesthetists.  

The BON includes a note in the APRN application specifically addressing this:

“A note to CRNAs: The BON does not require that you have prescriptive authority to write orders for drugs and devices for the purpose of administering anesthesia or anesthesia-related services.”

There is a legal distinction between ordering a medication for administration in a healthcare setting and prescribing a medication for patients to self-administer at home.  When a CRNA writes an order for a dangerous drug or controlled substance in the recovery room, the CRNA is ordering the administration of the medication to the patient.  Prescriptive authority is not required for CRNAs to order medications.  In addition, CRNAs are not required to possess a Drug Enforcement Agency (DEA) registration number when ordering controlled substances within Texas licensed hospitals or ambulatory surgery centers.

When a CRNA issues a prescription for a medication that is dispensed to the patient by a pharmacist, it is considered prescribing.  For practices in which a CRNA needs prescriptive authority, the process begins with applying for prescriptive authority and obtaining a prescriptive authority number from the BON.  The CRNA and delegating physician must also ensure that the requirements of the Texas Medical Board have been met, including the filing of a properly executed Prescriptive Authority Agreement.