What Florida Healthcare Professionals Should Know About Substance Abuse, Impairment, IPN/PRN — and Your License

Medial Professional Drinking Beer Behind the Steering Wheel of a vehicle.

What are IPN and PRN?

IPN (Intervention Project for Nurses) is the designated Impaired Practitioner Program for Florida-licensed nurses. As such, it is the primary consultant for the Florida Department of Health (DOH) regarding any allegations of impairment concerning a nurse, and it determines whether that nurse needs to enter a treatment program and/or monitoring contract per an evaluator’s assessment.

PRN (Professionals Resource Network) is similar to IPN, but it provides evaluation, treatment, and monitoring to impaired medical practitioners who are not nurses (physicians, dentists, osteopathic specialists, dieticians, optometrists, etc.) on behalf of the DOH.

For some nurses and medical practitioners, entering into IPN/PRN is mandatory; for example, as required by an order of the practitioner’s respective board (i.e., Board of Nursing, Board of Medicine, Board of Pharmacy, Board of Dentistry). For others, IPN/PRN is suggested by an employer as a way to avoid disciplinary action, such as license suspension or revocation.

Either way, IPN and PRN require serious commitment, out-of-pocket expenses, and total compliance. Failure to comply will result in a disciplinary action against the practitioner’s license.

Why Did My Employer Refer Me to IPN or PRN?

Nurses and medical practitioners are most often referred to IPN and PRN, respectively, by employers due to potential safety-to-practice concerns. These concerns can stem from matters involving substance abuse or other psychiatric or physical conditions that could put public safety at risk. Employers will often refer healthcare providers to IPN or PRN if drug diversion is suspected, or if the provider’s results from a pre-employment or employer-ordered drug screen come back positive.

Who Determines Whether I Am Ultimately Enrolled in IPN or PRN?

An IPN/PRN-approved evaluator is assigned to conduct a mental health evaluation to assess whether you have a mental, physical, or substance abuse disorder that may pose a danger to your ability to practice with reasonable skill and safety. The evaluator is the one who recommends whether you should be in IPN/PRN.

The evaluator will ask questions about your medical history, your family’s medical history, your history with drugs/alcohol, whether you have been in substance abuse treatment programs before, and the likes. Your responses will assist the evaluator in determining whether you can be diagnosed with a potentially impairing condition, or, if absent true diagnosis, whether you should still be referred to IPN/PRN for diagnostic purposes.

(As an Example,) I Was Slightly Intoxicated When I Showed Up at Work on the Day in Question. This Was an Isolated Incident, and I Don’t Actually Have a Drinking Problem, But the Evaluator Still Determined I Should Be in IPN/PRN. Why?

IPN and PRN evaluators are medical practitioners themselves, and they serve as not just agents of IPN/PRN and the DOH, but also as those of individual practitioners. For this reason, they need to use independent medical judgment. However, when it comes to deciding IPN/PRN referral, evaluators do not need to assess the existence of an actual diagnosis; rather, they simply need to assess risk. In your case, your evaluator saw the potential for risk given his/her professional medical background as well as IPN/PRN and DOH standards.

What Are the Advantages of Pre-Emptively Enrolling in IPN or PRN?

IPN and PRN are voluntary intervention alternatives to the disciplinary process administered by the DOH, the Department of Business and Professional Regulation (DBPR), and your respective professional board (such as the Florida Board of Medicine). If a practitioner enrolls in IPN/PRN, the DOH will not initiate a disciplinary action so long as the practitioner remains compliant with IPN/PRN until IPN/PRN formally releases them. Depending on your particular circumstances, IPN/PRN might be the only way to maintain a license to practice.

Sara Bazzigaluppi, one of Chapman Law Group’s Florida-based regulatory and licensing healthcare defense attorneys, discusses IPN and PRN with Chapman Law Group founder Ronald W. Chapman Sr.

What are the Disadvantages of Enrolling in IPN or PRN?

The typical outcome for IPN/PRN enrollment is being put under, and complying with, a monitoring contract. These contracts can be for 2-5 years, and you will be under strict orders to comply.

You will have to pay out-of-pocket for all costs involved in monitoring, such as random urine toxicology screenings, ongoing psychotherapy, and fees for the facilitator of the group you attend as a requirement of your contract. Participants report that they spend up to $30,000 of their own money through the course of a three-year monitoring agreement.

If you are in the IPN/PRN program but leave because you can no longer afford it, you will be reported to the DOH as “non-compliant.” This can lead to formal action against your license. Also, leaving IPN/PRN or failure to follow recommendations of an evaluator is a violation of your respective board’s Practice Act. This means that if you reject IPN/PRN after initiating the process, you could be investigated for multiple counts of violating the Practice Act, as opposed to fewer violations if you had instead chosen to fight the accusations at the outset.

What If I Refuse to Enroll in IPN or PRN?

If you refuse to enroll, IPN or PRN will refer you to the DOH along with all of your files, including your evaluation, which serve as evidence that the DOH will use against you during prosecution before your respective practice board.

How Long Can a DOH Investigation into My Case Take?

At the start of every disciplinary case, the DOH will initiate an investigation into the allegations to collect evidence. Investigations can take anywhere between 6 months to 2 years. The length of the investigation depends on the complexity of the case and other factors.

Can I Still Practice During a DOH investigation?

Generally, because an investigation is not considered a formal charge, and because being under investigation is a “confidential” process, the practitioner under investigation should still be able to practice or to look for work. A sure way to verify whether you can practice is by looking up your license online. Does it read “CLEAR AND ACTIVE?” If so, you can technically practice.

However, if the DOH can prove to the State Surgeon General that you are “an immediate threat of serious harm to the public,” you may be placed on an emergency suspension order, thus prohibited from practicing until the disciplinary case is resolved. 

If I Don’t Enroll in IPN/PRN, Am I Immediately Suspended?

No. Suspension is a determination for your board (i.e., Florida Board of Nursing, Board of Medicine), not IPN/PRN, to make. However, be careful of what IPN/PRN makes you sign.

Sometimes, IPN/PRN will make you sign a “voluntary withdrawal” form, which is then provided to DOH. If the voluntary withdrawal is implemented, then you cannot practice because you would not have an active license.

Please note, IPN/PRN can recommend you do not practice even if your license is “CLEAR AND ACTIVE.” All this means is that if you practice against IPN/PRN recommendations, they will deem you non-compliant and report you to the DOH. 

Who Imposes Penalties for Disciplinary Cases?

While the DOH serves as the investigator and prosecutor for the (alleged) Practice Act violations, the board for your respective practice chooses the penalty to impose.

Why Should I Call a Florida Health Care Attorney at Chapman Law Group Before I Contact IPN or PRN?

Because the Florida healthcare licensing attorneys at Chapman Law Group have decades of experience in helping nurses and medical practitioners avoid IPN/PRN enrollment and formal licensing action.

Our Florida health lawyers are experienced in helping nurses, nurse practitioners, physicians, and other Florida healthcare providers resolve allegations of drug diversion, positive drug screens, DUIs, and other impairment matters.

We use three factors when helping nurses and medical practitioners decide whether IPN/PRN is a good option for avoiding licensing action:

    1. Do you have an alcohol or drug addiction?
    2. Is this your first offense?
    3. Are you able to prove to the relevant board that:
      • this was an isolated situation;
      • you are safe to practice;
      • you would not benefit from a period of monitoring; and
      • you do not need active supervision?

The Florida healthcare attorneys at Chapman Law Group is prepared to work through these critical steps with you and, if possible, prove to the relevant board that you are capable of continuing without an intervention.

If IPN/PRN is your only option, a Florida healthcare attorney from Chapman Law Group can help negotiate a favorable agreement that is less restrictive and less expensive than standard IPN/PRN agreements. We also may be able to help you find a private treatment that is less expensive and still is sufficient to help you maintain your license.

We strongly advise you to not reach out to IPN/PRN without first discussing your options with our Florida medical licensing lawyers. A Florida health care attorney from Chapman Law Group can prepare your defense and negotiate options before licensing action commences and enrollment in IPN/PRN becomes mandatory.

Our Florida professional health care licensing defense lawyers work with physicians, nurses, pain management clinics, pharmacists and other licensed healthcare professionals. 

Our Florida offices are in Miami and Sarasota, Florida. We serve all of Florida, from Jacksonville and Tampa, to Gainesville and Orlando; and from West Palm Beach and Fort Lauderdale, to Cape Coral and Tallahassee.

Contact us today and let us put our know-how to work for you.

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Sara A. Bazzigaluppi


Professional Licensing & Regulatory Affairs,

Civil Litigation

Sarasota Office
6841 Energy Court
Sarasota, FL 34240
Phone: (941) 893-3449

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