The Arizona State Board of Nursing publishes its sedation guidance as an advisory opinion of its “SCOPE OF PRACTICE COMMITTEE” (p. 1). It covers moderate, deep and palliative sedation in one text, drawing a different line for each.
Arizona at a glance
| Board | Arizona State Board of Nursing |
| Document | Advisory Opinion, “SEDATION: DEEP, MODERATE, AND PALLIATIVE” (p. 1) — 10-page PDF. |
| Rule it is | None — an advisory opinion, not a numbered rule; its operative text rests on no numbered Board rule or statute section. The one Arizona authority it cites is a reference-list entry: “Arizona revised statute § 32-1634.03: Qualifications for certified registered nurse anesthetist” (p. 6). |
| Status | Advisory opinion of the Board’s Scope of Practice Committee (p. 1); it does not describe its own legal force. Of itself it says it “is NOT intended to delineate what medications can or cannot be given but rather to focus the nurse on providing safe care at the desired level of sedation” (p. 4). Most of its requirements are written in “must”, but the eleven policy items are not uniform: alongside “must” come bare noun phrases, “will be maintained”, “is required”, “can administer” and, in item 4’s parenthetical about reversal agents, “should” (p. 2). |
| Dates | “DATE APPROVED: 1/07” · “REVISED DATE: 03/10; 9/13, 5/20, 7/21 9/23” (p. 1); most recent revision 9/23. |
| Who it covers | RNs — the grant to “administer medications to clinical response” runs “when general requirements are met for the purpose(s) of” (p. 1) three named purposes: deep sedation “in acute care settings” where the patient is intubated or mechanically ventilated, or where the RN is “assisting with RSI”; “Moderate sedation for diagnostic or therapeutic procedures when a qualified Licensed Practitioner(LP) is present at the bedside”; and “Palliative (end of life) care” (p. 1) — the bedside LP being part of that grant itself. |
| Who it does not cover | LPNs — moderate, deep and palliative sedation and RSI are “NOT within the LPN scope of practice” (p. 1), the LPN being limited to minimal sedation (anxiolysis). Two of the opinion’s limits are written for “a registered nurse (RN) who is not a certified registered nurse anesthetist (CRNA)” (p. 1): deep sedation for non-ventilated patients, and medications given to a general anesthesia level. The moderate-sedation requirements (p. 3) carry no such exemption — their subject is “The RN” (p. 3). Local anesthetic agents not injected into the vascular system “are not included in this advisory” (p. 2). |
| Settings the document names | One: “acute care settings” (p. 1), and only in the deep-sedation situations. For moderate sedation it names no setting type, addressing the “employer/facility” (p. 2) instead. |
| Re-verification interval | Not stated — no renewal or re-verification period for sedation competency, and none attached to the age-appropriate advanced life support documentation it requires for moderate to deep sedation (p. 2). |
| Where the record lives | “Written policies and procedures are developed and maintained by the employer/facility” (p. 2). Where an individual nurse’s instructional-program, supervised-practice or competency record is kept: not stated. |
| CE hours | Not stated — no contact-hour count appears. It specifies content instead: nine subjects the “instructional program includes, but not limited to” (p. 4). |
What the Arizona State Board of Nursing says
Part I opens with eleven things the employer’s written sedation policies “must include, but are not limited to” (p. 2) — who may prescribe, the levels RNs may assist with, approved medications and reversal agents, titration parameters, emergency equipment, monitoring and documentation requirements, venous access, life-support documentation, and the education item quoted below.
For moderate sedation, the policy identifies which medications and routes the RN may use, and six further conditions follow (p. 3). The LP who orders the medication and performs the procedure must be credentialed for it and “must be at the bedside from the time the medication is initiated through the completion of the procedure”; afterwards an LP capable of managing complications “must be immediately available in the facility” until the patient is “medically discharged from the post-procedure area” (p. 3) — “Immediately available” being “present in the facility and not otherwise engaged in any other uninterruptible procedure or task” (p. 4). On capnography the opinion softens: “Documentation of adequate ventilation using continuous capnography is strongly recommended” (p. 3) — recommended, not required.
The education requirement is one sentence:
“Only RNs who have completed an instructional program and have had supervised clinical practice can administer and manage deep, moderate, and palliative sedation.”
Arizona State Board of Nursing — Advisory Opinion, Sedation: Deep, Moderate, and Palliative (p. 2)
The “COURSE OF INSTRUCTION” part adds a second test: “Only RNs who have the knowledge and have demonstrated competency may administer deep, moderate, or palliative sedation” (pp. 3–4). Nine subjects follow (p. 4): respiratory anatomy and physiology; the physiology of each sedation level; indications, contraindications and over- or under-sedation; legal implications, responsibility and documentation; pharmacology of sedatives, reversal agents and anesthesia; interventions for complications; patient assessment; monitoring devices and sedation scales; and content specific to the sedation type.
Two further lines bear on the RN: those who administer moderate sedation “must be qualified to provide rescue support to patients who proceed to a deeper level of sedation” (p. 1), and the RN’s own obligation to assure patient safety “supersedes any LP order or facility policy” (p. 4).
What an Arizona facility should be able to show
Read as an audit list, the opinion asks for three things:
- Written sedation policies and procedures covering the eleven general items (p. 2) and, for moderate sedation, the seven level-specific ones (p. 3) — agents and routes, the LP at the bedside, an LP immediately available afterwards, the monitoring RN’s freedom from duties that would interfere with monitoring, the pre-sedation assessment and plan, supplemental oxygen, and monitoring documentation.
- Per-nurse evidence of the instructional program and supervised clinical practice for every RN who administers or monitors moderate sedation, covering those of the p. 4 subjects that bear on it — the ninth adds mechanical-ventilation instruction only “If providing deep sedation” (p. 4).
- Per-nurse evidence of knowledge and demonstrated competency in moderate sedation — the second test the opinion applies on top of course completion (pp. 3–4). It names no interval, so the interval is your policy’s.
The CSRN™ course — 10 CE contact hours developed and delivered by Capt. M. Ron Eslinger, CRNA, with module exams, case studies and a certificate ID your credentialing office can verify — is built to be records 2 and 3 on that list. Facility seats and roster tracking →
Questions Arizona facilities ask
Does Arizona require ACLS for moderate sedation, and how often?
The opinion requires the facility’s written policies to include “Documentation of age appropriate advanced life support (ACLS, NRP, PALS) is required for moderate to deep sedation” (p. 2) — age-appropriate, so which of the three depends on your patients. On frequency it says nothing: it sets no renewal period, review cycle or expiry for any of the records it asks for.
Does the opinion require the CSRN™ course specifically?
No — it requires no particular course, and no state mandates this specific one. What it requires is “an instructional program” plus “supervised clinical practice” (p. 2), then “knowledge” and “demonstrated competency” (pp. 3–4), with a nine-subject syllabus (p. 4) and no named provider, hour count or approval body. CSRN™ is designed to be that evidence for moderate sedation.
Can the RN monitoring moderate sedation do anything else during the procedure?
No duty that would interfere with monitoring — the qualifier is the Board’s own: “The RN administering medications and monitoring the patient receiving moderate sedation will have NO other duties that would interfere with primary responsibility of monitoring the patient during the procedure, must remain at bedside during procedure” (p. 3). The same sentence names two jobs for that nurse — administering the medications and monitoring the patient — and a few lines down the opinion adds recording physiologic measurements “per facility guidelines during the procedure and throughout the recovery period” (p. 3). What it rules out is competing duties, not the work of the sedation itself.
Compliance note (last reviewed September 2026): This page is educational information about the Arizona State Board of Nursing advisory opinion Sedation: Deep, Moderate, and Palliative, not legal advice or a compliance determination. Every quotation was checked word-for-word against the banked text extract of the Board’s 10-page PDF on 2026-09-01; page numbers refer to that PDF. A 2026-09-02 check found the same document, revised 2023, still listed on the Board’s advisory-opinion index and the linked PDF ten pages long; its text was not re-extracted, so the live file’s wording was not read again. Board typographical errors are reproduced as printed. Confirm the current revision and your own facility policy before relying on this summary. No state mandates this specific course.