Can PAs Prescribe Controlled Substances in Florida?

Yes, physician assistants in Florida can prescribe controlled substances, but the authority is delegated, not independent, and it comes wrapped in training, registration, and day-supply rules that leave little room for improvisation. Florida Statute 458.347 sets the framework: a supervising physician delegates prescribing through a written protocol, the PA completes a specific controlled-substance course and obtains a DEA number, and most Schedule II prescriptions are capped at a 7-day supply.

What a PA Needs Before Writing a Controlled Substance Prescription

A Florida PA has no independent prescribing authority. Everything flows from the supervising physician, who delegates specific drugs through a written protocol. Those drugs must fall inside the supervising physician’s own scope of practice. A PA working under an internist cannot prescribe something an internist would not use, even if the medication is otherwise legal for PAs to prescribe.¹

The supervising physician also has to notify the Florida Board of Medicine on the Board’s prescribing notification form before the PA writes anything. There’s no fee, but the notification has to be on file first.²

Two additional prerequisites apply specifically to controlled substances. First, the PA must complete a minimum 3-hour continuing medical education course on the safe and effective prescribing of controlled substances, from a statewide professional physicians’ association accredited for AMA Category 1 credit or designated by the American Academy of Physician Assistants as Category 1 credit. This is not a one-time hurdle. Three of the 10 specialty CME hours required at each license renewal must be this controlled-substance course.³

Second, the PA must hold their own DEA registration. The DEA classifies PAs as mid-level practitioners and requires individual registration before they can prescribe or dispense controlled substances.⁴ Registration runs for three years; the most recently published mid-level fee is $888 for that period.⁵

What PAs Are Not Allowed to Prescribe

Florida keeps a negative formulary of drugs PAs cannot prescribe no matter what the supervising physician delegates. The prohibited categories are general, spinal, and epidural anesthetics, and radiographic contrast materials.⁶

Everything else loops back to the protocol and the supervising physician’s practice area. A drug can be perfectly legal, on no prohibited list, and still off-limits to a given PA because their supervising physician does not use it.

The 7-Day Schedule II Cap and the Opioid Rules

Schedule II prescriptions written by a PA are capped at a 7-day supply. That ceiling applies across the board, whether the drug is a stimulant, an opioid, or something else in Schedule II.¹

For Schedule II opioids prescribed to treat acute pain, a tighter rule applies to every Florida prescriber. The default is a 3-day supply. A prescriber can go up to 7 days only by determining it is medically necessary, writing “acute pain exception” on the prescription, and documenting the justification in the patient’s record. Writing back-to-back short prescriptions for the same condition to work around the cap is not allowed.⁷

Several situations are exempt from the acute pain day-supply limits:

Cancer, with no day-supply cap.
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.

Schedule II drugs prescribed for non-pain conditions, such as a stimulant for ADHD, are not subject to the 3-day acute pain rule, though the 7-day PA formulary cap still applies.⁷ Schedules III through V face no day-supply ceiling under these rules, but still must sit inside the written protocol.

Schedule II Psychiatric Medications for Minors

When a PA prescribes a Schedule II psychiatric medication to a patient under 18, the supply limit is 14 days rather than 7. This exception only applies if the supervising physician is a pediatrician, family practice physician, internal medicine physician, or psychiatrist. A PA working under a surgeon or another specialty outside those four cannot use this provision to prescribe psychiatric controlled substances to minors.¹

The Mandatory PDMP Check

Before prescribing any controlled substance in Schedules II through V to a patient 16 or older, a PA must consult Florida’s Prescription Drug Monitoring Program, E-FORCSE. The system tracks a patient’s controlled-substance dispensing history statewide and shows whether other prescribers are already supplying the patient.⁸ The check is mandatory, not advisory. Skipping it is a basis for discipline.

Electronic Prescribing

Florida law requires practitioners who use electronic health records to transmit prescriptions electronically rather than on paper. PAs who prescribe within a practice that keeps electronic records are covered. There are narrow exceptions, including situations where electronic transmission is impractical and would delay patient care, and hardship waivers issued by the Department of Health.⁹

A separate federal rule reaches PAs who prescribe controlled substances under Medicare Part D. Starting with the 2026 measurement year, the CMS Electronic Prescribing for Controlled Substances program requires prescribers to electronically prescribe at least 70% of their qualifying Schedule II through V controlled substance prescriptions billed to Medicare Part D. Prescribers who write 100 or fewer qualifying prescriptions during the year are automatically excepted, and non-compliant prescribers receive a notice in the fall following the measurement year.¹⁰

Penalties for Getting It Wrong

The Florida Board of Medicine’s disciplinary guidelines give the Board a range of options depending on the facts. For inappropriate or excessive prescribing, a first offense can bring anything from one year of probation up to license revocation, plus a $1,000 to $5,000 administrative fine. 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 mandatory mental and physical examination in both cases. A prescribing pattern that shows a lack of reasonable skill or safety can draw fines up to $10,000 and suspension or revocation even on a first finding.¹¹

Those are the state-level consequences. A PA who prescribes controlled substances without proper DEA registration or outside delegated authority also risks 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.¹²

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
Florida Senate. Florida Statutes 456.42 – Written Prescriptions for Medicinal Drugs
10
CMS. CMS EPCS Program Requirement At-A-Glance
11
Legal Information Institute (LII) at Cornell Law School. Florida Admin Code 64B8-30.015 – Disciplinary Guidelines
12
Office of the Law Revision Counsel. 21 U.S. Code 841 – Prohibited Acts A