Beyond State Scope of Practice Laws for Advanced Practitioners: Additional Supervision Requirements for Buprenorphine Prescribing


Barbara Andraka-Christou, Adam Gordon, Joanne Spetz, Rachel Totaram, Matthew Golan, Olivia Randall-Kosich, Jordan Harrison, Spencer Calder, Stefan Kertesz, and Bradley Stein

Jul 2022

Buprenorphine is a life-saving medication for people with opioid use disorder (OUD). U.S. federal law allows advanced practice clinicians (APCs), such as nurse practitioners (NPs) and physician assistants (PAs), to obtain a federal waiver to prescribe buprenorphine in office-based practices. However, states regulate APCs' scope of practice (SOP) variously, including requirements for physician supervision. States may also have laws entirely banning NP/PA buprenorphine prescribing or requiring that supervising physicians have a federal waiver to prescribe buprenorphine. We sought to identify prevalence of state laws other than SOP laws that either (1) prohibit NP/PA buprenorphine prescribing entirely, or (2) require supervision by a federally waivered physician. We found that one state prohibits all APCs from prescribing buprenorphine for OUD, even though the state's general SOP laws permit APC buprenorphine prescribing. Five states require PA supervision by a federally waivered physician. Three states require NP supervision by a federally waivered physician. Aside from general scope of practice laws, several states have created laws explicitly regulating buprenorphine prescribing by APCs outside of licensed state SUD facilities.