• Licensure Issues
• Collaborating Physicians and Collaborative Agreements
• Prescription Points
• Other Important Information
  
  
• ILLINOIS DEPARTMENT OF PROFESSIONAL REGULATION
  
  The Illinois Department of Financial and Professional Regulation's (IDFPR) website is: www.ildpr.com From this site you can download copies of the Illinois Nursing and Advanced Practice Nursing Act, Controlled Substance Act, as well as the practice acts for numerous health professionals. All practices acts have rules for administration that are available for download, but usually in a separate file. In order to fully understand the regulations governing a professional's practice, it is vital to review both the act and its rules. If you wish to obtain a Federal DEA number, you must first obtain an Illinois Controlled Substances License (CSL). Information on DEA numbers can be found at: http://www.usdoj.gov/dea/index.htm. From that page, Find the links  From the DEA home page, scroll down the left frame to “Diversion Control and Prescription Drugs” and the link underneath “Registration.”

Licensure Issues
Q: What is the Illinois law about APNs and continuing education?
A: APNs must obtain 50 hours of CE during each 2-year licensing cycle. However, this requirement has nothing to do with keeping your certification current. It is up to you to differentiate how you comply with Illinois license requirements and your respective certification requirements. IDFPR does not require everyone to submit proof of CE as is done with some certifying bodies. However, at any given time the IDFPR has the right to perform random audits. Therefore, it behooves everyone to continue to be prepared to show proof of their CE.

Q: How long does it take to get an APN license?
A: It can several weeks before an APN gets that license and that’s assuming IDFPR DEEMS THE APPLICATION TO BE "COMPLETE." A "complete" file is one that has all the necessary documents, including forms, transcripts, proof of certification, etc. Therefore, kindly advise anyone one you know who anticipates getting an Illinois RN and/or APN license (soon-to-be new grads or out-of-staters)to do the following:

1. They should get their own copies of transcripts just as soon as the transcript reflects completion of their APN program and have them ready to include with their application.
2. They should make copies of EVERYTHING that they ever send to IDFPR.
3. They should send all documents either by certified mail, Fed Ex, or some means that provides proof of IDFPR's receiving them.

Q: Can an APN get a temporary license in Illinois?
A: Our practice act refers to "license pending status"; however, IDFPR has translated application for that status into a "Temporary Permit" form. Finding this form takes some digging--it's on page 4 of the regular APN application (which, of course, can be found at (www.ildpr.com). You will not find a specific link for this form on the website anywhere. Quite honestly, the way IDFPR has interpreted the law regarding license pending is such that it will benefit very few people to apply for this status (permit). Furthermore, it may take as long to get a temporary permit and a full license, so it's not like it will greatly facilitate your job search. The best advice is that new grads should take their certification examinations just as soon as they possibly can, so that they can submit those results with the rest of their application, so that their file will be complete once it hits IDFPR. And anyone who is an APN from out-of-state should apply well in advance of actually relocating. The only people who might benefit from the temporary permit are those people who for some reason or another, simply cannot take their certification examinations in a timely fashion.

Q: Now that I have my APN license, how do I sign my name?
A: Getting an APN license accords an individual three titles: registered nurse (RN), advanced practice nurse (APN) and one of the four APN specialties—certified nurse practitioner (CNP), certified nurse midwife (CNM), certified registered nurse anesthetist (CRNA) and clinical nurse specialist (CNS). However, it’s ponderous to put all those title abbreviations after one’s name—and unnecessary. One cannot be an APN without first being an RN; therefore, the RN title is truly superfluous. It’s perfectly legal to distill everything down to one’s specialty. Therefore, simply writing “CNP” or “CNM” or “CRNA” or “CNS” is totally appropriate.

There is a tricky aspect to the CNS designation, however. The practice act refers to only “CNS”, which is the universally accepted abbreviation for clinical nurse specialist. But when the IDFPR designed our licenses, someone mistakenly thought that consistency dictated that the CNSs should be called “certified clinical nurse specialists.” But the problem with that premise is that its abbreviation is “CCNS”, which as it happens, is an abbreviation trademarked by the American Association of Critical Care Nurses and denotes certification by AACN as a “Clinical Nurse Specialist in Acute and Critical Care.” Therefore, since CCNS ™ is a trademarked abbreviation—despite what one’s license says—no one should use this abbreviation unless s/he is, indeed, so certified by the AACN.

Most people who raise the question of titles are NPs, because we have so many certifying bodies and so many specialties. There are FNPs, PNPs, GNPs, ANPs, ACNPs, WHNPs, APRNs, ARNPs, BCs, and NP-Cs, just to name a few. Furthermore, many APNs are used to signing their names with academic credentials, such as BS, MS, MSN, ND, PhD, etc. In Illinois, the only acronyms of significance are APN and either CNP, CNM, CNS, or CRNA. Those are the only letters that are "legal" in Illinois. The "C" in all of those indicates that they are board certified by a body acceptable to the State of Illinois. All those other letters reflecting types of certification and academic credentials might have value when one is writing a journal article or giving a scholarly presentation. But these "extra" letters are not helpful in clarifying our role to patients, pharmacists, or other professionals in health care. When we sign our charts and prescriptions, we should sign our names using only those letters recognized in our practice act.

Q: Can an NP keep his/her license for controlled substances and the DEA number upon leaving a collaborative agreement arrangement?
A: When it appears that a collaborative arrangement will be dissolved, the APN should go to the IDFPR website (www.ildpr.com) and download 2 documents: (a) Termination of Delegation of Prescriptive Authority, and (b) Delegation of Prescriptive Authority. The "Termination" form has to be signed by the soon-to-be "outgoing" collaborating physician (CP). There's a place to indicate the date that the termination will take place, so the APN should be sure to get this form signed before s/he and the CP part company. Then s/he should get the "Delegation" form signed by her/his new CP prior to prescribing under that relationship. These forms will generate a new form from IDFPR (gets mailed to the "outgoing" and "incoming" CPs) that clarifies the APN's authority related to her/his controlled substance license. The DEA doesn't need to know about a change in CPs; that's handled through the controlled substance license. However, it MIGHT need to know a change of employment--if that is the address that was submitted on the DEA application.

It should be noted that technically DEA number isn't required for an APN to prescribe non-controlled substances, meaning that a DEA number isn't required by law if the APN doesn't prescribe controlled substances. However, Medicaid and other reimbursers seem to require a DEA number before they pay for a script, so we urge all APNs to get a DEA #, even if s/he only gets authority for Schedule V drugs (the least risky drugs), so that s/he had a # to put on her/his script. It's embarrassing for a patient to try to get a script filled just because there's no DEA #--even though it's not really required by law.

Collaborating Physicians and Collaborative Agreements

Q: If an APN is working in a single-physician practice, what are the issues involved when that physician needs to be out of town for vacation or attending a conference?
A: An APN always needs to have a mechanism for consultation and referral with some physician. If the APN's "ordained" collaborating physician (CP) is not available, there must be some physician available to provide the consultation and referral in the CP's absence.

Generally, there should be only ONE physician who has the "title" of collaborating physician because the CP has certain "duties" to perform (e.g., monthly site visits). However, an APN may consult with any number of physicians both within and outside of a practice. It is wise to clarify this situation in one's collaborative agreement (CA), but it does not necessarily mean that both the CP and the whole host of consulting physicians have to sign the CA. If possible, the reference to consulting physicians should be as general as possible. Take, for example, if an APN were working in a large group practice (XYZ Medical Practice) that employs several physicians. An APN would specifically name the physician who is her/his actual CP, but note in the agreement that there are occasions where s/he will consult with any or all physicians employed by XYZ Medical Practice. The point is that the CA should not have to be changed every time a consulting physician leaves or joins the practice.

If an APN works with only one physician who has physician colleagues from other practices take call or cover for his/her patients when s/he's out of town, an APN might describe this situation in a generic fashion such as "in Dr. Jones' absence, will consult with the physicians associated with ABD Medical Practice." An APN should keep the number of physician signatures on a CA to a minimum, if possible. If an APN is consulting with physicians within their own (large) practice, this is easily accomplished because there are probably other internal documents that apprise those physicians that they may be called to work with the APN from time to time. However, if the APN is going to consult outside of the practice, then it would probably be a good idea to have some signed document that indicates that this is acceptable to those outside physicians. The main reason for this is to prevent some physician from coming back at a later date claiming that s/he did not agree to be the APN's consultant in the absence of the CP. Again, this document should make it clear that these other physicians are NOT the official CP, to make it clear that these other physicians will not be responsible for monthly site visits or ongoing oversight of the APN's practice.

There is, however, a caveat in naming only one physician as the CP. The services that an APN provides to patients have to be similar to those that her/his CP "generally provides to his or her patients in the normal course of his or her clinical medical practice" (Illinois Nursing and Advanced Practice Nursing Act, 65/15-15). Therefore, for example, if you see patients of all ages, and you don't have a family practitioner available to be your CP, then you would need to collaborate with at least two Cps (e.g., a pediatrician and an internist).

Prescription Points
Q: What should a prescription written by an APN look like?
A: The Administrative Rules of the Illinois Nursing and Advanced Practice Act dictates prescription writing as follows:

"All prescriptions written and signed by an advanced practice nurse shall indicate the name of the collaborating physician. The collaborating physician's signature is not required. The advanced practice nurse shall sign his/her own name."

Technically, one does not need a DEA number to prescribe non-controlled substances. However, pharmacies often will not fill a prescription without a DEA number on it, since most reimbursers won't pay for a prescription without one. Therefore, assuming that an APN does have a DEA number, then the APN's name and APN's DEA number should appear on the script. The collaborating physician's DEA number should not appear on the script, because pharmacists will be tempted to consider the physician the prescriber instead of the APN (meaning the physician's name will appear on the medication bottle instead of the APN's).

All of this information can be added to each individual prescription by hand or included on pre-printed prescription pads. Some providers like to have the DEA # pre-printed, but some do not.

Q: What Scheduled Druges Are APNs allowed to prescribe in Illinois
A: Currently, APNs are allowed to prescribe drugs in Schedules V, IV, and III, but not those in Schedule II (which includes Ritalen). We are expecting that to change soon, however.  SB 360—which is the bill containing the entire new practice act for RNs, LPNs, and APNS--was passed by the Illinois General Assembly on July 11, 2007, and will go to the Governor for his signature. The General Assembly has 30 days to get the bill to the Governor, who has another 60 days to sign the bill.  As with all prescription authority for APNs in Illinois, delegation of Schedule II drugs must be described in the collaborative agreement between the APN and the collaborating physician. Furthermore, there will be some unique restrictions regarding Schedule II drugs: (a) No more thatn 5 Schedule II or II-N substances may be delegated to the APN, (b) Any prescription must be limited to no more than a 30-day oral dosage, with any continuation authorized only after prior approval of the collaborating physician, and (c) The APN must discuss the condition of any patients for whom a controlled substance is prescribed monthly with the delegation of the physician.

Even after the bill is signed by the Governor, implementing this part of the new law will require some work on IDFPR staff, who will have to create a new “Delegation of Prescription Authority” form which is required to obtain an Illinois Controlled Substance License, which is a prerequisite for obtaining a DEA number. That form will need to be revised to reflect the option of prescribing Schedule II drugs.

Rev. 7-15-07