Important: Read This Before You Get Audited!

By on Jun 3, 2014 in Notes from the President | 1 comment

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To all TANA members:

I would like to reiterate the importance of this letter as it DOES pertain to your LICENSURE and

ability to practice:

Recently, a CRNA was audited by the Board of Nursing (BON) in regard to their APN Licensure.

We have received new information, and confirmation from the BON that there will be an increase

in the number of audits for APNs in light of the recent issues regarding the prescribing of pain

medicines. What each CRNA must be aware of is that the requirements changed in 2013. I have

included these changes in the following section:

The following rule for APN prescribers that requires a one-hour board approved course addressing controlled substance

prescribing practices became effective March 20, 2013.

1000-04-.05 Renewal of Certificate and Demonstration of Competency. All advanced practice nurses who hold a

Tennessee registered nurse license must biennially renew their Tennessee registered nurse license pursuant to

Rule 1000-.01-.03 and must demonstrate competency as a registered nurse pursuant to Rule

1000-01-.14. Additionally, to demonstrate competency to hold and/or renew an Advanced Practice Nurse Certificate,

an advanced practice nurse shall:

(1) Have initially obtained or maintained, during the most recent biennial renewal period, certification from a nationally

recognized certification body appropriate to the nurse’s specialty area; and

(2) If in possession of a Certificate of Fitness pursuant to Rule 1000-04-.04, have successfully completed a

minimum one (1) contact hour course designed specifically to address controlled substance prescribing

practices and offered through a continuing education provider approved by any certifying board of an

advanced practice nurse, as the term advanced practice nurse is defined in T.C.A. § 63-7-126(a).

So what does this mean for you as a CRNA?

1) This change only affects those CRNAs who have a Certificate of Fitness (COF) (even if you

do not have a DEA number).

2) You must complete 1 CE in Controlled Substance Prescribing during each recertification cycle.

If the required course is not completed and you are audited, will you will be subject to penalties.

3) Each CRNA must still meet the 40 CE requirements for recertification, although one of these

can be your Controlled Substance Provider Class.

4) If a CRNA does possess a DEA number and currently prescribes, they will be required to

complete a second CE in Controlled Substance Providing during each recertification cycle.

5) Each CRNA with COF can take the class online at www.tnpap.org. Also TANA will be

looking at opportunities to provide the class at future TANA Annual Meetings or district


Note that TANA has been in discussions with the BON, and CRNAs will not be able to be

exempt from this requirement. Your TANA Board of Directors, Lobbyist’s, and Executive

Director have worked very hard to address this issue and what alternatives we may have as

CRNAs. The only option currently is for CRNAs to complete the class.

Please feel free to email with questions. We will try and answer these in a timely manner. Have

a great day.


Mark J. Haffey MSN, CRNA, APN

TANA President

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