Pharmacists’ Authority to Initiate PrEP and PEP and Engage in Collaborative Practice Agreements

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently distribute PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists broad authority to administer injectable PrEP. The definition of “scope of practice” includes administration, and “administration” explicitly includes drug administration by injection. Alaska Stat. Ann. § 08.80.480.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes, pharmacists are allowed to enter into a CPA with a PCP. Alaska Admin. Code tit. 12 § 52.240.

Does the CPA need to be patient-specific?

No, the CPA does not need to be patient-specific, but the CPA must list the specific types of patients to which the pharmacist may provide services. This means a general population may be identified (rather than one specific patient).

Are there filing requirements?

Yes, the pharmacist must submit a copy of the CPA to the Board of Pharmacy. The CPA is not effective until approved by the Board, and the pharmacist and the PCP must each keep a written copy of the CPA on file.

Are there content requirements?

Yes, the CPA must identify the following: 1) the collaborating pharmacist; 2) the collaborating primary care provider; 3) the time period in which the agreement will be in effect; and 4) a description of the scope of services covered under the agreement. Regarding the scope of services, the agreement must explicitly specify the decisions the pharmacist is authorized to make. This includes the types of diseases, drugs, or drug categories involved and the type of collaborative authority. The agreement must state the procedures, decision criteria, or plans the pharmacists are to follow when making therapeutic decisions, particularly when modification or initiation of drug therapy is involved. All authority granted to the pharmacist must be within the PCP’s scope of practice. Statute explicitly prohibits a CPA from giving a pharmacist authority to prescribe a controlled substance.

Is there a time limit?

Yes, the CPA must be renewed no later than every 2 years.

Is the pharmacist required to undergo additional training?

It depends. The Board of Pharmacy determines whether additional training is required based on the scope of services outlined in the submitted CPA. If the Board is not satisfied that the pharmacist has been adequately trained in the procedures outlined in the CPA, then the Board will require the completion of specific additional training that covers those procedures. The pharmacist must then complete said training before the Board approves the CPA.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

Yes, statute defines the scope of pharmacy practice as the "provision of patient counseling and the provision of those acts or services necessary to provide pharmaceutical care."

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

No.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes. Alaska Stat. Ann. § 21.07.250 recognizes pharmacists as providers.

Does the law or regulation apply to specific services?

No.

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently distribute PrEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Statute gives pharmacists broad authority to administer injectable PrEP. The definitions of "scope of practice" and "dispense" include administration. Ala. Code § 34-23-1.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes, pharmacists are allowed to enter into a CPA with a PCP. Ala. Code § 34-23-77; Ala. Admin. Code 680-X-2-.44.

Does the CPA need to be patient-specific?

Yes, the CPA must be patient-specific. The patient (or patient representative) must sign a form agreeing to receiving health care services under a CPA.

Are there filing requirements?

Yes, the pharmacist and PCP must respectively submit copy of agreement to the Board of Pharmacy and the Board of Medical Examiners within 10 days of each party signing the CPA. The CPA is not effective until approved by the Boards. The CPA may be subject to fees from the Boards, not to exceed $300. Amendments to the CPA must go through the same approval process as the original CPA. The pharmacist and PCP must each keep a copy of the CPA on file.

Are there content requirements?

Yes, the CPA must identify the following: 1) the collaborating pharmacist; 2) the collaborating PCP; 3) the date of the agreement; and 4) a description of the scope of services covered under the CPA. Statute explicitly prohibits a CPA from giving a pharmacist authority to prescribe a controlled substance.

Is there a time limit?

Yes, the CPA must be renewed every 2 years.

Is the pharmacist required to undergo additional training?

No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

Yes, pharmacists can independently perform CLIA-waived tests. As long as the pharmacy submits the CMS 1116 Form, it may apply for approval by the Alabama Department of Public Health to perform any CLIA-waived test, including HIV and hepatitis point-of-care tests. Alabama Department of Public Health, Bureau of Health Provider Standards.

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

No, the pharmacist may perform any CLIA-waived test for which the pharmacy submits the CMS 1116 Form.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes, Medicaid may reimburse for professional services provided by licensed pharmacists. Ala. Admin. Code 560-X-16-.06.

Does the law or regulation apply to specific services?

Yes, the law allows Medicaid to reimburse for "professional services" provided by licensed pharmacists, including vaccine administration, medication maintenance therapy adherence and other clinical services as designated by the Agency.

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 Yes, statute gives pharmacists the authority to independently initiate PrEP or PEP (passed 3/21/23). HB 1007 (Ark. 2023); Ark. Code § 17-92-101(17)(A)(i)(g) and (26); Ark. Code § 17-92-115; Ark. Code § 23-92-506(b)(6) and (7); Ark. Code Ann. § 23-99-1120.

Does the pharmacist need a standing order from a PCP?

No. Pharmacists are required to inform a patient’s PCP if the pharmacist prescribes PrEP or PEP. If the patient does not have a PCP, then the pharmacist must provide a list of local PCPs.

Does the legislation address pharmacists’ reimbursement or any other insurance provisions?

Yes, insurers are prohibited from requiring prior authorization or step therapy to cover PrEP and PEP.

Is there a quantity limit for prescriptions?

Yes, pharmacists are limited to prescribing up to a 60-day supply (with a requirement of prescribing at least a 30-day supply) of PrEP or one complete 28-day course of PEP.

Does the pharmacist have to undergo additional training?

Yes, pharmacists must complete a training program approved by the Arkansas State Board of Pharmacy. The training must include information on the use of PrEP and PEP and financial assistance for PrEP and PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, pharmacists have limited authority to administer injectable PrEP. The prescription must have explicit instructions from a PCP to administer and must either be a patient-specific standing order, a prescription, or a general protocol from a PCP. Ark. Code Ann. § 17-92-101.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. Ark. Code Ann. § 17-92-101(17)(A)(i)(e), (ix)(a).

Does the CPA need to be patient-specific?

 Yes.

Are there filing requirements?

 No.

Are there content requirements?

Yes, the CPA must state the specific act of drug therapy management or disease state management the PCP is delegating to the pharmacist. The CPA may authorize the pharmacist to engage in drug therapy management. This may include the prescribing, dispensing, and administration of explicitly identified drugs.

Is there a time limit?

 No.

Is the pharmacist required to undergo additional training?

 No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

Laws and rules do not address pharmacist provision of CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently distribute PrEP or PEP 

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists broad authority to administer injectable PrEP. The definition of “scope of practice” includes administration, and “administration” explicitly includes drug administration by injection. Ariz. Rev. Stat. Ann. § 32-1901.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. Ariz. Rev. Stat. Ann. § 32-1970.

Does the CPA need to be patient-specific?

No, the CPA does not need to be patient-specific, but it must list the specific types of patients to whom the pharmacist may provide services. This means a general population may be identified (rather than one specific patient). The PCP must also have an established provider-patient relationship with a patient before a pharmacist may provide services to that patient under a CPA. PCPs may include nurse practitioners.

Are there filing requirements?

No, but the pharmacist must keep a written copy of the CPA on file, which the Board of Pharmacy may request a copy of at any time.

Are there content requirements?

Yes, the CPA must outline the duties related to drug therapy and disease management that the pharmacist is authorized to perform, including drug therapy that the pharmacist may initiate, monitor and modify and laboratory tests that the pharmacist may order. For drug therapy, the CPA must also identify the specific drug, drugs, or drug classes and the conditions to be managed by the pharmacist. The CPA must also state the conditions and events for which the pharmacist must notify the PCP.

Is there a time limit?

 No.

Is the pharmacist required to undergo additional training?

 No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 No.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

Yes, statute gives pharmacists the authority to independently initiate PrEP and PEP (enacted 10/2019). SB 159 (Cal. 2019); Cal. Bus. & Prof. Code § 4052.02, .03; Cal. Health & Safety Code § 1342.74; Cal. Ins. Code § 10123.1933; Cal. Welf. & Inst. Code § 14132.968.

Does the pharmacist need a standing order from a PCP?

 No.

Does the legislation address pharmacists’ reimbursement or any other insurance provisions?

Yes, the law expands the Medi-Cal schedule of benefits to include PrEP and PEP as pharmacist services, so low-income individuals can receive PrEP and PEP prescribed by a pharmacist with little to no cost-sharing. The legislation requires private insurance companies to cover PrEP and PEP prescribed by a pharmacist and restricts insurers from requiring patients to obtain prior authorization or step therapy to obtain PrEP or PEP. However, coverage protections for PrEP and PEP under both Medicaid and private insurance is limited to no more than a 60-day supply in a two-year period when initiated by a pharmacist.

Is there a quantity limit for prescriptions?

Yes, pharmacists are permitted to prescribe up to a 60-day supply of PrEP in a two-year period or a full 28-day regimen of PEP.

Does the pharmacist have to undergo additional training?

Yes, to initiate PrEP or PEP, pharmacists must complete a training program approved by the California State Board of Pharmacy. The training must include information on the use of PrEP and PEP, HIV prevention, interpreting HIV tests, and linking individuals to primary care.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists broad authority to administer injectable PrEP. The definition of “scope of practice” includes administration, and “administration” explicitly includes drug administration by injection. Cal. Bus. & Prof. Code § 4016; Cal. Bus. & Prof. Code § 4052.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. Cal. Bus. & Prof. Code § 4052(a)(13).

Does the CPA need to be patient-specific?

 No.

Are there filing requirements?

 No.

Are there content requirements?

No, there are no specific content requirements, but the CPA may authorize pharmacists to initiate, adjust, or discontinue drug therapy, and a pharmacist may enter into a CPA with any healthcare provider with prescriptive authority.

Is there a time limit?

 No.

Is the pharmacist required to undergo additional training?

 No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

Yes. Ann. Cal. Bus. & Prof. Code § 1206.6; Ann. Cal. Bus & Prof. Code § 4052.4; Ann. Cal. Bus. & Prof. Code § 1209.

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

Yes, in community pharmacy settings, pharmacists may only perform blood glucose, hemoglobin A1c, or cholesterol tests that are classified as waived under CLIA. In pharmacies located in health care settings with a lab onsite, pharmacists may perform a broader number of CLIA-waived tests including STI tests and kidney and liver function tests, as long as it does not require the use of specimens collected by vaginal swab, venipuncture, or the collection of seminal fluid. A pharmacy with a laboratory director of a laboratory with a CLIA waiver may provide any CLIA-waived test.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes. Medi-Cal Pharmacist Services (updated 2021).

Does the law or regulation apply to specific services?

Yes, the law requires Medi-Cal to reimburse pharmacists for furnishing naloxone, self-administered hormonal contraception, initiating and administering immunization, furnishing nicotine replacement therapy, furnishing HIV PrEP and PEP, and furnishing travel medications.

Does the law or regulation require parity (equity) between pharmacists and other providers?

 No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

Yes, pharmacists may prescribe and dispense PrEP and PEP pursuant to a non-patient-specific standing order (passed July 2020). H.B. 20 – 1061, (Colo. 2020); Colo. Rev. Stat. Ann. § 10-16-102(27.5), (38.5), (50.5), (50.7); Colo. Rev. Stat. Ann. § 10-16-104 (18)(e); Colo. Rev. Stat. Ann. § 10-16-152; Colo. Rev. Stat. Ann. § 12-280-103(39)(c)(II)(C), (39)(d), (39)(e); Colo. Rev. Stat. Ann. § 12-280-125.7; Colo. Rev. Stat. Ann. § 25-1-130.

Does the pharmacist need a standing order from a PCP?

Yes, pharmacists need a non-patient specific standing order from a physician, physician assistant, or advanced practice nurse.

Does the legislation address pharmacists’ reimbursement or any other insurance provisions?

Yes, health insurance providers are prohibited from requiring step therapy or prior authorization for PrEP and PEP. Private insurance plans are required to cover PrEP and PEP prescribed by a pharmacist and pay a consultative fee to pharmacists for prescribing PrEP or PEP.

Is there a quantity limit for prescriptions?

No.

Does the pharmacist have to undergo additional training?

No.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists broad authority to administer injectable PrEP. The definition of "scope of practice" includes administration, and "administration" explicitly includes drug administration by injection. Colo. Rev. Stat. Ann. § 12-280-103.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. Colo. Rev. Stat. Ann. § 12-280-601, 602.

Does the CPA need to be patient-specific?

No, but a PCP must have an established provider-patient relationship with a patient before a pharmacist may provide services to that patient under a CPA.

Are there filing requirements?

No.

Are there content requirements?

Yes, the CPA must specify the treatment protocol the PCP is delegating to the pharmacist. The CPA must establish a means for the PCP and pharmacist to communicate and document changes to the patient’s medical record. The CPA must also be in writing and signed by both the PCP and pharmacist. PCP includes advanced practice registered nurses.

Is there a time limit?

No.

Is the pharmacist required to undergo additional training?

No, but the pharmacist must carry professional liability insurance and devote a portion of their pharmacy practice to CPA.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

Maybe. Colorado defines "pharmacist care services" as "patient care activities provided by a pharmacist, with or without dispensing a drug, that are intended to achieve outcomes related to curing or preventing disease, eliminating or reducing a patient’s symptoms, or arresting or slowing the process of a disease." Colo. Rev. Stat. § 12-280-103.

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

No.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes. Colorado Pharmacist Services Billing Manual.

Does the law or regulation apply to specific services?

Yes, the law applies to “medically necessary” services provided by a pharmacist.

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

No, a pharmacist’s scope of practice does not include the authority to administer. "Scope of practice" includes the ability to dispense. "Dispense" explicitly excludes the ability to administer drugs, which includes injectable prescription drugs. A pharmacist seeking to administer injectable PrEP would need to do so under the terms of a CPA. Conn. Gen. Stat. Ann. § 20-571.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. Conn. Gen. Stat. Ann. § 20-631.

Does the CPA need to be patient-specific?

No, but the CPA must list the specific types of patients to which the pharmacist may provide services. This means a general population may be identified (rather than one specific patient). The PCP must also have an established provider-patient relationship with the patient before a pharmacist may provide services to that patient under a CPA.

Are there filing requirements?

No, but the CPA must be made available to the Department of Consumer Protection and the Department of Public Health upon request. A written copy of the CPA must be held within the medical file of each patient receiving services pursuant to the CPA.

Are there content requirements?

Yes, the CPA must identify the specific drug, drugs, or drug classes and the conditions to be managed by the pharmacist and the laboratory tests that the pharmacist may order. All services the pharmacist provides pursuant to the CPA must be documented in the relevant patient’s medical file. When a pharmacist discontinues drug therapy or deprescribes a drug pursuant to their authority to do so under a CPA, the pharmacist must notify the PCP within 24 hours. The CPA may authorize the pharmacist to initiate, modify, continue, discontinue, or deprescribe a drug therapy or device that has been prescribed for a patient, order associated laboratory tests, and administer drugs.

Is there a time limit?

No.

Is the pharmacist required to undergo additional training?

No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests (with the exception of the Executive Order specifically authorizing the performance of COVID-19 tests).

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP. 

Do pharmacists have the legal authority to administer injectable PrEP?

No, the administration of injectable PrEP is prohibited. Pharmacists' authority to administer medication extends only to immunizations and vaccines. D.C. Code Ann. § 3-1201.02.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. D.C. Mun. Regs. Tit. 17, § 10001; D.C. Code Ann. § 3-1202.08(h)(1).

Does the CPA need to be patient-specific?

No, but the PCP must have a valid patient-physician relationship prior to referring a patient to a pharmacist for participation in a CPA.

Are there filing requirements?

No, but the Boards may deny approval of a physician or pharmacist to participate in a CPA if the PCP or pharmacist has 1) a final order by the governing Board disciplining the PCP's or pharmacist's license for a practice issue within the 5 years immediately preceding the formation of the agreement; or 2) limitations placed on the PCP's or pharmacist's license by the governing board.

Are there content requirements?

Yes, the CPA must include 1) specification of the drug therapy to be provided and any tests that may be necessarily incident to its provision; 2) the conditions for initiating, modifying, or discontinuing a drug therapy; and 3) directions concerning the monitoring of drug therapy, including the conditions that would warrant a modification to the dose, dosage regime, or dosage form of the drug therapy.

Is there a time limit?

No.

Is the pharmacist required to undergo additional training?

Yes, to participate in a CPA, a pharmacist must possess relevant advanced training, complete a residency or a certificate program, and complete 3 (for Doctor of Pharmacy) or 5 (for Bachelor of Science in Pharmacy) years of relevant clinical experience.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

Yes, the "practice of pharmacy" definition includes "conducting health screenings, including obtaining finger-stick blood samples." D.C. Code § 3-1202.02.

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

No.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists broad authority to administer injectable PrEP. The definition of "scope of practice" includes administration, and "administration" explicitly includes drug administration by injection. Del. Code Ann. tit. 24 § 2502.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

N/A.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

Yes. The "practice of pharmacy" includes "performing and interpreting capillary blood tests to screen and monitor disease risk factors or facilitate patient education, the results of which must be reported to the patient’s health-care practitioner; screening results to be reported only if outside normal limits” as well as “ordering, performing, and interpreting" CLIA-waived tests. Del. Code tit. 24 § 2502.

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

No.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

No, a pharmacist may only administer if under the authority of a CPA with a PCP. Fla. Stat. Ann. § 465.003; Fla. Stat. Ann. § 465.0125.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. Fla. Stat. Ann. § 465.1865; Fla. Admin. Code Ann. r. 64B16-31.001, 31.003, 31.005, 31.007, 31.009.

Does the CPA need to be patient-specific?

No.

Are there filing requirements?

Yes, the pharmacist must submit a signed copy of the CPA to the Board of Pharmacy before the CPA may be implemented.

Are there content requirements?

Yes, the CPA must include: 1) the patient's name, 2) each chronic health condition to be managed, 3) the specific drugs to be managed, 4) circumstances under which the pharmacist may perform laboratory or clinical tests, 5) events for which the pharmacist must notify the collaborating physician and the manner and timeframe of such notification, 6) beginning and end dates for the CPA and termination procedures, and 7) a statement that the CPA may be terminated by either party at any time.

Is there a time limit?

Yes, the CPA automatically terminates after 2 years unless renewed.

Is the pharmacist required to undergo additional training?

Yes, a pharmacist who enters into a CPA must complete 8 hours of continuing education.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No. Florida Fla. Stat. § 465.1895.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists broad authority to administer injectable PrEP. The definition of "scope of practice" includes administration. The definition of "administration" includes the provision of drugs pursuant to a prescription order, which is interpreted to include drug administration by injection. Ga. Code Ann. § 26-4-4; Ga. Code Ann. § 26-4-5.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. Ga. Code Ann. § 43-34-24; Ga. Code Ann. § 26-4-50; Ga. Comp. R. & Regs. 480-35-.02 — .07.

Does the CPA need to be patient-specific?

Yes, the CPA must identify each patient for whom the pharmacist is authorized to modify drug therapy.

Are there filing requirements?

Yes, a pharmacist must apply to the Board for certification which will allow them to enter into a CPA.

Are there content requirements?

Yes, the CPA must include 1) the name and signature of the pharmacist and physician who are parties to the agreement; 2) the date the CPA was established and becomes effective; 3) the length of time the protocol shall be effective; 4) the physician's diagnosis; 5) the identity of each patient for whom the pharmacist is authorized to modify drug therapy; 6) a description of the specific responsibilities and parameters for modification of drug therapy; 7) the medication the pharmacist may modify including minimum and maximum dosage levels; and 8) a statement that each patient must be notified that the pharmacist is authorized to modify their drug therapy.

Is there a time limit?

Yes, the CPA shall not be valid for more than 2 years from the date of issue.

Is the pharmacist required to undergo additional training?

Yes, the pharmacist must annually successfully complete a continuing education program regarding modification of drug therapy and be approved by the Board. In order to renew the pharmacist’s certification, their continuing education must 1) be from a provider approved by the Board pursuant to Rule 480-3-.03 or a provider approved by ACPE; 2) have been taken and credit received for the continuing education during the 12 months preceding the application for renewal; 3) have been from a live program at least 1.0 contact hour in length; and 4) have been on the topic of the therapy area in which the pharmacist seeks to make drug therapy modifications.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

Yes, the "practice of pharmacy" definition includes "performing capillary blood tests and interpreting the results as a means to screen for or monitor disease risk factors and facilitate patient education, and a pharmacist performing such functions shall report the results obtained from such blood tests to the patient's physician of choice."

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

No.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists broad authority to administer injectable PrEP. The definition of "scope of practice" explicitly includes the administration of injectable drugs. Haw. Rev. Stat. Ann. § 461-1.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. Haw. Rev. Stat. Ann. § 461-1 (falls under the definition of "practice of pharmacy").

Does the CPA need to be patient-specific?

No.

Are there filing requirements?

It depends. If the CPA authorizes a pharmacist to initiate emergency contraception, the Board of Pharmacy must approve the agreement.

Are there content requirements?

No, there are no specific content requirements, but pharmacists may specifically be authorized to perform the following services: ordering or performing routine drug therapy; ordering drug therapy-related lab tests; initiating emergency contraception oral drug therapy; administering drugs orally, topically, by intranasal delivery, or by injection, pursuant to the order of the patient's licensed physician; administering certain vaccines and immunizations; initiating or adjusting a patient's drug regimen; transmitting prescriptions to another pharmacist for the purpose of filling or dispensing; providing consultation, information, or education to patients and health care professionals; and prescribing or dispensing an opioid antagonist.

Is there a time limit?

No.

Is the pharmacist required to undergo additional training?

No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No. Haw. Code R. § 461-1.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes. Hawaii Medicaid Provider Manual Attachment 4.19-B.

Does the law or regulation apply to specific services?

Yes, the law applies to "other licensed provider services" provided by a licensed pharmacist.

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists broad authority to administer injectable PrEP. The definition of "scope of practice" includes dispensing, "dispensing" includes drug administration, and "administration" explicitly includes drug administration by injection. Iowa Code Ann. § 155A.3.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. Iowa Code Ann. § 155A.48.

Does the CPA need to be patient-specific?

No.

Are there filing requirements?

No.

Are there content requirements?

Yes, the CPA must define the nature, scope, conditions, and limitations of the patient care and drug therapy management services to be provided by the pharmacist.

Is there a time limit?

No.

Is the pharmacist required to undergo additional training?

No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

Yes. Iowa Code Ann. § 155A.46.

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

Yes, pharmacists may provide point-of-care testing and treatment for influenza, streptococcus A, and COVID-19 as well as point-of-care testing at the point of interaction between a pharmacist and a patient in response to a public health emergency.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes. Iowa Medicaid Pharmaceutical Care Management.

Does the law or regulation apply to specific services?

Yes, the law applies only to pharmaceutical care management services for complex patients.

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists broad authority to administer injectable PrEP. The definition of "scope of practice" includes administration, and "administration" is interpreted to be included in the definition of "dispense". Idaho Code Ann. § 54-1705.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. Idaho Admin. Code r. 24.36.01.351 (emergency rule).

Does the CPA need to be patient-specific?

No.

Are there filing requirements?

No.

Are there content requirements?

Yes, the CPA must identify the parties to the agreement, the pharmacist's scope of practice authorized, and if necessary, any monitoring parameters.

Is there a time limit?

No.

Is the pharmacist required to undergo additional training?

No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

Yes. Idaho Code § 54-1704 (see "practice of pharmacy" definition).

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

No.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes. Idaho Medicaid Provider Handbook, General Information and Requirements for Providers.

Does the law or regulation apply to specific services?

Yes, the regulation applies to "medical services" provided by licensed pharmacists.

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

Yes, pharmacists may prescribe and dispense PrEP and PEP pursuant to a non-patient-specific standing order (1/1/23). H.B. 4430 (Ill. 2022); S.B. 1344 (Ill. 2023); 305 Ill. Comp. Stat. Ann. 5/5-5.12d; 225 Ill. Comp. Stat. Ann. 85/3, 85/43.5; 215 Ill. Comp. Stat. Ann. 5/356z.45; 215 Ill. Comp. Stat. Ann. 5/356z.60.

Does the pharmacist need a standing order from a PCP?

Yes, the pharmacist needs a non-patient-specific standing order issued by a licensed physician or the medical director of a county or local health department. The pharmacist is required to inform the patient’s PCP of any services related to the initiation and dispensing of PrEP or PEP. If the patient does not have a PCP, then the pharmacist must give them a list of PCPs or clinics in the area. The pharmacist may also prescribe pursuant to a non-patient-specific standing order issued by the Illinois Department of Public Health. However, the Illinois Department of Public Health has yet to issue such a standing order.

Does the legislation address pharmacists’ reimbursement or any other insurance provisions?

Yes, reimbursement for PrEP and PEP-related services is required to be 85% of what the rate would be if these same services had been provided by a primary care provider. Any accident and health insurance issued or renewed after 1/1/24, is required to provide coverage for PrEP and PEP.

Is there a quantity limit for prescriptions?

No, Illinois law does not impose quantity limits on pharmacy-initiated PrEP nor limit the frequency with which pharmacists can prescribe PrEP or PEP to a given patient.

Does the pharmacist have to undergo additional training?

Yes, pharmacists seeking to initiate and dispense PrEP and PEP must first complete an educational training program related to PrEP and PEP that is accredited by the ACPE or Department of Financial and Professional Regulation.

Do pharmacists have the legal authority to administer injectable PrEP?

No, administration is prohibited. Administration is explicitly limited to only five listed prescription drug types. Injectable PrEP does not fall into one of these five types of injectable drugs, and pharmacists are, therefore, prohibited from administration. 225 Ill. Comp. Stat. Ann. 85/3.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes, pharmacists are allowed to enter into a CPA with a PCP for the provision of PrEP and PEP for eligible patients. 225 Ill. Comp. Stat. Ann. 85/43.5 (specific to HIV PrEP/PEP; CPA standing order).

Does the CPA need to be patient-specific?

No, but pharmacists may only initiate PrEP or PEP for patients whose test results are nonreactive. Patients with reactive test results must be referred to an appropriate health care professional or clinic.

Are there filing requirements?

No.

Are there content requirements?

Yes, pharmacists must communicate the services that will be provided to the patient and the patient’s PCP. If the patient does not have a PCP, the pharmacist shall give the patient a list of providers in the area. The services provided must be documented and retained in a confidential manner consistent with state HIV confidentiality requirements.

Is there a time limit?

No.

Is the pharmacist required to undergo additional training?

Yes, the pharmacist shall complete an educational training program accredited by the Accreditation Council for Pharmacy Education and approved by the Department that is related to the initiation, dispensing, or administration of drugs, laboratory tests, assessments, referrals, and consultations for PrEP and PEP.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

Yes. 225 Ill. Comp. Stat. § 85/3.

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

Yes, statute specifically authorizes provision of CLIA-waived tests for PrEP and PEP initiation as well as ordering and administration of tests and screenings for influenza, SARS-COV 2, and "health conditions identified by a statewide public health emergency, as defined in the Illinois Emergency Management Agency Act."

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists broad authority to administer injectable PrEP. The definition of "scope of practice" includes administration, and "administration" explicitly includes drug administration by injection. Ind. Code Ann. § 25-26-13-2.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. Ind. Code Ann. § 25-26-13-2; Ind. Code Ann. § 25-26-16-4.5; Ind. Code Ann. § 155A.48.

Does the CPA need to be patient-specific?

Yes, the protocols developed under a CPA need to be patient-specific, but they may apply to a single patient or a group of patients.

Are there filing requirements?

No.

Are there content requirements?

Yes, the CPA must define the nature, scope, conditions, and limitations of the patient care and drug therapy management services to be provided by a pharmacist in order to ensure that a patient achieves the desired outcomes.

Is there a time limit?

No.

Is the pharmacist required to undergo additional training?

No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes, but only for services authorized under recently passed Indiana statute allowing pharmacists to deliver birth control without a prescription. Indiana HB 1568.

Does the law or regulation apply to specific services?

Yes, birth control.

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, but only pursuant to a CPA with a primary care provider. Kan. Stat. Ann. § 65-1626a.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes, statute permits pharmacists to enter into "Collaborative Drug Therapy Management (CDTM)" with a PCP. Kan. Stat. Ann. § 65-1626a; Kan. Admin. Regs. 68-7-22.

Does the CPA need to be patient-specific?

No, but a pharmacist shall not provide CDTM to a patient if the pharmacist knows that the patient is not being treated by the same physician who has signed the agreement.

Are there filing requirements?

Yes, the collaborating pharmacist must submit a copy of the agreement to the Board of Pharmacy within 5 business days of the agreement being signed by all parties.

Are there content requirements?

Yes, the agreement must define the nature, scope, conditions, and limitations of the patient care and drug therapy management services to be provided by a pharmacist. The agreement must be signed by the participating physician and pharmacist and must include: 1) the general methods, procedures, and decision criteria that the pharmacist must follow; 2) the procedures the pharmacist must use to document the CDTM decisions made by the pharmacist; 3) the procedures that the pharmacist is to follow to communicate to the physician changes in the patient's condition and each CDTM decision made by the pharmacist; 4) situations in which the pharmacist is required to initiate contact with the physician; and 5) the procedures to be followed by the pharmacist if an urgent situation involving a patient's health occurs. The pharmacist must contact the physician within 48 hours of making any changes to the patient's treatment.

Is there a time limit?

Yes, the agreement must be reviewed and updated every 2 years.

Is the pharmacist required to undergo additional training?

No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

Yes. K.S.A. 65-16,131.

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

Yes, pharmacists may initiate test and treat under a statewide protocol for flu, strep, and UTI.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists broad authority to administer injectable PrEP. The definition of "scope of practice" includes administration, and "administration" explicitly includes drug administration by injection. Ky. Rev. Stat. Ann. § 315.010.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes, pharmacists are allowed to enter into a "collaborative care agreement (CCA)" with a PCP. Ky. Rev. Stat. Ann. § 315.010(5); 201 Ky. Admin. Regs. 2:220.

Does the CPA need to be patient-specific?

No, the CCA does not need to be patient-specific. However, the pharmacist must document each patient (and the patient’s identifiable info) receiving care under the CCA. The patient’s drug-related healthcare needs must fall within the practitioner’s statutory scope of practice. Patients must be referred by the practitioner or practitioners to the pharmacist(s).

Are there filing requirements?

No.

Are there content requirements?

Yes, the CCA must: 1) identify the physician(s) and pharmacist(s) who are parties to the agreement; 2) specify the drug-related regimen to be provided, and how drug therapy is to be monitored; 3) stipulate the conditions for initiating, continuing, or discontinuing drug therapy and the conditions which warrant modifications to dose, dosage regimen, dosage form, or route of administration; 4) be in writing; 5) be signed and dated by each practitioner and pharmacist who is a party to the CCA; 6) provide the method for referral of patients to be managed under the CCA; 7) state the method for terminating the CCA; 8) contain the protocol, criteria, standing orders, or other method by which services are authorized; 9) contain the method established for the assessment of patient outcomes, if appropriate; and 10) indicate the lab tests that may be ordered. Documentation relating to the care and course of therapy of the patient pursuant to the agreement shall be documented in the patient's record maintained by the pharmacist, provided to the collaborating practitioner, and be readily available to other healthcare professionals providing care to the patient.

Is there a time limit?

No.

Is the pharmacist required to undergo additional training?

No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists limited authority to administer injectable PrEP. Pharmacists are required to undergo additional training in order to administer medications, which includes injectable drugs. Pharmacists must also complete an ACPE-approved certificate program for medication administration that provides at least 20 hours of instruction and experiential training on the following areas: 1) standards for medication administration practices; 2) basic immunology; 3) recommended medication administration schedules; 4) medication storage and management; 5) informed consent, physiology, and techniques for medication administration; 6) pre- and post-administration assessment and counseling; 7) medication administration record management; and 8) management of adverse events, including identification and appropriate response, as well as documentation and reporting. 46 La. Admin. Code Pt. LIII, § 521.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes, pharmacists are allowed to enter into "collaborative drug therapy management (CDTM)" with a PCP. La. Admin. Code tit. 46, Pt LIII § 523.

Does the CPA need to be patient-specific?

Yes.

Are there filing requirements?

Yes, pharmacists must apply to the Board of Pharmacy for registration to engage in CDTM.

Are there content requirements?

Yes, the contents of the agreement are limited to: 1) monitoring and modifying disease-specific drug therapy; 2) collecting and reviewing patient history; 3) obtaining and reviewing vital signs, including pulse, temperature, blood pressure, and respiration; 4) ordering, evaluating, and applying lab results (but the pharmacist may not interpret such test results or formulate a diagnosis); and 5) providing disease-specific counseling and education. The physician must sign a written set of instructions called an order set that contains, at a minimum, the: 1) pharmacist and physician, and their contact information; 2) patient's name, address, gender, date of birth, and telephone number 3) the disease or condition to be managed; 4) the disease-specific drug or drugs to be utilized; 5) the type and extent of drug therapy management the physician authorizes the pharmacist to perform; 6) specific responsibilities of the pharmacist and physician; 7) procedures, criteria, or plan the pharmacist is required to follow; 8) specific lab or other tests, if any, the physician authorizes the pharmacist to perform; 9) reporting and documentation requirements of the pharmacist and physician; 10) conditions and events in which the pharmacist and physician are required to notify each other; and 11) procedures to accommodate immediate consultation by telephone or direct telecommunication with, between, or among the pharmacist, physician, and the patient. The order set must also include a predetermined range of medication set by the physician.

Is there a time limit?

Yes, the pharmacist must reapply to engage in CDTM each year. A pharmacist’s registration to engage in CDTM shall terminate in the event of any of the following: 1) the pharmacist’s or physician’s death; 2) the pharmacist’s loss of license; 3) disciplinary action limiting the pharmacist’s ability to participate in CDTM; 4) notification to the Board of Pharmacy that the pharmacist has withdrawn from CDTM; 5) a finding by the Board of any cause that would render the pharmacist ineligible for registration; or 6) expiration of the pharmacist’s license or registration to engage in CDTM. The order set shall also be reviewed annually by the collaborating physician, or more frequently as deemed necessary.

Is the pharmacist required to undergo additional training?

No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes, for limited services. Louisiana Medicaid Pharmacy Benefits Management Services Manual, Chapter 37.

Does the law or regulation apply to specific services?

The law applies only to administering immunizations (influenza, hepatitis, HPV, etc.) and family planning items/services.

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

No, pharmacists are explicitly permitted to only administer four types of vaccines/injections. Injectable PrEP does not fall into one of these four types. 247 Mass. Code Regs. 2.00.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. Mass. Gen. Laws Ann. ch. 112, §§ 24B ½, 24B ¾; 247 Mass. Code Regs. 16.02 — .04.

Does the CPA need to be patient-specific?

Yes.

Are there filing requirements?

No, but the pharmacist must maintain a copy of the agreement, including copies of patient referral and patient consent, in the primary practice setting, readily retrievable at the request of the Board of Registration in Pharmacy and Board of Registration in Medicine. The physician must also maintain the original agreement, including the patient referral and patient consent, in the patient's medical record in the custody of the supervising physician.

Are there content requirements?

Yes, there are content requirements that depend on the pharmacy setting. In the community pharmacy setting, the agreement shall include: 1) a written referral of a specific patient from the supervising physician to an authorized pharmacist; and 2) the written consent of the patient to the agreement. In all practice settings, the agreement shall include: 1) specific disease states being co-managed including identification as primary or co-morbid; 2) specific pharmacist prescribing authority pursuant to the agreement; 3) detailed practice protocols; 4) description of risk management activities; 5) documentation of any initiation, modification or discontinuation of a patient’s medication in the patient's permanent medical record; 6) description of outcome measurements; 7) detailed informed consent procedures; and 8) detailed procedures and periods by which time any test results, copies of initial prescriptions, modifications or discontinuances, copies of the patient consent and the agreement, and other patient information will be forwarded by the pharmacist to the physician, and a specific procedure for the pharmacist to identify and transmit any urgent communications; description of the nature and form of the supervision of the pharmacist by the physician, and a description of the procedure to follow when either the pharmacist or physician is unavailable or absent

Is there a time limit?

Yes, the CPA must be renewed every two years.

Is the pharmacist required to undergo additional training?

Yes, the pharmacist must complete, in each year of the term of the CPA, at least 5 additional contact hours of Board-approved continuing education that address areas of practice generally related to the particular CPA.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes. MassHealth Provider Manual Series, Subchapter 4. Program Regulations (2022); MassHealth Pharmacy Covered Professional Services List.

Does the law or regulation apply to specific services?

Yes, the MassHealth Pharmacy Covered Professional Services List specifies certain services that may be provided by a pharmacy provider and payable through the Pharmacy Online Processing System (POPS). Services include the administration of numerous vaccines, including influenza, COVID-19, hepatitis A and B, HPV, and many others.

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP. 

Do pharmacists have the legal authority to administer injectable PrEP?

No. Administration is explicitly limited to only certain listed prescription drug types. Injectable PrEP does not fall into one of these types of injectable drugs, and pharmacists are, therefore, prohibited from administration. While pharmacists are permitted to administer injectable drugs for the treatment of sexually transmitted infections, they are not permitted to administer injectable drugs for the prevention of sexually transmitted infections. Md. Code Ann., Health Occ. § 12-101; Md. Code Ann., Health Occ. § 12-509.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes, pharmacists are allowed to enter into a “physician-pharmacist agreement.” Md. Code Ann., Health-Gen. § 19-713.6; Md. Code Regs. 10.34.29.03 — .07.

Does the CPA need to be patient-specific?

It depends. A general physician-patient agreement does not need to be patient-specific. However, an agreement specifically concerned with drug therapy management must be patient-specific.

Are there filing requirements?

Yes, the pharmacist must submit a copy of the agreement and any subsequent modifications to the State Board of Pharmacy. The physician must submit a copy of the agreement and any subsequent modifications to the State Board of Physicians. Modifications to the agreement shall be registered with the Board of Pharmacy within 30 days. The Board of Pharmacy requires a $100 fee per agreement.

Are there content requirements?

Yes, the agreement must contain: 1) names and signatures of the physicians with prescriptive authority and pharmacists authorized to act under the contract; 2) locations where the pharmacist may provide services; 3) titles of the protocols to which the agreement pertains; 4) methods and time frames by which documentation and routine communication will occur between the physicians and the pharmacists, including the time frames in which the pharmacist will fully update the patient's record in writing; 5) name, address, and telephone number of the party to the agreement who is to receive correspondence from the Boards related to the agreement; 6) statement that the physicians and pharmacists shall comply with all State and federal laws relating to patient confidentiality; and 7) list of devices available to the pharmacists performing under the agreement, which are relevant to the disease-states or conditions to be managed. The therapy management contract shall contain: 1) list of allowable substitutions of chemically dissimilar drugs, if any; 2) statement that none of the parties have been coerced, given economic incentives, or are involuntarily required to participate in the contract; 3) statement that the pharmacist shall notify the prescribing provider if the pharmacist modifies the dose or agent under the contract, or detects an abnormal result from an assessment activity; 4) notice to the patient stating that the patient may terminate the contract at any time and the procedure by which they may terminate; 5) procedure for periodic review of drugs by the prescribing provider; 6) reference to the protocol(s) under which the pharmacist shall act; and 7) exceptions or limitations to the protocol(s) for the specific patient.

Is there a time limit?

No.

Is the pharmacist required to undergo additional training?

No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

Yes. MD ADC 10.10.03.02.

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

Yes, a pharmacist may obtain a letter of exception that allows them to independently perform the following CLIA-waived tests in a medical laboratory: whole blood glucose, Prothrombin Time/International Normalized Ratio, blood lipid for cholesterol, whole blood lead testing, and urine drug screens.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes, but very vague and non-specific. Marland Department of Health, Medicaid Pharmacy Program Provider Information (see Provider Manual link on this page – downloads a Word document); 2022 Maryland Medical Assistance Program
Professional Services Provider Manual.

Does the law or regulation apply to specific services?

Unclear.

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

Yes, a statewide protocol gives pharmacists the authority to independently initiate PrEP and PEP (enacted 6/18/21). LD 1115 (Maine, 2021); Me. Rev. Stat. tit. 22, § 3174-M; Me. Rev. Stat. tit. 24-A, § 4317-D; Me. Rev. Stat. tit. 32, § 13702-A(28); Me. Rev. Stat. tit. 32, § 13786-E.

Does the pharmacist need a standing order from a PCP?

No.

Does the legislation address pharmacists’ reimbursement or any other insurance provisions?

Yes, insurance companies are required to cover PrEP and PEP prescribed by pharmacists without prior authorization or step therapy for the time period pharmacists are permitted to prescribe PrEP and PEP.

Is there a quantity limit for prescriptions?

Yes, pharmacists are limited to prescribing up to 60 days of PrEP in a two-year period and one complete, 28-day course of PEP.

Does the pharmacist have to undergo additional training?

No.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists limited authority to administer injectable PrEP. Pharmacists may only administer drugs, including injectable prescription drugs, in compliance with a treatment protocol established by a licensed practitioner. A copy of the original treatment protocol and any subsequent revisions to the treatment protocol must be kept on file. Me. Rev. Stat. tit. 32, § 13702-A.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. Me. Rev. Stat. tit. 32, § 13843; Code Me. R. tit. 02-392 Ch. 39-A, § 3.

Does the CPA need to be patient-specific?

No.

Are there filing requirements?

Yes, pharmacists must submit a copy of the CPA to the Board of Pharmacy before the agreement is effective.

Are there content requirements?

Yes, the CPA must contain: 1) a provision stating that activity in the initial 3 months of a CPA, the pharmacist is limited to monitoring drug therapy (the CPA may then be expanded to include initiating, administering, monitoring, modifying, and discontinuing a patient’s drug therapy); 2) identification and signatures of the parties to the CPA, the dates the agreement is signed, and the beginning and ending dates of the period the agreement is in effect; 3) a provision allowing either party to cancel the CPA by written notification; 4) the site at which the collaborative practice will occur; 5) qualifications of the participants in the CPA; 6) a detailed description of the types of diseases, drugs, or drug categories involved and collaborative drug therapy management allowed in each patient's case; 7) a procedure for referring each patient to the practitioner; 8) a plan for measuring and assessing patient outcomes; 9) a requirement that all parties maintain professional liability insurance that covers the CPA; 10) treatment protocol(s) that will be utilized; 11) a provision stating that the CPA will terminate immediately in the event that the pharmacist no longer holds an unrestricted pharmacist license and immediately when the pharmacist knows or should know that the nurse practitioner no longer holds an unrestricted license; 12) a provision stating that the CPA will terminate upon the death of a party to the agreement; and 13) specify how the continuity of care for patients will be handled in the event that the CPA suddenly terminates. The collaborating pharmacist and PCP must establish a procedure for reviewing and revising the agreement. Any amendments must be documented, signed, and dated.

Is there a time limit?

No.

Is the pharmacist required to undergo additional training?

No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, but only if under the authority of a CPA with a PCP. The definition of "scope of practice" includes "dispense," and dispensing medication must be pursuant to a prescription or other authorization issued by a prescriber. Mich. Comp. Laws Ann. § 333.17707; Mich. Comp. Laws Ann. § 333.17703.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 N/A

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes. Michigan Department of Health & Human Services, Payment Rates for MTM Services; Medicaid Provider Manual, Practitioner.

Does the law or regulation apply to specific services?

Yes, pharmacists can be reimbursed for providing medication therapy management (MTM) services.

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, but only under the authority of a collaborative practice agreement with a PCP. Minn. Stat. Ann. § 151.01.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. Minn. Stat. Ann. § 151.01(subd. 27).

Does the CPA need to be patient-specific?

No.

Are there filing requirements?

No.

Are there content requirements?

No.

Is there a time limit?

No.

Is the pharmacist required to undergo additional training?

No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

Yes. Minn. Stat. Ann. § 151.01(subd. 27).

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

No, but the pharmacist may not modify drug therapy as a result of the clinical test without a CPA.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes. Minnesota Medicaid Provider Manual, Pharmacy Services; Minnesota Medicaid Provider Manual, Medication Therapy Management Services (MTMS); Minn. Stat. § 265B.0625 (2022); 

Does the law or regulation apply to specific services?

Yes, pharmacists can be reimbursed for providing family planning services and supplies, administering vaccines, and providing medication therapy management (MTM) services.

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, but only under the authority of a CPA with a PCP. Mo. Ann. Stat. § 338.010.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes, pharmacists are allowed to enter into a "written protocol" with PCP. Mo. Ann. Stat. § 338.010; Mo. Code Regs. Tit. 20 §§ 2150-5.024, 5.028, 5.029.

Does the CPA need to be patient-specific?

Yes.

Are there filing requirements?

Yes, the collaborating pharmacist must submit proof of successful completion of a board-approved course of academic clinical study to the state board of pharmacy before entering into a written protocol.

Are there content requirements?

Yes, the protocol must include the following: 1) the identity and signatures of the physician and pharmacist; 2) effective dates; 3) a statement of clinical conditions, diagnoses, diseases, and specific drugs or drug categories included in the protocol and the type of medication therapy services allowed in each case; 4) a statement of the methods, procedures, decision criteria, and plan the pharmacist is to follow when conducting medication therapy services; 5) procedures for documenting decisions made by the pharmacist and a plan for communication, feedback, and reporting to the physician; 6) a mechanism and procedure that allows the physician to override, rescind, modify, or otherwise amend the protocol; 7) a statement that the pharmacist shall not delegate their responsibility to another person; 8) a description of any authority granted to the pharmacist to administer any drug or medication including the identification of any such drug, medication, or device; 9) a description of drug therapy related patient assessment procedures or testing that may be ordered or performed by the pharmacist, including lab testing; 10) provisions for allowing the pharmacist to access the patient's medical records; 11) a provision for providing the physician access to patient records for medication therapy services provided by the pharmacist for patients of the authorizing physician; 12) provisions establishing a course of action the pharmacist is authorized to follow to address emergency situations; 13) criteria for timely communication between the physician and pharmacist; 14) notification requirements; and 15) the method for reviewing the pharmacist's work by the physician. HIV PEP protocols must, at a minimum, include the following: 1) directions/guidelines for patient assessment and counseling; 2) authorized drug therapies to be dispensed, including the specified dosage regimen and forms; 3) authorized route(s) of administration; 4) specific requirements for referring patients to a healthcare provider for additional evaluation/treatment; 5) any patient counseling requirements designated by the authorizing physician; and 6) any documentation or recordkeeping required by the authorizing physician. Protocols must also be signed and dated by the authorizing physician and the authorized pharmacist.

Is there a time limit?

Yes, the protocol must be reviewed and signed by the pharmacist and the physician every year. Prescription orders can be valid for no more than 1 year.

Is the pharmacist required to undergo additional training?

No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No specific statute specifically allowing or prohibiting pharmacists from independently providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes. MO HealthNet Pharmacy Manual.

Does the law or regulation apply to specific services?

Yes, pharmacists can be reimbursed for participating in the medication therapy management (MTM) program, administering vaccines, and providing diabetes self-management training. Pharmacy providers can no longer bill for long-acting reversible contraceptives (e.g., implants, IUDs).

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists broad authority to administer injectable PrEP. The definition of "scope of practice" includes administration, and "administration" explicitly includes drug administration by injection. Miss. Code. Ann. § 73-21-73.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes, pharmacists are allowed to enter into a "written guideline" or "protocol" with a PCP. 30 Code Miss. R. Pt. 2630, R. 2.3, 2.4.

Does the CPA need to be patient-specific?

Yes.

Are there filing requirements?

Yes, the protocol must be filed with the Mississippi State Board of Pharmacy and the Mississippi State Board of Medical Licensure.

Are there content requirements?

Yes, the protocol must: 1) identify the physician who agrees to supervise the pharmacist and the scope of the physician's active practice; 2) describe the specific responsibilities authorized by the physician; 3) describe the method the pharmacist shall use to document decisions or recommendations they make to the physician; 4) describe the patient activities the physician requires the pharmacist to monitor; 5) describe the types of reports the physician requires the pharmacist to report and the schedule by which they are to submit these reports; 6) include a statement of the medication categories and the type of initiation and modification of drug therapy that the physician authorizes the pharmacist to perform; 7) describe the procedures or plan the pharmacist shall follow if they exercise initiation and modification of drug therapy; 8) indicate the date the agreement ends; 9) be dated and signed by the pharmacist(s) and physician(s); 10) include a statement that the patient has been notified by the pharmacist(s) and physician(s) that an agreement exists; and 11) includes a statement which certifies that the physician(s) have advised their respective malpractice liability carriers concerning the protocol, and that any potential liability that may ensue as a result of implementing the agreement shall be covered by those policies or endorsements. The above content requirements apply to agreements authorizing care and consultation with a patient, agreements authorizing initiation and/or modification of prescription drug therapy, and agreements authorizing lab work. The protocol must also be signed by each patient.

Is there a time limit?

Yes, the duration of the protocol cannot be longer than 1 year.

Is the pharmacist required to undergo additional training?

No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes. Mississippi Division of Medicaid Administrative Code, Title 23, Part 214: Pharmacy Services.

Does the law or regulation apply to specific services?

Yes, pharmacists can be reimbursed for disease state management services, including patient evaluation and education, drug therapy review, and other disease state management activities.

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP. 

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, but only under the authority of a CPA with a PCP. Mont. Code Ann. § 37-7-101.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. Mont. Admin. R. 24.174.524.

Does the CPA need to be patient-specific?

No.

Are there filing requirements?

No, but the pharmacist must maintain a written copy of the agreement that is available for inspection by the Board of Pharmacy.

Are there content requirements?

Yes, the CPA must include 1) identification of the practitioner(s) who are parties to the agreement; 2) the types of decisions that the pharmacist is allowed to make; 3) a method for the practitioner to monitor compliance with the agreement and clinical outcomes and to intercede where necessary; 4) a provision allowing the practitioner to override a decision made by the pharmacist if the practitioner deems it necessary or appropriate; 5) a provision allowing either party to cancel the agreement by written notification; 6) an effective date; 7) signatures of collaborating pharmacists and practitioners, or a representative from the medical practice or clinic that is authorized to represent its practitioners, who are party to the agreement, as well as dates of signing; and 8) a procedure for periodic review and renewal within a clinically-appropriate timeframe.

Is there a time limit?

No.

Is the pharmacist required to undergo additional training?

No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 Yes, statewide standing order gives immunizing pharmacists the authority to independently initiate PEP (not PrEP) (Effective since March 2022). B. 96 (N.C. 2021); C. Gen. Stat. Ann. § 90-85.15B; C. Gen. Stat. Ann. § 90-85.3(i1); NC PEP Standing Order.

Does the pharmacist need a standing order from a PCP?

No. A standing order authorizing pharmacists to independently prescribe PEP was signed by the North Carolina State Health Director and was effective immediately upon signing. Pharmacists are required to inform a patient’s PCP within 72 hours of prescribing PEP. If the patient does not have a PCP, then the pharmacist must provide a list of local PCPs.

Does the legislation address pharmacists’ reimbursement or any other insurance provisions?

No, North Carolina law does not address pharmacist’s reimbursement or other insurance provisions regarding PrEP and PEP related services.

Is there a quantity limit for prescriptions?

No, North Carolina law does not impose quantity limits on pharmacy-initiated PrEP nor limit the frequency with which pharmacists can prescribe PrEP or PEP to a given patient.

Does the pharmacist have to undergo additional training?

It depends. The standing order only permits “immunizing pharmacists” to prescribe PEP. To be qualified as an immunizing pharmacist in North Carolina, a pharmacist must: 1) hold CPR certification issued by the American Heart Association or the American Red Cross, or an equivalent certification; 2) complete a vaccine administration certificate program that is accredited by the CDC, ACPE, or a similar health authority or professional body approved by the Board of Pharmacy; 3) maintain documentation of three hours of continuing education every two years, designed to maintain competency in the disease states, drugs, and vaccine administration; 4) complete training approved by the Division of Public Health's Immunization Branch for participation in the North Carolina Immunization Registry; 5) notify the North Carolina Board of Pharmacy and the North Carolina Medical Board of immunizing pharmacist status; and 6) administer vaccines, long-acting injectable medications, or immunizations.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, pharmacists have limited authority to administer. The definition of scope of practice includes administration, subject to certain requirements. Administration explicitly includes drug administration by injection. An immunizing pharmacist may administer a long-acting injectable medication to an adult pursuant to a patient-specific prescription if the following requirements are met: 1) keep on file a record of the patient and drug administration and 2) notify within 72 hours the provider who wrote the prescription whether the drug was administered. C. Gen. Stat. Ann. § 90-85.3A; C. Gen. Stat. Ann. § 90-85.3; C. Gen. Stat. Ann. § 90-85.15B

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. C. Gen. Stat. Ann. § 90-85.3A; C. Gen. Stat. Ann. § 90-18(c)(3a); C. Gen. Stat. Ann. § 90-18.4; 21 N.C. Admin. Code 46.3101.

Does the CPA need to be patient-specific?

Yes.

Are there filing requirements?

Yes, the pharmacist must receive approval from the Board of Pharmacy to engage in a CPA. To receive approval, the pharmacist must submit an application and corresponding fee as well as a signed copy of the CPA to the Board. If the pharmacist and primary care practitioner terminate CPA, the Board of Pharmacy must be notified within 10 days of the agreement’s termination. Pharmacists must keep a written copy of CPA on file, which must be made available to the Board of Pharmacy upon request. The initial application fee is $100, and the annual renewal fee is $50.

Are there content requirements?

Yes, the CPA must identify the following: 1) the collaborating pharmacist; 2) the collaborating PCP; and 3) a description of the scope of services covered under the CPA. Regarding the scope of services, the CPA must explicitly specify the decisions the pharmacist is authorized to make. This includes the types of drugs or drug categories involved and the type of collaborative authority. The CPA must be disease-specific. The pharmacists and PCP must each sign the CPA. The CPA must include a statement prohibiting the pharmacist from substituting chemically dissimilar drug products by the CPA for the product prescribed by the PCP without first obtaining the written consent of the PCP. For the first six months following the date the CPA goes into effect, the pharmacist and PCP must meet monthly to discuss services provided pursuant to the CPA. After the first six months, the pharmacist and PCP must meet every six months to discuss services provided pursuant to the CPA. The CPA must require the patient to be notified of the CPA’s existence and contents.

Is there a time limit?

Yes, the CPA and the pharmacist’s authority to engage in a CPA must be reviewed by the Board of Pharmacy once a year.

Is the pharmacist required to undergo additional training?

Yes, the pharmacist is required to undergo and provide proof to the Board of Pharmacy of 35 hours of practice-relevant continuing education each year. A pharmacist must have a certain number of years’ experience in the practice of pharmacy based on the pharmacist’s level of education. A pharmacist must meet one of the three following criteria to engage in a CPA: 1) Certification from the Board of Pharmaceutical Specialties, is a Certified Geriatric Pharmacist as certified by the Commission for Certification in Geriatric Pharmacy, or has completed an American Society of Health System Pharmacists (ASHP) accredited residency program with two years of Clinical Experience approved by the Board of Pharmacy; 2) Holds the academic degree of Doctor of Pharmacy, has three years of Clinical Experience approved by the Boards, and has completed a North Carolina Center for Pharmaceutical Care (NCCPC) or ACPE-approved certificate program in the area of practice covered by the CPA; and 3) Holds the academic degree of Bachelor of Science in Pharmacy, has five years of Clinical Experience approved by the Boards, and has completed two NCCPC or ACPE approved certificate programs with at least one program in the area of practice covered by the CPA.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

 Yes, pharmacists have limited authority to administer. To be eligible for drug administration, a pharmacist must be certified through an ACPE-approved course for drug administration. Pharmacists must receive a written protocol from a primary care provider that identified the following information: 1) identity of the practitioner issuing the order; 2) identity of the patient to receive the injection; 3) identity of the medication and dose to be administered; and 4) date of the original order and the dates or schedule, if any, of each subsequent administration. Pharmacists must also have a private space to administer injections. D. Admin. Code 61-04-11-02; D. Admin. Code 61-04-11-04; D. Admin. Code 61-04-11-07.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. D. Cent. Code Ann. § 43-15-31.4.

Does the CPA need to be patient-specific?

 No.

Are there filing requirements?

 No, but the pharmacist must make a copy of the CPA available to the Board of Pharmacy upon request.

Are there content requirements?

 Yes, the CPA must require the pharmacist to document any services provided to the patient pursuant to the CPA in said patient’s medical file. The CPA must include a provision that requires the pharmacist to immediately notify the PCP if the pharmacist initiates or modifies a drug therapy. The CPA may authorize the pharmacist to have limited prescriptive practices to initiate or modify drug therapy following diagnosis or established protocols by a PCP. “Primary care practitioner” includes an advanced practice registered nurse.

Is there a time limit?

 No.

Is the pharmacist required to undergo additional training?

 No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 Yes, pharmacists have the legal authority to independently perform CLIA-waived tests. N.D. Admin. Code 61-04-10-06.

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

 Yes, the following tests are included: total cholesterol, HDL cholesterol, LDL cholesterol, and triglycerides test by any accepted method; bilirubin, blood, glucose, ketone, leukocyte, nitrate, potential of hydrogen (pH), protein, specific gravity, and urobilinogen tests by nonautomated or automated urinalysis by dipstick; fecal occult blood by any accepted method; ovulation test by visual color comparison; qualitative urine pregnancy test by visual color comparison; erythrocyte sedimentation rate by any accepted nonautomated method; whole blood glucose by any accepted single analyte method; spun microhematocrit by any accepted method; hemoglobin by single analyte instrument or manual copper sulfate method; helicobacter pylori, influenza, mononucleosis, streptococcus group A, hepatitis C virus, and respiratory syncytial virus by immunoassay using a rapid test device that detects antibodies or antigens; prothrombin time international normalized ratio by mechanical endpoint; antibodies to HIV types 1 and 2; nicotine or cotinine test by urine; thyroid stimulating hormone test by blood; bone mass and bone mineral density test by any accepted method; and drug screening tests by urine.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 Yes. Pharmacy Medical Billing.

Does the law or regulation apply to specific services?

 Yes, pharmacists are reimbursable for tobacco cessation counseling, immunizations, and MTM services.

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP. 

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists broad authority to administer injectable PrEP. The definition of "scope of practice" includes administration, and "administration" explicitly includes drug administration by injection. Neb. Rev. Stat. Ann. § 38-2806; Neb. Rev. Stat. Ann. § 38-2837.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. Neb. Rev. Stat. Ann. § 38-2867.03.

Does the CPA need to be patient-specific?

No.

Are there filing requirements?

Yes, the pharmacist must notify the Board of Pharmacy of the CPA and any subsequent amendments to the CPA. The notice must identify the PCP with whom the pharmacist is entering into the CPA and provide a description of the therapy being monitored or initiated. A copy of the CPA must be made available to the Board upon request.

Are there content requirements?

Yes, the CPA must be in writing and signed by both the pharmacist and the PCP. The CPA is effective once both parties have signed. The CPA should identify the drug therapy being monitored or initiated.

Is there a time limit?

Yes, the CPA must be renewed every 2 years.

Is the pharmacist required to undergo additional training?

No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests. 

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists broad authority to administer injectable PrEP. The definition of "scope of practice" includes administration, and "administration" includes the provision of drugs pursuant to a prescription order, which is interpreted to include injectable prescription drugs. N.H. Rev. Stat. Ann. § 318:1.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. N.H. Rev. Stat. Ann. § 318:16-a; N.H. Code Admin. R. Ph 1103.01; N.H. Code Admin. R. Ph 1104.01; N.H. Code Admin. R. Ph 1105.01—.03.

Does the CPA need to be patient-specific?

Yes, the CPA must be patient-specific. The pharmacist must obtain the written consent of the patient to provide services under the CPA. Such a statement must include explicit consent for the pharmacist to provide the services outlined in the CPA.

Are there filing requirements?

Yes, the pharmacist must submit a copy of the CPA and proof of professional liability insurance to the Board of Pharmacy. Any subsequent changes made to the CPA must be submitted to the Board within 15 days of such changings going into effect. The pharmacist and PCP must each keep a copy of the CPA on file, which the Board can request a copy of at any time.

Are there content requirements?

Yes, the CPA must: describe the types of decisions concerning the management of drug therapy that the pharmacist is authorized to make, which may include a specific description of the diseases and drugs for which the pharmacist is authorized to manage drug therapy; list the laboratory tests that the pharmacist may order to manage a medication therapy; include a statement of the expected amount of dedicated time that a pharmacist will use exclusively to perform duties in the CPA; list beginning and ending dates agreement will be in effect; state the conditions and events for which the pharmacist must notify the PCP; and include a statement that the agreement may be terminated in writing by either party at any time. The pharmacist must also have at least $1,000,000 of professional liability insurance coverage.

Is there a time limit?

Yes, the CPA must be renewed every 2 years.

Is the pharmacist required to undergo additional training?

It depends. The pharmacist may have to undergo additional training if the Board of Pharmacy determines such training is necessary for the pharmacist to adequately provide the services outlined in the CPA. If the CPA delegates authority to administer vaccines, the pharmacist is required to hold current basic or higher certification in cardiopulmonary resuscitation (CPR) from the American Heart Association, the American Red Cross, or another organization or entity that is nationally recognized as an issuer of such certifications.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests. 

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, but only under the authority of a CPA with a PCP. N.J. Stat. Ann. § 45:14-41.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. N.J. Admin. Code §§ 13:39-13.3—13.5.

Does the CPA need to be patient-specific?

No.

Are there filing requirements?

Yes, the pharmacist must receive approval from the Board of Pharmacy to engage in a CPA. To receive approval, the pharmacist must submit proof that one of the following has been completed: 1) an ACPE-approved training program; 2) a post-graduate residency program accredited by the American Society of Health-System Pharmacists; or 3) a certification program from the Board of Pharmacy Specialties. A written copy of the CPA and any changes made to the CPA must be made available to the Board of Pharmacy upon request.

Are there content requirements?

Yes, the CPA must identify the following: 1) the collaborating pharmacist; 2) the collaborating PCP; 3) the date of the agreement; and 4) the description of the scope of services covered under the CPA. Regarding the scope of services, the CPA must explicitly specify the decisions the pharmacist is authorized to make.  This includes the types of diseases, drugs, or drug categories involved and the type of collaborative authority.  The CPA must state the procedures, decision criteria, or plans the pharmacists are to follow when making therapeutic decisions, particularly when modification or initiation of drug therapy is involved. The CPA must be signed by both the pharmacist and the PCP. The CPA must state the effective date of the agreement and must include a statement that the agreement may be terminated in writing by either party at any time.

Is there a time limit?

Yes, the CPA must be reviewed at least once per year by the parties to determine whether the protocol should be renewed, modified, or terminated.

Is the pharmacist required to undergo additional training?

Yes, the pharmacist must complete a minimum of 10 credits of continuing education every biennial renewal period in each disease(s) or condition(s) covered by the CPA.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No. Statute does not mention federal CLIA, but states that pharmacists may only order clinical laboratory tests “based on the standing orders of a physician as set forth in the written protocol, provided those laboratory tests are granted waived status in accordance with the provisions of the “New Jersey Clinical Laboratory Improvement Act,” P.L.1975, c. 166 (C.45:9-42.26 et seq.)”. N.J. Stat. Ann. 45:14-41.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

Yes, a statewide protocols give pharmacists the authority to independently initiate PrEP and PEP (PEP: effective since 5/31/21; PrEP: passed on 4/4/23, effect since 7/1/23). S.B. 92 (N.M. 2023); N.M. Stat. Ann. § 61-11-2; N.M. Admin. Code 16.19.26.14; AETC Pharmacists Providing PEP Training Program; Protocol for Pharmacists Providing HIV PEP Therapy in Conjunction with POCT.

Does the pharmacist need a standing order from a PCP?

No, the pharmacist does not need a standing order from a PCP. The pharmacist is required to inform a patient’s PCP of any services related to the initiation and dispensing of PrEP or PEP. The pharmacist must first obtain informed consent from the patient to do so.

Does the legislation address pharmacists’ reimbursement or any other insurance provisions?

No.

Is there a quantity limit for prescriptions?

No, New Mexico law does not impose quantity limits on pharmacy-initiated PrEP nor limit the frequency with which pharmacists can prescribe PrEP or PEP to a given patient.

Does the pharmacist have to undergo additional training?

Yes, the pharmacist must undergo additional training. To prescribe PEP, the pharmacist must follow the instructions of the Board of Pharmacy’s protocol. This protocol requires pharmacists to complete two hours of ACPE-approved continuing education regarding HIV PEP every two years. To prescribe PrEP, SB 92 requires pharmacists to follow the instructions of a statewide protocol developed by the Board of Pharmacy. However, the Board has yet to establish a protocol regarding pharmacists seeking to prescribe PrEP. Pharmacists in New Mexico must wait until such a statewide protocol is released before they may prescribe PrEP. 

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists broad authority to administer injectable PrEP. The definition of "scope of practice" includes administration, and "administration" explicitly includes drug administration by injection. N.M. Stat. Ann. § 61-11-2.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. N.M. Stat. Ann. § 61-11B-3; N.M. Admin. Code 16.19.4.7; N.M. Admin. Code 16.19.4.17.

Does the CPA need to be patient-specific?

No.

Are there filing requirements?

Yes, pharmacists must submit a copy of the CPA to the Board of Pharmacy to keep on file.

Are there content requirements?

Yes, the CPA must identify the following: 1) the collaborating pharmacist; 2) the collaborating PCP; and 3) a description of the scope of services covered under agreement. Regarding the scope of services, the CPA must explicitly specify the decisions the pharmacist is authorized to make.  This includes the types of diseases, drugs, or drug categories involved and the type of collaborative authority.  The CPA must state the procedures, decision criteria, or plans the pharmacists are to follow when making therapeutic decisions, particularly when modification or initiation of drug therapy is involved.  Granting authority to a pharmacist to provide services outside of the PCP’s scope of practice is explicitly prohibited. The CPA must establish a means for the PCP and pharmacist to communicate and must identify what laboratory tests, if any, the pharmacist is authorized to order.

Is there a time limit?

Yes, the CPA must be renewed every 2 years.

Is the pharmacist required to undergo additional training?

Yes, the pharmacist must apply for certification to enter into a CPA. To receive certification, the pharmacist must submit each of the following to the Board of Pharmacy: 1) proof of completion of a 60-hour, board-approved physical assessment course, followed by a 150-hour, 300-patient contact preceptorship supervised by a physician or other practitioner with prescriptive authority, with hours counted only during direct patient interactions and 2) a log of patient encounters initiated and completed within two years of the application. If the pharmacist is seeking to prescribe controlled substances through a CPA, then proof of completing a training course on responsible opioid prescribing practices must also be submitted to the Board. Pharmacists must be re-approved every other year. Recertification requires the following documentation to be sent to the Board: 1) proof of continuing education hours, including proof of completion of 2.0 CEU 20 contact hours of live CPE or continuing medical education (CME) approved by (ACPE) or ACCME; 2) a copy of the CPA signed by the collaborating PCP; and 3) a copy of initial CPA certification. If the CPA delegates the pharmacist the authority to prescribe controlled substances, the pharmacist must also submit proof of completing a minimum of 0.2 CEU (two contact hours) per renewal period in the subject area of responsible opioid prescribing practices. 

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No specific statute specifically allowing or prohibiting pharmacists from independently providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes. State of New Mexico Medical Assistance Program Manual, Supplement 22-03 (2022).

Does the law or regulation apply to specific services?

Yes, New Mexico law allows pharmacists to be certified to prescribe in areas such as hormonal contraception, tobacco cessation, immunizations, Naloxone drug therapy, tuberculosis testing (serum prescribing, administration, and follow-up reading are included as a single submission), and HIV Post-Exposure Prophylaxis (PEP) therapy, in accordance with the written protocols approved by the NMBOP.

Does the law or regulation require parity (equity) between pharmacists and other providers?

Yes, reimbursement shall be paid to the Pharmacist Clinician or entity at the same rate that is paid to a licensed physician, physician assistant (PA), or advanced nurse practitioner (NP) for the same service.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

Yes, a statewide protocol gives pharmacists the authority to independently initiate PrEP and PEP (enacted 10/1/21). S.B. 325 (Nev. 2021); Nev. Rev. Stat. Ann. §§ 639.0124, 639.28085; Nev. Rev. Stat. Ann. § 689B.0312; Nev. Admin. Code R039-21.

Does the pharmacist need a standing order from a PCP?

No.

Does the legislation address pharmacists’ reimbursement or any other insurance provisions?

Yes, Nevada law requires health insurers, Medicaid, and state employee plans to provide coverage and reimbursement for PrEP- and PEP-related services at a rate equal to the rate of reimbursement provided to a physician, physician assistant, or advanced practice registered nurse for similar services. State Medicaid is required to cover any laboratory tests ordered in connection with pharmacists prescribing PrEP and PEP.

Is there a quantity limit for prescriptions?

No.

Does the pharmacist have to undergo additional training?

Yes, the pharmacist prescribing and dispensing PrEP and PEP must complete a two-hour course approved by the ACPE regarding treatment for PrEP and PEP for HIV-negative persons. The pharmacist must also have professional liability insurance coverage of at least $1,000,000.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, statute gives pharmacists limited authority to administer injectable PrEP. Pharmacists have explicit authority to prescribe, dispense, and administer any drug approved by the FDA to prevent HIV. Before a pharmacist may do so, however, the pharmacist must meet the following requirements: 1) complete an ACPE-approved course of training concerning the prescribing, dispensing, and administering of such drugs; 2) maintain and make readily available proof of completion of the training course; and 3) maintain professional liability insurance coverage of at least $1,000,000. Nev. Rev. Stat. Ann. §§ 639.0124, 639.28085; Nev. Admin. Code R039-21 3.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. Nev. Rev. Stat. Ann. §§ 639.2623, 639.2627.

Does the CPA need to be patient-specific?

Yes. The pharmacist must obtain the written consent of the patient to provide services under the CPA. Such a statement must include explicit consent for the pharmacist to initiate, modify, or discontinue the medication of the patient pursuant to the CPA. The patient must also receive notification from the pharmacist of the following: 1) any test administered by the pharmacist and the results of such a test; 2) the name of any drug or prescription filled and dispensed by the pharmacist to the patient; and 3) the contact information of the pharmacist.

Are there filing requirements?

Yes, a written copy of the CPA must be submitted to the Board of Pharmacy.

Are there content requirements?

Yes, the CPA must describe the types of decisions concerning the management of drug therapy that the pharmacist is authorized to make, which may include a specific description of the diseases and drugs for which the pharmacist is authorized to manage drug therapy. The pharmacist must be required to document any services provided to the patient pursuant to the CPA in said patient’s medical file. Granting authority to the pharmacist to provide services outside of the PCP's scope of practice is explicitly prohibited. The CPA must include a clause granting the PCP authority to override the agreement if necessary to protect the health of the patient or accomplish the goals of the treatment prescribed for the patient. The CPA must establish a means for the PCP and pharmacist to communicate and document changes to the patient's medical record. The CPA must state the conditions and events for which the pharmacist must notify the PCP, and it must be in writing and signed by both the pharmacist and the PCP.

Is there a time limit?

Yes, the CPA must be renewed, at the latest, one year after the date on which the agreement becomes effective.

Is the pharmacist required to undergo additional training?

No, but the CPA may require the pharmacist to undergo additional training.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests. 

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Yes. In 2021, SB190 and SB325 passed, allowing pharmacists to provide and be reimbursed for services related to self-administered hormonal contraceptives and the prevention acquisition of HIV. In 2022, CMS approved Nevada Medicaid’s state plan amendment to include pharmacists as a new provider type. Since then, Nevada Medicaid has implemented a new provider type: PT 91 – Pharmacist and established Medicaid policy surrounding pharmacist-provided services. Pharmacists Can Now Bill Medicaid & Provide New Services.

Does the law or regulation apply to specific services?

Yes, pharmacists are reimbursed for more than 40 codes including the following services without a prescription: ordering certain HIV laboratory testing; the dispensing of self-administered hormonal contraceptives; and the prescribing, dispensing, and administration of drugs to prevent the acquisition of HIV.

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

Yes, pharmacists may prescribe and dispense PEP (not PrEP) pursuant to a non-patient-specific standing order (effective since 2017). S.B. 129 (N.Y. 2017); N.Y. Comp. Codes R. & Regs. tit. 8, § 63.13.

Does the pharmacist need a standing order from a PCP?

Yes, the pharmacist needs a non-patient-specific standing order from a PCP. Nurse practitioners qualify as PCPs. To participate as a licensed practitioner under a non-patient specific standing order, the licensed physician or nurse practitioner must be available to provide follow-up appointments for patients who initiated PEP in the pharmacy, establish agreements with other healthcare providers to accept referrals of patients within one to three days and respond to calls from pharmacists in cases where a patient has a negative reaction to a PEP regimen.

Does the legislation address pharmacists’ reimbursement or any other insurance provisions?

No.

Is there a quantity limit for prescriptions?

Yes, pharmacists are limited to prescribing seven days of PEP.

Does the pharmacist have to undergo additional training?

No.

Do pharmacists have the legal authority to administer injectable PrEP?

No, administration is explicitly limited to only certain listed prescription drug types. Injectable PrEP does not fall into one of these types of injectable drugs, and pharmacists are, therefore, prohibited from administration. N.Y. Educ. Law § 6802.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. N.Y. Educ. Law § 6801-a ; N.Y. Comp. Codes R. & Regs. tit. 8, § 63.10.

Does the CPA need to be patient-specific?

No, but a patient must consent in writing prior to receiving a pharmacist’s services under a CPA.

Are there filing requirements?

No.

Are there content requirements?

Yes, the CPA must describe the types of decisions concerning the management of drug therapy that the pharmacist is authorized to make, which may include a specific description of the diseases and drugs for which the pharmacist is authorized to manage drug therapy. The CPA must establish a means for the PCP and pharmacist to communicate. The pharmacist must be required to document any services provided to the patient pursuant to the CPA in said patient’s medical file. The CPA must state the conditions and events for which the pharmacist must notify the PCP. The CPA is prohibited from authorizing the pharmacist to diagnose a disease. The CPA should contain a clause stating that, in the event that a treating physician may disagree with the exercise of professional judgment by a pharmacist, the judgment of the treating physician shall prevail.

Is there a time limit?

No.

Is the pharmacist required to undergo additional training?

It depends. A pharmacist must have a certain number of years of experience in the practice of pharmacy based on the pharmacist’s level of education. If the pharmacist has either a master’s or doctorate in pharmacy, the pharmacist must, within the last 3 years, have two years of experience, of which at least one year shall include clinical experience in a health facility, which involves consultation with physicians with respect to drug therapy and may include a residency at a facility involving such consultation. If the pharmacist has a bachelor’s in pharmacy, the pharmacist must, within the last 7 years, have three years of experience, of which at least one year shall include clinical experience in a health facility, which involves consultation with physicians with respect to drug therapy and may include a residency at a facility involving such consultation. One year of experience shall mean not less than 1,680 hours of work, which includes an average of 15 hours of clinical experience a week, as a pharmacist within a period of one calendar year.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

 Yes, pharmacist may administer if under the authority of a collaborative practice agreement with a primary care provider. Ohio Rev. Code Ann. § 4729.01.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. Ohio Rev. Code Ann. § 4729.01; Ohio Rev. Code Ann. § 4729.39; Ohio Admin. Code 4729:1-6-01 – 03.

Does the CPA need to be patient-specific?

 No, but a PCP must have an established provider-patient relationship with a patient before a pharmacist may provide services to that patient under a CPA.

Are there filing requirements?

 No, but a written copy of the CPA must be made available to the Board of Pharmacy upon request.

Are there content requirements?

Yes, the CPA must identify the following: 1) collaborating pharmacist; 2) collaborating PCP; 3) the effective date and expiration date of the agreement; and 4) a description of the scope of services covered under the agreement. Regarding the scope of services, the agreement must explicitly specify the decisions the pharmacist is authorized to make. This includes the types of diseases, drugs, or drug categories involved and the type of collaborative authority. The agreement must state the procedures, decision criteria, or plans the pharmacists are to follow when making therapeutic decisions, particularly when modification or initiation of drug therapy is involved. Granting authority to a pharmacist to provide services outside of the PCP’s scope of practice is explicitly prohibited. The CPA must establish a means for the PCP and pharmacist to communicate. Said communication must occur at specified regular intervals. The CPA must identify what laboratory tests, if any, the pharmacist is authorized to order. The existence of the CPA must be relayed to any patient receiving services pursuant to the agreement. The pharmacist and PCP must sign the CPA and any subsequent amendments added to the original CPA. The CPA must also contain a clause stating that the agreement may be terminated by either 1) the collaborating physician, 2) the collaborating pharmacist, or 3) the patient receiving services pursuant to the agreement.

Is there a time limit?

 Yes, the CPA must be renewed every two years.

Is the pharmacist required to undergo additional training?

 It depends. Pharmacists must have training and experience related to the diagnosis for which drug therapy is to be prescribed. A CPA may require a pharmacist to undergo additional training.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 Yes. Ohio. Admin. Code 4729:1-3-01

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

 No. there are no limitations on which tests may be performed, but the pharmacist may only perform CLIA-waived tests if the following conditions are met: (1) The pharmacy or facility is certified by HHS as a clinical laboratory through the CLIA; (2) The pharmacy or facility has obtained a CLIA certificate of waiver from HHS; and (3) The responsible person of the terminal distributor of dangerous drugs and the terminal distributor of dangerous drugs ensures and documents that all pharmacists conducting CLIA-waived tests pursuant to this rule receive appropriate training to conduct testing in a safe and effective manner.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 Yes, and it is an ongoing effort in the state. In 2019, Governor John Kasich signed SB 265, which formally recognized pharmacists as providers in Ohio. SB 265 changed key provider definitions and insurance laws to catch up to the growing role of the pharmacist and removed barriers that prevented health plans, hospitals and healthcare teams from integrating and utilizing the expertise of the pharmacist. As of 2020, pharmacists enrolled with UHC Medicaid will be reimbursed for the time spent managing chronic conditions, conducting transitions of care visits, and interprofessional consults with other healthcare providers. Pharmacists as Providers.

Does the law or regulation apply to specific services?

 No, it is a broad expansion of pharmacists’ role statewide. UHC specified which services are reimbursable: adherence checks, medication reconciliations, new medication counseling, disease state management, and transitions of care management.

Does the law or regulation require parity (equity) between pharmacists and other providers?

No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

 Yes, pharmacists have broad authority to administer. The definition of scope of practice includes administration. Administration explicitly includes drug administration by injection. Stat. Ann. tit. 59, § 353.1.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. Okla. Stat. Ann. tit. 59, § 353.30; Okla. Admin. Code 535:10-9-5.

Does the CPA need to be patient-specific?

 No.

Are there filing requirements?

 No, but the pharmacist must keep a written copy of the CPA on file, which must be made available to the Board of Pharmacy upon request.

Are there content requirements?

 No.

Is there a time limit?

 No.

Is the pharmacist required to undergo additional training?

 No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 Yes, statute gives pharmacists the authority to independently initiate PrEP and PEP (Effective since 9/25/21). H.B. 2958 (Or. 2021); Rev. Stat. Ann. § 689.005; Rev. Stat. Ann. § 689.704; Rev. Stat. Ann. § 743A.051; Rev. Stat. Ann. § 743B.425; Rev. Stat. Ann. § 743B.602.

Does the pharmacist need a standing order from a PCP?

 No.

Does the legislation address pharmacists’ reimbursement or any other insurance provisions?

 Yes, health insurers covering services within a pharmacist’s scope of practice must provide reimbursement at a rate equal to the rate that the services are reimbursed when provided by a physician. Health insurers are prohibited from requiring prior authorization before a pharmacist dispenses PrEP and PEP.

Is there a quantity limit for prescriptions?

 Yes, pharmacists are limited to prescribing up to a 30-day supply of PrEP and a complete course of PEP.

Does the pharmacist have to undergo additional training?

 No.

Do pharmacists have the legal authority to administer injectable PrEP?

 Yes, pharmacist has broad authority to administer. The definition of scope of practice includes administration. Administration explicitly includes drug administration by injection. Rev. Stat. Ann. § 689.005; Rev. Stat. Ann. § 689.655.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. Rev. Stat. Ann. § 689.655; Admin. R. 847-015-0040; Admin. R. 855-006-0005(10); Admin. R. 855-019-0250; Admin. R. 855-019-0260.

Does the CPA need to be patient-specific?

 Yes.

Are there filing requirements?

 No.

Are there content requirements?

 Yes, the CPA must identify the following: 1) the collaborating pharmacist; 2) the collaborating PCP; 3) the effective and expiration dates of the CPA; and 4) a description of the scope of services covered under the CPA. Regarding the scope of services, the CPA must explicitly specify the decisions the pharmacist is authorized to make. This includes the types of diseases, drugs, or drug categories involved and the type of collaborative authority. The CPA must state the procedures, decision criteria, or plans the pharmacists are to follow when making therapeutic decisions, particularly when modification or initiation of drug therapy is involved. The CPA must also state the conditions and events for which the pharmacist must notify the PCP. The pharmacist must document any services provided pursuant to the CPA.

Is there a time limit?

 No.

Is the pharmacist required to undergo additional training?

 No, but the CPA may require the pharmacist to undergo additional training.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 Yes. O.R.S. § 689.661.

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

 No.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 Yes. Pharmacist Reimbursement.

Does the law or regulation apply to specific services?

 Yes, pharmacists are reimbursed for prescribing hormonal contraception, prescribing smoking cessation products, initiating vaccination, administering immunizations, providing MTM, and preventive medicine counseling.

Does the law or regulation require parity (equity) between pharmacists and other providers?

 No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

 Yes, pharmacists have limited authority to administer. Before a pharmacist may do so, however, the following requirements must be met: 1) complete an ACPE-approved course of training concerning the prescribing, dispensing and administering of such drugs; 2) maintain and make readily available proof of completion of said course; and 3) maintain professional liability insurance coverage of at least $1,000,000. Pharmacist must notify the individual's primary care provider, if known, within forty-eight hours of administration. A minimum of two hours of the thirty-hour requirement for continuing education for license renewal be dedicated to injectable medications. 63 Pa. Stat. Ann. § 390-9.2. 

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. 49 Pa. Code § 27.302; 63 Pa. Stat. Ann. §390-2(14); 63 Pa. Stat. Ann. § 390-9.1; 63 Pa. Stat. Ann. 390-9.3.

Does the CPA need to be patient-specific?

 No, the CPA does not need to be patient specific. However, a pharmacist may only manage a patient’s drug therapy pursuant to a CPA if said patient’s drug therapy management was initiated by the collaborating PCP. Each patient receiving services pursuant to a CPA must be notified of the agreement’s existence and be provided the opportunity to refuse management of drug therapy by the collaborating pharmacist.

Are there filing requirements?

 Yes, the CPA must be filed with the state’s Bureau of Professional and Occupational Affairs, the Board of Pharmacy, and the Board of Medicine. The pharmacist and PCP must each keep a written copy of CPA on file, which must be made available to patients, the Bureau of Professional and Occupational Affairs, and the Department of Health upon request.

Are there content requirements?

 Yes, the CPA must identify the following: 1) the collaborating pharmacist; 2) the collaborating PCP; 3) dated signatures of the collaborating PCP and pharmacist; and 4) a description of the scope of services covered under the CPA. Regarding the scope of services, the CPA must explicitly specify the decisions the pharmacist is authorized to make. This includes the types of diseases, drugs, or drug categories involved and the type of collaborative authority. The CPA must state the procedures, decision criteria, or plans the pharmacists are to follow when making therapeutic decisions, particularly when modification of drug therapy is involved. The CPA must also specify what, if any, lab and/or diagnostic tests the pharmacist is authorized to order. The CPA must state that the pharmacist must notify the PCP within 72 hours of changes in dose, duration, or frequency of medication prescribed. As drug therapy management must be initiated by the PCP, the CPA may not provide the pharmacist prescriptive authority. The pharmacist must document any services provided pursuant to the CPA. The CPA must also contain a clause permitting the pharmacist or the PCP to terminate the agreement at any time. The pharmacist and PCP must explicitly have access to all medical records of patients provided services pursuant to the CPA.

Is there a time limit?

 Yes, the CPA must be renewed every two years.

Is the pharmacist required to undergo additional training?

 No, but the pharmacist must have at least $1,000,000 in professional liability insurance coverage.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 Yes. 63 P.S. § 390-9.5.

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

 Yes, pharmacists are limited to COVID-19, influenza and streptococcal infections.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 Yes, but only for naloxone. Naloxone Reimbursement.

Does the law or regulation apply to specific services?

 Yes, FFS Medicaid covers dispensing generic Naloxone.

Does the law or regulation require parity (equity) between pharmacists and other providers?

 No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

 Yes, pharmacists have broad authority to adminster. The definition of scope of practice includes administration. Administration explicitly includes drug administration by injection. 216 R.I. Code R. 40-15-1.2.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. 5 R.I. Gen. Laws Ann. § 5-19.2-2, 3; R.I. Code R. 40-15-1.13.

Does the CPA need to be patient-specific?

 No.

Are there filing requirements?

 No.

Are there content requirements?

 Yes, the CPA must be in writing and signed by both the collaborating pharmacist and PCP. The CPA must identify the following: 1) the site and setting where the collaborative practice is to take place; 2) informed consent procedures; (3) qualifications of participating pharmacist and PCP; 4) the role of any employed healthcare professional with prescriptive privileges participating in the collaborative practice; 5) scope of conditions or diseases to be managed; 6) practice protocols; 7) risk management activities; and 8) outcome measurements. 

Is there a time limit?

 Yes, the CPA must be renewed every other year following the agreement’s effective date.

Is the pharmacist required to undergo additional training?

 It depends. The pharmacist must be licensed to practice in the state of Rhode Island and have a Bachelor of Science in pharmacy and a postgraduate educational degree or a Doctor of Pharmacy degree. The pharmacist must also have experience relevant to the scope of services outlined in the CPA. The CPA may require the pharmacist to undergo additional training.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 Yes. CLIA-waived tests are referred to as “limited-function tests” in this section. 5 R.I. Gen. Laws. Ann. § 5-19.1-2.

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

 Yes, includes only the following: blood glucose, hemoglobin A1c, cholesterol tests, and/or other tests that are classified as waived under CLIA and are approved by the United States Food and Drug Administration for sale to the public without a prescription in the form of an over-the-counter test kit.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

 Yes, pharmacists have broad authority to adminster.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP. 

Do pharmacists have the legal authority to administer injectable PrEP?

 Yes, pharmacists have limited authority to administer. S.D. Codified Laws § 36-11-2.2; S.D. Admin. R. 20:51:31:15.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. S.D. Codified Laws § 36-11-19.1(6).

Does the CPA need to be patient-specific?

 No.

Are there filing requirements?

 No.

Are there content requirements?

 No.

Is there a time limit?

 No.

Is the pharmacist required to undergo additional training?

 No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 No, no specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

Yes, pharmacists have broad authority to administer. The definition of scope of practice includes administration. Administration explicitly includes drug administration by injection. Tenn. Code Ann. § 63-10-204.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. Tenn. Code Ann. § 63-10-204(5); Tenn. Code Ann. § 63-10-217; Tenn. Comp. R. & Regs. 1140-15-.04; Tenn. Comp. R. & Regs. 1140-03-.17.

Does the CPA need to be patient-specific?

 No, but a patient receiving services under a CPA must have signed a general consent that the patient is to receive services from the healthcare team, including the pharmacist.

Are there filing requirements?

 Yes, the pharmacist must notify the Board of Pharmacy of the existence of the CPA within 30 days following the agreement’s effective date. The notice must identify the following: 1) the collaborating pharmacist; 2) the collaborating PCP; 3) the effective date of the CPA; and 4) the scope of services covered by the agreement. The pharmacist and the PCP must each keep a written copy of the CPA on file.

Are there content requirements?

 Yes, the CPA must be in writing and signed by both the collaborating pharmacist and PCP. The pharmacist must document within 72 hours of administration any services provided pursuant to the CPA in a patient record, to which the PCP has access. The CPA must identify the scope of services the pharmacist may provide under the CPA. Regarding the scope of services, the CPA must explicitly specify the decisions the pharmacist is authorized to make. This includes the types of diseases, drugs, or drug categories involved and the type of collaborative authority. The CPA must state the procedures, decision criteria, or plans the pharmacists are to follow when making therapeutic decisions, particularly when modification or initiation of drug therapy is involved. Granting authority to the pharmacist to provide services outside of the PCP’s scope of practice is explicitly prohibited. The CPA must include a clause granting the PCP the authority to override the agreement if necessary to protect the health of the patient or accomplish the goals of the treatment prescribed for the patient. All care and services provided by the pharmacist pursuant to the CPA, except immunizations, opioid antagonists, and preventative care, must be pursuant to a diagnosis made and documented by the collaborating PCP. The CPA must also include a section with written measurable and objective performance goals for evaluating the quality of care provided for the patients treated pursuant to the CPA. These goals and patient data must be reviewed by the pharmacist and PCP at least quarterly. The CPA is explicitly prohibited from delegating the authority to prescribe controlled substances to the pharmacist.

Is there a time limit?

 Yes, the CPA must be renewed every 2 years.

Is the pharmacist required to undergo additional training?

 It depends. A pharmacist must be licensed to practice in the state of Rhode Island and have a Bachelor of Science in pharmacy and been active on the practice of pharmacy (“active” time period not specified) or a Doctor of Pharmacy degree. A pharmacist must have at least $1,000,000 professional liability insurance coverage. Pharmacists engaged in collaborative pharmacy practice are strongly encouraged, but not required, to complete ten hours of the biennially required thirty hours of continuing education in topics related to the clinical practice of pharmacy.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 No. T. C. A. § 63-10-204(39)(B).

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 Yes. TN has a MTM program that allows pharmacists to provide various clinical services. The program authorizes qualified Tennessee-licensed pharmacists to provide MTM services to eligible TennCare members under a CPA with TennCare Patient Centered Medical Homes (PCMH) and Health Link. Medication Therapy Management Program (tn.gov)

Does the law or regulation apply to specific services?

 Yes, “MTM services include medication reviews, pharmacotherapy consult, anticoagulation management, immunizations, health and wellness programs and many other clinical services.”

Does the law or regulation require parity (equity) between pharmacists and other providers?

 No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

 Pharmacists may administer only if under the authority of a collaborative practice agreement with a PCP. Tex. Occ. Code Ann. § 551.003; Tex. Occ. Code Ann. § 563.051.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. Tex. Occ. Code Ann. § 554.005; 22 Tex. Admin. Code § 295.13.

Does the CPA need to be patient-specific?

 No, but the PCP must establish and maintain a physician-patient relationship with each patient provided drug therapy management under the CPA.

Are there filing requirements?

 Yes, notice that a pharmacist is entering into a CPA must be submitted to the Board of Pharmacy for approval. The pharmacist must keep a written copy of the CPA on file.

Are there content requirements?

 Yes, the CPA must identify the following: 1) the collaborating pharmacist; 2) the collaborating PCP; and 3) a description of the scope of services covered under the CPA. The PCP must be geographically close enough that they can be physically present to supervise pharmacist as needed. Regarding the scope of services, the CPA must explicitly specify the decisions the pharmacist is authorized to make. This includes the types of diseases, drugs, or drug categories involved and the type of collaborative authority. The CPA must state the procedures, decision criteria, or plans the pharmacists are to follow when making therapeutic decisions, particularly when modification or initiation of drug therapy is involved. Granting authority to pharmacist to provide services outside of the PCP’s scope of practice is explicitly prohibited. The CPA must establish a means for the PCP and pharmacist to communicate. The CPA must state the conditions and events for which the pharmacist must notify the PCP. The CPA must identify what laboratory tests, if any, the pharmacist is authorized to order. If the CPA grants the pharmacist the authority to implement or modify a patient’s drug therapy, the collaborating PCP must first assess and diagnose the patient and relay a specific drug therapy order to the pharmacist. The CPA cannot grant the pharmacist the authority to prescribe dangerous drugs* if the pharmacist practices in any setting other than a federally qualified health center, hospital, hospital-based clinic, or an academic health care institution. *A dangerous drug is defined as any drug that is either 1) unsafe for self-medication AND that is not included in Schedules I through V or Penalty Groups 1 through 4 as listed in the Texas Controlled Substances Act or 2) is labeled as “Rx Only.” Tex. Occ. Code Ann. § 551.003

Is there a time limit?

 Yes, the CPA must be renewed every year.

Is the pharmacist required to undergo additional training?

 Yes, the pharmacist must have completed six hours of ACPE-approved continuing education related to drug therapy offered by a provider and have engaged in drug therapy management. Both requirements must have been completed within the last year, and a statement attesting to completion must be provided to the Board of Pharmacy within 24 hours of requesting the Board to approve CPA. A pharmacist engaged in drug therapy management must complete six hours of ACPE-approved continuing education related to drug therapy each year.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 No.

Does the law or regulation require parity (equity) between pharmacists and other providers?

Yes. Pharmacists acting within their scope of practice are considered practitioners for a purposes of reimbursement. As a practitioner, an insurer may not discriminate against pharmacists for payment or reimbursement for services performed in the scope of that pharmacist’s license if the same services or procedures are provided and covered by another listed health care practitioner. Tex. Ins. Code Ann. § 1451.128; Tex. Ins. Code Ann. § 1451.1261.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 Yes, statute gives pharmacists the authority to independently initiate PrEP and PEP (effective since September 2021). H.B. 178 (Utah 2021); Utah Code Ann. § 58-17b-627; UT ADC R156-17b-627; PrEP/PEP Distribution Guiding Protocol.

Does the pharmacist need a standing order from a PCP?

 Nop>

Does the legislation address pharmacists’ reimbursement or any other insurance provisions?

 No.

Is there a quantity limit for prescriptions?

 No, Utah law does not impose quantity limits on pharmacy-initiated PrEP nor limit the frequency with which pharmacists can prescribe PrEP or PEP to a given patient.

Does the pharmacist have to undergo additional training?

 No, but when prescribing PrEP and PEP, the pharmacist must follow the statewide protocol established by the Division of Occupational and Professional Licensing.

Do pharmacists have the legal authority to administer injectable PrEP?

 Yes, pharmacists have broad authority to administer. Definition of scope of practice includes administration. Administration explicitly includes drug administration by injection. Utah Code Ann. § 58-17b-102.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. Utah Code Ann. § 58-17b-102; Utah Code Ann. § 58-17b-601; Utah Admin. Code r. R156-17b-611.

Does the CPA need to be patient-specific?

 No.

Are there filing requirements?

 No.

Are there content requirements?

 Yes, the CPA must be in writing and signed by both the collaborating pharmacist and PCP.

Is there a time limit?

 No.

Is the pharmacist required to undergo additional training?

 No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 No. U.A.C. R156-17b-611

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 Yes. Medication Therapy Management Services.

Does the law or regulation apply to specific services?

 Medicaid-enrolled pharmacists in an outpatient setting are eligible for reimbursement for providing medication therapy management (MTM) services.

Does the law or regulation require parity (equity) between pharmacists and other providers?

 No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 Yes, a statewide protocol gives pharmacists the authority to independently initiate PrEP and PEP (effective since December 2021). H.B. 2079 (Va. 2021); Va. Code Ann. § 54.1-3300; Va. Code Ann. § 54.1-3303.1; VA PrEP Statewide Protocol.

Does the pharmacist need a standing order from a PCP?

 No.

Does the legislation address pharmacists’ reimbursement or any other insurance provisions?

 No.

Is there a quantity limit for prescriptions?

 No, Virginia law does not impose quantity limits on pharmacy-initiated PrEP nor limit the frequency with which pharmacists can prescribe PrEP or PEP to a given patient.

Does the pharmacist have to undergo additional training?

 Yes, pharmacists are required to complete a comprehensive training program related to the prescribing and dispensing of HIV prevention and medications. When prescribing PrEP and PEP, the pharmacist must follow the statewide protocol established by the Virginia Board of Pharmacy.

Do pharmacists have the legal authority to administer injectable PrEP?

 Yes, pharmacists have broad authority to administer. The definition of scope of practice includes administration. Administration is interpreted to be included within the definition of dispense. Va. Code Ann. § 54.1-3300.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. Va. Code Ann. § 54.1-3300; Va. Code Ann. § 54.1-3300.1; 18 Va. Admin. Code 110-40-10 –– 70.

Does the CPA need to be patient-specific?

 Yes, the CPA must be patient-specific, and the patient must be notified of the existence and scope of the CPA and provide written consent.

Are there filing requirements?

 No, as long as CPA’s scope is within the clinically-accepted standard of care. The pharmacist and PCP must each keep a written copy of CPA and patient’s consent on file.

Are there content requirements?

 Yes, the CPA must describe the disease state or condition, drugs or drug categories, drug therapies, laboratory tests, medical devices, and substitutions authorized by the PCP. The CPA must outline the procedures, decision criteria, or plan the pharmacist must follow when providing drug therapy management. The CPA must outline how/if pharmacist must document services provided pursuant to the agreement. The CPA must state the conditions and events for which the pharmacist must notify the PCP. The CPA must specify a timeline for the agreement to be reviewed/renewed periodically. The CPA must include a clause granting the PCP the authority to override the agreement if necessary to protect the health of the patient or accomplish the goals of the treatment prescribed for the patient. The CPA must include a statement that the pharmacist, PCP, or patient may terminate the agreement at any time. The CPA must also be related to treatment using drug therapy, laboratory tests, or medical devices that is defined under specific conditions or limitations and is for the purpose of improving patient outcomes. PCP includes advance practice registered nurses.

Is there a time limit?

 No.

Is the pharmacist required to undergo additional training?

 No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 Yes, for limited services. Va Pharmacist Covered Services; Va Pharmacist Billing Instructions.

Does the law or regulation apply to specific services?

 Yes, pharmacists can be reimbursed for providing the influenza vaccine, birth control pills, other family planning devices (e.g., condoms), and nutritional supplements.

Does the law or regulation require parity (equity) between pharmacists and other providers?

 No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

 Yes, phamacists have broad authority to administer. The definition of scope of practice includes administration. Administration explicitly includes drug administration by injection. 20-4 Vt. Code R. § 1400.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. Vt. Stat. Ann. tit. 26, § 2022(15)(B)(iii); Vt. Stat. Ann. tit. 26, § 2023; Vt. Admin. Code 20-4-26:1; Vt. Admin. Code 20-4-1400:1.10(a)(8).

Does the CPA need to be patient-specific?

No.

Are there filing requirements?

 No, but the CPA must be readily available to any patient or regulatory authority that may request it.

Are there content requirements?

 Yes, the CPA must: 1) permit prescribing only when there is an established patient-physician relationship between the patient and the collaborating PCP; 2) contain the name, license number, and dated signature of the collaborating PCP; 3) specify start and end dates of the CPA separated by not more than one year; 4) and describe the scope of clinical pharmacy services and/or prescribing to be provided, including any limitations on the scope of those services. The CPA must require pharmacist and PCP to notify one another of any changes to a patient’s drug therapy or medical status.

Is there a time limit?

 Yes, the CPA must be renewed every year.

Is the pharmacist required to undergo additional training?

 No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 Yes, for limited services. Vermont Medicaid Provider Manual; Provider Manual _0.pdf (vermont.gov)

Does the law or regulation apply to specific services?

 Pharmacies can be reimbursed for ACIP approved vaccines and immunizations (cost of the vaccine + administration fee). Pharmacists can conduct and be reimbursed for medically necessary EPSDT screenings/services with prior authorization.

Does the law or regulation require parity (equity) between pharmacists and other providers?

 No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

 Yes, pharmacists have broad authority to administer. The definition of scope of practice includes administration. Administration explicitly includes drug administration by injection. Wash. Rev. Code Ann. § 18.64.011.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

Yes. Wash. Rev. Code Ann. § 18.64.011(28); Wash. Admin. Code 246-945-350.

Does the CPA need to be patient-specific?

No.

Are there filing requirements?

 Yes, the pharmacist must submit a copy of the CPA to the pharmacy quality assurance commission and must keep a written copy of the CPA on file.

Are there content requirements?

Yes, the CPA must identify the following: 1) the collaborating pharmacist; 2) the collaborating PCP; and 3) the scope of services covered under agreement. Regarding the scope of services, the CPA must explicitly specify the decisions the pharmacist is authorized to make. This includes the types of diseases, drugs, or drug categories involved and the type of collaborative authority. The CPA must state the procedures, decision criteria, or plans the pharmacists are to follow when making therapeutic decisions, particularly when modification or initiation of drug therapy is involved. The CPA must outline how/if pharmacist must document services provided pursuant to the agreement. The CPA must also outline a plan for communication or feedback to the PCP concerning specific decisions made by the pharmacist.

Is there a time limit?

 Yes, the CPA must be renewed every two years.

Is the pharmacist required to undergo additional training?

 No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 Yes. WAC 182-530-7250: ; WAC 182-531-0100: ; WAC 182-531-0250: ; WAC 182-502-0002.

Does the law or regulation apply to specific services?

 Yes, an extensive list of covered/reimbursable services is outlined in WAC 182-531-0100. Said services include vaccines, HIV/AIDS counseling/testing (WAC 182-531-0600:), tobacco/nicotine cessation counseling (WAC 182-531-1720:), and reproductive health services (including OTC and emergency contraception).

Does the law or regulation require parity (equity) between pharmacists and other providers?

 No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

 Yes, pharmacists have broad authority to administer. The definition of scope of practice includes administration. Administration explicitly includes drug administration by injection. Wis. Stat. Ann. § 450.01.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. Wis. Stat. Ann. § 450.033; Wis. Stat. Ann. § 49.46(2)(bh); Wis. Admin. Code § 7.12

Does the CPA need to be patient-specific?

 No.

Are there filing requirements?

 No, but the pharmacist shall document the delegation by a physician, and the delegated act may not be started prior to documentation.

Are there content requirements?

 No.

Is there a time limit?

 No, but the documentation (see filing requirements) shall be maintained for a minimum of 5 years after the end of the last delegated act.

Is the pharmacist required to undergo additional training?

 No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 Yes. Online Handbook Display (wi.gov).

Does the law or regulation apply to specific services?

 Yes, pharmacists can be reimbursed for providing medication therapy management (MTM) services. The MTM benefit consists of Comprehensive Medication Review and Assessment services, which are private consultations between a pharmacist and a member to review the member's drug regimen.

Does the law or regulation require parity (equity) between pharmacists and other providers?

 No. 

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

 Yes, pharmacists have broad authority to administer. The definition of scope of practice includes dispensing. Dispensing includes drug administration. Administration explicitly includes drug administration by injection. W. Va. Code R. 15-1-2. 

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. W. Va. Code Ann. § 30-5-18; W. Va. Code Ann. § 30-5-19; W. Va. Code R. 11-8-3; W. Va. Code R. 11-8-4; W. Va. Code R. 11-8-5.

Does the CPA need to be patient-specific?

 No.

Are there filing requirements?

 Yes, the parties must file a complete practice notification with the Board of Pharmacy before the CPA becomes effective. The practice notification shall include 1) the full name, license number, licensing board, preferred mailing address, telephone number, and email address of the pharmacist(s) and physician(s) who are entering into the CPA; 2) the name and address of each location where the pharmacist will engage in collaborative practice pursuant to the CPA; 3) the proposed effective date; and 4) certification by the collaborating pharmacist and physician that a) the pharmacist has been verified as eligible for the CPA by the Board, b) the physician is eligible to serve as a collaborating physician, c) the CPA is consistent with the physician’s scope of practice, the pharmacist’s education, training, and experience, and includes, at a minimum, the content required by statute, d) the pharmacist will maintain a copy of the CPA at their place of practice and will provide a copy to any of the boards upon request, e) collaborative practice shall only be performed after informed consent of the patient, noted in the medical record, and f) the parties acknowledge that the CPA does not include management of controlled substances. The pharmacist must have the CPA on file at his or her place of practice. The existence and subsequent termination of the agreement and any additional information the rules may require concerning the agreement, including the agreement itself, shall be made available to the appropriate licensing board for review upon request.

Are there content requirements?

 Yes, each protocol developed pursuant to the CPA shall include 1) the specific drug(s) to be managed by the pharmacist; 2) the terms and conditions under which drug therapy may be implemented, modified, or discontinued; 3) the conditions and events upon which the pharmacist is required to notify the physician; 4) the lab tests that may be ordered in accordance with drug therapy management; and 5) the mutually agreed upon patient evaluations the pharmacist may conduct.

Is there a time limit?

 No, but either party may terminate the CPA at any time. The CPA automatically terminates if either the collaborating pharmacist(s) or collaborating physician(s) are no longer eligible to collaborate.

Is the pharmacist required to undergo additional training?

 No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 No. 

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

 Yes, pharmacists have broad authority to administer. The definition of scope of practice includes dispense. Administration is interpreted to be included within the definition of dispense. Administration explicitly includes drug administration by injection. Wyo. Admin. Code 059.0001.2 § 4.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 Yes. Wyo. Stat. Ann. § 33-24-101(b)(iii); Wyo. Admin. Code 059.0001.20 § 4; Wyo. Admin. Code 059.0001.20 § 5.

Does the CPA need to be patient-specific?

 Yes.

Are there filing requirements?

 Yes, the pharmacist must send 5 copies of the CPA to the Board for review. The CPA must be reviewed and approved by the Board of Pharmacy. The Board’s decision shall be delivered to the pharmacist and practitioner within 10 days of the decision.

Are there content requirements?

 Yes, the CPA must include 1) the names of the prescribing practitioner and pharmacist who are parties to the CPA; 2) the specific types of MTM decisions the pharmacist is allowed to make, including a) the types of diseases, drugs, or drug categories involved and the extent of MTM allowed, b) the methods, procedures, decision criteria and plan the pharmacist is to follow when conducting MTM, and c) the procedures the pharmacist is to follow in the course of conducting MTM, including documenting decisions and reporting mechanisms; 3) a method for the practitioner to monitor compliance with the CPA and clinical outcomes, and a process to intercede when necessary; 4) a provision allowing the practitioner to override the CPA whenever deemed necessary or appropriate; 5) a provision allowing the practitioner, pharmacist, and patient or patient’s agent to cancel the CPA at any time by written notice to all parties, and 6) the signatures of the practitioner and pharmacist, and the date of signature.

Is there a time limit?

 No, but if the CPA is canceled by any party, the pharmacist shall keep the original written notice of cancellation for 2 years.

Is the pharmacist required to undergo additional training?

 No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 Yes. Wyo. Admin. Code 059.0001.20 § 4.

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

 No.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 No.

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

 Yes, pharmacist may administer if under the authority of a CPA with a primary care provider. 20 L.P.R.A. § 407; 20 L.P.R.A. § 407b.

Do pharmacists have the legal authority to enter into a collaborative practice agreement (CPA) with a primary care provider (PCP)?

 No.

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 No specific statute specifically allowing or prohibiting pharmacists from providing CLIA-waived tests.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

Does the law or regulation apply to specific services?

Does the law or regulation require parity (equity) between pharmacists and other providers?

Does the law/regulation apply to Medicaid, state employee benefits, and/or private insurance regulated by the state?

Do pharmacists have the legal authority to distribute oral PrEP without a prescription from a primary care provider (PCP)?

 No, neither statute nor statewide standing order/protocol gives pharmacists the authority to independently initiate PrEP or PEP.

Do pharmacists have the legal authority to administer injectable PrEP?

 N/A

Do pharmacists have the legal authority to enter into a collaborative practice agreement with a primary care provider (PCP)?

 N/A

Do pharmacists have the legal authority to independently perform CLIA-waived tests?

 Yes. 27 V.I.C. § 141; 27 V.I.C. § 153b.

Are there limitations to which CLIA-waived tests pharmacists can independently perform?

No.

Is there a law or regulation requiring Medicaid reimbursement for pharmacist-provided clinical services?

 N/A