Can PAs Prescribe Controlled Substances in Florida?

Yes, physician assistants in Florida can prescribe controlled substances, but only when a supervising physician has delegated that authority in writing, the PA has completed a specific continuing education course, and the PA holds an active DEA registration. Every prescription must stay inside the supervising physician’s scope of practice, respect Florida’s negative formulary, and follow the state’s day-supply caps for Schedule II drugs.

Where the Authority Comes From

A Florida PA has no independent prescribing authority. The right to prescribe flows from a supervising physician who delegates it in a written protocol, and the protocol has to list the medications the PA may prescribe. Those medications must also fall within the supervising physician’s own scope of practice.¹ A PA supervised by an internist cannot prescribe outside internal medicine even if the drug is otherwise permissible.

Before any of this can happen, the supervising physician has to notify the Florida Board of Medicine on the Board’s prescribing notification form. There is no fee, but the notification must be on file before the PA writes a single prescription.²

What the PA Needs Before Writing a Controlled Substance Prescription

Two personal prerequisites apply to the PA before controlled substances enter the picture.

The first is education. A PA must complete at least a 3-hour continuing medical education course on the safe and effective prescribing of controlled substances. The course has to be provided by a statewide professional association of physicians accredited for AMA Category 1 credit, or designated as Category 1 credit by the American Academy of Physician Assistants. This isn’t a one-time obligation: 3 of the 10 specialty CME hours required at each license renewal must be this controlled substance course.³

The second is federal registration. The DEA classifies physician assistants as mid-level practitioners and requires each PA to hold an individual DEA number before prescribing or dispensing controlled substances.⁴ Registration runs on a three-year cycle, and the most recently published fee for mid-level practitioners is $888 for those three years.⁵

What PAs Cannot Prescribe at All

Florida keeps a negative formulary of medications physician assistants may never prescribe, no matter what the supervising physician tries to delegate. The formulary bars PAs from prescribing general, spinal, or epidural anesthetics and radiographic contrast materials.⁶

Even off the prohibited list, a PA is still bounded by the supervising physician’s practice. If the physician doesn’t use a drug in their own practice, the PA cannot prescribe it.¹

Schedule II Supply Limits

Any Schedule II prescription written by a Florida PA is capped at a 7-day supply. That cap covers stimulants, opioids, and other Schedule II drugs alike.¹

Schedule II opioids for acute pain carry an additional, stricter limit that applies to every Florida prescriber. The default is a 3-day supply. A prescriber can go up to 7 days only after determining it is medically necessary, writing “acute pain exception” on the prescription, and documenting the justification in the medical record. Splitting a course of treatment into repetitive short prescriptions to sidestep the limit isn’t allowed.⁷

Some conditions are exempt from the acute pain caps entirely:

Cancer.
Terminal conditions, defined as a progressive disease expected to result in death within one year if it runs its normal course.
Palliative care aimed at relieving symptoms of an incurable, progressive illness or injury.
Traumatic injury with an Injury Severity Score of 9 or higher.

The acute pain supply rule also does not apply to Schedule II drugs prescribed for non-pain conditions. A PA prescribing methylphenidate for ADHD, for example, is not held to the 3-day acute pain rule, though the 7-day PA formulary cap still applies.⁷ Schedules III through V have no equivalent state day-supply cap, but they still have to sit inside the written supervisory protocol.

Psychiatric Medications for Patients Under 18

There is a narrow exception to the 7-day Schedule II cap. When a PA prescribes a Schedule II psychiatric medication to a patient under 18, the supply can go up to 14 days. This exception applies only when the PA is supervised by a pediatrician, family practice physician, internal medicine physician, or psychiatrist. A PA working under a surgeon or another specialist outside those four categories cannot use this provision.¹

The Mandatory PDMP Check

Before prescribing any Schedule II through V controlled substance to a patient aged 16 or older, a Florida PA must consult the state’s Prescription Drug Monitoring Program. The system, E-FORCSE, tracks a patient’s controlled substance dispensing history statewide, so the query shows whether the patient has been receiving controlled substances from other prescribers.⁸ The check is not optional; skipping it exposes the PA to disciplinary action.

Penalties for Getting It Wrong

Consequences scale with the violation. For inappropriate or excessive prescribing, a first offense can bring anything from one year of probation to license revocation, plus an administrative fine of $1,000 to $5,000. A subsequent offense raises the fine range to $5,000 to $10,000. A PA who prescribes a controlled substance to themselves faces probation to suspension on a first offense and suspension to revocation on a second, with a mandatory mental and physical examination in both cases. A prescribing pattern showing a lack of reasonable skill or safety can trigger fines up to $10,000 and suspension or revocation on a first finding.⁹

State discipline isn’t the only exposure. A PA who prescribes controlled substances without proper DEA registration or outside delegated authority also faces potential federal criminal liability under 21 U.S.C. § 841, which treats unauthorized distribution of controlled substances as a federal offense with penalties that vary by drug schedule and quantity.¹⁰

1
The Florida Statutes. Florida Statutes 458.347 – Physician Assistants
2
Florida Board of Medicine. Physician Assistant Prescribing Notification
3
Florida Board of Medicine. Continuing Education (CE/CME) Requirements
4
Drug Enforcement Administration. Mid-Level Practitioners Authorization by State
5
Federal Register. Registration and Reregistration Fees for Controlled Substance and List I Chemical Registrants
6
Legal Information Institute (LII) at Cornell Law School. Florida Admin Code 64B8-30.008 – Formulary
7
Florida Department of Health. FAQs – Take Control of Controlled Substances
8
Florida Department of Health. Prescription Drug Monitoring Program – Take Control of Controlled Substances
9
Legal Information Institute (LII) at Cornell Law School. Florida Admin Code 64B8-30.015 – Disciplinary Guidelines
10
Office of the Law Revision Counsel. 21 U.S. Code 841 – Prohibited Acts A