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Summary of Prescriptive Authority for CRNA’s in Massachusetts

Historically CRNAs practiced nurse anesthesia in hospitals as hospital employees. Under the Controlled Substance Act (Chapter 94C of the Massachusetts General Laws), there are exemptions from having to register as a prescribing practitioner in order to distribute, dispense, administer controlled substances (meaning that CRNA’s were able to write orders as hospital employees under the “hospital” as the registered practitioner) See Section 7 (d)(1) of chapter 94C.


The job descriptions of CRNA’s who were employed by hospitals that were registered and authorized as dispensers of controlled substances included CRNA’s among those who could issue “medication orders.” In the 1990’s, the Board of Registration in Nursing (BORN) was asked why CRNA’s could issue medication orders if they did not have authority to issue prescriptions like the other APRN’s. At the same time, CRNA’s were working as contractors (aka “1099”), and in facilities other than hospitals (i.e. surgery centers, outpatient facilities, etc.) Additionally many anesthesia departments were (and continue to be) outsourced as private groups meaning CRNA’s were no longer “employees” of a dispenser (the hospital), registered under chapter 94C.

The BORN concluded that in order for CRNA’s to issue medication orders they would need prescribing authority like the other APRN’s (NP’s, Midwives, etc.) and other prescribers in Massachusetts. Therefore, CRNA’s had to file legislation to change the Massachusetts General Laws (MGL’s) to authorize CRNA’s to issue prescriptions. In 2010, the Massachusetts legislature enacted legislation and granted CRNA’s the authority to issue prescriptions. It wasn’t until August of 2014 that the language in the MGL’s and the Code of Massachusetts Regulations (CMR’s) was finalized.

Current MGL’s and Department of Public Health (DPH) regulations identify three types of prescriptions; 1) written prescriptions, 2) oral (verbal) prescriptions, 3) written medication orders. All practitioners (including physicians, PA’s, all APRN’s, etc.) who engage in prescriptive practice in Massachusetts must obtain a Massachusetts Controlled Substance Registration (MCSR) and where applicable, a Drug Enforcement Agency (DEA) registration and comply with MA prescribing laws.

Current law regarding prescriptive authority pertaining to CRNA’s requires that the BORN and the Board of Registration in Medicine (BORiM) develop prescriptive authority regulations jointly, specifically limits the prescriptive authority of CRNA’s to the 24-hour period around a surgery/procedure date, and finally, states that the administration of anesthesia by a CRNA does not require a prescription/order.

This has resulted in regulations, both in the CMR’s of BORN and BORiM, requiring physician supervision of the issuing of prescriptions only. There are no Massachusetts laws that require physician supervision of the administration of anesthesia by a CRNA. (For information, see Laws and Regulations Governing CRNA Practice in MA under the “Professional Practice” tab on the MANA website,

The regulations stipulate that in order for CRNA’s to utilize their authority to issue prescriptions, CRNA’s and their supervising physicians develop mutually agreed upon guidelines and establish a mechanism to perform a retrospective review of prescriptions and/or medications, tests, therapeutics, etc. These mutually agreed upon written guidelines are separate from any other collaborative agreement, and by law, are public documents. These guidelines must be kept on file at the practice location and must be provided to anyone who requests a copy.


In the pages below, we have provided documentation of the MGL’s, CMR’s, and notices from the BORN. An important document is the MCSR Audit Tool provided by the BORN, which specifies the requirements for guidelines for prescriptive authority. Below, you will find a link to a step-by-step guide to establishing authority to issue prescriptions at your facility.

For a

Step-by-Step Guide to Prescriptive Practice


Click Here




Tools to Navigate MA Laws Tools to Navigate the Board of Registration Other Supporting Documents
Tools to Navigate Massachusetts Laws
Tools to Navigate the Board of Registration
Important Documents

The information provided does not provide nor replace legal or insurance advice; be sure to utilize professional counsel in the areas of legal or insurance. The Massachusetts Association of Nurse Anesthetists (MANA) accepts no liability if there is any damages caused by you or your organization due to the use or interpretation of the information provided.

MANA has exercised due and customary care in providing this information but has not independently verified information provided by others. No other warranty, express or implied, is made in relation to the conduct of the contents of these materials. Therefore, MANA assumes no liability for any loss resulting from errors, omissions or misrepresentations made by others. 

Any recommendations, opinions or findings stated in this content are based on circumstances and facts as they existed at the time MANA performed the work. Any changes in such circumstances and facts upon which this information is based may adversely affect any recommendations, opinions or findings contained within.

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Massachusetts Association of Nurse Anesthetists, Inc.

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Phone: 978 250-9847 | Fax: 978 250-1117

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