Nearly half of US states have expanded the scope of nursing practice, with several more evaluating the appropriateness of such measures. The debate between physicians and nurses regarding nursing autonomy remains a contentious issue that is likely to resurface in legislative discussions. In the meantime, the Board of Medicine and the Board of Nursing will continue to enforce existing requirements quietly. Under current Florida laws, advanced registered nurse practitioners (ARNPs) are authorized to perform medical diagnoses, treatments, and prescriptions, but these acts generally require the supervision of a physician. This supervisory relationship must be detailed in a protocol that specifies the medical acts to be performed and the conditions for their performance.
Contents of an ARNP Protocol:
With few exceptions, every ARNP must file an original protocol with the Florida Board of Nursing within 30 days of:
- Entering into a supervisory relationship with a physician,
- Renewing a State of Florida medical license, or
- Any changes to the information contained in an existing protocol
The protocol should include:
- The date of the protocol or amendment,
- The nature of the ARNP’s practice and duties,
- The location of the ARNP’s practice,
- The names, signatures, license numbers, and DEA numbers of the supervising physician(s),
- The duties of each supervising physician, and
- All medications that each supervising physician has agreed the ARNP may prescribe.
If multiple physicians supervise the ARNP, only one protocol needs to be filed, but it must include signatures, license numbers, and DEA numbers of all supervisors. A sample ARNP protocol is available on the Board of Nursing’s website at floridasnursing.gov/forms/arnp-protocol-sample.pdf.
Physician Obligations:
Every physician supervising an ARNP must file a notice of supervision with the Board of Medicine within 30 days of entering or terminating the relationship. If the physician supervises an ARNP in an office different from their primary practice location, they must post:
- The times when the physician is physically present in each office, and
- Office hours when the physician is not present.
Primary care physicians may not supervise more than four primary care offices other than their primary location, while specialists are limited to two additional offices. Additional regulations apply if the ARNP provides dermatologic or skin care services.
Evolution:
Florida law has greatly expanded the scope of APRN services to include those which don’t require physician supervision. That expansion is expected to continue and is something to watch virtually every legislative session.
By: Jeff Cohen
Founder, Florida Healthcare Law Firm
