Prior Authorization Requirements For Providers Prescribing Buprenorphine-Containing Products

Gov. Tom Wolf announced in October of 2018 that he reached an agreement with seven major insurers to end prior authorization for medication-assisted treatment (MAT) for substance-use disorders (SUDs). Insurers also agreed to including a comprehensive range of medications to treat SUDS on the lowest cost-sharing tier of a health plan’s pharmacy benefit. This action was not legislative.

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Education Required for Addiction Counselor Credentialing

Pennsylvania credentials three types of addiction counselors. A Certified Associate Addiction Counselor requires a high school diploma, 300 hours of relevant education courses and 300 hours of supervised experience. A Certified Alcohol and Drug Counselor requires a bachelor’s degree, 300 hours of relevant education courses and 200 hours of supervised experience. A Certified Advanced Alcohol and Drug Counselor requires a master’s degree, 180 hours of relevant education courses and 100 hours of supervised practice. Pa. Cons. Stat. tit. 28 §704 and Pennsylvania Certification Board

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Licensed Professional Counselor Ability to Diagnose

Licensed professional counselors may assess patients, provide therapy and/or psychotherapy, family therapy and group therapy consistent with the counselor’s education and training. Diagnostic ability is not outlined in statute. Pa. Code §49.13

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Peer Support Specialist Certification or Credentialing Authority

The standards and requirements for certification of a peer support specialists, recovery specialists, or family recovery specialists are developed and administered by a third-party, non-profit certification provider.

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Certified Nurse Midwife Practice Authority

Physician relationship required for practice and prescriptive authority.

A nurse midwife may not engage in midwifery practice without having entered into a collaborative agreement and having filed the collaborative agreement with the board. A nurse midwife shall only engage in midwifery practice in accordance with the midwife practice guidelines and collaborative agreements. Pa. Code §49.18.5

A nurse midwife may, in accordance with a collaborative agreement with a physician, and consistent with the nurse midwife’s academic educational preparation and National certification by the AMCB or its successor organizations, prescribe, dispense, order and administer medical devices, immunizing agents, laboratory tests and therapeutic, diagnostic and preventative measures. This includes Schedules II-V. Schedule II must be limited to a 72-hour supply and Schedules III-IV are limited to a 30-day supply. Pa. Code §49.18.6

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Nurse Practitioner Practice Authority

Physician relationship required for practice and prescriptive authority.

Written collaboration agreement required and the agreement must be signed by both the NP and the physician and agree to the details of their collaboration. Pa. Code §49.21.251

Drugs and therapeutic measures available for prescribing must be outlined in the written collaboration agreement and relevant to the NP’s specialty. The NP may prescribe Schedule II-V controlled substances. Pa. Code §49.21.284

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Nurse Practitioner Authority to Sign POLST Forms

NPs are authorized to sign POLST forms. Pa. Con. Stat. tit. 20 §5422

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Nurse Practitioner as a Primary Care Provider

NPs are recognized in state policy as primary care providers. There are six patient populations the State Board of Nursing designates for NPs to focus including neonatal, pediatrics, family/across the life span, adult/gerontology, women’s health/gender-related and psychiatric/mental health. Pa. Code §28.9.678

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Authority to perform ophthalmic procedures

Optometrists may only perform procedures related to foreign body removal and the examination, evaluation, diagnosis and treatment of the human eye. Pa. Code §49.23.3

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Injectable Authority

Optometrists may use epinephrine auto-injectors for anaphylaxis. Optometry Practice Act, Act 130, Section 2

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Prescription of controlled substances

Optometrists may prescribe Schedule III-V controlled substances and Schedule II controlled substances containing hydrocodone combinations. The prescription for hydrocodone combinations cannot exceed a 72-hour supply.  Optometry Practice Act, Act 130, Section 2

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Dental Hygienists with Direct Access

A certified public health dental hygiene practitioner may provide care in a variety of public health settings without the supervision or prior authorization of a dentist. The dental hygienist must have 3,600 hours of practice experience and liability insurance. PA Code §33.205b

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Dental Therapists

Statute does not identify dental therapists as an oral health provider.

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Practice of Teledentistry

Pennsylvania does not explicitly allow for the practice of teledentistry.

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Administration of COVID-19 Vaccine

Pennsylvania has not enacted legislation allowing pharmacists to administer the COVID-19 vaccine. However, the federal PREP Act does allow pharmacists to administer the COVID-19 vaccine through the duration of the public health emergency.

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Prescription Adaptation

Pennsylvania does not allow pharmacists to modify prescriptions.

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Prescription of Hormonal Contraceptives

Pennsylvania does not allow pharmacists to prescribe hormonal contraceptives.

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Prescription of Tobacco Cessation Aids

Pennsylvania does not allow pharmacists to prescribe tobacco cessation aids.

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Supervision Requirements (Practice and Prescriptive Authority)

Supervision by a physician required for practice and prescriptive authority.

The PA practices medicine with physician supervision. A PA may perform those duties and responsibilities, including the ordering, prescribing, dispensing and administration of drugs and medical devices, as well as the ordering, prescribing and executing of diagnostic and therapeutic medical regimens, as directed by the supervising physician. (b) The PA may provide any medical service as directed by the supervising physician when the service is within the physician assistant’s skills, training and experience, forms a component of the physician’s scope of practice, is included in the written agreement and is provided with the amount of supervision in keeping with the accepted standards of medical practice. 49 PA. CODE § 18.151

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Number of PAs Supervised

Statue limits the number of PAs a physician may supervise.

A PA shall not assist a physician in a manner not described in the agreement or without the nature and degree of supervision described in the agreement. There shall be no more than six PAs for whom a physician has responsibility or supervises pursuant to a written agreement at any time. 63 PA. CONS. STAT. § 422.13(e)

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Chart Co-Signatures

Chart co-signatures are required by statute to practice or prescribe as a PA.

The primary supervising physician shall determine countersignature requirements of patient records completed by the PA in a written agreement, except as provided for in paragraph (4).

(4) The primary supervising physician shall countersign 100% of patient records completed by the PA within a reasonable time, which shall not exceed 10 days, during each of the following time periods: (i) The first 12 months of the PA’s practice post-graduation and after the PA has fulfilled the criteria for licensure. (ii) The first 12 months of the PA’s practice in a new specialty in which the PA is practicing. 63 PA. CONS. STAT. § 422.13(d.1)

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Adaptable Proximity Requirements

Statute allows adaptable proximity.

The supervising physician shall be responsible for the medical services that a PA renders. Supervision shall not require the onsite presence or personal direction of the supervising physician. 63 PA. CONS. STAT. § 422.13(d)

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Scope of Practice Determination

State regulations outline services a PA may provide to patients. The medical services must be delegated by the supervising physician if the services are within the PA’s skills, training and experience, and outlined in the written agreement. Pa. Code §49.18-151

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