AZANA President's Fall Welcome

As Arizona welcomes the cooler weather, our AZANA will welcome the incoming FY19 Board of Directors (BOD).  The official joint meeting of your outgoing and incoming BOD’s takes place annually each fall.  This joint meeting is essentially our ‘passing of the torch’ from one board to the other, and I couldn’t be more excited for our association. 

                  Shaun K. Ferrie, CRNA, AZANA President FY19

Shaun K. Ferrie, CRNA, AZANA President FY19

This year, for the first time, our meeting will take place at the inaugural AZANA Sun & Sedona 2018 Conference.  We are especially excited about partnering with CE2 to bring this premier regional anesthesia and ultrasound course to such a desirable destination! 

If you are attending our upcoming conference or happen to find yourself in the Sedona area November 3rd, please join us at the Sedona Under the Stars PAC event Saturday evening.

Your all-volunteer FY19 BOD is a uniquely qualified and diverse group of CRNAs who live and work throughout Arizona.  They represent a variety of CRNA practice models and include military, non-military, and faculty from both Arizona CRNA educational programs.  Comprised of both fresh and familiar faces, these influential leaders are exceptional representatives of our state.

“Our vision is clear: Protecting and advancing the CRNA profession in Arizona so that we are able to practice to the full extent of our education and training as desired.”
— Shaun K. Ferrie, CRNA, AZANA President FY19

Our vision is clear: Protecting and advancing the CRNA profession in Arizona so that we are able to practice to the full extent of our education and training as desired.  Our goal is to remove any real or perceived barriers to CRNA practice in all anesthesia practice models.  No CRNA should be subject to unnecessary burden or limitation of the free market.  

With this vision as our motivation, we look to build upon our previous accomplishments while renewing our focus on improved organizational efficiency and a sound fiscal agenda.  Organizational and financial preparedness advances educational opportunities, creating a more consistent culture and fostering new leaders for our association. This, in turn, serves the greater membership as a whole.

Because of the tremendous work by previous boards, we can look forward to staying the course on our state-specific strategic plan and continuing to grow as an association.  We remain vigilant in serving our members, facing challenges as they arise, and actively working behind-the-scenes to create new opportunities for CRNAs in Arizona.   

Included in this update, you will find our CRNAs of Arizona PAC legislative candidate contribution list.  Let this serve as a reminder to all of our members of the importance of getting out to vote in the fast-approaching general elections November 6th.   

I am incredibly humbled and proud to serve amongst your elected leadership and am full of optimism that CRNAs will thrive in our great state of Arizona!

  Shaun Ferrie, CRNA  AZANA President FY19

Shaun Ferrie, CRNA
AZANA President FY19

 

Anesthesiologist Assistants (AAs)

       The AZANA recognizes the importance of protecting our profession and securing its future. There is a constant presence, pressing to restrict CRNAs into roles that limit full practice capabilities. With this in mind, we have formed a special task force to monitor and educate key stake holders regarding Anesthesiologist Assistants (AAs).

       We are fortunate to have a specialist in the field, Mike MacKinnon, CRNA, to lead this endeavor. Mike currently serves on the AANA AA task force and has years of experience consulting with multiple states assisting with education and preparation related to AAs. Additionally, the AZANA board representative to this task force will be our 2018-2019 President-Elect Lee Ranalli, CRNA

       Now is the time to renew and maintain memberships. Furthermore, it has never been so vital that our members recognize the importance of contributing to the CRNAs of AZ PAC. Currently, we have over 120 recurring contributors of at least $25/month. These PAC dollars help ensure that we have a seat at the table when AA issues arise. This elephant in the room is no longer an “if” but a “when”.

Headshot C. Peterson.jpeg

       Whether you practice independently or within an ACT, the issues of AAs will ultimately impact all. Please maintain your membership, renew if necessary, and strongly consider becoming a recurring contributor to the CRNAs of AZ PAC

Chad Peterson, DNAP, CRNA
President, Arizona Association of Nurse Anesthetists

DEA Numbers RESTORED

DEA Registration Restored

The AZANA is excited to announce that the ability for CRNAs in the state of Arizona to obtain their Drug Enforcement Administration (DEA) individual registration has officially been restored. It has been an uphill battle over the past six years, and this a huge win for Arizona CRNAs. This was an even more momentous task in that once something like this is interpreted from existing statute, it is significantly more difficult to reverse. 

So how was it done? The AZANA updated and clarified the law. 

Memoirs of a DEA Number

Like many subjects on a federal level, the remedy isn’t always straightforward.  Since the early 1940’s CRNAs have administered anesthesia in Arizona based on laws in the Nurse Practice Act (A.R.S. § 32-1661).  In 1999, the Arizona State Board of Nursing (BON) adopted rules to formalize the prescription drug ordering process for CRNAs.  These scope of practice rules would remain in place until 2012 at which point they were moved from rule to statute.  

This move to statute was tasked following a routine audit in 2011 by the Arizona Auditor General who at the time questioned certain provisions of these rules, which included granting prescriptive authority to CRNAs to write prescriptions and for patients to have them filled at pharmacies. The difference between the use of the “prescribing” language and authority for medications to be administered preoperatively, postoperatively, or as part of a procedure by “ordering” CRNAs created confusion and needed clarification.  To clarify the difference between the practice of a CRNA and other advanced practice nurses who write prescription, the final consensus language provided that CRNAs could “order medication” instead of have “prescriptive authority,” and made its way into statute with SB1362 in 2012.  

Prescriptive Authority

Prescriptive authority and federal law can get convoluted and vary greatly from state to state.  What may be good for one state may not be good for another.  In DEA regulations, “the term prescription means an order for medication which is dispensed to or for an ultimate user but does not include an order for medication which is dispensed for immediate administration to the ultimate user.”1  This definition of prescription is part of the basis for the DEA interpreting federal law for CRNAs.  The “traditional” practice of nurse anesthetists – ordering and directly administering controlled substances and other drugs preoperatively, intraoperatively, and postoperatively – does not constitute “prescribing” under federal law. 

Because the DEA has not regarded traditional CRNA practice as "prescribing" under federal law, most nurse anesthetists have not had to individually register with the DEA. Also, the DEA’s interpretation of federal law does not necessarily mandate a similar conclusion under state law.2

Following SB1362, the DEA interpreted the new language to mean that CRNAs did not have prescriptive authority and sent letters to the twelve Arizona CRNAs that had active DEA numbers, asking them to surrender the number or have it formally revoked.  This unintended revocation left Arizona as one of the few states where CRNAs were unable to obtain DEA individual registration and left the providers required to have them looking for out of state solutions.  While small in number, Arizona CRNAs required DEA numbers at various practices such as Indian Health Service and Veterans Health Administration Hospitals.  

Clarifying the Law

In the 2017 legislative session, the AZANA was able to pass SB1336, which (amongst other things) restored prescriptive authority language.  Soon after SB1336 was passed, both the AZ State BON and the AZANA contacted the DEA again, requesting they resume issuing DEA numbers to CRNAs in Arizona. 

In May of 2018, after a full year of pressure that included a letter from Senator Jeff Flake’s office, the DEA notified the AZ State BON that they would, in fact, begin issuing DEA numbers to CRNAs.

With the new passage of SB1336, the AZANA clarified that CRNAs have prescribing authority, but that it does not include the ability to write or issue a prescription for medications to be filled by a patient.  This was not an expansion of scope, but essentially restored CRNA’s ability to obtain DEA numbers so that they are able to practice in settings where they are required, as was the case prior to the 2012 change.

Team Effort

This win was very much a team effort brought forth by the AZANA in conjunction with the AZ State BON.  These efforts highlight the importance of maintaining these good working relationships.  With remarkable persistence the AZANA was able to get difficult legislation passed without having to make unacceptable compromises (which is not always the case in many states with this type of legislative push).

A Huge Win for Arizona  

Restoring prescriptive authority language that allows for DEA numbers has specific advantages that affect all Arizona CRNAs. First, it allows CRNAs to practice where individual DEA numbers are required.  Other important advantages include greater autonomy and professional independence capacity (improved leadership qualification and ability to order necessary supplies, etc.), reduction of perceived surgeon liability fears (even though no liability was verified in statute with SB1336)3, helping resolve questions/issues related to cosignatures, and enhancing opportunities in pain management.  Healthcare is continually shifting under our feet and opportunities for independent CRNA practice in Arizona continue to grow.  With every increasing capacity and advantage putting CRNAs on a level playing field with other healthcare providers, the better we are all served. 

How Do I Apply?

Most Arizona CRNAs do not need a DEA number and can legally practice under their facility's DEA number at this time.  While you are fully able to apply for a DEA number at this time, we encourage you to only submit an application if needed for employment.  We have secured this win and don’t need to inundate the DEA with CRNA applications.  Online 224 forms are located at: https://apps.deadiversion.usdoj.gov/webforms/newAppLogin.do where you would select “MLP – Nurse Practitioner ($731 / 3 YRS).”4

Many Thanks

Notable thanks goes to Senator Jeff Flake and his office staff, President Randy Quinn and all of the staff at the AZ State BON, as well as all the preceding and present AZANA Board of Directors and committee members for your persistence and hard work fighting to secure this win and restore DEA numbers for Arizona CRNAs.  Also, thank you Arizona CRNAs for your continual AANA membership and PAC support that played an enormous role in facilitating this win.  This continual membership backs the only association exclusively looking out for your profession, your AZANA. 

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Shaun Ferrie, MSN, CRNA
President-Elect, Arizona Association of Nurse Anesthetists

 

 

References

1. DEA Code of Federal Regulations §1300.01 21 CFR Ch. II (4-1-12 Edition). Definitions relating to controlled substances. https://www.gpo.gov/fdsys/pkg/CFR-2012-title21-vol9/pdf/CFR-2012-title21-vol9-part1300.pdf. Accessed June 8, 2018. 

2. Federal Summary. American Association of Nurse Anesthetists. https://www.aana.com/states/state-association-advocacy-resources/prescriptive-authority-tool-kit. Accessed June 8, 2018. 

3. Arizona Revised Statutes § 32-1634.04. Certified registered nurse anesthetist; scope of practice; physician and surgeon immunity. Accessed June 8, 2018. https://www.azleg.gov/viewdocument/?docName=https://www.azleg.gov/ars/32/01634-04.htm. Accessed June 8, 2018. 

4. Drug Enforcement Administration. Application for Registration Under Controlled Substances Act of 1970. https://apps.deadiversion.usdoj.gov/webforms/newAppLogin.do. Accessed June 8, 2018. 

President's Update

Headshot Chad Peterson.jpg

The AZANA is very excited to present to CRNAs nationwide a state-sponsored neuraxial and regional education symposium. 

Success does not come easy.

Recently, a large, for-profit company attempted to bully the AZANA. This company threatened legal recourse on the grounds that we are offering a conference in Sedona around the same time that they are offering a conference. According to our legal team, we are completely within our rights to offer a competitive, superior education experience. It is hard to not feel betrayed as this company utilizes CRNAs to deliver most of their lecture material. We have stood our ground and have prevailed, bringing the first AZANA fall conference to fruition. 

The Sun & Sedona 2018 Conference will offer three days of extensive training in regional procedures and skills. Ce2U has graciously planned the program agenda for the weekend, catering it to CRNA practice and utilizing both lecture and hands-on training. This is a very unique opportunity unlike anything we’ve experienced here in Arizona. The Sun & Sedona 2018 Conference will be an incredible education experience brought to you by CRNAs for CRNAs.

As we continue to work diligently to promote this exciting fall event, your board members continue to work behind the scenes to secure your profession and promote AANA membership. Most recently, the AZANA worked in conjunction with the Board of Nursing to reinstate Arizona CRNAs ability to successfully apply for DEA licensure. This has been a long road with many roadblocks and speedbumps. The AZANA must give a huge “thank you” to U.S. Senator Jeff Flake for lending his voice and concern to this issue. 

The AZANA has been networking with student registered nurse anesthetists from Midwestern University and The University of Arizona. We have had two very successful student events this year where we have promoted the importance of association membership and political involvement. According to data collected by the AANA, there has been a dramatic decrease in membership for CRNAs with zero to five years of experience. The AZANA feels that by including students in our endeavors and goals for the future, the excitement and momentum will continue beyond graduation. Fellow AZANA board members were able to join me in meeting the incoming SRNAs during their orientation. I feel strongly that our education system will only grow stronger and create some of the nation’s best nurse anesthesiologists. Thank you to both programs for allowing us to visit.

The AZANA is proud to be associated with the CRNAs from the great state of Arizona. We always have the security of our profession and the best interests of our membership as our focus. Our goal is success and security. Thank you for being nurse anesthesiologists and making this association one of the strongest in the nation.

 

Chad Peterson, DNAP, CRNA

AZANA President

Closing Thoughts from Joe Rodriguez, AZANA President, 2016-17

Closing Thoughts from Joe Rodriguez, AZANA President, 2016-17

In 2016-17, we decided to take on a great deal - and we were fortunate to have in place a humble, diverse leadership team, focused on delivering real results for our membership.  AZANA is essential in ensuring our ability to take great care of people - and in that way, being involved in AZANA isn't some career-building activity, or just something extra - it's the right thing to do.