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Physician Assistant Controlled Substance Education Requirement

The Physician Assistant Practice Act (Act) provides for licensure and regulation of physician assistants by the Physician Assistant Board (Board). The Act is comprised of Business and Professions Code (Code), Division 2, Chapter 7.7.

Beginning January 1, 2020, physician assistants, who have not completed a one–time controlled substance education course in accordance with California Code of Regulations (CCR), title 16, sections 1399.610 and 1399.612, must complete a course, as part of the continuing education requirements, within the two–year period immediately preceding the license expiration date.

This requirement applies to physician assistants who:

  • Hold an active California license;
  • Are authorized through a California practice agreement to furnish Schedule II controlled substances; and
  • Are registered with the U.S. Drug Enforcement Administration (DEA).

To demonstrate compliance, a certificate of completion must be submitted to the Board as proof that the course has been successfully completed.

Please be advised that the course required by the Board as a condition of license renewal supersedes the DEA’s one–time eight–hour training requirement for all practitioners implemented by the DEA on June 27, 2023. A course or activity completed to fulfill the DEA’s requirement may NOT fulfill the Board’s requirement.

Please contact the DEA directly for assistance with their course requirement and acceptable courses/activities.

Please review the information below for assistance with interpreting this 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 California practice agreement to furnish Schedule II controlled substances at the time of renewing my license?
    2.

    No. Only licensees who are authorized through their California PA practice agreement to furnish 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. If I am registered with the DEA and authorized through my California PA practice agreement to furnish Schedule II controlled substances but I am not furnishing Schedule II controlled substances, am I required to complete a one-time controlled substance education course pursuant to CCR section 1399.610?
    3.

    Yes. The requirement is based on being authorized through a California PA practice agreement to furnish Schedule II controlled substances, not whether you are currently furnishing Schedule II controlled substances.

  3. What if I remember taking the controlled substance education course but I do not have a copy of my certificate?
    4.

    Certificates of completion are not automatically filed with the Board by the course provider. You must contact the course provider directly for assistance with obtaining a new certificate. Current course providers whose course has been deemed approved by the Board are:

    Kaiser Permanente previously provided an approved one–time controlled substance education course; certificates of completion issued by Kaiser will be accepted if they are compliant with CCR section 1399.612.

  4. Can I renew my license if I am unable to complete the course prior to the expiration date of my license?
    5.

    Yes, however, until this requirement is met, section 3501.1(d)(2) of the Code requires a patient–specific order approved by the treating 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 section 1399.612 must be submitted to the Board on or 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, proof of registration for a future course is required and must be submitted to the Board.

  5. How do I know if the Board has a copy of my certificate of completion on file?
    6.

    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.

  6. Do I have to complete the controlled substance education course prior to registering with the U.S. Drug Enforcement Administration (DEA)?
    7.

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

  7. Does a continuing medical education (CME) course specific to opioids fulfill the controlled substance education course requirement?
    8.

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

  8. When was the controlled substance education course first offered?
    9.

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

  9. How do I submit a copy of my certificate to the Board?
    10.

    The certificate of completion can be faxed to (916) 263–2671, or you may contact the Board at (916) 561–8780 for assistance.

Education Course Providers

The Physician Assistant Board does not develop or administer the controlled substance education courses directly. A provider’s course is deemed approved by the Board if it meets all criteria and learning objectives in accordance with CCR section 1399.610. Feedback from course attendees is welcome and can be submitted by completing the Contact Us form. Please visit the course provider’s website to view scheduled controlled substance education courses or contact the course provider directly for assistance.