Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Medicine
 
chapter
Regulations Governing the Practice of Physician Assistants [18 VAC 85 ‑ 50]
Action Removal of patient care team physician or podiatrist name from prescriptions issued by physician assistants
Stage NOIRA
Comment Period Ended on 4/9/2025
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37 comments

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3/11/25  4:36 pm
Commenter: Josh Detrick

Support removal of physician name from controlled substance prescriptions
 

As a practicing surgical physician associate, I support the removal of the physicians name from controlled substance prescriptions. Many EMRs lack this capability and since it is required to transmit those ordered electronically this inherently causes some level of non compliance. Also, I question the utility as many PAs work at a different site from their physician. We have prescriptive authority to order the medications, what purpose does their name serve? We have our DEA on the prescription already. Please consider removing this antiquated process. 

CommentID: 233003
 

3/11/25  4:36 pm
Commenter: Evan Turnbull, UVA Health

Agree
 

This change would be immensely helpful. I have received calls from pharmacists from Walmart and CVS stating they need additional physician information in order to fill the prescription I wrote. The prescription includes the physician’s name and NPI, but the computer program does not generate the DEA. While that is not required by law, and my prescription is otherwise compliant with current law, they will not proceed until they have the DEA. Removing the physician name requirement all together will help eliminate confusion and improve patient experience, not to mention reduce delays and additional time burden on the prescribing PA. 

CommentID: 233004
 

3/11/25  5:44 pm
Commenter: Erika Francis, Shenandoah University

Support of Petition to Remove Physician Name Requirement on Prescriptions
 

As the Interim Program Director of the Shenandoah University Physician Assistant (PA) Program, I strongly support the petition to remove the requirement that a patient care team physician’s name be included on prescriptions for Schedule II-V medications.

This change is a necessary step in recognizing the autonomous prescribing authority of PAs within the collaborative practice framework. PAs are rigorously trained medical professionals who provide high-quality patient care, and their ability to prescribe controlled substances is already regulated through state licensure, DEA registration, and collaborative practice agreements. Requiring a supervising physician’s name on prescriptions does not enhance patient safety but rather creates administrative burdens that can delay care, contribute to confusion at the pharmacy, and misrepresent the prescribing provider’s role in the patient’s treatment plan.

Removing this requirement aligns with best practices in other states and supports a more efficient and transparent healthcare system. I urge the Board of Medicine to approve this petition and modernize regulations to better reflect the evolving role of PAs in Virginia’s healthcare workforce.

Sincerely,

Erika Francis, DMS, PA-C

Interim Program Director

Shenandoah University PA Program

CommentID: 233006
 

3/11/25  5:44 pm
Commenter: Samantha Buhler

Support of Action
 

As a licensed Physician Assistant in Virginia with an independent DEA registration, the removal of the requirement for including the supervising physician's or podiatrist's name on prescriptions for Schedule II-V controlled substances is a necessary and logical step. This adjustment reflects the professional accountability of PAs, as listing a physician's name does improve patient care but instead creates unnecessary administrative burdens. 

 

CommentID: 233007
 

3/12/25  6:26 am
Commenter: Kim Ketchersid, VCU Health

Support in removing this barrier to care
 

Requiring a physician or podiatrists' name on scripts for controlled substances has caused patients to experience delays in having their pain medications filled. PAs hold their own DEA licenses, have completed the required pharmacology training, and have access to the Prescription Monitoring Program. Removing this requirement only increases access to care. 

CommentID: 233009
 

3/12/25  8:12 am
Commenter: Jerry Weniger, PhD, PA-C

Please change this obsolete regulation
 

As the Director of the PA Program at James Madison University, I strongly support the removal of the current requirement that a patient care team physician’s name be included on prescriptions for Schedule II-V medications.  PAs already have prescriptive authority at the state level via licensure, are registered with the DEA federally, and have a practice agreement locally.  Requiring a physician name on a script serves no meaningful purpose.  On the contrary, the rule in fact delays patient care when pharmacists are made to contact PA prescribers when the physician’s name is missing, mostly due to incapable EMR systems.  At best, this rule creates some level of unintentional non-compliance.  And at worst, it is completely illogical and administratively burdensome.

Sincerely,

Jerry Weniger, PhD, PA-C

Director, PA Program

James Madison University

CommentID: 233011
 

3/12/25  8:33 am
Commenter: Laura DeWitz PA-C

antiquated rule not benefitting patient care
 

Most PAs have been there, we are in clinic seeing patients when we get the call. The pharmacy needs you to resend the prescription with the collaborating physician's name on it.  We must stop everything and either call the pharmacy or resend the prescription. This takes away from patient care and adds ONE MORE additional bureaucracy to our day. ONE MORE rule that does not make any sense or add benefit to patients. This rule wastes pharmacy's time and takes away from PA's time we could/should be spending with patients.  It adds to burn out with PAs, clinic staff and pharmacy staff. Please tell me how this is value-added to the patient? Often times my prescription will make it onto the PMP in Virginia for my collaborating physician. The MD/DO doesn't even know the patient, and now MY PATIENTS' controlled meds are falsely elevating the MDs' list of prescribed controlled meds. This is a liability. Perhaps this is another reason it can be hard to find collaborators in psychiatry; add that to the critical shortages of psychiatrists. Please help us rid these antiquated rules that hinder patient care and steal valuable time from providers.

CommentID: 233012
 

3/12/25  2:43 pm
Commenter: Kristina Kinsella

Support in Removing this antiquated rule that hinders care
 

Please remove this antiquated rule.  All it does is hinder patient care and unnecessarily increase workload.  

CommentID: 233015
 

3/12/25  11:28 pm
Commenter: Olushola Ilogho, PA-C

Call to action.
 

I fully support the removal of physician name on schedule II-V drug prescriptions written by Virginia PAs. As highly trained medical professionals, PAs possess the expertise to safely and effectively prescribe these medications within their scope of practice.

Eliminating this requirement will:

1. Enhance Efficiency and Patient Care 2. Expand Access to Care: PAs are essential healthcare providers, particularly in rural and underserved areas. This regulatory change will empower PAs to provide comprehensive care where physician shortages are present.
3. Reduce Administrative Burden: Removing this requirement will alleviate administrative workload, including pharmacy calls, allowing healthcare teams to focus more on patient care. 4. Reduce unnecessary emergency room visits. 

 

CommentID: 233017
 

3/13/25  3:37 pm
Commenter: Melissa Shaffron, DMSc, PA-C

Support of Petition to Remove the Physician Name Requirement on Schedule II-V Prescriptions
 

As a practicing PA and a PA Medicine program director, I strongly support the petition to remove the requirement that a patient care team physician’s name be included on prescriptions for Schedule II-V medications in Virginia.

This outdated requirement places an unnecessary administrative burden on PAs and their collaborating physicians without providing any added benefit to patient safety or care quality. PAs are highly trained, licensed medical professionals who prescribe these medications within their scope of practice and in accordance with state and federal regulations. The current rule creates inefficiencies that can delay patient access to necessary medications and adds redundant documentation requirements that do not enhance oversight or accountability.

Furthermore, this requirement does not align with the prescribing practices in many other states where PAs can prescribe independently within the bounds of their scope of practice. Removing this requirement would modernize Virginia’s approach, reducing administrative barriers and improving workflow efficiency while maintaining high standards of patient care.

I urge the regulatory board to support this petition and remove this requirement, ensuring that PAs can continue to provide timely, effective, and patient-centered care without unnecessary administrative constraints.

 

CommentID: 233020
 

3/14/25  2:31 am
Commenter: Amber Balzer

Support removing a barrier to adequate patient care
 

I support removing this barrier to patient care

CommentID: 233022
 

3/14/25  10:30 pm
Commenter: Grace Burman

Support this in order to reduce care barriers
 

As the healthcare field & scopes of practice change, it is important that legislation change with it in order to support patient-centered, accessible care. 

CommentID: 233086
 

3/16/25  1:10 pm
Commenter: Kathleen Scarbalis PA-C

Support regulatory action
 

I support the proposed regulatory change to PA prescribing requirements.

PAs have individual DEA license numbers. The PA prescribing is responsible, and educated. PAs have pharmacology training. PAs are trained, licensed and credentialed to appropriately prescribe in Virginia. Should a pharmacist or patient have questions regarding the prescription, the prescriber/PA is the best contact. 

PAs work in a variety of environments. Many EMRs prove difficult to navigate, Adding a note to the prescription with the collaborating physician can be cumbersome. This has created delays care for the patient if the pharmacy must be called, in my experience. Many hours on hold have been wasted waiting to speak with a pharmacist to clarify. Physicians have been contacted in lieu of the prescribing PA. PAs are capable and will provide excellent care. 

CommentID: 233215
 

3/16/25  9:04 pm
Commenter: Anonymous

Removal of need for physician name on PA prescriptions
 

In today's day and time PA's practice in all fields of medicine and all states, so why do we still have this obsolete clause. This is unfair to PA's and their patients and creates unnecessary delays in patient care. PA's have their own DEA license (similar to NP's ) and should not need any other physician's name / DEA to write any prescriptions which their DEA allows them to. PA's and NP's have the same scope of practice, however just because NP's have a bigger lobby, they are exempt from this while PA's are still required to have a physician name on a PA's prescription.  PA's undergo more vigorous training and education than NP's, are held to much higher standards of certification maintenance than NPs , are licensed by Board of Medicine similar to physicians and despite that have to deal with these unfair regulations. It' s high time that these unfair regulations are put to an end. 

CommentID: 233241
 

3/16/25  9:09 pm
Commenter: Daniel Dollison PA-C

Support the Regulatory Action
 

I've been a PA for 30 years both in rural as well as urban settings. I feel we need to remove barriers to the most effective use of PA's. My home state of Nebraska fully removed the need for the supervising physician's name being added to PA prescriptions in 2020 via LB 755. Nebraska more progressive than Virginia? 

CommentID: 233242
 

3/17/25  9:37 am
Commenter: Anonymous

FNP in Support of Petition to Remove the Physician Name Requirement on Schedule II-V Prescriptions
 

As a Family Nurse Practitioner, I strongly support the petition to remove the requirement that a patient care team physician’s name be included on prescriptions for Schedule II-V medications in Virginia.

This outdated requirement places an unnecessary administrative burden on PAs and their collaborating physicians without providing any added benefit to patient safety or care quality. PAs are highly trained, licensed medical professionals who prescribe these medications within their scope of practice and in accordance with state and federal regulations. The current rule creates inefficiencies that can delay patient access to necessary medications and adds redundant documentation requirements that do not enhance oversight or accountability.

Furthermore, this requirement does not align with the prescribing practices in many other states where PAs can prescribe independently within the bounds of their scope of practice. Removing this requirement would modernize Virginia’s approach, reducing administrative barriers and improving workflow efficiency while maintaining high standards of patient care.

I urge the regulatory board to support this petition and remove this requirement, ensuring that PAs can continue to provide timely, effective, and patient-centered care without unnecessary administrative constraints.

CommentID: 233254
 

3/17/25  5:55 pm
Commenter: Bobby Cockram, DMSc PA-C

Support removal of the need for physician name on controlled rx written by PAs
 

As a leader of approximately 1600 advanced practice providers across northern Virginia I have seen first-hand how the current language requiring a physician's name to be present on a controlled substance prescription by a PA has caused significant delay in care for patients, significant burden on physicians and PAs delivering care, and broad confusion among pharmacies, leading to their own interpretation of this language, further complicating patients filling prescriptions for needed medications.  I have countless examples of how this language has delayed or prevented patients from receiving medications.  Imagine a patient being discharged from the hospital after major surgery and being unable to pick up pain medications for a full day.  Imagine a patient receiving cancer treatment being delayed in picking up much needed medications.  These are 2 quick examples of real-world scenarios happening regularly across the commonwealth.  This language needs to be removed right away and align our prescriptive requirements with our NP colleagues.  This language has no benefit to patient care at all.  

CommentID: 233261
 

3/18/25  2:16 pm
Commenter: Anonymous

In support of removing requirement for physician's name on controlled substances
 

As a practicing PA of 12 years, I fully support the removal of the requirement to have a physician's name on prescriptions for controlled substances. It is illogical as we already have a DEA number and ability to independently prescribe controlled substances, and it does nothing to improve patient care or access to care. It does, however, add administrative burden to an already overworked group of professionals who just want to care for our patients. 

CommentID: 233272
 

3/18/25  8:11 pm
Commenter: Dara Wotherspoon, PA-C

Support Removal of Physician Name on Controlled Substance Prescriptions
 

In support of removing physician names from controlled substances. 

CommentID: 233276
 

3/19/25  4:13 pm
Commenter: Jared Ng, PA-C

Allow providers to practice to maximum of their licensure
 

Hello,

I'm a PA practicing for nearly 10 years.  I believe the current language within the Virginia physician assistant langugage requiring name to be on prescriptions is not necessary and provides a barrier to patient care and confusion.  Nurse practitioners do not currently utilize these same regulations.  Physician assistant function similarly as advanced practice providers.  Medications and management of patients happen with the care of physicians.

CommentID: 233279
 

3/21/25  7:49 am
Commenter: Mark Ford

Remove restrictions
 

Good morning,

Simply ask that you remove the unneeded MD name to prescriptions.  It is cumbersome, stimulates call backs from pharmacies and just delays care for the patient.  

I have 26 years of experience and I am all for patient safety.  This does not improve safety or patient care.

Thank you

Mark Ford, PA-C

Fredericksburg, VA

CommentID: 233286
 

3/23/25  5:54 pm
Commenter: Jenna Rolfs

Support Removing Barriers in Order to Improve Access to Patient Care
 

Please support the removal of the physician name on schedule II-V drug prescriptions written by Virginia PAs. As highly trained medical professionals, PAs possess the expertise to safely and effectively prescribe these medications within their scope of practice.

Eliminating this requirement will:

1. Enhance Efficiency and Patient Care 2. Expand Access to Care: PAs are essential healthcare providers, particularly in rural and underserved areas. This regulatory change will empower PAs to provide comprehensive care where physician shortages are present. 
3. Reduce Administrative Burden: Removing this requirement will alleviate administrative workload, including pharmacy calls, allowing healthcare teams to focus more on patient care. 4. Reduce unnecessary emergency room visits. 

CommentID: 233299
 

3/23/25  7:30 pm
Commenter: Grace Allison Beers - Direct Wellness RVA

Statement of support
 

Statement in Support of Removing the Requirement for a Collaborating Physician’s Name on Controlled Substance Prescriptions

 

I am a Physician Assistant with 10 years of experience in both emergency medicine and primary care, and I have seen firsthand the delays and barriers caused by Virginia’s outdated requirement for a collaborating physician’s name to be included on controlled substance prescriptions. This antiquated rule leads to unnecessary pharmacy call-backs, confusion for patients, and delays in accessing essential medications.

 

Nurse Practitioners in Virginia are not subject to this requirement, yet PAs function similarly as advanced practice providers. This discrepancy places an undue burden on PAs and creates unnecessary hurdles for patients who are already facing long wait times and increased healthcare costs due to provider shortages.

 

As a PA serving my hometown community, I witness daily the impact of these regulatory barriers. Removing this outdated requirement will allow PAs to practice more efficiently, ensuring patients receive the care they need without unnecessary delays. I urge the state to modernize its regulations, eliminate unnecessary restrictions, and empower PAs to help address Virginia’s healthcare access shortage.

 

CommentID: 233301
 

3/23/25  7:40 pm
Commenter: Christie Meek, PA-C

MD name on prescription
 

Good Evening,

As providers approved by the DEA and trained in prescribing, please remove the requirement for MD name on the prescription. The DEA is the organization that confirms we have been adequately trained and gives us authorization to prescribe. Duplication isn’t helpful, rather cumbersome.

Sincerely,

Christie L Meek, PA-C

graduation 8/1993

CommentID: 233302
 

3/24/25  10:38 am
Commenter: Tara Villano, PA-C

Support removal of unnecessary and burdensome regulation
 

Hello,

I am writing to support this legislation to improve the patient care process by removing unnecessary and burdensome regulation for Physician Assitant practice. PA's have proven more than competent to manage their patient's care plan under such circumstances as this regulation addresses. When patient's access to care increases by streamling processes and removing unnecessary burden's, all the people of Virginia benefit.  

CommentID: 233305
 

3/24/25  11:53 pm
Commenter: Nicole Lando, MSHS, PA-C

I support removing this regulatory language
 

As a critical care PA, I am a member of a large and interdisciplinary care team. Because of this, it is quite rare that I work with my designated supervising physician. I am always working collaboratively with attending physicians, but this changes every 12 hours based on the nature of my work and shift work in general. Adding the requirement for physician signature for controlled substances seems both redundant in the setting of my training and DEA certifications; it also adds confusion for pharmacies filling said prescriptions. The language should align with that of our NP colleagues, who do not have this proposed requirement when writing prescriptions.

CommentID: 233310
 

3/25/25  10:27 am
Commenter: Kimberly Gordon PA-C

Support for regulatory change
 

I support removal of the current requirement that a physician’s name be included on prescriptions for Schedule II-V medications.  PAs already have prescriptive authority at the state level and DEA via licensure. PAs undergo pharmacological education both during initial training and through ongoing CME.  Requiring a physician name on a prescription serves no meaningful purpose and creates unnecessary administrative burden.  In the scenario of EMR downtimes or network issues, it creates delays in patient care when pharmacists are made to contact PA prescribers when the physician’s name is missing. 

CommentID: 233312
 

3/25/25  6:25 pm
Commenter: Max Doyle, PA-C

I support removing this requirement
 

I support removing this requirement

CommentID: 233316
 

3/28/25  6:00 pm
Commenter: Carolyn Herrera

I support removal of this requirement.
 

I am in support of the petition to remove this requirement and to increase access to care for patients by PAs. 

CommentID: 233333
 

3/29/25  1:59 pm
Commenter: Emily Frank

See below
 

I support removal of this requirement

CommentID: 233356
 

4/7/25  10:49 am
Commenter: Emory and Henry School of Health Sciences Masters in Physician Assistant Pr

COMMENT NO PRESCRIPTION REQUIREMENT
 

Physician Assistants are licensed and credentialed providers most of whom are also registered with the DEA for prescribing controlled substances.

Physicians are not liable for prescriptions that PAs write so having physician's name on the prescriptions is an unnecessary administrative requirement. 

CommentID: 233534
 

4/7/25  10:53 am
Commenter: Meredith Dhillon

Please remove this barrier to care
 

Please remove the SP requirement for controlled substances.  Its a barrier to care and causes issues with patients getting their script filled if missing.  Pharmacies are always calling about it.  Its not necessary if I pay all that money for my DEA.

 

 

 

 

 

CommentID: 233535
 

4/7/25  10:55 am
Commenter: Aaron Horton PA-C

Statement of support
 

I support the petition to remove the requirement that a patient care team physician’s name be included on prescriptions for Schedule II-V medications in Virginia. This is an unnecessary administrative redundancy that doesn’t benefit patients or providers in any way. 

CommentID: 233536
 

4/7/25  11:08 am
Commenter: J. Barton Gillum,

Romoval of Name of Physician
 

I support these proposed regulatory changes because they reflect the modern realities of PA practice and foster a more efficient, team-based approach to care. Removing outdated supervisory language aligns with current standards in many other states and empowers PAs to practice at the top of their license.

CommentID: 233539
 

4/8/25  7:21 am
Commenter: Terry Carlisle PAC

Removing physician name from prescription for controlled substances
 

I support this change of removing the physicians name 

CommentID: 233557
 

4/8/25  7:37 am
Commenter: Alison Moran

I support removal of this requirement
 

I am in support of removing the requirement for a physician signature on prescriptions.  This is an unnecessary administrative burden and limits access to care. Let's make it easier for our patients to receive the care they need and for providers to give appropriate care!

CommentID: 233559
 

4/8/25  10:02 pm
Commenter: Tara Elkins, PA-C

I support this initiative 
 

I support this initiative.

CommentID: 233577