HMNT Position Statement

Situation: The United States continues to experience an opioid crisis marked by high rates of addiction and overdose fatalities. Making reversal agents, such as Naloxone, available to the public has been shown to reduce overdose deaths. Many healthcare professionals, including nurses and individuals without professional licensure, play a key role in this effort by providing community education, training, and access to life‑saving reversal agents offered by local and state programs.

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Background: Education, training, and distribution of reversal agents have been focused on the general public and those individuals most likely to witness an overdose, such as relatives or friends. However, recent shifts in law and policy have broadened access to Naloxone making it available over the counter. While many licensed nurses and community healthcare promoters participate in these programs, training materials often do not address the specific obligations of licensed professionals.

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Assessment: The State Board of Nursing (TBON) mandates that licensed nurses adhere to the Nurse Practice Act while participating in community-based efforts to address the opioid crisis. When presenting oneself as a nurse in a professional capacity, they must have a provider’s order to administer prescription medications, and they remain responsible for documenting any interventions or care given. This includes conducting assessments, planning care, performing interventions, and documenting outcomes for individuals under their professional responsibility. However, since Naloxone is now over the counter, off-duty individuals, including nurses acting as private citizens, can legally obtain and administer reversal agents without a provider’s order, as allowed by Texas law without concern of being subject to criminal prosecution, sanction under any professional licensing statute, or civil liability.

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The Faith Community Nurse (FCN) is not acting as a private citizen when in the role of serving their faith community. As a volunteer, or paid position, when representing oneself as an RN, the nurse must follow TBON rules and guidelines.

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Recommendation: Both licensed and unlicensed individuals should follow safe practices when supporting overdose prevention efforts in the community. Considering Naloxone’s new over-the-counter status, it is important to clarify how these changes affect nurses on duty, who must observe professional licensure requirements, as well as unlicensed community members. Accordingly, HMNT offers this updated position statement to address key issues not covered in existing community education on reversal agents.

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Position Statement: It is the position of the Health Ministry Network of Texas (HMNT) to support community programs aimed at administering and distributing opioid reversal agents. To provide safe care for Texans, HMNT reminds nurses to adhere to their licensure requirements and scope of practice when they are on duty, which includes obtaining a provider’s order for prescription medications. Off-duty administration of Naloxone does not require a provider’s order under current Texas law. HMNT encourages all community members, whether licensed or not, to use Naloxone responsibly and to seek out appropriate training on recognizing and responding to opioid overdoses. The State of Texas provides medical orders, competency and training for free on their website at Texas.gov