PMHNP Scope of Practice for ADHD in Michigan

You’re a psychiatrist or PMHNP treating ADHD patients, and you’re wondering: Can I legally prescribe Adderall or other stimulants through telehealth in 2026?

The short answer: Yes—but the rules are shifting, and you need to know both federal and state requirements.

Since COVID-19, telehealth ADHD care has exploded. The DEA waived the Ryan Haight Act’s in-person exam requirement, opening the floodgates for remote stimulant prescribing. But those flexibilities are temporary. As of early 2026, providers can still prescribe Schedule II ADHD medications via video visits without an initial in-person exam—but only through December 31, 2026. After that, new DEA rules will likely require a special telemedicine registration and additional patient safeguards.

Meanwhile, state laws add another layer. Some states explicitly permit telehealth ADHD prescribing (like Florida’s psychiatric disorder exception). Others restrict what nurse practitioners can prescribe (Texas bans NPs from prescribing any Schedule II stimulants outside hospitals). And if you’re practicing across state lines, you need to navigate each state’s licensing, PDMP checks, and scope-of-practice rules.

This guide breaks down what you actually need to know: the current federal extension, what’s coming next from the DEA, and the real requirements in six key states (California, Texas, Florida, New York, Pennsylvania, Illinois). Whether you’re a psychiatrist scaling your practice or a PMHNP exploring telehealth platforms, you’ll get the regulatory clarity you need—without the legal jargon.

Federal Rules: Where We Stand Now (and What’s Coming)

The Ryan Haight Act and COVID-Era Waivers

The Ryan Haight Act (2008) is the federal law that governs prescribing controlled substances via telemedicine. Its core requirement: providers must conduct at least one in-person medical evaluation before prescribing any controlled substance—including ADHD stimulants—unless an exception applies.

Before COVID, this was a dealbreaker for fully remote ADHD care. In March 2020, the DEA and HHS exercised emergency authority to waive the in-person exam requirement during the Public Health Emergency. Suddenly, psychiatrists and PMHNPs could initiate Adderall prescriptions after a video consult, no office visit needed.

Current Status (2026): The DEA has extended this flexibility four times. The most recent extension (announced January 2026) keeps the waiver in place through December 31, 2026. You can still prescribe Schedule II–V controlled substances—Adderall, Vyvanse, Ritalin, etc.—via telehealth without an initial in-person visit, as long as:

• You conduct a real-time audiovisual evaluation (video required, not just phone)
• You’re prescribing for a legitimate medical purpose
• You follow standard controlled-substance protocols (PDMP checks, proper documentation, e-prescribing)

This extension buys time while the DEA finalizes permanent rules. But make no mistake: the temporary waiver expires at the end of 2026 unless extended again.

What the DEA’s Permanent Rules Will Likely Require

In January 2025, the DEA announced it’s developing three new telemedicine rules to replace the temporary COVID flexibilities. These rules aim to preserve telehealth access while adding patient protections. Here’s what we know:

1. Telemedicine Special Registration
The DEA plans to create a pathway for providers to obtain a special DEA registration specifically for telemedicine prescribing. With this registration, you could prescribe Schedule II–V controlled substances to new patients via telehealth without an in-person exam—indefinitely.

The catch? You’ll need to comply with new safeguards:

• Mandatory nationwide PDMP checks (the DEA is building a national Prescription Drug Monitoring hub)
• Strict patient identity verification during audiovisual consults
• Likely, additional reporting or auditing requirements

Think of it as a specialized credential proving you’re following best practices for remote controlled-substance prescribing.

2. Telehealth Platform Registration
For the first time, the DEA will require telehealth companies (the platforms that facilitate virtual visits) to register as well. This suggests corporate-level oversight to prevent ‘pill mill’ behavior. If you’re joining a platform like Klarity, the platform itself will need DEA registration—another layer of accountability.

3. Established Patient Exception
If you’ve already seen a patient in person at least once (or they were seen by another provider in your practice), the new telemedicine rules won’t apply to that patient. You can continue prescribing via telehealth freely. This exception is aimed at continuity of care—ensuring patients who transition from in-person to virtual visits aren’t disrupted.

When Do These Rules Take Effect?
The DEA hasn’t published final rule text yet (as of February 2026), but they’re expected to be finalized before the current extension expires in late 2026. Once active, these rules will replace the blanket COVID waiver. Providers who want to continue prescribing ADHD meds via telehealth to new patients should plan to obtain the special registration.

Bottom Line: From now through the end of 2026, prescribing ADHD medications via telehealth is fully legal under federal law—no in-person exam needed. After 2026, expect a shift to a special registration system with added compliance steps. Stay tuned for DEA announcements, and plan to adjust your practice accordingly.

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State-by-State Rules: Where Geography Matters

Federal law sets the floor, but states can impose their own telehealth and prescribing rules. Some states are highly permissive. Others restrict who can prescribe stimulants or add telehealth-specific requirements. Here’s what you need to know in six priority states.

California: Progressive Telehealth, NPs Gaining Independence

Telehealth Prescribing: California doesn’t require an in-person exam for prescribing via telehealth. State law explicitly allows providers to conduct an ‘appropriate prior examination’ through telehealth—even structured online questionnaires plus video follow-up, if clinically appropriate. No California law prohibits prescribing Schedule II stimulants remotely; the state defers to federal rules.

What You Must Do:

• PDMP Check: California mandates checking the CURES database (CA’s PDMP) before prescribing any Schedule II–IV controlled substance for the first time, and at least every four months for ongoing stimulant therapy. This isn’t optional—document every check.
• E-Prescribing: Required for controlled substances (with rare exceptions). Make sure your telehealth platform integrates with California pharmacies.

Licensure: You must hold a California medical or nursing license to treat patients located in CA. California is not part of the Interstate Medical Licensure Compact (IMLC) for physicians, so out-of-state MDs need a full CA license (which can take months). No special telehealth license exists.

NP Scope of Practice: California is transitioning to Full Practice Authority (FPA) for nurse practitioners. Under AB 890 (passed 2020), experienced NPs can practice and prescribe independently—including ADHD medications—without physician supervision, as of 2026.

• New NPs still need a supervising physician initially (during a 3-year/4,600-hour transition period).
• Experienced NPs (those who’ve completed the transition) can prescribe stimulants independently via telehealth.

This shift dramatically expands the pool of ADHD prescribers in California, especially for telehealth platforms.

Key Takeaway: California is telehealth-friendly for ADHD care. Psychiatrists have no special restrictions. NPs are gaining independence, which opens opportunities for scalable tele-psychiatry. Just stay on top of CURES checks and ensure your evaluation meets the standard of care.

Texas: Physician-Only for Stimulants

Telehealth Prescribing: Texas allows telemedicine for mental health care, including ADHD. There’s no state ban on prescribing stimulants via telehealth—Texas’s ‘no telehealth for chronic pain’ law doesn’t apply to ADHD. Physicians (MD/DO) can prescribe Adderall via video consult, following federal rules and standard of care.

The NP Restriction:
Here’s the problem: Texas prohibits nurse practitioners and physician assistants from prescribing Schedule II controlled substances in outpatient settings. Period.

The only exceptions are narrowly defined:

• Hospital inpatient orders (for patients hospitalized ≥24 hours)
• Hospice care
• Emergency medication orders in the ER

Outpatient ADHD treatment doesn’t qualify. So if you’re a PMHNP practicing in Texas, you cannot prescribe Adderall, Ritalin, Vyvanse, or any Schedule II stimulant to outpatient telehealth patients. Only physicians can write those prescriptions.

This is a dealbreaker for NP-driven telehealth models in Texas. Platforms like Klarity must use Texas-licensed psychiatrists (or arrange physician oversight) to prescribe stimulants in TX.

What You Must Do:

• Licensure: Texas physicians need a TX medical license or use the IMLC to expedite licensing. NPs need a TX nursing license.
• PDMP Check: Texas law requires checking the Prescription Monitoring Program for opioids, benzos, barbiturates, and carisoprodol—but not stimulants. Still, it’s best practice to check the PMP for any controlled substance to avoid overlapping prescriptions.
• E-Prescribing: Mandatory for all controlled substances in Texas (since 2021). No paper scripts allowed.

Key Takeaway: Texas is fine for telehealth ADHD care if you’re a physician. If you’re an NP, you’ll need a physician to write the stimulant prescriptions. This state’s restrictive NP scope makes it harder to scale NP-led telehealth ADHD services.

Florida: Explicitly Permits Psychiatric Telehealth Prescribing

Telehealth Prescribing: Florida has the clearest law on this topic. Under Florida Statutes §456.47, telehealth providers generally cannot prescribe Schedule II controlled substances—except for treatment of a psychiatric disorder (plus inpatient, hospice, or nursing home settings).

Since ADHD is a psychiatric disorder, you can legally prescribe stimulants via telehealth in Florida without an in-person exam. This carve-out was included when Florida enacted its telehealth law in 2019, specifically to preserve mental health treatment access.

What You Must Do:

• PDMP Check: Florida requires checking the E-FORCSE PDMP before prescribing any controlled substance to patients age 16 or older. Document every check.
• E-Prescribing: Mandatory for controlled substances.
• Telehealth Consent: Obtain and document patient consent for telehealth services.

Licensure Options:
Florida offers a unique pathway: an out-of-state telehealth provider registration. If you’re licensed in another state, you can register with Florida’s Department of Health to provide telehealth services to Florida patients—without getting a full FL license.

Requirements:

• Active, unrestricted license in another state
• Clean disciplinary record for 5 years
• Malpractice insurance
• Compliance with Florida rules (including the psychiatric disorder exception for stimulants)

This registration does allow you to prescribe ADHD medications via telehealth, as long as it’s for psychiatric treatment. You’ll also need to register with Florida’s PDMP.

NP Scope of Practice:
Florida allows APRNs to prescribe controlled substances, but with limitations:

• General Rule: APRNs can prescribe Schedule II substances for a maximum 7-day supply for acute conditions.
• Psychiatric Nurse Exception: If you’re a psychiatric nurse (PMHNP with an advanced degree in psychiatric nursing and ≥2 years post-grad psych clinical experience under a psychiatrist), the 7-day limit does not apply. You can prescribe full-length ADHD medication refills.
• Supervision Required: All psychiatric NPs in Florida must work under a written protocol agreement with a supervising psychiatrist. The psychiatrist doesn’t need to sign every prescription, but the oversight relationship must exist.

Florida’s 2020 legislation created independent practice pathways for some NPs (adult primary care, family medicine), but psychiatric NPs were excluded. Psych NPs must maintain physician collaboration.

Key Takeaway: Florida’s clear statutory exception for psychiatric disorders makes telehealth ADHD prescribing straightforward. Out-of-state providers can use the telehealth registration to access the FL market. NPs need physician oversight but aren’t limited to 7-day supplies for mental health meds.

New York: Aligned with Federal Rules (as of 2025)

Telehealth Prescribing: New York State updated its regulations in May 2025 to explicitly allow prescribing controlled substances via telehealth consistent with federal law. Previously, NY mirrored the Ryan Haight Act’s in-person requirement. The new rule (10 NYCRR §80.63) includes an exception for telehealth prescribing when it aligns with DEA rules.

Translation: As long as the federal extension is in place (through 2026), you can prescribe ADHD stimulants via telehealth in New York. When the DEA’s permanent rules take effect, NY will require compliance with those as well.

What You Must Do:

• PDMP Check: New York mandates checking the I-STOP/PMP registry before prescribing any Schedule II, III, or IV controlled substance. This is strictly enforced. Check the registry for every ADHD stimulant prescription.
• E-Prescribing: Mandatory for all controlled substances since 2016. No exceptions for telehealth.
• 90-Day Supply Option: New York allows prescribing up to a 90-day supply of stimulants for ADHD (or narcolepsy) if you indicate the prescription is for ‘minimal brain dysfunction’ (the old term for ADHD) by assigning Code B on the prescription. This can reduce refill hassle for stable telehealth patients.

Licensure: You must hold a New York medical or nursing license. NY is not part of the IMLC for physicians, so out-of-state doctors need a full license. No telehealth registration shortcut exists.

NP Scope of Practice:
New York is relatively progressive for nurse practitioners:

• Experienced NPs (≥3,600 hours of practice) can practice independently without a written collaborative agreement, including prescribing ADHD medications.
• NPs can prescribe Schedule II–V controlled substances (with DEA registration and a NYS narcotic prescribing number).
• No state-specific quantity limits on NP prescribing of stimulants—same as physicians.
• NPs must complete a one-time continuing education course on pain management and addiction (targeted more at opioid prescribing, but required).

Key Takeaway: New York’s 2025 regulatory update removes any ambiguity about telehealth controlled-substance prescribing. NPs have strong prescriptive authority. The 90-day supply option is a practical advantage. Just stay compliant with PDMP checks and e-prescribing—NY has strict monitoring.

Pennsylvania: Telehealth Allowed, NPs Limited to 30-Day Supplies

Telehealth Prescribing: Pennsylvania has no state law prohibiting telehealth prescribing of stimulants. The state defers to federal rules (Ryan Haight Act), so during the current DEA extension, PA providers can prescribe ADHD medications via video consult. Pennsylvania’s medical boards have issued guidelines stating that a valid patient-provider relationship can be established through telemedicine, and prescribing is acceptable if the encounter meets the standard of care.

What You Must Do:

• PDMP Check: Pennsylvania law requires querying the PA PDMP before prescribing opioids or benzodiazepines, and at the start of a new course of treatment for any controlled substance (including stimulants). Best practice: check the PDMP for every ADHD prescription.
• E-Prescribing: Mandatory for controlled substances (with few exceptions), effective since 2019.

Licensure: You need a Pennsylvania license. PA is a member of the Interstate Medical Licensure Compact (IMLC) for physicians, so out-of-state psychiatrists can expedite licensing if they’re from a compact state.

NP Scope of Practice:
Pennsylvania is a restricted practice state for nurse practitioners:

• Collaborative Agreement Required: CRNPs must have a written collaborative agreement with a physician. The physician doesn’t co-sign every script but must be available for consultation.
• 30-Day Limit on Schedule II: Pennsylvania regulations limit CRNPs to a 30-day supply of Schedule II controlled substances. Any continuation beyond 30 days requires physician approval (i.e., the NP must consult their collaborator before refilling).
• 90-Day Limit on Schedule III/IV: NPs can prescribe up to 90 days for lower schedules.

For ADHD stimulants (Schedule II), this means the NP can write an initial one-month prescription. For month two and beyond, they need to loop in their collaborating psychiatrist for approval (which could be as simple as a chart review or brief consult).

Key Takeaway: Pennsylvania’s telehealth environment is permissive, but NP prescribing is tightly controlled. If you’re building a telehealth practice with NPs in PA, you’ll need a physician collaborator actively involved in reviewing stimulant cases monthly. Psychiatrists have no special state limits.

Illinois: Telehealth-Friendly, NP Rules Depend on Experience

Telehealth Prescribing: Illinois law permits telehealth broadly and doesn’t restrict prescribing controlled substances via telemedicine beyond federal requirements. Illinois updated its Telehealth Act in 2021 to ensure parity and allow provider-patient relationships to be established virtually. There’s no state-mandated in-person exam for controlled substances.

What You Must Do:

• Illinois Controlled Substance License: In addition to your professional license and DEA registration, any provider prescribing controlled substances in Illinois must obtain an Illinois Controlled Substance License (through the IL Department of Financial & Professional Regulation). This is a separate credential required for prescribing.
• PDMP Check: Illinois law requires documenting an attempt to access the Illinois PMP (AWARxE) for each opioid prescription and initial benzodiazepine prescription. While not explicitly mandated for stimulants, checking the PMP for ADHD meds is best practice.
• E-Prescribing: Required for controlled substances.

Licensure: You need an Illinois license (physicians can use the IMLC to expedite). Illinois also requires the state CS license mentioned above.

NP Scope of Practice:
Illinois offers a two-tier system for APRNs:

Option 1: Full Practice Authority (FPA)
APRNs who complete 4,000 hours of clinical practice under a collaborative agreement and 250 hours of continuing education/training can apply for Full Practice Authority. With FPA, an APRN can:

• Practice independently (no physician collaboration required for most activities)
• Prescribe Schedule II–V controlled substances independently
• Exception: For Schedule II narcotic drugs (opioid analgesics) or benzodiazepines, the FPA APRN must maintain a ‘consultation relationship’ with a physician and consult at least monthly.

The key point: Stimulants for ADHD (amphetamines, methylphenidate) are Schedule II non-narcotic controlled substances. The consultation requirement does not apply to stimulants. Therefore, an Illinois FPA-certified PMHNP can prescribe Adderall independently via telehealth—no physician oversight needed.

Option 2: Collaborative Agreement
APRNs who don’t have FPA must work under a written collaborative agreement with a physician. Under collaboration:

• The physician may delegate Schedule II prescribing authority to the NP for substances the physician routinely prescribes (must be listed in the agreement).
• Any Schedule II prescription is limited to a 30-day supply, and the collaborating physician must approve any continuation beyond 30 days.
• The physician must conduct a monthly review of the NP’s Schedule II prescribing.

This is similar to Pennsylvania’s model but with added monthly oversight.

Key Takeaway: Illinois is telehealth-friendly for ADHD care. The FPA pathway allows experienced NPs to prescribe stimulants independently, which is great for scaling telehealth. Newer NPs need physician collaboration and face the 30-day limit. Make sure all Illinois providers have the state CS license in addition to their DEA registration.

Provider Type Differences: Psychiatrist vs PMHNP

Your credential matters—not just for scope of practice, but for how states regulate you.

Psychiatrists (MD/DO):

• Full prescribing authority in all 50 states for ADHD medications
• No quantity limits or physician oversight requirements
• Must hold a state medical license and DEA registration
• Can practice via telehealth in any state where licensed, following that state’s telehealth rules
• Generally exempt from the restrictive supervision rules that affect NPs

Psychiatric Nurse Practitioners (PMHNPs):

• Can diagnose ADHD and prescribe stimulants in all 50 states, but scope of practice is state-dependent
• Some states require physician supervision or collaboration (Florida, Pennsylvania, Illinois without FPA)
• Some states impose quantity limits (Pennsylvania and Illinois collaboration: 30-day max on Schedule II)
• Texas bans NPs from prescribing Schedule II stimulants entirely in outpatient settings
• States like California, New York, and Illinois (with FPA) grant independent practice authority after meeting experience requirements
• Must hold a state nursing license, DEA registration, and sometimes a state controlled-substance license

Practical Implications for Telehealth:

If you’re a psychiatrist, telehealth ADHD prescribing is straightforward: get licensed in your target state(s), follow federal DEA rules, check the PDMP, use e-prescribing. You’re not navigating supervision agreements or quantity limits.

If you’re a PMHNP, your autonomy depends heavily on where you practice:

• In California, New York, or Illinois (with FPA), you can operate like a physician—independently prescribing via telehealth.
• In Pennsylvania or Illinois (without FPA), you’ll need a collaborating psychiatrist and will face monthly oversight or 30-day refill limits.
• In Florida, you need a protocol agreement with a psychiatrist but can prescribe full refills for mental health meds.
• In Texas, you’re essentially sidelined from stimulant prescribing—you can evaluate patients, but a physician must write the script.

For telehealth platforms aiming to scale across multiple states, this means hiring a mix of psychiatrists and experienced PMHNPs (with FPA where applicable) is the most flexible approach. In restrictive states like Texas, you’ll lean on psychiatrists. In progressive states, you can leverage NP independence to increase capacity.

The Economics of Telehealth ADHD Care: Why Platforms Make Sense

Let’s talk about what it actually costs to acquire an ADHD patient through DIY marketing vs. joining a telehealth platform.

The Reality of DIY Patient Acquisition:

Many providers assume they can build a telehealth ADHD practice cheaply by running Google Ads, investing in SEO, or listing on directories like Psychology Today or Zocdoc. Here’s what that actually looks like:

• Google Ads for ADHD Keywords: Mental health keywords (especially ‘ADHD treatment,’ ‘online ADHD diagnosis,’ ‘Adderall prescription’) cost $15–40+ per click. Most clicks don’t convert to booked patients. A realistic cost per booked patient through PPC is $200–400+, once you factor in click-through rates, no-show rates, and ad optimization.

• SEO Investment: Building organic search traffic takes 6–12 months of consistent content creation, technical optimization, and backlink building. If you hire an agency or consultant, expect to spend $2,000–5,000/month during the ramp-up phase. Even if you do it yourself, your time has value—and most solo providers don’t have the expertise to rank competitively.

• Directory Listings: Psychology Today charges a monthly subscription (~$30/month per listing), but you’re competing with hundreds of other providers on the same search page. Zocdoc charges $35–100+ per booking plus a monthly subscription fee. Total monthly cost (subscription + per-booking fees) can easily hit $500–1,000+ if you’re booking volume.

• Cold Lead Waste: DIY marketing generates cold leads. You’ll spend staff time (or your own time) qualifying leads, answering calls and emails, handling no-shows from people who weren’t serious. These hidden costs—staff time, scheduling software, follow-up systems—add up.

Total Real Cost: When you add it all up—ad spend, agency fees, staff time, no-shows, months of SEO investment before results—acquiring a qualified ADHD patient through DIY channels typically costs $200–500+ per patient. And that’s if you have the budget, expertise, and patience to test and optimize campaigns over many months.

The Platform Advantage:

Platforms like Klarity use a pay-per-appointment model. You pay a standard fee per new patient lead—but only when a pre-qualified patient books with you. Here’s why that’s economically smart:

• No Upfront Marketing Spend: You’re not gambling $3,000–5,000/month on ads that might not work. You pay only when you see a patient.
• Pre-Qualified Patients: Klarity (and similar platforms) match patients to your specialty, availability, and insurance panel. You’re not wasting time on unqualified leads or patients looking for services you don’t offer.
• No Wasted Ad Spend: You’re not paying for clicks that don’t convert. Every dollar goes toward an actual appointment.
• Built-In Infrastructure: The platform handles telehealth software, scheduling, insurance verification, PDMP integration, e-prescribing—costs you’d otherwise pay separately.
• Both Insurance and Cash-Pay Flow: Platforms aggregate demand from multiple channels (insurance panels, cash-pay patients), giving you access to volume you couldn’t generate solo.
• You Control Your Schedule: Only pay when you accept appointments. No monthly subscription fees eating into revenue during slow months.

ROI Comparison:

Let’s say you want to add 20 new ADHD patients per month.

DIY Approach:

• Cost per patient: $300 (conservative estimate)
• Total monthly acquisition cost: $6,000
• Plus: Staff time, no-show risk, software costs, months of ramp-up

Platform Approach:

• Pay per appointment (exact fee varies by platform, but let’s say similar to Zocdoc’s per-booking model)
• Predictable cost per patient
• Zero upfront marketing risk
• Immediate patient flow (no 6-month SEO wait)
• Built-in telehealth infrastructure included

The platform model eliminates uncertainty. You know your patient acquisition cost upfront, you’re only paying for results, and you’re not sinking thousands into marketing experiments that may fail.

When DIY Makes Sense:

If you’re an established psychiatrist with a strong local reputation, a marketing budget of $5,000+/month, and the patience to wait 6–12 months for SEO to pay off, DIY marketing can eventually be cost-effective. But for most providers—especially those starting out, scaling a telehealth practice, or working part-time—a platform removes the risk entirely.

Practical Compliance Checklist for Telehealth ADHD Prescribing

Here’s what you need to have in place to prescribe ADHD medications via telehealth legally and safely:

Federal Requirements (All States):

• [ ] DEA Registration: Active DEA registration in the state(s) where patients are located
• [ ] Video Evaluation: Conduct initial evaluation via real-time audiovisual communication (video required, not just phone)
• [ ] Legitimate Medical Purpose: Document a proper ADHD evaluation (clinical interview, symptom assessment, DSM-5 criteria, ruling out other conditions)
• [ ] E-Prescribing: Use Electronic Prescribing of Controlled Substances (EPCS) for all Schedule II stimulant prescriptions
• [ ] Patient Identity Verification: Verify patient identity during the telehealth visit (required under upcoming DEA rules)
• [ ] Prepare for Special Registration: Plan to obtain DEA Telemedicine Special Registration when available (likely required after Dec 2026 for new patients)

State-Specific Requirements:

California:

• [ ] CA medical or nursing license
• [ ] Check CURES PDMP before initial stimulant prescription and every 4 months
• [ ] Document telehealth exam meets standard of care
• [ ] NPs: Ensure you meet FPA criteria or have supervising physician

Texas:

• [ ] TX medical license (or IMLC) or TX nursing license
• [ ] Physicians only for Schedule II stimulant prescribing (NPs cannot prescribe in outpatient settings)
• [ ] Check Texas PMP (recommended, though not legally mandated for stimulants)
• [ ] Use EPCS for all controlled substances

Florida:

• [ ] FL medical/nursing license or out-of-state telehealth registration
• [ ] Register with E-FORCSE PDMP and check before prescribing (patients ≥16)
• [ ] Document patient consent for telehealth
• [ ] NPs: Written protocol agreement with supervising psychiatrist
• [ ] Confirm prescription falls under ‘psychiatric disorder’ exception in documentation

New York:

• [ ] NY medical or nursing license
• [ ] Check I-STOP/PMP registry before every Schedule II prescription
• [ ] Use EPCS (mandatory since 2016)
• [ ] NPs: Ensure you have NYS narcotic prescribing number and DEA registration
• [ ] Consider 90-day supply option for stable patients (use Code B on prescription)

Pennsylvania:

• [ ] PA medical or nursing license (or use IMLC)
• [ ] Check PA PDMP before initial controlled-substance prescription
• [ ] NPs: Collaborative agreement with physician; 30-day limit on Schedule II; physician approval required for refills
• [ ] Use EPCS

Illinois:

• [ ] IL medical or nursing license
• [ ] Illinois Controlled Substance License (in addition to DEA registration)
• [ ] Check Illinois PMP (AWARxE) (recommended for stimulants, required for opioids/benzos)
• [ ] NPs: Either obtain FPA (for independent prescribing) or maintain collaborative agreement (30-day limit, monthly physician review)
• [ ] Use EPCS

What’s Next: Preparing for DEA’s Permanent Rules

The current federal extension runs through December 31, 2026. What should you do now to prepare for the transition to permanent rules?

1. Monitor DEA Announcements
The DEA will publish final rules in the Federal Register before the extension expires. Sign up for alerts from the DEA’s website or follow industry news (Fierce Healthcare, Healthcare Dive, APA SmartBrief) to catch the announcement as soon as it drops.

2. Plan to Obtain Telemedicine Special Registration
When the DEA launches the special registration program, apply early. This registration will likely become the primary pathway for prescribing ADHD meds via telehealth to new patients without in-person exams. Don’t wait until the last minute—the DEA may have a backlog of applications.

3. Implement Nationwide PDMP Checks
The DEA’s proposed rules include mandatory PDMP checks using a national hub. Start checking PDMPs religiously now (most states already require it). Document every check in your patient records. When the national system launches, you’ll already have the workflow in place.

4. Strengthen Patient Identity Verification
The DEA will require strict identity verification during telehealth consults. Review your platform’s identity verification process (photo ID checks, two-factor authentication, etc.). Make sure your documentation clearly shows you verified the patient’s identity at the initial visit.

5. Review Your Telehealth Platform’s Compliance
If you’re using a telehealth platform, confirm they’re preparing for DEA registration requirements. Platforms that facilitate controlled-substance prescribing will need to register with the DEA. Choose a platform that’s proactively addressing compliance—this isn’t something you want to be scrambling to fix in late 2026.

6. Document, Document, Document
The DEA (and state medical boards) are watching telehealth ADHD prescribing closely, especially after high-profile investigations into some telehealth startups. Your documentation needs to be bulletproof:

• Detailed ADHD evaluation (symptom history, functional impairment, DSM-5 criteria)
• Differential diagnosis (ruled out other conditions, substance use, medication diversion risk)
• PDMP review documented in chart
• Informed consent for stimulant therapy (risks, benefits, monitoring plan)
• Regular follow-ups documented (not just prescription renewals—actual clinical reassessment)

If you’re ever audited, your chart should show a thorough, standard-of-care evaluation—not a rubber-stamp prescription mill.

FAQs: Telehealth ADHD Prescribing

Can I prescribe Adderall via telehealth in 2026?
Yes, through December 31, 2026, you can prescribe Schedule II ADHD medications (Adderall, Vyvanse, Ritalin) via telehealth without an initial in-person exam, under the current DEA extension. After 2026,

Source:

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• https://rxagent.co/blog/np-prescribing-authority#:~:text=Proposed%20DEA%20rules%20create%20a,for%20telemedicine%20prescribing
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