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Colorado Society of Advanced Practice Nurses

Second Request-Please comment on the 3600 hour requirement for Prescriptive Authority

Posted over 4 years ago by Margaret Catchpole

Fellow APNs, I would like your comments and ideas.  We all know that the current law establishing the minimum  3600 hours for prescriptive authority has been a barrier for graduates in Colorado.  We, also know that the demand for a preceptorship and mentorship by a physician is difficult to establish.  NPATCH will draw up some recommendations for DORA and I think DNA 30 should speak up and provide some recommendations from the people who are practicing APNs.

  • What do you think the minimum hours for prescriptive authority should be?

  • Should graduates have both preceptors and mentors or just mentors?

  • Or if a different type of post graduate training would be defined what would that be?

Please share your ideas here or in an email to me. I would like to have some thoughts to share with NPATCH by the next DNA 30 meeting.


M. David Rodriguez


Deanna Tolman over 4 years ago

There are several problems here:

1) The NPATCH committee is a very thinly disguised path for physicians to control nurses and nursing scope of practice. The committee should never have existed, because allowing it to exist gives medicine the permission to influence nursing's control of its own education and licensure. How would the medical society like it if we started making rules about their licensure? We are our own profession, and physicians have no place saying or doing anything that influences our license.
2) The second problem is that NP programs are inadequately funded and clinical hours are severely problematic. Physicians have their medical education underwritten by CMS, are paid a salary for their 3-5 year residencies and their precepting physicians are also paid a salary. We have allowed our education to continue to be substandard. We have no compensation for our clinical time, and in fact, we must pay tuition for those hours. Thus, they must be limited. And finding preceptors for those clinical hours depends on the willingness of the NP and the whims of their employer-physicians. I take a student every semester, and we have a waiting list and are booked two years into the future. This is shameful, and we should demand equal treatment with physicians in our education. We should be paid for a residency (1-2 years), and the preceptors should also be paid, and the funding should come from CMS, as it does for physicians.
3) If we thus had decent hours of residency, this entire discussion would be moot. In the meantime, we look ridiculous to potential NPs because we have allowed medicine to dictate our licensure requirements, which are burdensome in the extreme.

Deanna Tolman, DNP

Ann Marie Mallory over 4 years ago

Ms. Tolman presents valid points relating to our profession. However, those are goals that will need to be achieved at the national level if CMS were to be involved. While change most certainly needs to happen on a large scale, NPATCH will be creating recommendations specific to Colorado. The problem at hand now is that new graduate nurse practitioners cannot find employment in the state of Colorado because of the cumbersome laws regarding mentorship and preceptorship.

Perhaps we should examine how other states with full practice authority approach prescriptive authority. Evaluating laws that are already in existence may be a good starting point for drafting recommendations for our state. Any APRN in Washington State is eligible for prescriptive authority. To apply for prescriptive authority in Wyoming, an applicant must submit evidence that they have received education in pharmacology (either a class or 30 contact hours). Similarly, Arizona requires 45 contact hours of pharmacology related education in the 3 years preceding the application for prescriptive authority. Nevada is transitioning to full practice authority now, as the law permitting it was just passed last year. Their requirement is that if you have not practiced for more than 2 years (or 2000 hours) and want to prescribe Schedule II drugs, you must have prescribing protocols in place with a physician (a collaborative agreement for new grads). This seems much more logical than Colorado’s current arrangement.

Incidentally, I am a “new” graduate. I graduated nearly a year ago and then made the horrible mistake of relocating to Colorado. I have been board certified since July, and have been on the advance practice registry since September. In the past 8 months I have submitted countless applications and received just as many rejections. I am providing my input, because I would like to see things changed for NPs in the future. As it is at this point in time, I will not be able to remain in this state if I want to use my advanced degree.

Kelly Mowrey over 4 years ago

I LOVE Ms. Tolmans comments and whole-heartedly agree!

I feel there should be ZERO hours required upon graduation to obtain prescriptive authority. I also feel there should be NO language for mentors or preceptors mentioned. We are fully functional independent providers upon graduation. While we all informally have mentors we do not want this restrictive language written into any new regulations.

Virginia Gillispie over 4 years ago

I have to agree with the comments already posted. I finished my NP program in December in CO, obtained board cert mid-Jan and received my state of CO license in early March. I was turned away from many employers and experienced quite a delay with my current employer because I did not have prescriptive abilities. As a result, I will have been fully cooked and ready to go March 6th, but not starting work as an NP until early June. I am particularly concerned that I haven't seen any evidence to date that the CO requirements are actually evidence-based. I agree with the post that mentions allowing medicine to have a say in nursing practice. I should mention too that, fed up with looking for work as a new NP in CO (I DO NOT say 'new grad,'since I am an RN with 18 years of experience!), I was seriously being courted by a recruiter and considering a placement in rural Nebraska. I think what 'gets my goad' more than anything is the variation in state to state practice acts. Is it that way for Medicine? I doubt it. But if one state says I have to do thus and such and another says something altogether different, how can this really be about protecting and serving the public? Thank you for listening.

Virginia Gillispie over 4 years ago

To clarify: I meant to say I agree that Nursing should govern it's own practice, and that other professions should not be dictating it.

Diane Chase over 4 years ago

NP programs have pharmacology. I don't think there is a need for extra hours for prescriptive authority. Perhaps a few hours for narcotics for the new guidelines. I see the hours as just a barrier to practice and obtaining jobs. Why do we need physician mentorship? There are experienced NP's who can precept student NP. Diane Chase,FNP

Phillis Rutt over 4 years ago

I also have to agree with previous post. I graduated in 2008 and it took me three years to achieve my prescriptive authority hours. I was without work for six months trying to find a position as a NP, after my position was dropped due to budget cuts. I continue to pay for student loans after achieving my MSN. I have been an RN for 19 years and an APNP for five years. The first three years were the most heart wrenching, frustrating, challenging, depressing and costly years I have ever experienced. Something needs to change. Phillis Rutt, FNP-C

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