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Prescribing & DEA Roadmap

Missouri Registered Nurse Prescriptive authority

Separate professional authority, state registration and federal DEA steps.

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Showing findings with official source evidence. Check the conditions for each requirement and confirm your circumstances with the board.

Use the boxes to track your preparation. Checking an item does not verify compliance.

Who may prescribe

  • A physician may delegate to a registered professional nurse the authority to administer or dispense drugs, if the delivery is within the RN’s scope of practice and consistent with the nurse’s skill, training, and competence.

    Applies when: When there is a written collaborative practice arrangement.

    Source evidence
    1. 1. revisor.mo.gov ↗
      A physician may enter into collaborative practice arrangements with registered professional nurses.
    2. 2. revisor.mo.gov ↗
      Collaborative practice arrangements shall be in the form of written agreements, jointly agreed-upon protocols, or standing orders for the delivery of health care services
    3. 3. pr.mo.gov ↗
      Collaborative practice arrangements, which shall be in writing, may delegate to a registered professional nurse the authority to administer or dispense drugs and provide treatment as long as the delivery of such health care services is within the scope of practice of the registered professional nurse and is consistent with that nurse’s skill, training and competence.

  • A collaborative practice arrangement may delegate authority to administer, dispense, or prescribe drugs only if the registered professional nurse is an APRN.

    Applies when: For Missouri collaborative practice prescribing.

    Source evidence
    1. 1. revisor.mo.gov ↗
      2. (1) Collaborative practice arrangements, which shall be in writing, may delegate to a registered professional nurse the authority to administer, dispense or prescribe drugs and provide treatment if the registered professional nurse is an advanced practice registered nurse as defined in subdivision (2) of section 335.016
    2. 2. revisor.mo.gov ↗
      (1) Collaborative practice arrangements, which shall be in writing, may delegate to a registered professional nurse the authority to administer, dispense or prescribe drugs and provide treatment if the registered professional nurse is an advanced practice registered nurse as defined in subdivision (2) of section 335.016

  • Could not confirm that a Missouri Registered Nurse may independently prescribe drugs. Missouri authority cited for RN collaborative practice instead allows only delegated administration or dispensing, and prescribing is limited to an APRN.

    Applies when: For a Missouri RN license type.

    Source evidence
    1. 1. pr.mo.gov ↗
      Through a written agreement, jointly agreed upon written protocols, or written standing orders for the delivery of health care services, a physician may delegate to a RN who is not an advanced practice nurse the authority to administer
    2. 2. pr.mo.gov ↗
      Collaborative practice arrangements, which shall be in writing, may delegate to a registered professional nurse the authority to administer or dispense drugs and provide treatment as long as the delivery of such health care services is within the scope of practice of the registered professional nurse and is consistent with that nurse’s skill, training and competence.
    3. 3. revisor.mo.gov ↗
      2. (1) Collaborative practice arrangements, which shall be in writing, may delegate to a registered professional nurse the authority to administer, dispense or prescribe drugs and provide treatment if the registered professional nurse is an advanced practice registered nurse as defined in subdivision (2) of section 335.016

License and education prerequisites

  • Missouri collaborative practice can delegate prescribing only if the registered professional nurse is an APRN.

    Applies when: For delegated prescribing under Missouri collaborative practice.

    Source evidence
    1. 1. revisor.mo.gov ↗
      2. (1) Collaborative practice arrangements, which shall be in writing, may delegate to a registered professional nurse the authority to administer, dispense or prescribe drugs and provide treatment if the registered professional nurse is an advanced practice registered nurse as defined in subdivision (2) of section 335.016

  • Delegated treatment must stay within the RN’s scope and be consistent with the nurse’s skill, training, and competence.

    Applies when: For delegated drug or treatment authority.

    Source evidence
    1. 1. pr.mo.gov ↗
      Collaborative practice arrangements, which shall be in writing, may delegate to a registered professional nurse the authority to administer or dispense drugs and provide treatment as long as the delivery of such health care services is within the scope of practice of the registered professional nurse and is consistent with that nurse’s skill, training and competence.

  • Missouri collaborative practice can delegate prescribing only if the registered professional nurse is an advanced practice registered nurse.

    Applies when: For delegated prescribing under Missouri collaborative practice.

    Source evidence
    1. 1. revisor.mo.gov ↗
      2. (1) Collaborative practice arrangements, which shall be in writing, may delegate to a registered professional nurse the authority to administer, dispense or prescribe drugs and provide treatment if the registered professional nurse is an advanced practice registered nurse as defined in subdivision (2) of section 335.016

  • Delegated treatment must stay within the RN’s scope and be consistent with skill, training and competence.

    Applies when: For delegated drug or treatment authority.

    Source evidence
    1. 1. revisor.mo.gov ↗
      Collaborative practice arrangements, which shall be in writing, may delegate to a registered professional nurse the authority to administer or dispense drugs and provide treatment as long as the delivery of such health care services is within the scope of practice of the registered professional nurse and is consistent with that nurse's skill, training and competence

Collaboration and supervision

  • Collaborative practice must be consistent with each professional’s skill, training, education, and competence, and maintain geographic proximity.

    Applies when: For Missouri collaborative practice arrangements.

    Source evidence
    1. 1. revisor.mo.gov ↗
      (a) Engage in collaborative practice consistent with each professional's skill, training, education, and competence; (b) Maintain geographic proximity, except as specified in this paragraph.
    2. 2. revisor.mo.gov ↗
      Maintain geographic proximity, except as specified in this paragraph.

  • The healing arts board and the board of nursing may jointly promulgate rules regulating collaborative practice arrangements; neither may separately promulgate them.

    Applies when: Rulemaking on collaborative practice arrangements.

    Source evidence
    1. 1. revisor.mo.gov ↗
      4. The state board of registration for the healing arts pursuant to section 334.125 and the board of nursing pursuant to section 335.036 may jointly promulgate rules regulating the use of collaborative practice arrangements.
    2. 2. revisor.mo.gov ↗
      Neither the state board of registration for the healing arts nor the board of nursing may separately promulgate rules relating to collaborative practice arrangements

  • A physician may enter into collaborative practice arrangements with registered professional nurses, and the arrangements shall be in writing.

    Applies when: When Missouri collaborative practice applies.

    Source evidence
    1. 1. revisor.mo.gov ↗
      A physician may enter into collaborative practice arrangements with registered professional nurses.
    2. 2. revisor.mo.gov ↗
      Collaborative practice arrangements shall be in the form of written agreements, jointly agreed-upon protocols, or standing orders for the delivery of health care services

  • The arrangement must maintain geographic proximity, and when it is used in clinical situations with APRN diagnosis and treatment initiation, a physician must be present at least once every two weeks, except in extraordinary documented circumstances.

    Applies when: When the statutory collaboration terms apply.

    Source evidence
    1. 1. revisor.mo.gov ↗
      Maintain geographic proximity, except as specified in this paragraph.
    2. 2. revisor.mo.gov ↗
      at least once every two weeks, except in extraordinary circumstances that shall be documented

  • A physician may enter into collaborative practice arrangements with registered professional nurses, and the arrangement must be in writing.

    Applies when: When Missouri collaborative practice applies.

    Source evidence
    1. 1. revisor.mo.gov ↗
      A physician may enter into collaborative practice arrangements with registered professional nurses. Collaborative practice arrangements shall be in the form of written agreements
    2. 2. revisor.mo.gov ↗
      Collaborative practice arrangements, which shall be in writing

  • The collaborative arrangement must address geographic proximity, and some settings require chart review and medical direction at least once every two weeks.

    Applies when: When the statute’s collaboration terms apply.

    Source evidence
    1. 1. revisor.mo.gov ↗
      Maintain geographic proximity, except as specified in this paragraph.
    2. 2. revisor.mo.gov ↗
      at least once every two weeks, except in extraordinary circumstances that shall be documented

  • Collaborative practice must be consistent with each professional’s skill, training, education, and competence.

    Applies when: For Missouri collaborative practice arrangements.

    Source evidence
    1. 1. revisor.mo.gov ↗
      (a) Engage in collaborative practice consistent with each professional's skill, training, education, and competence; (b) Maintain geographic proximity, except as specified in this paragraph.

State controlled-substance authority

  • BNDD is the Missouri DHSS entity tasked with regulating legitimate medical controlled substance activities performed by licensed medical professionals and entities in Missouri.

    Applies when: State controlled-substance oversight in Missouri.

    Source evidence
    1. 1. health.mo.gov ↗
      The Bureau of Narcotics and Dangerous Drugs (BNDD) is the entity within the Department of Health and Senior Services (DHSS) tasked with regulating legitimate medical controlled substance activities performed by licensed medical professionals and entities within the State of Missouri.
    2. 2. health.mo.gov ↗
      BNDD’s authority is derived from Chapters 195 & 579 RSMo., collectively known as the Comprehensive Drug Control Act.

  • Applications for a Missouri state-level controlled substance registration can only be submitted online; paper applications are no longer accepted.

    Applies when: Applicants for Missouri state-level controlled substance registration.

    Source evidence
    1. 1. health.mo.gov ↗
      applications for a Missouri state-level controlled substance registration can only be submitted online.
    2. 2. health.mo.gov ↗
      Paper applications are no longer accepted.

  • Please allow 3-5 business days for application processing.

    Applies when: Missouri state-level controlled substance registration application.

    Source evidence
    1. 1. health.mo.gov ↗
      Please allow 3-5 business days for application processing.

  • The Missouri Bureau of Narcotics and Dangerous Drugs regulates legitimate medical controlled substance activities in the state.

    Applies when: For Missouri controlled-substance oversight.

    Source evidence
    1. 1. health.mo.gov ↗
      The Bureau of Narcotics and Dangerous Drugs (BNDD) is the entity within the Department of Health and Senior Services (DHSS) tasked with regulating legitimate medical controlled substance activities performed by licensed medical professionals and entities within the State of Missouri.

  • Missouri state-level controlled substance registration applications are submitted online.

    Applies when: For BNDD registration processing.

    Source evidence
    1. 1. health.mo.gov ↗
      applications for a Missouri state-level controlled substance registration can only be submitted online.

  • BNDD is within DHSS and regulates legitimate medical controlled substance activities performed by licensed medical professionals and entities in Missouri.

    Applies when: For Missouri controlled-substance registration.

    Source evidence
    1. 1. health.mo.gov ↗
      # Narcotics & Dangerous Drugs ## Contact The Bureau of Narcotics and Dangerous Drugs (BNDD) is the entity within the Department of Health and Senior Services (DHSS) tasked with regulating legitimate medical controlled substance activities performed by licensed medical professionals and entities within the State of Missouri.
    2. 2. health.mo.gov ↗
      BNDD’s authority is derived from Chapters 195 & 579 RSMo., collectively known as the Comprehensive Drug Control Act.

Federal DEA requirements

  • DEA registration is contingent in part on the applicant’s authorization in the state where they practice, and DEA says state licensing boards determine controlled-substance privileges and limits.

    Applies when: Federal DEA registration context.

    Source evidence
    1. 1. deadiversion.usdoj.gov ↗
      Since DEA's authority to register practitioners to dispense (including to prescribe) controlled substances is contingent, in part, upon the applicant's authorization in the state in which he or she practices, his or her controlled substance privileges and limits are determined by that specific state.
    2. 2. deadiversion.usdoj.gov ↗
      DEA relies on State licensing boards to determine whether a practitioner is qualified to dispense, prescribe, or administer controlled substances and to determine which schedules he/she may dispense, prescribe, or administer.

  • A separate DEA registration is required at each principal place of business or professional practice.

    Applies when: For each practice location.

    Source evidence
    1. 1. deadiversion.usdoj.gov ↗
      The Controlled Substances Act requires a separate registration at each principal place of business or professional practice where the controlled substances are distributed or dispensed.
    2. 2. deadiversion.usdoj.gov ↗
      DEA regulations require a separate registration for each principal place of business or professional practice at one general physical location where controlled substances are manufactured, distributed, imported, exported, or dispensed by a person.

  • State authority only confers rights and privileges within the issuing State; a DEA registration based on a State license cannot authorize dispensing outside that State.

    Applies when: When relying on state licensure for DEA registration.

    Source evidence
    1. 1. deadiversion.usdoj.gov ↗
      State authority to conduct the above-referenced activities only confers rights and privileges within the issuing State.
    2. 2. deadiversion.usdoj.gov ↗
      Thus, a DEA registration based on a State license cannot authorize controlled substance dispensing outside the State.

  • DEA authority to register practitioners is contingent in part on state authorization, and a separate DEA registration is required at each principal place of practice.

    Applies when: For DEA controlled-substance registration.

    Source evidence
    1. 1. deadiversion.usdoj.gov ↗
      Since DEA's authority to register practitioners to dispense (including to prescribe) controlled substances is contingent, in part, upon the applicant's authorization in the state in which he or she practices, his or her controlled substance privileges and limits are determined by that specific state.
    2. 2. deadiversion.usdoj.gov ↗
      The Controlled Substances Act requires a separate registration at each principal place of business or professional practice where the controlled substances are distributed or dispensed.

  • A DEA registered address must be the physical location of the principal practice; a PO Box alone is not a registered address.

    Applies when: For DEA registration address.

    Source evidence
    1. 1. deadiversion.usdoj.gov ↗
      Answer: Your registered address must be the physical location of your principal place of business or professional practice where controlled substances are manufactured, distributed, imported, exported, or dispensed.
    2. 2. deadiversion.usdoj.gov ↗
      In limited circumstances, a PO Box may be included in addition to the physical business address, but a PO Box alone is not a registered address.

Training and monitoring

  • All DEA-registered practitioners, except practitioners that are solely veterinarians, must attest to the CAA training requirement on the first applicable registration on or after June 27, 2023.

    Applies when: DEA registration or renewal on or after June 27, 2023.

    Source evidence
    1. 1. deadiversion.usdoj.gov ↗
      Answer: All DEA-registered practitioners, with the exception of practitioners that are solely veterinarians.
    2. 2. deadiversion.usdoj.gov ↗
      Answer: As a condition of registration, the new training requirement in section 1263(a) of the CAA went into effect on June 27, 2023, and applies to all qualified practitioners when they apply for a new registration or a renewal of registration on or after that date.
    3. 3. deadiversion.usdoj.gov ↗
      The term "first applicable registration" means the first registration or renewal of registration by a qualified practitioner on or after June 27, 2023, under 21 U.S.C. 823(l)(4)(A).

  • For non-physician practitioners legally authorized by the State to dispense controlled medications under schedules II-V, at least 8 hours of training must include treatment and management of patients with opioid or other substance use disorders.

    Applies when: For the qualifying DEA cohort described in the FAQ.

    Source evidence
    1. 1. deadiversion.usdoj.gov ↗
      For those applicants who are non-physicians and legally authorized by the State to dispense controlled medications under schedules II-V, at least 8 hours of training must include training with respect to the treatment and management of patients with opioid or other substance use disorders delivered by an entity listed in the CAA.
    2. 2. deadiversion.usdoj.gov ↗
      Those applicants, other than a physician or a veterinarian, legally authorized by the State to dispense controlled medications under schedules II-V, may meet the training requirement when they have graduated in good standing from an accredited physician assistant school or accredited school of advanced practice nursing in the United States during the past 5 years, and successfully completed a comprehensive physician assistant or advanced practice nursing curriculum that
    3. 3. deadiversion.usdoj.gov ↗
      5 years, and successfully completed a comprehensive physician assistant or advanced practice nursing curriculum that included at least 8 hours of training on treating and managing patients with opioid or other substance use disorders, including the appropriate clinical use of all medications approved by the FDA for the treatment of substance use disorder.

  • DEA says it is recommended that each practitioner keep training certificates or other materials documenting completion, but these documents do not need to be submitted to DEA at initial application or renewal.

    Applies when: DEA MATE attestation.

    Source evidence
    1. 1. deadiversion.usdoj.gov ↗
      It is recommended that each practitioner keep a record of training certificates or other materials documenting completion.
    2. 2. deadiversion.usdoj.gov ↗
      However, these documents will not need to be submitted to DEA for review at the time of initial application or renewal of registration.

Fees and renewals

  • License renewal for a professional nurse and an APRN is biennial, occurring on odd-numbered years, and the license expires on April 30 of each odd-numbered year.

    Applies when: Professional nurse and APRN licenses.

    Source evidence
    1. 1. sos.mo.gov ↗
      4. License renewal for a professional nurse and an APRN shall be biennial, occurring on odd-numbered years and the license shall expire on April 30 of each odd-numbered year.

  • The required fee and practice/demographics information must be submitted prior to the license expiration date.

    Applies when: Missouri nurse renewal.

    Source evidence
    1. 1. sos.mo.gov ↗
      (B) The required fee and information related to the nurse’s practice and demographics for the purpose of collecting nursing workforce data shall be submitted prior to the expiration date of the license

Applications and documents

  • The Missouri Board of Nursing page identifies a controlled substance prescriptive authority application and the supporting documents for APRN category and controlled substance delegation, with BNDD and DEA listed as related sources.

    Applies when: Missouri APRN controlled-substance authority process.

    Source evidence
    1. 1. pr.mo.gov ↗
      # Board of Nursing ### Controlled Substance Prescriptive Authority Information Instructions for Controlled Substance Prescriptive Authority Controlled Substance Prescriptive Authority Application Statement of Preceptorial Experience/APRN Category Statement of Controlled Substance Delegation Bureau of Narcotics and Dangerous Drugs (BNDD) Drug Enforcement Administration (DEA) See statute, 335.019, RSMo See rule, 20 CSR 2200-4.100 Advanced Practice Registered Nurse See rule, 20
    2. 2. pr.mo.gov ↗
      (DEA) See statute, 335.019, RSMo See rule, 20 CSR 2200-4.100 Advanced Practice Registered Nurse See rule, 20 CSR 2200-4.200 Collaborative Practice

  • DEA says the practitioner must first obtain authorization to handle controlled substances in each state where they have an office before obtaining a separate DEA registration there.

    Applies when: When seeking DEA registration for a practice location.

    Source evidence
    1. 1. deadiversion.usdoj.gov ↗
      Further, to do so the practitioner must first obtain authorization to handle controlled substances in each state where he or she has an office.
    2. 2. deadiversion.usdoj.gov ↗
      Consequently, DEA requires that the practitioner obtain a separate DEA registration in each state.

Authorities and sources

  • BNDD is the Missouri controlled-substance authority within DHSS.

    Applies when: For Missouri controlled-substance authority.

    Source evidence
    1. 1. health.mo.gov ↗
      The Bureau of Narcotics and Dangerous Drugs (BNDD) is the entity within the Department of Health and Senior Services (DHSS) tasked with regulating legitimate medical controlled substance activities performed by licensed medical professionals and entities within the State of Missouri.
    2. 2. health.mo.gov ↗
      # Narcotics & Dangerous Drugs ## Contact The Bureau of Narcotics and Dangerous Drugs (BNDD) is the entity within the Department of Health and Senior Services (DHSS) tasked with regulating legitimate medical controlled substance activities performed by licensed medical professionals and entities within the State of Missouri.

  • DEA’s Registration Q&A and MATE Act Q&A are the federal sources for registration and training attestation requirements.

    Applies when: For federal DEA obligations.

    Source evidence
    1. 1. pr.mo.gov ↗
      Fully licensed APRNs will be independent practitioners.
    2. 2. senate.mo.gov ↗
      5 Collaborative practice arrangements, which shall be in 6 writing, may delegate to a registered professional nurse the 7 authority to administer or dispense drugs and provide 8 treatment as long as the delivery of such health care 9 services is within the scope of practice of the registered 10 professional nurse and is consistent with that nurse's 11 skill, training and competence. 12

  • The Missouri Board of Nursing is the state nursing authority page for collaborative practice and controlled-substance prescriptive authority information.

    Applies when: For Missouri nursing authority sources.

    Source evidence
    1. 1. pr.mo.gov ↗
      # Board of Nursing ### Nursing & Collaborative Practice
    2. 2. pr.mo.gov ↗
      # Board of Nursing ### Controlled Substance Prescriptive Authority Information
    3. 3. pr.mo.gov ↗
      # Board of Nursing ### Controlled Substance Prescriptive Authority Information Instructions for Controlled Substance Prescriptive Authority Controlled Substance Prescriptive Authority Application Statement of Preceptorial Experience/APRN Category Statement of Controlled Substance Delegation Bureau of Narcotics and Dangerous Drugs (BNDD) Drug Enforcement Administration (DEA) See statute, 335.019, RSMo See rule, 20 CSR 2200-4.100 Advanced Practice Registered Nurse See rule, 20

  • BNDD is the Missouri controlled-substance authority within DHSS, and the Board of Nursing page links BNDD and DEA as relevant sources.

    Applies when: For Missouri controlled-substance authority.

    Source evidence
    1. 1. health.mo.gov ↗
      # Narcotics & Dangerous Drugs ## Contact The Bureau of Narcotics and Dangerous Drugs (BNDD) is the entity within the Department of Health and Senior Services (DHSS) tasked with regulating legitimate medical controlled substance activities performed by licensed medical professionals and entities within the State of Missouri.
    2. 2. pr.mo.gov ↗
      # Board of Nursing ### Controlled Substance Prescriptive Authority Information Instructions for Controlled Substance Prescriptive Authority Controlled Substance Prescriptive Authority Application Statement of Preceptorial Experience/APRN Category Statement of Controlled Substance Delegation Bureau of Narcotics and Dangerous Drugs (BNDD) Drug Enforcement Administration (DEA) See statute, 335.019, RSMo See rule, 20 CSR 2200-4.100 Advanced Practice Registered Nurse See rule, 20

  • DEA’s Registration Q&A and MATE Act Q&A are the federal sources for registration and the training attestation requirement.

    Applies when: For federal DEA obligations.

    Source evidence
    1. 1. deadiversion.usdoj.gov ↗
      # Registration Q&A ### Registration **Answer**: Yes.
    2. 2. deadiversion.usdoj.gov ↗
      # Opioid Use Disorder – MATE Act Home Resources Questions & Answers Opioid Use Disorder – MATE Act Q&A ### Opioid Use Disorder – MATE Act #### Question: I am a DEA-registered practitioner.
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