I support the petition to remove the physician's name from prescriptions written by a PA. This is burdensome particularly since most prescriptions are electronic and not all EMR systems have capacity to meet these requirements. Furthermore, the collaborating physician in a group setting changes from day to day and an arbitrary physician's name on the prescription is meaningless as that provider was probably not involved in the patient's care.

The current requirement does nothing to promote patient safety and removing it is a sensible advancement for medicine. 

I petition to remove the requirement that a patient care team physician’s name be included on prescriptions for Schedule II-V drugs- this  seems to be a step that can be avoided- for one all EMRs do not have the ability to do this which has potential to hinder patients care- and PA's should have the authority to rx scheduled drugs without having a potential arbitrary patient care team physician on the rx who knows nothing about the patient.

I fully support the removal of requirements to include patient care team physician's name on prescriptions for Schedule 2-5 drugs.  It serves no purpose and creates extra barriers to patient's getting their medications timely.  This requirement wastes the time, not only of our patients, but of pharmacists having to get hold of us and our front desk staff. It is important to note that the PA's collaborator is usually not directly involved in our patient's care and may not be the provider working that day.  Let's please remove bureaucracy that wastes the time of patients and already overburdened healthcare workers. This requirement is antiquated and does not benefit patients.

What is the point of having a supervising physician's name on prescriptions for controlled substances?  PAs are licensed, credentialed, and privileged and have DEA licenses to prescribe controlled substances.  The Commonwealth of Virginia monitors all prescriptions for controlled substances and provides a monthly prescription report for all licensed providers.

What additional public protection or patient safety does the requirement to list a physician on the prescription add?

PAs are required to have collaborating physicians but those physicians are in no way responsible for the prescriptions that a PA writes and therefore this is an unnecessary regulation.

I agree that this requirement should be removed.  As part of their prescriptive authority, PAs enter into a written agreement that the supervising physician will supervise the prescriptive practices of the assistant.  This is a condition of the employment protocol which all PAs are required to have to be licensed by the board to practice.  Therefore, the supervision of prescribing practices is inherent in a PA's employment.  Placing the supervising physician's name on all prescriptions does not strengthen this supervision in any way.  Additionally, removing this requirement would not weaken the supervision.  This requirement is simply a burdensome keystroke that can easily be eliminated without interfering with the supervising relationship between the physician and PA.   

As a practicing PA in Virginia, I fully support removal of this language (that the collaborating physician’s name be on prescriptions for scheduled 2-5 medications) for the following reasons:

• PAs are licensed, credentialed and have their individual DEA license to prescribe controlled substances
• The Commonwealth of Virginia monitors all prescriptions for controlled substances.
• PAs have extensive training in pharmacology and substance use disorder
• Some ERMs still do not have the ability of including this information and attempts to comply are cost prohibitive so the burden lies with an already over taxed provider
• Attempting to add this information to electronic prescriptions causes delay in patients receiving prescriptions in a timely manner as pharmacists, front desk staff, providers make several phone calls to comply, causing further barriers to patient access
• PAs may have several rotating collaborating physicians that rotate through different clinics.  Attempting to find the specific physician also causes further delay in patient care.
• This language adds no additional public protection or patient safety.

I support removal of this language for the benefit of patients.  

Physician Assistants (PAs) are licensed medical providers with individual DEA registrations. Within the State of VA, PA's are allowed to hold prescriptive authority which should allow them to independently write for prescriptions, including controlled substances. The oversight of a physician having to sign every prescription is a barrier to access and patient care. Within the current healthcare climate, there are decreasing amount of physician and non physician providers since the COVID19 pandemic and access to care has only worsened. Continued barriers and restrictions are only hurting patients. 

I support the petition to no longer require a physician's name on prescriptions written by a PA.  PAs are licensed medical providers who have extensive training in pharmacology and can already retain their own individual DEA numbers.  To require a physician's name on a prescription is illogical and burdensome.  It does nothing for patient care or patient safety.  Furthermore, not all EMR systems are able to meet this requirement.

I am supportive of removing this requirement as it poses a barrier to providing safe and efficient care to our patients. Requiring a PA prescribing medications to include a collaborating physician's name on the prescription is an unnecessary burden on patients, physicians, and PA's.  It does not increase safety for patients, if anything it may create a safety issue as patients meds are unnecessarily delayed.  In addition, it reduces the efficiency in which we can provide patient care services, putting an unnecessary barrier on patient access.  I serve as a director in a large healthcare system here in Virginia and I am consistently made aware of situations where patients have been prescribed meds after hospitalization or an ED visit and those prescriptions are being refused to be filled by pharmacies because of this requirement.  This results in a delay in patients receiving medications and requires the patient to return to the hospital, ED, or providers office to obtain a new prescription. I am consistently made aware of this unfortunately happening to patients.  PAs in Virginia have prescriptive authority and are required to have a DEA registration unique to them and thus should be able to exercise this prescriptive authority without this unnecessary additional requirement.  

This regulation is being applied to PAs without good reason (neither NPs nor physicians in training are subject to similar regulations). This creates an additional burden for PAs and their collaborating physicians, and causes delays in care for their patients. 

I support the proposed regulatory change to PA prescribing requirements for the following reasons:

• PAs have individual DEA license numbers. The PA prescribing is responsible, not the collaborating physician. Should a pharmacist or patient have questions regarding the prescription, the prescriber/PA is the best contact.
• PAs have pharmacology training. PAs are trained, licensed and credentialed to appropriately prescribe in Virginia.
• PAs work in a variety of environments. Many EMRs prove difficult to navigate and add a note to the prescription with the collaborating physician name. This is cumbersome and delays care for the patient if the pharmacy must be called. Many hours on hold have been wasted. Requiring facilities to amend EMRs could be cost prohibitive.
• The PA is the best point of contact for a prescription written by the PA. As an example, I have been contacted more than 24 hours after prescription submission. My collaborating physician referred the pharmacist back to me for information regarding an ADHD medication change. There was a drug shortage, and the family could not pick up the prescribed medication until resolution. This created much stress for the family, poor patient care and an unnecessary delay. I should have been the initial call.

My patients who are discharged from the hospital following total knee replacement are often unable to pick up prescriptions due to this unnecessary regulation. I have learned to add the required information to the prescription so my patients aren’t burdened. But I fail to see how my attending’s name on the prescription stops or prevents an abuse of the prescribing system. 

why must we pay for a DEA license if a SP is still required to prescribe? 
I work in the ER where SP names are not included on the Rx. We get constant calls asking who the SP physician is. It takes up pharmacy time, providers time and causes more stress for the patient. Usually, physicians are not involved in the decision to prescribe a narcotic. Why have their name on the script? 

Agree

I have been a PA for 19 years. Having to have my collaborating physician’s name on my prescriptions is a barrier to patient care.

Agree with this change. There have been countless times were this was a barrier to patient care and unnecessary exchange with pharmacies to proceed with prescriptions. We have a DEA license to prescribe and a practice agreement with the MD. If there ever is any issue, we can be contacted and then directly discuss with supervising physician. 

I support the petition to remove the physician's name from prescriptions written by a PA. In most settings the collaborating physician in a group setting changes from day to day and an a physician's name on the prescription is meaningless as that provider was probably not involved in the patient's care.

The current requirement does nothing to promote patient safety and removing it is a sensible advancement for medicine. 

Thank you 

I have been in practice since 1980, hold VA Lic#122.
I have two DEA's, one for NY and one for VA.

Over that 43 year career, in many cases, a patient may have never seen the physician listed as my "supervising physician" and confusingly, may believe the name on the Rx is the provider they saw, a pharmacist attempting to verify information may attempt to contact that MD/DO (who knows nothing of patient except perhaps has seen the chart) and the Prescription Monitoring Program may reflect that MD/DO as the prescriber (which is misleading and in conflict with the entire idea of the PMP).

IAW § 54.1-2952, the physician has no responsibility for the Rx, thus the current situation is misleading, unnecessary and in no way helpful.

This can be changed with only positive effects.

Thanks for your consideration

Lorick Fox, PA-C, AACC, DFAAPA
Associate, American College of Cardiology
Distinguished Fellow, American Academy of Physician Associates
Affiliate, American College of Physicians

I definitely agree!!

I speak in favor of amending 18VAC85-50-160. 

We have our own license, DEA, and NPI.  There should be no reason to require a collaborating physician's name.

§ 54.1-2952.1. Prescription of certain controlled substances and devices by licensed physician assistants: requires that we provide our name, address, and telephone number, not that of our collaborating physician.

The electronic medical record and e-prescribing systems identify the prescriber (the PA) but are quite variable in their ability to identify a collaborating physician on the electronic prescription sent to the pharmacy.

To the best of my knowledge, PAs are the only prescribers in Virginia who are required to have this requirement.  There is no evidence that harm has occurred or will occur should the collaborating physician’s name not appear on PA prescriptions.

I agree with this change and find the current rule a hindrance to patient care.

Unnecessary requirement 

Physician assistants have their own NPI and DEA licenses.  Requiring the care team physician’s name to be on a PAs prescription for any medication is unnecessary and can lead to delay in delivery of medications to patients who need it.

This law is unnecessary.

I am in favor of amending 18VAC 85-50-160.  PAs are certified by a national certification body, licensed by the Commonwealth, and carry DEA certification.  There should be no need for additional steps for prescription authorization that may delay the treatments needed by our patients.

As a nurse of 30 years, I am a strong advocate to remove delays in patient care that come from unnecessary red tape.  I had many patients on scheduled medications and programs like the PMP are more effective in monitoring safe prescriptive patterns.  My patients have spinal cord injuries and it takes a lot of effort for them or their care takers to go to a pharmacy to pick up medications. Many of them have had to wait HOURS which is an inconvenience that could be righted be removing this regulation. 

The requirement to include physician’s name on the PA’s prescriptions does not improve patient safety but creates logistical difficulties during patient visits to the clinic. Every time I eprescribe, I have to manually add my supervising physician’s information to the prescription as it is not automatically set in the EMR. 

I agree with removing this requirement as it can be a barrier for patient care

I speak in favor of amending 18VAC85-50-160.  

As PAs, we have our hold  license, DEA, and NPI.  There should be no reason to require a collaborating physician's name on a prescription.

The electronic medical record and e-prescribing systems identify the prescriber (the PA) but are quite variable in their ability to identify a collaborating physician on the electronic prescription sent to the pharmacy.

To the best of my knowledge, PAs are the only prescribers in Virginia who are required to have this requirement.  There is no evidence that harm has occurred or will occur should the collaborating physician’s name not appear on PA prescriptions.

Agree this should be removed 

Requirement of the physician's name on the patient's prescription adds an unnecessary  logistical burden which delays patient care (should one accidentally fail to manually add the name before e-prescribing). Physician Assistants follow a contract with their collaborating physicians. PA's who prescribe these medications have their own DEA number and NPI. No other prescriber in the Commonwealth is required to document this.

Requirement of the physician's name may lead to misinformation in pharmacy records, reflecting incorrect prescriber information and confusing the patient.

Please amend legislation to remove the requirement to include patient care team's physician's name on prescriptions for schedule ii-iv drugs.

PAs are certified by a national certification body, licensed by the Commonwealth of Virginia, and certified by the DEA to prescribe controlled substances. This requirement both delays patient care and inhibit optimal team practice.

Agreed

Thank you for considering and removing language that requires physician names on prescriptions along side their physician assistant.  As you are already aware, we are highly trained providers who comply with state regulations for extra training regarding concerning Schedule drugs.  The current legislation is not only redundant but unnecessary. Even with the best of intentions it stimulates call backs from pharmacies and lost time rewriting prescriptions.   Thank you for cleaning up the legislation and moving forward.   Mark Ford. 24 years Orthopedics.  Fredericksburg,VA

Delays patient care. Burden.

Unnecessary ruling that impedes patient care. As a provider with a DEA I should be allowed and capable of making the best decisions for patients including prescribing controlled substances without my supervising physicians name on the script. 

Agree

Endorse removal 

Agree with removal

Agree

Agree with removal; as PAs we have our own DEA number/license. The removal will improve and expedite patient care. 

There are plenty of practice protocols in place that negate the need to have the supervising physician’s name on the prescriptions. Having the supervisors name could prevent delay in patient access to appropriate medications in a timely manner for their health. In addition, there is excessive unnecessary work for the practitioners when there is a discrepancy in who is the supervising physician for the PA at the time the prescription was written. Most often the PA is writing prescriptions without the physician’s direct oversight. Each practice dictates how much oversight each PA has and therefore this gives flexibility in each practice, deciding how the supervising physician wants to oversee the PA. 

Agree with removal

This is a huge barrier to timely patient care and should be removed immediately. PAs are fully licensed providers with their own DEA license. They should be able to prescribe without restriction. 

I agree with this removal. My DEA and VA license should allow me to prescribe within my scope of practice. The need to add a physician’s name cause extra paperwork and processing time for patients to receive their prescriptions.

Thank you for your consideration.

Removal would improve patient care, remove unnecessary barriers

Removing the requirement of SP name on controls would eliminate barriers to patient care, too many pharmacies are holding up patient's medications.

I agree with removal.