SARP for Massachusetts Nurses: What to Know Before You Apply
If substance use has affected your nursing practice, the Board of Registration in Nursing offers a path that doesn’t start with discipline: the Substance Addiction Recovery Program (SARP). For many nurses, SARP is the right choice. It’s confidential, it’s an alternative to traditional discipline, and it leads back to practice. But it’s also a multi-year commitment with strict rules, and leaving the program early can leave you worse off than if you’d never entered. Understand both sides before you apply.
To talk it through confidentially, call or text (978) 273-8337.
A lawyer who is also a nurse.
I’ve been a registered respiratory therapist since 2005 and a registered nurse since 2010. As a respiratory therapist I spent many years at the bedside providing hands-on respiratory care. As a nurse I’ve worked in critical care and the intensive care unit of an acute care hospital, and I’ve held management roles in that setting. Having worked in and managed in an acute care hospital, I understand what a monitored return to practice requires on a real unit, and I can help you decide whether SARP is right for you.
— Richard Alan Gaudet, JD, RN, RRT
What SARP is
SARP was created by statute, G.L. c. 112, § 80F, as a “voluntary alternative to traditional disciplinary actions” for RNs and LPNs whose practice has been affected by a substance use disorder. Nurses enter only by asking to. The program was once called the Substance Abuse Rehabilitation Program; the Board now calls it the Substance Addiction Recovery Program.
The program is run by Board staff and a Substance Addiction Recovery Evaluation Committee (SAREC). SAREC reviews applications, sets each participant’s individualized plan, and hears compliance matters. Its findings are recommendations that the full Board must approve.
A participant’s obligations are set out in a contract called the Consent Agreement for SARP Participation / Individualized Rehabilitation Plan (CASP/IRP).
Who is eligible
Under the Board’s current admission checklist, an applicant must:
Hold a current Massachusetts nursing license in good standing: not expired, surrendered, suspended, revoked or on disciplinary probation. Staff review the whole application, though, so a license with one of those statuses doesn’t automatically rule you out.
Admit to a substance use disorder, as a first-time or re-admission applicant, or as a participant in full compliance with a comparable program who wants to transfer in.
Be physically and psychologically able to participate: no condition that prevents safe practice or compliance with SARP, or that requires a medication that is itself a substance of abuse. Medications for opioid use disorder are handled separately (see below).
Meet the Board’s good moral character standard. Applicants with criminal matters at any stage can still qualify if the matters resulted from the admitted substance use disorder and aren’t a “permanent exclusion” crime under Board Licensure Policy 00-01.
Be in good standing with every other licensing body that has licensed you. Discipline elsewhere is allowed only if it was based on substance use and the Massachusetts Board declined to take reciprocal action.
Medications for opioid use disorder
Nurses treated with buprenorphine, buprenorphine/naloxone or methadone can participate under SARP Policy 13-01. The prescriber must monitor treatment with random, unscheduled toxicology screens at least monthly, send SARP quarterly provider reports, and either confirm you’ve stopped the medication or give medical clearance to practice safely while on it.
How to apply
Stop practicing. Applicants are expected to refrain from working during the admission process.
Get a pre-admission evaluation from a board-certified psychiatrist, or a psychiatric mental health nurse practitioner or clinical specialist.
Assemble the full application: the application form, a self-assessment, the evaluator form, a prescription verification form, a prescription-monitoring release, releases for your therapist, prescriber, primary care provider and any lawyer, plus a notarized CORI acknowledgment and a notarized license affidavit.
Submit everything at once. Partial submissions won’t be reviewed.
Expect follow-up. SARP staff may contact your care team and ask you to take a pre-admission urine screen, which must be negative for substances with addiction potential.
Your obligations under the CASP/IRP
According to the Board’s 2022 SARP Resource guide, a typical agreement requires:
Requirement
What it involves
Daily check-in
Every day, by app or phone, between 4 a.m. and 2 p.m., to learn whether you’ve been selected to test
Toxicology testing
At least 15 random, observed urine tests a year, plus hair or blood tests as needed. Results must be clean, and urine creatinine must not fall below 20 mg/dL
Recovery meetings
At least 4 meetings a week: 3 AA/NA meetings and 1 approved group
Therapy
At least every two weeks
Quarterly reports
Due in February, May, August and November: a self-assessment, therapist report, employer report and meeting logs
Medications
Any new medication must be approved before you take it
Practice
Keep your license active, and work as a nurse for at least one year with medication handling
Travel
Advance approval and testing arrangements; international trips of 14 days or less, only after 12 months of full compliance
Returning to practice
Participants don’t practice for at least the first six months after the agreement takes effect. After six months of full compliance, you can ask to return in stages:
Level
What you can do
When you can request it
CA1
Practice without medication privileges
After 6 months of full compliance
CA2
Practice with basic (non-controlled) medications
After 6 months of full compliance, or after 6 months working at CA1
CA3
Practice with full medication privileges, including controlled substances
After 6 months of full compliance while working at CA2
At every level, the conditions to practice are strict:
Direct supervision by a registered nurse who is on-site during every hour you work, with each supervisor signing a verification form
No narcotic keys or controlled-substance counts at the CA1 and CA2 levels
No more than 40 hours a week: no 11 p.m.–7 a.m. shifts, no overtime, no rotating shifts, no floating, and at least 12 hours between shifts
A structured setting. Home care and some school settings aren’t permitted
SARP must approve every job in advance. You tell the prospective employer you’re in SARP and show them your practice-level letter, though SARP staff don’t disclose what led to your participation. Remote or telehealth roles need SAREC and Board approval.
What it costs
Participants pay all program costs. The Board’s 2022 guide estimates about $64 for a urine test, $140 for a hair test and $110 for a blood (PEth) test, plus collection-site fees. Its own example puts testing alone at at least $4,500 over a minimum three-year agreement, before therapy, evaluations and the income lost during the months you can’t practice.
How confidential is SARP?
Very, while you’re in good standing. SARP records are confidential under § 80F, aren’t subject to public records requests, and aren’t subject to discovery. SAREC and Board matters about participants are heard in closed executive session. SARP staff talk with your employer and providers only with your signed release, and they don’t disclose the events that led to your participation.
There are limits, though (SARP Policy 12-01):
During admission, SARP staff may tell Board counsel and the prosecutor how your application is progressing, and whether you’ve been admitted, so that any pending complaint can be resolved.
During participation, staff may confirm to the Board’s prosecutors whether your SARP agreement already resolves a pending complaint.
If you’re turned down, withdraw or are terminated, § 80F confidentiality no longer applies to your SARP records. They can be moved to your complaint file, used as evidence in a disciplinary hearing, and SARP staff can testify about them.
What happens if you don’t comply
Missed check-ins, missed or dilute tests, a positive result, a relapse, missed meetings or therapy, late quarterly reports, starting a job without approval, or taking an unapproved medication are all compliance matters. SAREC and the Board can take no action, modify the agreement, extend it, or terminate it. The guide explains that unintended exposures, such as hand sanitizer, kombucha or CBD products, are investigated with a medical review officer and follow-up testing, and that you’re expected to know how to avoid them.
Medical or mental health problems that prevent compliance can be covered by a temporary medical waiver of up to 30 days, extendable to 90. You can’t practice during a waiver, and treatment needing more than 90 days leads to termination.
The real risk: leaving the program
According to the Board’s 2022 guide, if you’re terminated or withdraw from SARP, your nursing license becomes suspended and the complaint that led to SARP is unsealed. Your SARP records can then be used against you. You may be able to re-apply, but the original complaint stays unsealed even if you complete the program the second time. This is the most important thing to weigh before you sign.
Completing SARP
You can petition the Board for discharge after:
Three consecutive years of full compliance with your agreement
At least one year of safe, monitored nursing practice that includes medication management, documented by supervisor reports
A sworn statement that no criminal or administrative matters are pending against you anywhere, and a CORI check
On successful completion, your SARP participation records are sealed, along with the complaint that preceded SARP. The statute says sealing can’t happen sooner than five years after entry (§ 80F).
SARP or contesting the complaint?
Entering SARP
Responding to the complaint through the disciplinary process
Discipline on your record
None, if you complete it
Possible: a consent agreement, probation or worse, all public
Confidentiality
High, while you’re in good standing
Orders and consent agreements are public
Time out of practice
At least 6 months, then restricted practice
Depends on the case; may be none
Length
Multi-year commitment
Often shorter
Cost
You pay for testing, therapy and evaluations
Legal fees; monitoring costs if probation is imposed
If things go wrong
License suspended and complaint unsealed
You keep your defenses and hearing rights
Best fit
You have a substance use disorder and are ready for long-term recovery
The facts are disputed, or substance use isn’t really the issue
How I help
Decide whether SARP fits: review the complaint, the evidence and your situation before you admit anything in writing.
Prepare the application so it’s complete in one submission, and coordinate your evaluation and releases.
Handle the pending complaint and any criminal case so SARP resolves what it should.
Represent you at SAREC and Board meetings on compliance matters, employment approval and practice-level requests.
Protect you if participation ends, when the complaint and the records become live again.
Thinking about SARP?
Call or text (978) 273-8337, or send a message. Confidential consultations for nurses across Massachusetts, in person in Middleton or by video.
Frequently asked questions
Is SARP discipline? No. Under G.L. c. 112, § 80F, SARP is a voluntary alternative to traditional disciplinary action. Participation records are confidential while you’re in good standing and are sealed when you complete the program.
Can I keep working while I apply to SARP? No. Applicants are expected to stop working during the admission process, and participants don’t practice for at least the first six months of the agreement.
Can I enter SARP if I have a pending criminal case? Possibly. The Board’s checklist says applicants with criminal matters can meet the good moral character standard if the matters resulted from their substance use disorder and aren’t a permanent exclusion crime under Board policy.
Can I take Suboxone or methadone in SARP? Yes, under SARP Policy 13-01, with a qualified prescriber who monitors treatment with monthly random toxicology screens and sends SARP quarterly reports.
What happens if I leave SARP? According to the Board’s 2022 guide, if you withdraw or are terminated, your license becomes suspended and the complaint that led to SARP is unsealed. Your SARP records can then be used as evidence in a disciplinary proceeding.
Richard Alan Gaudet, Esq. is a Massachusetts attorney at the Law Offices of Richard Alan Gaudet, LLC in Middleton, Massachusetts, and an experienced administrative law practitioner who represents licensed professionals in board investigations, responses and hearings. He has been a respiratory therapist since 2005 and a registered nurse since 2010, including in critical care. He earned his J.D. in 2020 and was admitted to the Massachusetts bar in January 2021 and to the U.S. District Court for the District of Massachusetts in 2021. He is a member of the Massachusetts Bar Association. Reach him at 978-273-8337 or rgaudet@gaudetlawoffice.com. Office: 35 Village Rd., Ste 100, Middleton, MA 01949.
ABOUT THIS ARTICLE
This article was prepared by a Massachusetts attorney and is provided solely for general informational and educational purposes directed to members of the general public. It does not constitute legal advice and does not create an attorney-client relationship. The law applicable to any particular situation depends on the specific facts and circumstances of that matter. Readers are encouraged to seek the advice of a licensed Massachusetts attorney before taking any action.
