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Controlled Substance Education Course

The Physician Assistant Practice Act (Act) provides for licensure and regulation of physician assistants by the Physician Assistant Board (Board). On January 1, 2020, Senate Bill 697 (Chapter 707, Statutes of 2018) made numerous changes to the Act.

One of the changes impacted Business and Professions Code (Code) section 3502.1(e)(3), which states a physician assistant (PA) who holds an active license, is authorized through a practice agreement to furnish Schedule II controlled substances, is registered with the U.S. Drug Enforcement Administration (DEA), and who has not successfully completed a one-time course in compliance with sections 1399.610 and 1399.612 of Title 16 of the California Code of Regulations (CCR), as those provisions read on June 7, 2019, shall complete as part of their continuing education requirement, a course that covers Schedule II controlled substance and the risks of addiction associated with their use based on the standards developed by the Board.

Please review the following information to assist with interpreting this new requirement and how it impacts you as a licensee:

  1. Do I have to complete the controlled substance education course if I am not registered with the DEA and/or authorized through a practice agreement to furnish Schedule II controlled substances at the time I renew my license?

    No. Only licensees who are authorized through their California PA practice agreement to prescribe Schedule II controlled substances and who are registered with the DEA at the time of renewing their license, are required to complete the controlled substance education course. Licensees with a license status of inactive are not required to complete the controlled substance education course.

  2. What if I don’t remember taking the controlled substance education course?

    If you completed this course prior to January 1, 2020, you were not required to file a copy of the controlled substance course certificate with the Board, nor did the Board retain certificates submitted prior to January 1, 2020.  Please check with the course providers listed below to see if they have a record of you completing the course and can provide you with a replacement certificate.

  3. Can I renew my license if I am unable to complete the course prior to the expiration date of my license?

    Yes. Until this requirement is met, section 3501.1(d)(2) of the Code requires a patient-specific order approved by the treating or supervising physician and surgeon to furnish Schedule II controlled substances. A patient-specific order must be reviewed and approved by the supervising physician, written in the patient’s chart, and signed and dated by the supervising physician.
    A certificate meeting the requirements of CCR sections 1399.610 and 1399.612 must be submitted to the Board before the expiration date of your next renewal cycle or you may be ineligible to renew your license. If a course is not available prior to the expiration date of the next renewal cycle, evidence of your intent to enroll in a future course is required and must be submitted to the Board.

  4. How do I know if the Board has a copy of my certificate of completion on file?

    Visit DCA License Search to view your licensing details. Select Physician Assistant Board, License Type, and enter either your license number or name. Click on “More Details” from the results page. The controlled substance education course certificate of completion will show as a “Qualification” if the certificate is on file with the Board.

  5. Do I have to complete the controlled substance education course prior to registering with the U.S. Drug Enforcement Administration (DEA)?

    No. The controlled substance education course is a license renewal requirement and does not impact your ability to register with the DEA.

  6. Does a continuing medical education (CME) course specific to opioids or the MAT Waiver fulfill the controlled substance education course requirement?

    While many opioid CME courses do qualify for CAT 1 CMEs, they may not meet the requirements of CCR section 1399.610. The MAT Waiver is required to obtain a waiver from the DEA to prescribe buprenorphine for the treatment of opioid use disorder and does not fulfill the requirements of CCR section 1399.610.

  7. When was the controlled substance education course first offered?

    The controlled substance education course was first offered on or after January 1, 2008.

  8. How to I submit a copy of my certificate to the Board?

    Submit a copy of the certificate to the Board by email to paboard@dca.ca.gov .

Education Course Providers
The following course providers have submitted evidence to the Board that their course meets the regulatory requirements and have been deemed approved. Please visit the course provider’s website to view their schedule of upcoming controlled substance education courses or contact the course provider directly for assistance.

Course providers who wish to offer a controlled substance education course as required by Code section 3502.1(e)(3), must meet the requirements established by CCR sections 1399.610 and 1399.612 and the course must be sponsored by one of the following entities:

  • American Academy of Physician Assistants (AAPA)
  • American Medical Association (AMA)
  • American Osteopathic Association Council on Continuing Medical Education (AOACCME)
  • American Academy of Family Physicians (AAFP)
  • Accreditation Council for Continuing Medical Education (ACCME)
  • A state medical society recognized by the ACCME

Please submit course materials to the Physician Assistant Board if you wish to offer a controlled substance education course:

Physician Assistant Board
2005 Evergreen Street, Suite 2250
Sacramento, CA 95815
Contact Person:
Julie Caldwell
Lead Licensing Analyst
(916) 561-8781

Regulatory Language

Title 16, California Code of Regulations, section 1399.610. Requirements for an Approved Controlled Substance Education Course to Administer, Provide or Issue a Drug Order for Schedule II – V Controlled Substances without Advance Approval From a Supervising Physician.

A controlled substance education course shall be deemed approved by the Board if it meets all of the following criteria:

(a) The course includes all of the following learning objectives:
(1) Describes the applicable federal and state laws and regulations pertaining to the provision, administration and furnishing of controlled substances and the legal and professional relationship between a physician assistant and his or her supervising physician.
(A) This objective shall include a description of the applicable patient charting requirements and the use of secure drug order forms.
(2) Assessment strategies for the recognition, prevention and management of acute and chronic pain.
(3) Comparison of efficacy data and safety profiles which influence the selection, usage and conversion of pharmacological agents.
(4) The evaluation and comparison of the safety and efficacy profiles of controlled substances and the clinical rationale for their use.
(5) Describes disorders routinely requiring a therapeutic regimen of controlled substances for clinical management.
(6) Assessment of a controlled substance's potential for abuse and addiction, its psychosocial aspects, the recognition of the symptoms (including controlled substance-seeking behaviors) thereof and medically appropriate alternatives, if any, (7) Evaluation of the response and compliance of the patient to the controlled substances.
(8) Provision of appropriate patient education regarding controlled substances. For the purposes of this subdivision, "controlled substances" means Schedule II through Schedule V controlled substances.
(b) The course includes a comprehensive written examination, proctored by the course provider at the conclusion of the course, of the material presented. The licensee must successfully complete the examination to receive a certificate of completion issued pursuant to subdivision (b) of section 1399.612.
(c) The course is at least six (6) hours in duration, of which a minimum of three (3) hours shall be exclusively dedicated to Schedule II controlled substances. A course provider shall not include the time for the written examination specified in subdivision (b) in the (6) six hour requirement. The course shall be completed on or after January 1, 2008.
(d) The course is provided by one of following entities:
(1) A physician assistant program approved by the board in accordance with section 1399.530.
(2) A continuing education provider approved by the Medical Board of California for Category I continuing medical education.
(3) A Category I continuing education provider approved by American Academy of Physician Assistants.
(4) A Category I continuing education provider approved by the American Medical Association, the California Medical Association and/or the American Osteopathic Association.

Note: Authority cited: Sections 3502, 3502.1, and 3510, Business and Professions Code. Reference: Sections 2058, 3502, 3502.1, and 3509 Business and Professions Code.

Title 16, California Code of Regulations, section 1399.612. Responsibilities of Course Providers and Attendees.

(a) A course provider of any controlled substance educational course intended to meet the requirements of section 1399.610 shall use qualified instructors and shall provide course attendees with a written course outline or syllabus, as applicable. For the purposes of this section, a qualified instructor is a person who holds a current valid license to practice in the appropriate healing arts discipline, is free from any disciplinary action by the applicable licensing jurisdiction, and is knowledgeable, current and skilled in the subject matter of the course, as evidenced through either of the following:
(1) Experience in teaching similar subject matter content within two years immediately preceding the course; or,
(2) Has at least one year experience within the last two years in the specialized area in which he or she is teaching.
(b) A controlled substance course provider shall issue a certificate of completion to each licensee who has successfully completed the course. A certificate of completion shall include the following information:
(1) Name and license number of the physician assistant.
(2) Course title and each instructor's name.
(3) Provider's name and address.
(4) Date of course completion.
(c) A controlled substance education course provider shall retain the following records for a period of four years in one location within the State of California or in a place approved by the board:
(1) Course outlines of each course given.
(2) The date and physical location for each course given.
(3) The examination proctored at the conclusion of each course and the score of each physician assistant who took the examination.
(4) Course instructor curriculum vitae or resumes.
(5) The name and license number of each physician assistant taking an approved course and a record of any certificate of completion issued to a physician assistant.
A course provider shall make the records specified above available to the board upon request. A course provider may retain the records required by this subdivision in an electronic format.
(d) A physician assistant shall make his or her certificate of completion available for inspection upon the request of his or her employer or prospective employer, supervising physician or the board.

Note: Authority cited: Sections 3502 and 3510, Business and Professions Code. Reference: Sections 2058, 3502, 3502.1, and 3509 Business and Professions Code.