Blog #1 Reflection on Regulatory Agencies and Advisory Opinions


Advisory Opinion looks into a specific practice to determine if it is within the scope of practice of nursing or not. It analyzes a specific nursing practice question and may or may not give recommendations. The value attached to an advisory opinion differs from one state board of nursing to another. According to the Arizona State Board of Nursing, for instance, they describe advisory opinion as an “interpretation by the Board of what the law requires” and they see it as “more than a recommendation”. On the other hand, the Department of Human Services Nebraska considers their advisory opinion as “informational only and are nonbinding”. Therefore, it is important that registered nurses practicing in a jurisdiction are aware of their advisory opinion and the rules or restriction surrounding them. Another example of an advisory opinion is the administration of ketamine which will be compared between Arizona and South Carolina. In Arizona, registered nurses without CRNA (Certified Registered Nurse Anesthetist) cannot administer ketamine IV, or Intranasal bolus for the purpose of anesthesia or analgesia but can administer low dose ketamine for pain control, depression and sedation in line with their advisory opinion. For South Carolina, registered nurses can also administer low-dose ketamine but for specific diagnosis listed and not for sedation.

Arizona and South Carolina have some similarities in their advisory opinion regarding Ketamine administration which includes:

  • Registered nurses in both states can administer low-dose ketamine following monitoring precautions.
  • There must be frequent monitoring of patients such as frequent vital signs and the use of a sedation assessment scale.
  • Both states are mentioned that registered nurses can administer minimally low-dose ketamine.
  • Both states also mentioned that Ketamine is a controlled substance and therefore should be handled with precautions.
  • Both states’ advisory opinions are not intended for anesthesia.

Some of the differences between the two states regarding ketamine administration include:

  • In Arizona, health care professionals should have PALS and ACLS. This professional must be present from initiation till the end of the administration. Also, it is not within the scope of practice for non-CRNA registered nurses to administer ketamine bolus via IV or intranasal for analgesia or anesthesia. In South Carolina, it is within the scope of practice of a registered nurse to administer Ketamine IV push or continuous infusion for acute pain management and a list of other diagnoses. Other requirements include a physician order.
  • Although South Carolina has established some precautions, they allow facilities to make some decisions. Such as deciding the education and competencies required for the nurses designated by the facility to perform this role. On the other hand, Arizona seems to be more specific in stating what they want and defining the limits for their nurses.
  • In Arizona, standing orders or protocols are not used to adjust the infusion rate for low dose ketamine while in South Carolina, there can be an adjustment in line with the facility protocol but must be done under a physician’s supervision.

When advisory opinions are made, it requires competency on the part of the nurse for any nursing action performed. For example, if an advisory opinion states that registered nurses can administer naloxone in life-threatening opioid cases without an order. Even if it is not binding, it will still be the nurse’s responsibility to act competently and still be accountable for actions taken. The role of the regulatory agency focuses on making sure that the advisory opinions that are put out are adopted in line with the standard of practice. They also ensure that nurses are held accountable for their actions in the course of nursing practice.


Advisory Opinion Ketamine Administration. Arizona State Board of Nursing. (2020.).

Nursing Advisory Opinions. Department of Health and Human Services, Nebraska. (n.d.).

Joint Advisory Opinion Issued by the South Carolina State Boards of Medical Examiners, Nursing and Pharmacy Regarding the Administration of Low Dose Ketamine Infusions in Hospital Settings, including Acute-Care, by Nurses. South Carolina-labor Licensing Regulation. (n.d.).




Author: florence

I am in the RN to BS program through the SVCC-VCU co-enrollment program. I am excited as I am learning a lot about the Nursing Profession

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