Can a Registered Nurse Provide Psychotherepy Without Supervision or a Referral from a Practitioner Licensed to Prescribe Such Services ?
In Morwald v. Workmen's Compensation Appeal Board (Engineering & Refrigeration, Inc.), 143 Pa. Commw. 511, 599 A.2d 307 (Pa. Cmwlth. 1991), the Court determined that the employer was not required to pay for psychotherapy provided by a registered nurse without supervision or a referral from a practitioner licensed to prescribe such services.
The Court explained that even though the nurse may have been qualified by virtue of her nursing license to provide psychotherapy, psychotherapy was not essential to the nursing regimen and the nurse was not licensed to prescribe psychotherapy.
Therefore, she could not provide psychotherapy without supervision or referral by a practitioner licensed to prescribe such services. Morwald, 599 A.2d at 308-309.