Prescriptive Practice

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 CRNAs 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 CRNAs who were employed by hospitals that were registered and authorized as dispensers of controlled substances included CRNAs among those who could issue “medication orders.”  In the 1990s, the Board of Registration in Nursing (BORN) was asked why CRNAs could issue medication orders if they did not have the authority to issue prescriptions like the other APRNs. At the same time, CRNAs 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 CRNAs were no longer “employees” of a dispenser (the hospital), registered under chapter 94C. 

The BORN concluded that in order for CRNAs to issue medication orders they would need prescribing authority like the other APRNs (NPs, Midwives, etc.) and other prescribers in Massachusetts. Therefore, CRNAs had to file legislation to change the Massachusetts General Laws (MGLs) to authorize CRNAs to issue prescriptions. In 2010, the Massachusetts legislature enacted legislation and granted CRNAs the authority to issue prescriptions. Click here to view the BORN Notice. It wasn’t until August of 2014 that the language in the MGLs and the Code of Massachusetts Regulations (CMRs) was finalized.

Current MGLs 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, PAs, all APRNs, 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 CRNAs requires that the BORN and the Board of Registration in Medicine (BORiM) develop prescriptive authority regulations jointly, specifically limits the prescriptive authority of CRNAs 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 CMRs 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 CRNAs to utilize their authority to issue prescriptions, CRNAs 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. The BORN has provided a “MCSR Audit Tool”, which specifies the requirements for establishing guidelines for APRN prescriptive 

In the pages below, we have compiled documentation of the MGLs, CMRs, notices from the BORN, and 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

94C Section 7
94C Section 7(g)
94C Section 7A
94C Section 9
112 Section 80B
112 Section 80H

Tools to Navigate the Board of Registration

105 CMR: Department of Public Health: 700
244 CMR: Board of Registration in Nursing
243 CMR: Board of Registration in Medicine: 2.10: APN Eligible to Engage in Prescriptive Practice

Important Documents

BORN Notice
MCSR Application
MCSR Audit Tool
DEA New Registration Applications
Practice Prescriptive Guidelines/Prescriptive Authority
MA Prescription Monitoring Program
DEA Drug Scheduling

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 are 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.