If the nurse works in a state that requires that they prescribe under the supervision of or in collaboration with a qualified physician, the physician doesn’t need the waiver, they only need to be qualified to apply for it. The definition of a qualified physician is provided below and further information regarding the qualifications can be found in Public Law 114-198
(see page 27).
The term “qualifying physician” has a defined meaning within the context of CSA. Specifically, 21 USC 823(g)(2)(G)(ii) provides the following (emphasis added): See page 27 Public Law 114-198
Therefore, when the CSA references a “qualifying physician” in this context, it is not just referring to a physician with an active license, but to a licensed physician who also satisfies one or more of the above conditions. Please note that these conditions establish the eligibility requirements for receiving a waiver and do not include possession of a waiver itself.
Nurses may use their waiver to prescribe buprenorphine products for the treatment of opioid use disorder in any healthcare setting including OTPs. However, the healthcare setting or employer, OTP or otherwise, is free to establish by policy which services are to be provided and by which professionals. Any practitioner who uses the waiver to treat patients must comply with their patient limit regardless of the treatment setting. Nurses may order buprenorphine or methadone for administration or dispensing from an OTP without a DATA waiver, but must receive an exemption from SAMHSA to make dose and administration adjustments.
PCSS offers the entire 24 hours of training at no cost. All DATA 2000 organizations, including the American Academy of Addiction Psychiatry (AAAP
), American Society for Addiction Medicine (ASAM
), American Psychiatric Association
, and American Osteopathic Academy of Addiction Medicine
can provide this training as well (some fees may apply).
No. If you have completed the 8 hour waiver course and received your certificate of completion from a DATA 2000 organization (listed above), even if it was prior to the passage of CARA, you can use this certificate when applying to the Substance Abuse and Mental Health Services Administration (SAMHSA) for a waiver. Apply here ›
Contact the one of the DATA 2000 organizations (AAAP
, and AOAAM
) to determine if you have taken the training.
PCSS provides the 8 hour waiver course at no cost with continuing education credits for Nurses:
- Self-paced online: You must complete the training within 45 days of initiating.
- Online: 1st half live webinar followed by 2nd half online. PCSS partner organization, AOAAM, provides waiver trainings twice a month (second Saturday and fourth Wednesday) that consist of a live webinar (with Q&A) and an online portion. Once the webinar is completed, participants receive a link to complete the online portion on their own. View trainings ›
To accommodate larger groups, healthcare organizations may also request a training through the PCSS program. Contact PCSS
for more information.
Yes. You can complete the 8 hour waiver training provided by one of the DATA 2000 organizations (AAAP
, and AOAAM
), then complete the 16 hour training from a different organization. However, you must complete all of the 16 hours of training with the same organization.
No. All 16 hours must be completed by the same organization.
Nurses may take the required 16 hours of additional training through PCSS at no cost or through several other organizations which were listed in CARA Act, including AAAP
, and AOAAM
, the American Association of Nurse Practitioners
, and American Nurses Credentialing Center
(fees may apply).
Once you have completed the 24 hours of coursework required you will need to submit the following to SAMHSA to apply for the waiver
Certificate of completion for 8 hour waiver course
Certificate of completion of 16 hours of courses
Notice of Intent form ›
This infographic contains helpful information/links ›
Yes, they can take the training, but cannot submit their Notice of Intent (NOI) form until they are fully licensed and registered with the DEA.
At the end of the 8 hour waiver training you will receive a certificate of completion. When you complete the 16 hour waiver training for nurses through PCSS, you will receive a second certificate of completion.
Sponsoring organizations for the training submit a report to SAMHSA verifying completion of course. Nurses submit a notice of intent to SAMHSA requesting the waiver
along with the two certificates of completions received for the 8 hour and 16 hour waiver trainings.
At the end of the 8 hour waiver training for nurses through PCSS, you will receive a CE Certificate for 8.0 continuing nursing education contact hours (8.0 contact hours in pharmacology) provided by the American Psychiatric Nurses Association (APNA).
At the end of the 16 hour waiver training for nurses through PCSS, you will receive a CE Certificate for 16.0 continuing nursing education contact hours (13.0 contact hours in pharmacology) provided by APNA.
Note: The CE Certificates earned (1 certificate for the 8-hour Waiver Training and 1 certificate for the 16 hour waiver training) are in addition to the certificates of completion that are required for the waiver. Only the certificate of completion for (16 hour course + 8 hour course) 24 hours with the Notice of Intent form are needed to apply for the waiver.