Telehealth Narcolepsy Prescribing: What Psychiatric NPs Can Do in Illinois

If you’re a psychiatrist or psychiatric nurse practitioner considering narcolepsy management via telehealth, you’re probably asking: Can I even prescribe stimulants remotely? What are the state rules? How does my scope differ from other providers?

The short answer: Yes, you can prescribe narcolepsy medications via telehealth — but the specifics depend on your credentials, your state, and whether you’re treating across state lines. Let’s cut through the confusion with what actually matters for your practice.

Why Narcolepsy Patients Need Telehealth Prescribers Now

Narcolepsy affects roughly 1 in 2,000 Americans — about 160,000 people living with unpredictable sleep attacks, cataplexy, and profound daytime sleepiness. Yet most of these patients struggle to access specialized care. Sleep specialists are concentrated in major metros, and many narcolepsy patients can’t safely drive long distances due to their condition.

Enter telehealth. Since 2020, virtual care has expanded access to psychiatric prescribers who can manage narcolepsy medications — primarily stimulants and wakefulness-promoting agents. But here’s the catch: not all prescribers have the same authority, and state laws vary wildly on who can prescribe what, and how.

For psychiatrists, this represents a clinical opportunity to serve an underserved population with steady, recurring patient needs. For PMHNPs, it’s more complicated — your ability to independently prescribe narcolepsy meds depends entirely on which state you’re licensed in.

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Federal Rules: The Extended DEA Telehealth Flexibility

Let’s start with the federal baseline. Under the Ryan Haight Act, prescribing Schedule II controlled substances (like Adderall, Ritalin, Dexedrine) normally requires an in-person evaluation before any prescription. However, during COVID-19, the DEA suspended this requirement to enable remote care.

The good news: As of November 2024, the DEA extended these telehealth flexibilities through at least December 31, 2025. This means psychiatrists and qualified prescribers can initiate Schedule II stimulants for narcolepsy via video visits without first seeing the patient in person — provided you’re licensed in the patient’s state and maintain proper clinical standards.

What happens after 2025? That’s TBD. The DEA has proposed rules for a permanent telemedicine framework (including a special DEA registration for telehealth-only prescribers), but nothing is finalized. Smart prescribers are planning for potential changes — like requiring an initial in-person visit within 30 days of starting controlled substances remotely.

What Psychiatrists Can Prescribe for Narcolepsy (Via Telehealth)

Full scope, minimal barriers. As an MD or DO psychiatrist, you have the broadest authority to manage narcolepsy:

• All narcolepsy medications are within your scope: Schedule II stimulants (amphetamines, methylphenidate), Schedule IV wakefulness agents (modafinil, armodafinil), sodium oxybate (Schedule III, requires REMS enrollment), newer agents like pitolisant and solriamfetol, and off-label adjuncts (SSRIs for cataplexy).
• No physician supervision required — you practice independently in every state.
• Telehealth prescribing is fully allowed under current federal waivers, and most states don’t impose additional physician-specific restrictions beyond standard telemedicine requirements (video visit, proper documentation, PDMP checks).

Key Workflow for Psychiatrists:

1. Initial Evaluation (Video): Confirm diagnosis (usually requires previous sleep study documentation or specialist referral), assess symptoms, review medical history, check for contraindications (cardiac issues, substance use history).

2. PDMP Check: Before prescribing any controlled substance, query your state’s prescription drug monitoring program. This is mandatory in most states (e.g., New York requires it every time for Schedule II-IV drugs).

3. E-Prescribe: Use EPCS-certified e-prescribing software (required in states like California, New York, Illinois). Paper prescriptions are largely obsolete for controlled substances and impossible in telehealth.

4. Document Everything: Your chart should meet the same standard-of-care as in-person. Include diagnostic justification (referencing sleep study results), treatment plan, risks/benefits discussion, and monitoring plan.

5. Monthly Follow-Ups: Schedule II drugs can’t have refills under federal law, so monthly visits are the norm. These 15-20 minute med checks (billed as 99213 or 99214) allow you to assess efficacy, monitor side effects (BP, weight, sleep quality), and issue new prescriptions.

State-Specific Physician Considerations:

While psychiatrists have uniform prescribing authority across the U.S., a few states impose telehealth-specific restrictions:

• Florida: State law prohibits prescribing Schedule II controlled substances via telehealth unless it’s for a psychiatric disorder, inpatient care, hospice, or chronic pain management. Since narcolepsy isn’t technically psychiatric, a strict reading means you’d need at least one in-person visit to prescribe stimulants for narcolepsy. (Work-around: Many Florida prescribers use Schedule IV modafinil instead, or argue that comorbid ADHD/depression qualifies as psychiatric treatment.)

• Texas, California, Pennsylvania, others: No special telehealth barriers beyond standard practice requirements. As long as you’re licensed in the patient’s state and follow proper protocols, you can prescribe narcolepsy meds remotely.

Bottom line for psychiatrists: Your scope is essentially unrestricted. The main barriers are licensure (you must hold licenses in each state where your patients reside) and staying current with evolving DEA rules post-2025.

PMHNP Prescribing Authority: It’s Complicated (State-by-State Breakdown)

Psychiatric-Mental Health Nurse Practitioners face a patchwork of state laws that dictate whether you can independently manage narcolepsy patients or need physician oversight. Here’s what you need to know for key states:

Full Practice States (After Experience Requirements):

California:

• Now (through 2025): PMHNPs need a physician collaboration via ‘standardized procedures’ to prescribe Schedule II drugs. AB 890 created a pathway for independent practice: NPs first work as ‘103 NPs’ in group settings (no individual physician supervision for each decision), then after 3+ years can become fully independent ‘104 NPs’ starting in 2026.
• 2026+: Experienced PMHNPs (≥4,600 hours) can prescribe narcolepsy medications completely independently — including Adderall, modafinil, everything.
• Practical note: Until you reach 104 status, your prescribing must align with physician-approved protocols. Additional pharmacology training is required for Schedule II authority.

New York:

• <3,600 hours experience: Must have a written collaborative agreement with a physician. The agreement should explicitly authorize controlled substance prescribing for your practice area.
• ≥3,600 hours (roughly 2 years full-time): You’re fully independent — no collaborative agreement or physician oversight required. You can prescribe all narcolepsy meds (Schedule II-V) on your own.
• PDMP requirement: Every controlled substance prescription requires checking New York’s I-STOP database. This applies equally to MDs and NPs.

Illinois:

• Full Practice Authority (FPA) available after 4,000 hours of collaborative practice + 250 hours of pharmacology CE. Once you have FPA, you can prescribe Schedule II-V independently.
• Special rules: Even with FPA, you must maintain a ‘consultation relationship’ with a physician if prescribing Schedule II opioids long-term (monthly documentation required). This doesn’t apply to stimulants or other narcolepsy drugs — you’re free to prescribe those independently.
• Without FPA: Newer NPs need a written collaborative agreement; the physician must delegate Schedule II prescribing authority explicitly.

Restricted Practice States (Physician Supervision Always Required):

Texas:

• All NPs must have a Prescriptive Authority Agreement (PAA) with a supervising physician.
• Critical limitation: Texas NPs cannot prescribe Schedule II drugs for outpatients except in hospitals (≥24-hour admissions) or hospice care. This means you cannot prescribe Adderall or Ritalin for narcolepsy in a telehealth setting without your supervising physician writing those scripts.
• Work-around: You can prescribe Schedule IV modafinil or armodafinil independently (under your PAA), which are effective for many narcolepsy patients. For patients requiring amphetamine stimulants, your collaborating physician would need to handle those prescriptions.

Florida:

• Physician collaboration required for all PMHNPs (Florida’s autonomous NP law excluded psychiatric NPs).
• 7-day Schedule II limit: APRNs can prescribe Schedule II drugs but only for 7 days maximum per prescription — unless you’re a state-certified ‘psychiatric nurse’ prescribing psychiatric medications. Since narcolepsy isn’t psychiatric, you’re stuck with weekly refills (extremely cumbersome).
• Telehealth restriction: Florida bans tele-prescribing Schedule II drugs except for psychiatric conditions, inpatient care, or hospice. You’ll need physician involvement for ongoing stimulant management.
• Reality check: Many Florida PMHNPs managing narcolepsy rely on their supervising psychiatrist to write stimulant prescriptions, or stick to modafinil/armodafinil.

Pennsylvania:

• Collaborative agreement mandatory. CRNPs (PA’s term for NPs) can prescribe Schedule II for up to 30 days and Schedule III-IV for up to 90 days. Any longer requires physician sign-off.
• Practical workflow: Monthly visits align with Schedule II refill requirements anyway, so the 30-day limit isn’t a major barrier. Just ensure your collaborative agreement explicitly covers stimulants and narcolepsy management.

Quick Reference Table: PMHNP Narcolepsy Prescribing Authority by State

Key insight for PMHNPs: If you’re practicing in a restricted state, joining a platform that facilitates physician collaboration is essential. In Texas or Florida, you can absolutely manage narcolepsy patients — but you’ll need an MD partnership for certain prescriptions. In New York, Illinois, or California (once experienced), you’re on equal footing with psychiatrists.

Clinical Workflow: Managing Narcolepsy Meds Via Telehealth

Whether you’re an MD or NP, effective narcolepsy medication management follows a consistent pattern:

Initial Visit (30-45 minutes):

• Verify diagnosis: Request sleep study reports (polysomnography + MSLT showing sleep-onset REM or low hypocretin). Most narcolepsy patients have already been diagnosed by a sleep specialist.
• Assess symptoms: Epworth Sleepiness Scale, frequency of sleep attacks, cataplexy episodes (if Type 1), functional impairment (work, driving, relationships).
• Medical clearance: Screen for cardiovascular issues (stimulants can raise BP/HR), psychiatric comorbidities (depression/anxiety are common), substance use history.
• Set expectations: Explain the treatment plan (likely starting with modafinil or low-dose stimulant), need for monthly follow-ups, importance of sleep hygiene.

Follow-Up Visits (15-20 minutes, monthly):

• Symptom tracking: ‘How many unintended sleep episodes this month? Any cataplexy? How’s your alertness during the day?’
• Side effects: Monitor weight, blood pressure (patient can use home cuff), mood, appetite, sleep at night (stimulants can paradoxically worsen nighttime insomnia if dosed wrong).
• Dose optimization: Narcolepsy often requires titration. Starting dose might be modafinil 200mg or Adderall 10mg; many patients need higher doses (modafinil 400mg, or Adderall 30-60mg daily split into doses).
• Refill prescription: Since Schedule II can’t have refills, each visit generates a new 30-day script.
• PDMP review: Check for any other controlled prescriptions (detecting ‘doctor shopping’ or concerning patterns).

Billing & Reimbursement:

• E/M Codes: 99213 (established, straightforward) or 99214 (moderate complexity). Medicare allowables: ~$93 for 99213, ~$131 for 99214 (2024 rates).
• Telehealth parity: Most states mandate equal reimbursement for telehealth vs. in-person. Insurers must pay the same rates (applies in CA, NY, IL, PA, and others).
• NP reimbursement: Medicare pays NPs at 85% of physician fee schedule. Private insurers vary — some pay equally, others follow Medicare’s lead. Many insurers have historically underpaid mental health providers (~22% less than other specialties), which is why some psychiatrists opt out of insurance panels.

Prior Authorizations (The Administrative Burden):

Here’s a reality check: Narcolepsy medications often require prior auth. Newer agents like Sunosi, Wakix, and Xyrem/Xywav almost always do. Even modafinil and stimulants can trigger insurance reviews.

You’ll spend 30-60 minutes per patient gathering documentation (sleep study results, chart notes, proof of diagnosis) and submitting PA paperwork. Some platforms provide staff support for this — a huge time-saver. If you’re going solo, factor this unpaid time into your patient volume calculations.

The Adderall shortage (ongoing since 2022) has made things worse. Pharmacies frequently can’t fill stimulant prescriptions, forcing providers to switch medications mid-treatment or help patients find alternative pharmacies. Telehealth’s advantage: you can quickly e-prescribe to different pharmacies across the patient’s state without requiring them to drive around town.

The Economics: Why Narcolepsy Medication Management Makes Sense for Your Practice

Let’s talk numbers. Managing narcolepsy patients via telehealth can be financially attractive:

Patient Volume & Revenue:

• Recurring visits: Narcolepsy is a chronic condition requiring monthly med checks (dictated by Schedule II refill rules). Each patient generates 12+ visits per year.
• Per-visit reimbursement: $90-130 per visit (depending on code and payer). Annual revenue per patient: ~$1,200-1,500 from insurance, or $600-1,200 if doing cash-pay with a subscription model ($50-100/visit).
• Efficiency: 15-minute telehealth visits (vs. 30+ minutes with in-person overhead) mean you can see 3-4 patients per hour. If you dedicate 10 hours/week to narcolepsy care, that’s 30-40 patient visits — potentially $3,000-5,000 in weekly revenue.

Patient Acquisition: The Platform Advantage

Here’s where traditional DIY marketing becomes a money pit. Acquiring psychiatric patients through Google Ads, SEO, or directories like Psychology Today typically costs $200-500+ per booked patient when you factor in:

• Google Ads: Mental health keywords cost $15-40 per click. Conversion rates are low (most clicks don’t book). Realistic cost per booked patient: $300-400+.
• SEO: Takes 6-12 months of consistent investment ($2,000-5,000/month for agencies or consultant fees + content production) before generating meaningful patient flow. Most solo providers don’t have this expertise or patience.
• Directory listings: Psychology Today charges $30/month per location (adds up for multi-state licenses). Zocdoc charges per booking ($35-100+) but you compete with hundreds of other providers on the same page.
• All-in cost: If you’re running your own marketing, you’re easily spending $3,000-5,000/month with uncertain results — and you’re paying whether or not patients show up.

The Klarity Health model removes this risk. Instead of gambling on marketing channels, you pay a standard per-appointment fee only when a qualified patient books with you. The value proposition:

• No upfront marketing spend — zero monthly subscription fees or ad budgets
• Pre-qualified patients already matched to your specialty (narcolepsy/sleep disorders) and availability
• No wasted spend on clicks that don’t convert
• Built-in telehealth infrastructure (no separate platform costs or IT headaches)
• Both insurance and cash-pay patient flow (we handle credentialing and billing support)
• You control your schedule — see as many or as few patients as you want

For most providers — especially those starting out or scaling — this is guaranteed ROI vs. the uncertainty of DIY marketing. The psychiatrist shortage (projected 31,000 deficit by 2024) means narcolepsy patients are desperate for providers. Platforms that handle patient acquisition eliminate your risk entirely.

State Licensing: The Multi-State Reality

One non-negotiable: You must be licensed in every state where your patients physically reside during the telehealth visit. This applies to both MDs and NPs.

Licensure Options:

Interstate Medical Licensure Compact (IMLC): Available for physicians (MD/DO). Streamlines applications across 40+ member states (including CA, TX, FL, NY, PA, IL). You apply through your home state and pay fees (~$700 per additional state), which accelerates the process.

Nurse Licensure Compact (NLC): Covers RN/LPN licenses across 40+ states, but does not include NP prescriptive authority. PMHNPs still need individual APRN licenses in each state where they practice.

Practical strategy: Start with 2-3 high-demand states where your scope is favorable. For example, if you’re a PMHNP, prioritize New York or Illinois (independent practice after experience) over Texas (restricted). For psychiatrists, Texas and Florida represent huge underserved markets despite their quirks.

Cost reality: Multi-state licensing isn’t cheap. Budget $1,500-3,000 per additional state (application fees, background checks, processing). But if each state yields 10-20 narcolepsy patients at $1,200/year revenue, the ROI is there within months.

What’s Next: Preparing for Regulatory Changes Post-2025

The DEA’s telehealth waivers expire December 31, 2025 unless extended again. Proposed rules include:

• Special telemedicine DEA registration for providers practicing across state lines
• Possible in-person exam requirement within 30 days of initiating Schedule II prescriptions remotely
• Stricter PDMP monitoring and state reporting

How to prepare:

1. Stay informed: Join professional associations (APA, AANP) that track regulatory changes.
2. Build in-person partnerships: If new rules require periodic in-person visits, establish relationships with local physicians or clinics in key states who can handle one-off evaluations.
3. Document everything: The better your clinical documentation, the easier it is to defend your practice if regulations tighten.
4. Choose platforms wisely: Work with telehealth companies that have legal and compliance teams monitoring these changes (like Klarity Health).

The Bottom Line: Should You Add Narcolepsy to Your Telehealth Practice?

If you’re a psychiatrist: Absolutely. You have full prescribing authority, federal waivers currently allow Schedule II prescribing via telehealth, and narcolepsy patients represent stable, recurring revenue. The clinical work is straightforward (focused med management), and you’re filling a critical gap in an underserved population.

If you’re a PMHNP: It depends on your state and experience level. In New York, Illinois, or California (once independent), you can manage narcolepsy just like a psychiatrist. In Texas, Florida, or Pennsylvania, you’ll need physician collaboration — but that’s still workable with the right platform infrastructure. Focus on states that align with your scope.

Regardless of credentials: Narcolepsy medication management via telehealth is clinically rewarding (you’re dramatically improving patients’ functionality), financially viable (recurring visits with decent reimbursement), and increasingly in demand as patients discover virtual care options. The regulatory landscape is complex but navigable with proper preparation.

Joining a platform like Klarity Health removes the biggest barriers — patient acquisition, compliance infrastructure, multi-state support, and billing/PA assistance — so you can focus on what you do best: prescribing the right meds and optimizing outcomes.

Frequently Asked Questions

Can psychiatrists prescribe Adderall for narcolepsy via telehealth?

Yes, under current federal rules (extended through December 2025). Psychiatrists (MD/DO) can prescribe Schedule II stimulants like Adderall remotely without an initial in-person visit, provided they’re licensed in the patient’s state, use video (not audio-only), check the PDMP, and document appropriately. Some states (like Florida) impose additional restrictions — verify your specific state rules.

Can PMHNPs prescribe narcolepsy medications independently?

It depends on the state. In New York (after 3,600 hours experience), Illinois (with Full Practice Authority), and California (as a ‘104 NP’ starting 2026), yes — PMHNPs can prescribe narcolepsy meds including Schedule II stimulants independently. In Texas, Florida, and Pennsylvania, PMHNPs need physician collaboration, and Texas specifically prohibits NP Schedule II prescribing for outpatients (meaning you can’t prescribe Adderall; modafinil is allowed).

What happens to telehealth prescribing after December 2025?

The DEA’s extension of COVID-era flexibilities ends December 31, 2025. The agency has proposed permanent telemedicine rules but hasn’t finalized them. Possible outcomes: (1) another extension, (2) new rules requiring special DEA registration or periodic in-person visits, or (3) reversion to pre-COVID restrictions (in-person exam required before Schedule II). Providers should monitor DEA announcements and prepare for potential compliance changes.

How much can I earn managing narcolepsy patients via telehealth?

A narcolepsy patient requires monthly visits (due to Schedule II refill rules). Typical reimbursement: $90-130 per visit (E/M codes 99213-99214), or $50-100 for cash-pay models. Annual revenue per patient: $1,200-1,500. If you see 20 narcolepsy patients regularly, that’s $24,000-30,000/year in recurring revenue from this patient population alone.

Do I need malpractice insurance that covers telehealth prescribing?

Yes. Ensure your malpractice policy explicitly covers telemedicine and controlled substance prescribing. Most carriers now include telehealth, but verify there are no exclusions for Schedule II drugs or multi-state practice. Following evidence-based guidelines (confirming diagnosis, PDMP checks, proper documentation) protects you from liability claims.

What’s the difference between narcolepsy and ADHD prescribing for providers?

Both conditions use similar stimulant medications (amphetamines, methylphenidate), but there are key differences:

• Diagnosis: Narcolepsy requires objective sleep study confirmation (MSLT). ADHD is a clinical diagnosis.
• Prescribing patterns: Narcolepsy patients often need higher stimulant doses and may use additional medications (modafinil, sodium oxybate).
• Insurance: Narcolepsy meds frequently require prior authorization with sleep study documentation. ADHD meds often have fewer PA barriers.
• Scope concerns: Some states (like Florida) distinguish ‘psychiatric medications’ (which psychiatric NPs can prescribe more freely) from neurological conditions like narcolepsy. Verify your scope if you’re an NP.

Can I manage narcolepsy patients who don’t have a formal sleep study?

Standard of care requires objective confirmation (polysomnography + MSLT showing short sleep latency and REM abnormalities). Without this, you risk misdiagnosis and inappropriate stimulant prescribing. If a patient hasn’t had testing, refer them to a sleep specialist for workup first. Once diagnosed, you can manage medications via telehealth.

Are there any states where telehealth narcolepsy prescribing is completely banned?

No state bans it outright, but Florida comes closest for Schedule II stimulants (due to its telehealth controlled-substance restrictions). Most providers in Florida use Schedule IV alternatives (modafinil/armodafinil) or ensure at least one in-person visit. All other states allow telehealth narcolepsy prescribing under federal waivers, though scope of practice (especially for NPs) varies.

Ready to Start Managing Narcolepsy Patients Via Telehealth?

Narcolepsy patients are searching for providers right now — many have waited months for appointments with sleep specialists and are desperate for medication management they can access from home.

Klarity Health connects you with these patients without the marketing gamble. Our platform provides:

✅ Pre-qualified narcolepsy patients matched to your availability
✅ Built-in EPCS e-prescribing and PDMP integrations
✅ Multi-state licensing and compliance support
✅ PA assistance (we help with prior auth paperwork)
✅ Flexible scheduling — you control how many patients you see
✅ Pay-per-appointment model (no upfront costs or monthly fees)

Join psychiatrists and PMHNPs already treating narcolepsy via Klarity. Get started in minutes — no marketing budget required.

[Apply to Join Klarity’s Provider Network →]

Citations & Sources

1. Axios – ‘COVID-era telehealth prescribing extended again for Adderall and other controlled substances’ (November 18, 2024). Reports DEA extension of telehealth flexibilities through December 2025. www.axios.com

2. Texas Medical Board – ‘Who Can Prescribe Schedule II Drugs Under Physician Delegation?’ Official FAQ confirming NP/PA Schedule II prescribing limited to hospital/hospice settings in Texas. www.tmb.state.tx.us

3. California Board of Registered Nursing – AB 890 Implementation (Nurse Practitioner Practice). Details new 103/104 NP categories and timeline for independent practice starting 2026. www.rn.ca.gov

4. Florida Senate – Florida Statutes §464.012 (Nurse Practice Act, 2021 version). Primary law text showing 7-day Schedule II limit for APRNs and psychiatric nurse exception. www.flsenate.gov

5. National Law Review – ‘New Florida Law Allows Telemedicine Prescribing of Certain Controlled Substances’ (April 7, 2022). Legal analysis of Florida SB 312 telehealth controlled-substance rules. natlawreview.com

Source:

• https://www.axios.com/2024/11/18/covid-telehealth-prescribing-extended-adderall#:~:text=The%20Drug%20Enforcement%20Administration%20and,person%20doctor%27s%20visit%20for%20the
• https://natlawreview.com/article/new-florida-law-allows-telemedicine-prescribing-controlled-substances#:~:text=controlled%20substances%20via%20telemedicine%2C%20with,more%20on
• https://www.ilga.gov/legislation/ILCS/details?ActID=1312&ActName=Nurse+Practice+Act.&ChapAct=225+ILCS+65%2F&Chapter=&ChapterID=24&MajorTopic=&Print=True&SeqEnd=17850000&SeqStart=16500000#:~:text=,drugs%2C%20such%20as
• https://www.ilga.gov/legislation/ILCS/details?ActID=1312&ActName=Nurse+Practice+Act.&ChapAct=225+ILCS+65%2F&Chapter=&ChapterID=24&MajorTopic=&Print=True&SeqEnd=17850000&SeqStart=16500000#:~:text=,require%20a%20physician%20name%3B
• https://www.rivkinrounds.com/2022/04/new-law-allows-experienced-nps-to-practice-independently-in-ny/#:~:text=New%20York%E2%80%99s%202023%20state%20budget%2C,practice%20without%20a%20collaborative%20relationship
• https://www.rn.ca.gov/practice/ab890.shtml#:~:text=%2A%20103%20NP%20,focus%20of%20their%20National%20Certification
• https://www.rn.ca.gov/practice/ab890.shtml#:~:text=Please%20note%2C%20the%20law%20requires,certify%20104%20NPs%20until%202026
• https://www.tmb.state.tx.us/274-who-can-prescribe-schedule-ii-drugs-under-physician-delegation#:~:text=1.%20in%20a%20hospital%20facility,has%20elected%20to%20receive%20hospice
• https://www.flsenate.gov/Laws/Statutes/2021/Chapter464/All#:~:text=match%20at%20L1566%20limit%20the,455
• https://www.pacodeandbulletin.gov/Display/pacode?file=%2Fsecure%2Fpacode%2Fdata%2F049%2Fchapter21%2Fs21.284.html#:~:text=,may%20not%20delegate%20prescriptive%20authority