Treating licensed professionals in Texas: how a program works with TPAPN, TXPHP, PRN and TLAP

The short answer: Texas has four main monitoring programs for licensed professionals: TPAPN for nurses (run by the Texas Nurses Association), the Texas Physician Health Program (TXPHP) for physicians, PAs and other Texas Medical Board licensees, the Professional Recovery Network (PRN) for pharmacy, dental and veterinary professionals, and the State Bar's Texas Lawyers' Assistance Program (TLAP). None of them treats participants. They arrange an evaluation, write a monitoring agreement from it, and send the person to treatment. None of them publishes an application to become an "approved" treatment program that we could find. A program gets involved by being on a program's evaluator list (TPAPN publishes one), by already treating the professional, or by being known to a program's case managers as a provider that sends complete reports on time. Every report needs the client's written consent that meets 42 CFR Part 2.

1. The Texas programs at a glance

Program	Who it serves	Who runs it	Legal basis
TPAPN, Texas Peer Assistance Program for Nurses	RNs, LVNs and APRNs	The Texas Nurses Association; an alternative to Board of Nursing discipline	Peer assistance under the Nursing Practice Act (Occupations Code ch. 301)
TXPHP, Texas Physician Health Program	Physicians, physicians in training, PAs, acupuncturists, surgical assistants, medical radiologic technologists, respiratory care practitioners, medical physicists and perfusionists	A state program with its own governing board, administratively attached to the Texas Medical Board	Occupations Code ch. 167; TMB rules at 22 TAC ch. 180
PRN, Professional Recovery Network	Pharmacists, pharmacy technicians and students; dentists, hygienists and dental assistants; veterinary professionals	A department of the Texas Pharmacy Association, recognized by the pharmacy, dental and veterinary boards	Health and Safety Code ch. 467; pharmacy peer assistance in Occupations Code ch. 564
TLAP, Texas Lawyers' Assistance Program	Lawyers, law students and judges	The State Bar of Texas	State Bar programs; the Board of Law Examiners' chemical dependency process in Government Code §82.038

Chapter 467 sets the framework for most peer assistance programs. HHSC sets the minimum criteria (its rules are at 26 TAC ch. 8), a licensing board approves a program that meets them, and §467.007 keeps the program's records confidential except in the narrow cases the statute lists. The chapter doesn't apply to physicians' or pharmacists' programs, because other law authorizes those (HSC ch. 467): Occupations Code chapter 167 for TXPHP, and chapter 564, whose rules must be at least as strict as chapter 467's, for pharmacy peer assistance.

2. How these programs work

The details differ, but the order of steps is much the same:

1. Referral. The professional calls on their own, or an employer, colleague, family member or the licensing board makes the referral. TXPHP takes self-reports, third-party referrals and TMB referrals (TXPHP FAQ). PRN takes self-referrals and referrals from any concerned third party.
2. Intake and evaluation. TXPHP's medical director interviews the person privately to decide eligibility and monitoring needs, and may require an outside evaluation first. TPAPN requires most enrollees to be evaluated by a TPAPN-recommended evaluator.
3. The agreement. The evaluation sets the terms of a written agreement: TPAPN's Participation Agreement, TXPHP's Monitoring and Assistance Agreement, PRN's monitoring agreement. Terms usually include treatment, abstinence, random drug testing, support meetings and reports.
4. Treatment at the level the evaluator recommended, from providers the program accepts. This is where a treatment program comes in.
5. Monitoring for the length of the agreement: random toxicology through the program's testing vendor, check-ins, provider reports, and work-site conditions.
6. Confidentiality while compliant. A TXPHP participant's file is not available to the Medical Board as long as they follow their agreement; substantive non-compliance goes to TXPHP's governing board. PRN describes monitoring as confidential provided the participant follows the agreement. A board-ordered participant is different: the board already knows.

3. Two roles a program can play: evaluator or treatment provider

	Evaluator	Treatment provider
What you do	A comprehensive assessment with a diagnosis, an opinion on whether the person can practice safely, and treatment recommendations	Treat at the recommended level of care (assessment, IOP or PHP, individual sessions, psychiatric care, discharge and continuing-care planning)
How you get the work	The monitoring program's evaluator list, or its case manager's direction	The evaluator's recommendation, the participant's choice among acceptable providers, or a participant you're already treating
Who's qualified	Usually a physician (often an addiction psychiatrist), psychologist or licensed mental health professional who can interpret toxicology	A licensed program or clinician; for SUD treatment in Texas, a licensed chemical dependency treatment facility or a licensed clinician practicing within scope
Watch for	The conflict when an evaluator recommends their own program's treatment	Reports and releases that meet the program's form and schedule

On conflicts: a Utah evaluator toolkit built on the Federation of State Physician Health Programs' 2019 guidelines expects evaluators to hold a license in good standing, to be able to interpret toxicology reports, and to disclose any affiliation with a treatment facility before scheduling (Utah Professionals Health Program). Texas programs set their own rules, but expect the same question. If your program does both, write down how a participant you evaluated is told about other treatment options.

Our experience is on the treatment side: a licensed Texas IOP and PHP. Admission still runs on the same rules as any other client: a QCC authorizes it in writing at a level of care the assessment supports (26 TAC 564.802; see the 26 TAC 564 requirements). A monitoring program's recommendation doesn't replace your own placement decision. If your assessment points to a different level, tell the case manager, with consent, and document why.

4. TPAPN: nurses

• Who runs it. The Texas Nurses Association runs TPAPN. Its handbook describes the program as voluntary and an alternative to Board of Nursing discipline. Participants pay for their evaluations, treatment and drug testing.
• Evaluations. Most enrollees must be evaluated by a TPAPN-recommended evaluator and follow the recommendations. TPAPN publishes its recommended evaluator list, which tells nurses not to schedule an evaluation before talking to their TPAPN case manager, because every evaluation is coordinated with TPAPN. Most listed evaluators offer evaluations by secure video.
• What the evaluation covers. A comprehensive assessment, a diagnosis, an appraisal of the nurse's ability to provide safe care, and treatment recommendations. TPAPN places participants in tracks and tiers by diagnosis, severity, remission, needs and license type.
• Treatment providers. TPAPN's page for providers says it works with evaluators, treatment providers and specialists, can refer participants to them or use a participant's current providers, and posts its Therapist Report and Medication Report forms there. Treatment requirements are set by the case manager with the evaluator and treatment providers.
• Testing. Random testing through TPAPN's system. The 2020 participant handbook described 24 to 54 random selections over 12 months, by urine, blood, hair or nail, and abstinence from all abusable drugs, including alcohol, as a general requirement (TPAPN handbook). Check the current handbook for today's numbers.
• Help with cost. TPAPN's participant page describes grants from the Texas Nurses Foundation for nurses with financial need: 50% of the initial evaluation, up to $750, paid to the evaluator (TPAPN participants, as of October 2026).

5. TXPHP: physicians, PAs and other Texas Medical Board licensees

• What it is. A confidential, nondisciplinary program under Occupations Code ch. 167 offering early intervention, assessment, referral to treatment and post-treatment monitoring for substance use, psychiatric and physical conditions that could affect safe practice. It "does not itself treat participants but facilitates their treatment" (TXPHP FAQ). In 2025, S.B. 2480 aimed to extend the program and its funding surcharge to every TMB licensee; check the current statute.
• Who it serves. Physicians and physicians in training, physician assistants, acupuncturists and acudetox specialists, surgical assistants, medical radiologic technologists and non-certified technicians, respiratory care practitioners, medical physicists and perfusionists (TMB).
• Evaluations. The medical director interviews each person; an outside psychological or medical evaluation may be required before the agreement is signed.
• Reports from treaters. TXPHP uses standard report forms for treating providers, such as a primary care provider report that asks about adherence, controlled substances prescribed by other providers and whether impairment exists, and a psychiatry and mental health provider report. Ask the case manager which form fits your role and how often it's due.
• Testing. TMB rules require the program's drug testing to run through a TMB-approved vendor under contract. Your own clinical drug screens don't replace it.

6. PRN: pharmacy, dental and veterinary professionals

• Who runs it. The Texas Pharmacy Association, which founded PRN in 1981. It operates under Health and Safety Code ch. 467.
• Who it serves. Pharmacy professionals, and also Texas-licensed dentists, dental hygienists and dental assistants (recognized by the State Board of Dental Examiners) and veterinary professionals (in partnership with the Board of Veterinary Medical Examiners).
• Two kinds of participants. Volunteers and board-ordered participants. PRN takes self-referrals and third-party referrals, keeps referral sources confidential, and will advocate for a participant with a licensing board, credentialing bodies and employers.
• For providers. PRN's monitoring agreement sets the treatment, testing and reporting terms. Ask PRN's case manager what it needs from a treatment program before the first report is due.

7. TLAP: lawyers, law students and judges

• What it is. The State Bar's confidential help line and referral service for lawyers, law students and judges with substance use or mental health problems (800-343-8527). TLAP connects people to care, can help fund it, offers peer and group support, and keeps a database of physicians, behavioral health professionals and treatment programs in Texas and nationally.
• Where monitoring comes in. The State Bar's Grievance Referral Program lets a lawyer who comes into the discipline system through minor misconduct complete a remedial or rehabilitative program in exchange for dismissal of the complaint (State Bar of Texas). TLAP staff recruit, train and oversee the volunteer monitors for that program and for the Board of Law Examiners.
• Bar applicants. When the Board of Law Examiners decides an applicant may have a chemical dependency, it must have the applicant meet with TLAP and may require an evaluation by a licensed mental health professional it designates. It can issue a probationary license with conditions such as treatment and random testing (Gov't Code §82.038).
• For providers. TLAP is less formal than the health-profession programs. Being in its resource database, and sending clear reports when a lawyer's monitoring requires them, is how a program works with it.

8. What a referral expects from you

Put this in writing with the case manager at admission. A report that arrives late or says too little is how a professional ends up out of compliance, even when treatment is going well.

Item	What to have ready
The evaluation and its recommendations	A copy in the chart (with consent), and your own assessment and level-of-care decision next to it
A schedule they can keep	A professional who is still working needs an evening track (see IOP schedule templates) or a PHP-to-IOP step-down that matches return-to-work dates
Provider reports	The program's own form (TPAPN's therapist and medication reports; TXPHP's provider reports), on its schedule, signed by the right clinician
Toxicology	Your clinical drug screens under your drug testing policy, kept separate from the program's random testing. Report results only under the consent
Medications	Every prescription, especially controlled substances, reported on the program's medication form. Prescribers on your team need to know the person is monitored
Notice of a problem	An agreed way to report a positive screen, missed sessions or discharge against advice, and who gets told
Discharge	A discharge summary and continuing-care plan the program can build monitoring on (see discharge planning)

Our own program sees the same pattern with every outside party who needs reports: the client signs one release per recipient, with an end date, and someone owns the calendar of what's due. In Cima EHR, each release names the recipient, the purpose (choices include "Employer return-to-work, at my request") and what's shared. The chart won't send records on an expired or revoked consent, and consents ending soon are listed so staff renew them first. See Cima EHR for IOP and PHP programs.

9. Consents and 42 CFR Part 2

• Written consent for every recipient. A Part 2 program shares SUD records with a monitoring program, a licensing board or an employer only under a written consent with the elements in 42 CFR 2.31: the recipient, the specific information, the purpose, an end date or event, the right to revoke, and the signature.
• These consents stay revocable. Part 2's "can't revoke until an event" option in §2.35 applies only to criminal justice referrals (see court-ordered treatment). A professional can revoke a release to TPAPN or TXPHP. The monitoring agreement decides what that means for them. You just stop sending, and document it.
• The notice goes with every disclosure. Each disclosure carries the statement required by 42 CFR 2.32.
• Send what the consent names, no more. Attendance, results, diagnosis and progress, if that's what the client agreed to. SUD counseling notes need their own consent that can't be combined with any other.
• Separate releases for separate recipients. The monitoring program, the board, the employer's workplace monitor and a personal physician are different recipients with different purposes. Our 42 CFR Part 2 guide walks through the 2024 rule changes.

10. Getting known, legally

1. Decide your role. Evaluations need a qualified evaluator and a written report process. Treatment needs a schedule, staff and reporting habits that work for professionals.
2. Ask each program what it needs. Call the case management team and ask how it chooses treatment providers, which forms it uses and how often reports are due. Send a short description of your levels of care, schedule, clinical staff and licenses.
3. Ask about the evaluator list. TPAPN publishes one; ask how evaluators are added.
4. Show it with your first participant. Complete reports on the first due date, quick answers to case managers, and a clear discharge plan are what get a program used again.
5. Never pay for it. Nothing of value to a case manager, evaluator, employer or anyone else for referrals. Texas's Patient Solicitation Act and the federal Eliminating Kickbacks in Recovery Act apply to treatment programs (see patient brokering laws and how to market a treatment center legally).

We can't promise a program will send you participants. Nobody honest can.

11. Who pays

• The participant, mostly. TPAPN tells participants they pay for evaluations, treatment and drug testing. Under TMB's rules, TXPHP participants have also paid the monitoring costs in their agreements; check the current rule.
• Insurance for treatment. A commercial plan may pay for IOP or PHP when it's medically necessary, under the same prior authorization and review as any other client. Verify benefits before admission (the VOB checklist covers what to ask). The monitoring agreement doesn't make treatment medically necessary.
• Self-pay for evaluations and reports. Evaluations, monitoring reports and letters are usually not billable to insurance. Publish the fee, and give a self-pay client a good faith estimate before services, as the No Surprises Act requires (CMS).

Planning the payer mix around these clients? The IOP break-even calculator shows what a self-pay track adds.

12. Readiness checklist

• Licensed for the level of care you'll provide, with a QCC authorizing each admission.
• An evening or work-compatible track, or a clear step-down schedule.
• A release form with a purpose for each monitoring recipient, and a process to renew releases before they end.
• The program's report forms and due dates on a shared calendar, with an owner.
• A drug testing policy that separates clinical screens from the program's monitoring tests.
• Prescribers who check for monitoring status before prescribing controlled substances (see psychiatric services in an IOP).
• A written fee schedule for evaluations, reports and letters.
• A rule, in writing, that nobody gives anything of value for referrals.

Questions

How do I become a TPAPN-approved treatment provider?

TPAPN doesn't publish an application for treatment providers. It keeps a list of recommended evaluators, and its provider page says it can refer participants to providers or use a participant's current ones. Contact TPAPN's case management team, describe your program, and send complete reports on its forms when you treat a participant.

Does the Texas Physician Health Program provide treatment?

No. TXPHP arranges assessments, refers to treatment and monitors afterward. Participants are treated by outside providers, and those providers report on TXPHP's forms.

Is TPAPN part of the Texas Board of Nursing?

No. The Texas Nurses Association runs TPAPN as a voluntary alternative to Board of Nursing discipline.

What program monitors pharmacists in Texas?

The Professional Recovery Network (PRN), a department of the Texas Pharmacy Association. PRN also serves Texas dental and veterinary professionals.

Can a monitoring program see my treatment records?

Only what you consent to in writing. A Part 2 program shares substance use records with a monitoring program or licensing board only under a consent that names the recipient, the information and the purpose. You can revoke it, though your monitoring agreement may treat that as non-compliance.

Does insurance pay for treatment required by TPAPN or TXPHP?

It may pay for treatment that's medically necessary and covered by the plan, under its usual authorization rules. Evaluations, monitoring and reports are usually self-pay.

Sources

• Texas Nurses Association: TPAPN providers, TPAPN participants, recommended evaluator list (2026), participant handbook (2020)
• Texas Physician Health Program: FAQ, primary care provider report form; Texas Medical Board, physician health program; S.B. 2480 bill analysis (2025)
• Professional Recovery Network: State Board of Dental Examiners, Board of Veterinary Medical Examiners
• State Bar of Texas, programs supporting the grievance system; Government Code ch. 82
• Texas statutes: Health and Safety Code ch. 467, Occupations Code ch. 167, ch. 301, ch. 564
• eCFR: 42 CFR 2.31, 2.32, 2.35; Utah Professionals Health Program, evaluator training and toolkit; CMS, No Surprises Act

Cima Consulting isn't a law firm. This page summarizes program materials and rules as we found them in October 2026; each program's current agreement and forms control.