Washington guides RN sedation practice through an advisory opinion of its Nursing Care Quality Assurance Commission rather than a nursing rule on sedation. Advisory Opinion NCAO 7.1 calls itself “an official opinion about safe nursing practice” (p. 1) that is “not legally binding” (p. 1), and notes that the state’s nursing law and rules “do not explicitly permit or prohibit” (p. 3) the agents it covers. Everything below is quoted or paraphrased from the Commission’s seven-page PDF, with page numbers, so you can check it against the source.
Washington at a glance
| Board | Washington State Nursing Care Quality Assurance Commission (NCQAC), Department of Health (p. 1) |
| Document | Advisory Opinion NCAO 7.1, “Administration of Sedating, Analgesic, and Anesthetic Agents” — 7-page PDF, effective 3-13-15, approved by the Commission (p. 1) |
| Rule it applies | None directly. Issued “in accordance with WAC 246-840-800” (p. 1). It names the analgesia and anesthesia rules for office-based surgical settings (WAC 246-919), ambulatory surgical facilities (WAC 246-330) and hospitals (WAC 246-320), and the osteopathic and dental practitioner rules, without setting out what they require (p. 3). |
| Status | Advisory: “an official opinion about safe nursing practice” (p. 1) that is “not legally binding and does not have the force and effect of a duly promulgated regulation or a declaratory ruling by the NCQAC” (p. 1). “Institutional policies may restrict practice further in their setting” (p. 1). Its “must” language about a nurse’s training (p. 1) is the Commission’s conclusion about safe practice, not a rule with force of law. |
| Dates | Effective 3-13-15; supersedes NCAO 7.0 of 9-12-14 (p. 1). No revision date, review date or review cycle is stated. |
| Who it covers | Registered nurses: the Commission “concludes that registered nurses (RNs) may administer and maintain sedating, analgesic, anesthetic, and reversal agents prescribed by authorized providers” (p. 1). LPNs are covered as assistants for regional, moderate and deep sedation (p. 3); both licences “may administer topical (local) and minimal sedating agents for the purpose of anxiolysis” (p. 3). |
| Who it does not cover | LPNs as leads: “it is beyond the scope of a licensed practical nurse (LPN) to lead these activities” (p. 1). The medical pre-anesthesia assessment: “It is not within the RN’s or LPN’s scope of practice to perform a medical pre-anesthesia assessment as required by CMS or accrediting organizations” (p. 4). Monitored anesthesia care as CMS defines it, which the opinion says CMS requires to “be administered by an anesthesia provider” (p. 3). The opinion also says it “may not address the use of these medications in every setting or for every procedure” (p. 1). |
| Settings the document names | “operating rooms, obstetrical suites, emergency rooms, outpatient clinics, psychiatric clinics, pain clinics, special procedure areas, in-home, and hospice” (p. 2); gastrointestinal endoscopy, where “Moderate sedation is standard” (p. 2); and “non-traditional settings” (p. 5) for palliative and chronic-pain patients. |
| Re-verification interval | None stated. Competency is to be evaluated and documented “on an initial and periodic basis (defined by the institution)” (p. 4). |
| Where the record lives | In the institution’s “educational and/or credentialing mechanism that includes a process for evaluating and documenting the nurse’s competency” (p. 4). |
| CE hours | Not stated. No contact-hour count, course or continuing-education requirement appears in the opinion. Its one line on credentials cuts the other way: “Completion of formal certifications does not imply that a nurse has the competence to perform these or related activities” (p. 1). |
What the Washington State Nursing Care Quality Assurance Commission says
The Commission “concludes that registered nurses (RNs) may administer and maintain sedating, analgesic, anesthetic, and reversal agents prescribed by authorized providers” (p. 1) and names the agents it has in mind: “diazepam, chloral hydrate, nitrous oxide, etomidate, propofol, ketamine, fentanyl, methohexital, bupivacaine, ropivacaine, succinylcholine, and midazolam” (p. 1). Two conditions follow: nurses “must have the training, skills, knowledge, and ability to administer these drugs safely and competently” (p. 1) and “must have the ability to assess, interpret, and intervene in the event of complications” (p. 1).
Under Recommendations, the opinion lists what “may be within the RN’s scope of practice” (p. 3). Paraphrased except where quoted, an RN may administer analgesic, sedating and anesthetic agents:
- “for the purpose of regional and moderate sedation for non-intubated or intubated ventilated-patients” (p. 4);
- for regional, moderate and deep sedation in intubated, ventilated patients (p. 4);
- for deep sedation in non-intubated patients, provided an anesthesia professional is immediately available as the institution defines it (p. 4);
- “using CAPS systems” (p. 4) — computer-assisted personalized sedation devices (p. 2);
- as low-dose anesthetics for acute and chronic pain (p. 4);
- “for palliative sedation” (p. 4);
- “for emergency care, including rapid sequence intubation” (p. 4);
and may assist an anesthesia professional with general anesthesia while that professional is on the premises (p. 4). Under Competencies, the sentence this page is about:
“Institutions should have an educational and/or credentialing mechanism that includes a process for evaluating and documenting the nurse’s competency on an initial and periodic basis (defined by the institution).”
Washington State Nursing Care Quality Assurance Commission — Advisory Opinion NCAO 7.1 (effective 3-13-15, p. 4)
Nurses managing and monitoring sedated patients “should demonstrate competency specific to the procedure, setting, and patient care needs” (p. 4). Under Patient Monitoring, in some settings the nurse giving the drug or watching the patient “should not leave the patient unattended or perform other tasks that would compromise patient monitoring, including performance of the procedure itself” (p. 4).
What a Washington facility should be able to show
The Competencies and Policies paragraphs on p. 4 translate into three records a Washington facility should be able to produce:
- Sedation policies and procedures “based on current standards of practice, accreditation standards, regulations, or CMS requirements” (p. 4), written for the purpose and setting, defining the level of monitoring, and with resuscitation equipment that “should be age-appropriate, readily available, and appropriate for the setting and individual patient” (p. 4).
- Per-nurse evidence of initial competency from your “educational and/or credentialing mechanism” (p. 4) — the education and evaluation showing the nurse has the training, skills and knowledge for these drugs (p. 1) and competency specific to the procedure, setting and patient needs (p. 4).
- Per-nurse evidence of periodic re-evaluation, on the interval your own mechanism names — the opinion sets no period, only that the institution defines it (p. 4).
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 Washington facilities ask
Does Washington set a renewal interval for sedation competency?
No. NCAO 7.1 asks for competency to be evaluated and documented “on an initial and periodic basis (defined by the institution)” (p. 4) and says nothing more about frequency. Separately, it “recommends nurses follow best practice standards specific to the procedure, setting, and patient care needs” (p. 5) and lists resources from ASPMN, HPNA, ASA, SGNA, ASGE and the AANA (p. 5). The interval is yours to set; a certificate with an expiry date makes it visible on the roster.
Does Washington require the CSRN™ course specifically?
No. NCAO 7.1 names no sedation course, and no state mandates this specific one. It goes further than silence: “Completion of formal certifications does not imply that a nurse has the competence to perform these or related activities” (p. 1). What the opinion asks for is the institution’s own “process for evaluating and documenting the nurse’s competency” (p. 4). CSRN™ is designed to be the education and assessed-competency evidence that feeds that process, not a substitute for the institution’s evaluation.
Can a Washington RN give propofol for moderate sedation?
The opinion lists propofol among the agents an RN “may administer and maintain” (p. 1) and puts moderate sedation within what “may be within the RN’s scope of practice” (p. 3). The conditions: the two quoted above (p. 1), the Scope of Practice Decision Tree the Commission “advises nurses to use” (p. 1), your own institutional policy (p. 1), and the analgesia and anesthesia rule for your setting (p. 3).
Compliance note (last reviewed September 2026): This page is educational information about Washington State Nursing Care Quality Assurance Commission Advisory Opinion NCAO 7.1, not legal advice or a compliance determination. Every quotation was checked word-for-word against the Commission’s NCAO 7.1 PDF (effective 3-13-15) on 2026-09-01; page numbers refer to that PDF. An advisory opinion is not a rule and can be revised or replaced; confirm the current version on the Commission’s website, the rules for your setting, and your own facility policy before relying on this summary. No state mandates this specific course.