4.1 Prescriber Scope of Authority in Utah
Key Takeaways
A Utah APRN may prescribe prescription drugs including Schedule II–V controlled substances; a CRNA may prescribe only up to a five-day supply immediately before or after a procedure, and never ketamine (Utah Code § 58-31b-803).
A Utah physician assistant with fewer than 8,500 hours of practice must follow written collaboration policies, and a PA with 4,000–8,500 hours needs a written collaborative agreement (Utah Code § 58-70a-307, as amended in 2026).
A Utah optometrist may prescribe only a hydrocodone combination product or a Schedule III drug for eye pain, in no more than a 72-hour quantity with no refills (Utah Code § 58-16a-601).
A prescriber of controlled substances needs a Utah controlled substance license and, for an individual, a DEA registration within 120 days (Utah Code § 58-37-105; R156-37-305).
Utah prohibits prescribing any Schedule II or III controlled substance for weight reduction or control (R156-37-604).
4.1 Prescriber Scope of Authority in Utah
Blueprint item 2.1 asks about the "scope of authority, scope of practice, limitations or restrictions of practice, and valid registration of practitioners who are authorized to prescribe." The pharmacist's gatekeeping question is always the same: Is this prescriber authorized to issue this prescription, for this drug and purpose?
Who is a "practitioner"?
Utah defines a practitioner as an individual "currently licensed, registered, or otherwise authorized by the appropriate jurisdiction to prescribe and administer drugs in the course of professional practice" (§ 58-17b-102(61)). For controlled substances, a prescriber must be authorized to prescribe under Utah law or another state's similar law, and licensed under the Utah Controlled Substances Act or a similar law of another state (§ 58-37-304(1)). Federally, the prescriber must also hold a DEA registration or be exempt.
In Utah, a controlled substance prescriber needs:
- a professional license in a class allowed to hold a controlled substance license (R156-37-301 lists pharmacists, optometrists, podiatric physicians, dentists, osteopathic and allopathic physicians, PAs, veterinarians, APRNs and CRNAs, certified nurse midwives, naturopathic physicians, anesthesiologist assistants, and pharmacies);
- a Utah controlled substance license (§ 58-37-105(2)); and
- a DEA registration, obtained within 120 days after the Utah CS license is issued, unless the individual has written consent to use the employer's hospital or institutional DEA registration (R156-37-305).
If the professional license lapses or is revoked, surrendered, or suspended, the CS license is immediately suspended. If DEA denies, revokes, surrenders, or suspends the federal registration, DOPL immediately suspends the Utah CS license (§ 58-37-105(4)(g); R156-37-305(3)).
Prescriber-by-prescriber summary
| Prescriber | Authority and key limits |
|---|---|
| Physician (MD, DO) | Full scope of medicine; CII–V with CS license and DEA registration |
| APRN (NP, CNM, CNS) | May prescribe or administer prescription drugs including CII–V (§ 58-31b-803(1)); no physician co-signature required by Utah law |
| CRNA (APRN) | May prescribe up to a five-day supply, including CII–V, immediately before or after a procedure in a health care facility, physician office, or dental office, if the CRNA participates in the procedure, has a patient record, and the drug relates to the procedure. Ketamine may not be prescribed. (§ 58-31b-803(2)) |
| Physician assistant | May prescribe appropriate controlled substances with a Utah CS license and DEA registration. Fewer than 8,500 hours of post-graduate practice: must practice under written practice-level collaboration policies. First 4,000 hours: collaboration with a physician. 4,000–8,500 hours: written collaborative agreement with a physician or a PA with more than 8,500 hours in the same specialty. A PA changing specialties collaborates for 4,000 hours in the new specialty. (§ 58-70a-307, amended 2026) |
| Optometrist | Drugs for the eye and adnexa. Oral antibiotics only for eyelid-related and other rule-specified conditions. A hydrocodone combination drug or a Schedule III controlled substance only for pain of the eye or adnexa, oral or topical, no more than a 72-hour quantity, no refills. No other Schedule II drug. No surgery. (§ 58-16a-601) |
| Dentist | Within the practice of dentistry (Title 58, Chapter 69) |
| Podiatric physician | Conditions of the foot and ankle and their systemic manifestations (Title 58, Chapter 5a) |
| Veterinarian | Animals only. The prescription must name the owner and the species (§ 58-17b-602(1)(b)). Veterinarians are exempt from EPCS (§ 58-37-302(1)(b)) and from Utah CS rules for gabapentin (§ 58-37-308). |
A dispensing medical practitioner (DMP) is a physician, PA, APRN, or optometrist licensed under Part 8 of the Pharmacy Practice Act to dispense a limited formulary from a DMP clinic pharmacy. DOPL limits the formulary to certain cosmetic drugs (for example, Latisse), human chorionic gonadotropin for weight loss, hormonal contraception except injectable or implantable methods, hydroquinone up to 4%, and tretinoin up to 0.1% (R156-17b-623). DMPs may not dispense controlled substances except as § 58-17b-805 allows.
Utah limits on certain controlled substance uses (R156-37)
- Weight control. A practitioner may not prescribe, dispense, or administer a Schedule II or III controlled substance for weight reduction or control. A Schedule IV drug may be used only as an adjunct to a comprehensive program, after documented failed non-drug efforts, a history and physical, informed consent, and ongoing monitoring (R156-37-604).
- Cocaine. Only as a topical anesthetic for mucous membranes in surgery, or as a local anesthetic for facial and pediatric laceration repair when mixed and dispensed by a pharmacist (R156-37-603(1)).
- Schedule II stimulants. Before starting treatment, the practitioner must take a history and physical and rule out contraindications (R156-37-603(10)).
- Self-prescribing. Prescribing or administering to oneself any Schedule II or III controlled substance not lawfully prescribed by another practitioner is unprofessional conduct (R156-37-502(1)(a)).
- Minors. A practitioner may not prescribe a controlled substance to a child without the consent of a parent, guardian, or person standing in loco parentis, except in an emergency (§ 58-37-304(8)).
- Excess quantities. A practitioner may not prescribe or administer controlled substances in excess of medically recognized quantities (§ 58-37-304(9)).
Out-of-state and special prescriptions
- Out-of-state legend-drug prescriptions. A Utah pharmacist or intern may fill or refill a legend-drug prescription written by a licensed prescriber in another state after verifying that it is valid (§ 58-17b-609(5)).
- Out-of-state controlled substance prescriptions. These are valid if the prescriber meets the licensing and registration requirements of § 58-37-304(1). A non-electronic CS prescription from a prescriber licensed outside Utah is exempt from Utah's EPCS mandate when the pharmacy orally confirms it with the prescriber (R156-37-609(3)(a)(i)).
- Foreign prescribers cannot hold the DEA registration a controlled substance prescription requires. Utah's out-of-state recognition statute speaks only of prescribers "in another state."
- Expedited partner therapy (§ 58-1-501.3). For gonorrhea or chlamydia, a practitioner may write an antibiotic prescription to "partner of (patient name)" without examining the partner. A pharmacist may dispense it to the person claiming to be the partner, to the patient, or to an agent of either. The partner need not be named, the patient's information may be left off the partner's label, and counseling given to the patient satisfies counseling for both.
Prescribing without adequate information
Issuing a prescription to a person in Utah without first obtaining enough information to establish a diagnosis, identify underlying conditions, and identify contraindications is unprofessional conduct. For prescribers acting under an exception or multistate privilege, it is also unlawful conduct (§ 58-1-501(1)(f), (2)(a)(xiv)). Emergency, on-call, and cross-coverage situations are excepted.
A Utah optometrist writes a prescription for hydrocodone/acetaminophen 5/325 mg, 1 tablet every 6 hours as needed for corneal abrasion pain, #28, with one refill. How should the pharmacist handle it?
Fill it as written, because optometrists may prescribe any Schedule II opioid
Contact the optometrist, because Utah limits optometrists to a 72-hour quantity with no refills for a hydrocodone combination product prescribed for eye pain
Refuse it outright, because optometrists may never prescribe any controlled substance
Fill 7 days, because the Utah acute-opiate limit is the only restriction that applies
A CRNA who will administer anesthesia for an outpatient surgery in a Utah ambulatory surgical center writes a discharge prescription for oxycodone for the same patient. Under Utah Code § 58-31b-803, what limit applies?
A 30-day supply, because oxycodone is Schedule II
No more than a five-day supply, immediately following the procedure, and related to the procedure in which the CRNA participated
No limit, because CRNAs have the same prescriptive authority as other APRNs
CRNAs may not prescribe any controlled substance in Utah
A physician assistant with 3,000 hours of post-graduate clinical practice e-prescribes a Schedule II stimulant. Which statement about the PA's authority is correct under current Utah law?
PAs in Utah may prescribe only Schedule IV and V drugs
The prescription is valid only if co-signed by a physician
The PA may not prescribe Schedule II drugs until reaching 10,000 hours
The PA may prescribe it with a Utah controlled substance license and DEA registration, and must be practicing under written collaboration policies with a physician during the first 4,000 hours
A practitioner in Utah wants to prescribe phentermine-type therapy. Under R156-37-604, which prescription would be prohibited?
A non-controlled GLP-1 receptor agonist for chronic weight management
A Schedule IV drug for a patient who signed informed consent after failed non-drug efforts
A Schedule II or Schedule III controlled substance for weight reduction or control
A Schedule IV anorectic used as an adjunct to a documented comprehensive weight-loss program
Sections you finish are checked off in the contents.