A pharmacist's guide to prescribing — CPAs, CLIA Waivers, & more

By James Lott, PharmD

LAST UPDATED 11/03/2023

Can pharmacists prescribe? Yes — sometimes.

  • Pharmacists’ ability to prescribe depends on state law.

  • State law ranges from allowing pharmacists to prescribe independently, to pharmacists having no prescriptive authority.

  • In states where pharmacists’ cannot independently prescribe, they may prescribe under a supervising practitioner’s licence through a collaborative practice agreement (CPA).

Do pharmacists have prescriptive authority?

The short answer to this question is, yes, however it depends on the state the pharmacy is practicing in.

Pharmacists complete a doctoral program with a Doctor of Pharmacy degree where they receive 4 years of clinical training. Many pharmacists continue their education by pursuing fellowships and residencies that further add to their clinical knowledge and training.

Despite this high level of education, pharmacists cannot simply prescribe medications independently at a federal level. There are different circumstances in which a pharmacist may prescribe including standing orders, collaborative practice agreements, and pharmacists with provider status or broad prescriptive authority.

Do pharmacists have provider status in my state?

The differences in pharmacists’ prescribing power is the lack of consistency in Provider Status at a federal level.

Pharmacists have provider status in at least 37 states, however over the past several years many state policies have progressed to allow pharmacist provider status.
 
Having provider status gives pharmacists the incentive to expand their services such as in Idaho, where pharmacists may now prescribe over 20 categories of medications independently of any other healthcare provider. Granting Idaho pharmacists provider status not only allows them to prescribe, but gives them the ability to be reimbursed for their services.

The Social Security Act (SSA) provides a list of providers including physicians, physician’s assistants, certified nurse practitioners, qualified psychologists, clinical social workers, certified nurse midwives, certified registered nurse anesthetists, but not pharmacists.

This is important because the SSA also determines the eligibility for patient care services to be covered by entities such as Medicare Part B. Many state and private health plans generally use Medicare part B as a point of reference for services that they choose to cover.

While pharmacists have the clinical knowledge and expertise to expand their scope of practice, not having provider status limits their ability to be reimbursed from medical services.

What can pharmacists prescribe?

Due to the lack of consistency in Provider Status at a federal level, pharmacists in different states have different prescribing abilities.

In many states, pharmacists can provide dozens of clinical services ranging from test-to-treat to ongoing disease management. Our Services page represents a relatively comprehensive list of common conditions pharmacists can achieve prescriptive authority for through avenues like Collaborative Practice Agreements (CPAs) or CLIA waivers. 

It’s worth noting, though, that some states require oversight and authorization from a physician before a pharmacist is able to offer any prescription directly. Understanding both the regulatory environment in your state as well as your pharmacist’s training can help you get a concrete answer of what clinical and advanced services a specific pharmacy can provide. 

 

 

Can pharmacists prescribe Paxlovid?

Yes — since July 6, 2022, pharmacists in states with amenable regulations have been able to directly prescribe Paxlovid to patients.

This is a particularly important subject to us: our #LetUsPrescribe campaign demanding pharmacists gain this prescriptive authority earned hundreds of supporters and helped us pressure the FDA into reversing its original stance.

What's a collaborative practice agreement ?

How can I get one for my pharmacy?

Pharmacists that work in more clinical practice settings may expand the services they provide under a Collaborative Practice Agreement (CPA).

A CPA is a formal agreement in which a licensed provider makes a diagnosis and supervises patient care, then refers patients to a pharmacist under protocol to perform specific patient care services.

These services include:

  • patient assessments

  • counseling

  • referrals

  • ordering laboratory tests
  • administering drugs

  • selecting, initiating, monitoring, continuing, and adjusting drug regimens

 

Under a CPA, pharmacists may use their clinical knowledge and expertise without their services being limited by policy and compensation barriers.

You can learn more about CPAs and the process of attaining one on our CPA landing page.

How can I offer test-to-treat at my pharmacy?

Under most circumstances, pharmacies need to obtain a CLIA waiver to offer testing services.

A Clinical Laboratory Improvement Amendment (CLIA) Certificate of Waiver is an official certification that grants a facility the legal authority to conduct diagnostic tests on individuals for the purpose of assessing and treating patients. The U.S. Department of Health and Human Services is responsible for issuing these certificates, and each one is uniquely identified by a ten-digit CLIA number.

The primary objective of CLIA certificates is to uphold quality standards within laboratories, ensuring reliability and precision across a wide range of testing settings, including hospitals, pharmacies, clinics, and, most importantly, laboratories. These certificates mandate that each facility complies with federal and state laws and regulations related to clinical laboratory testing, subject to biannual onsite inspections.

Several types of CLIA certificates are available, and each type authorizes facilities to perform specific diagnostic tests.

The policies governing CLIA are established by three governmental agencies that share responsibility: the Center for Disease Control (CDC), the Food and Drug Administration (FDA), and the Center for Medicaid Services (CMS).

You can learn more and find direct instructions on applying for a CLIA waiver on our CLIA landing page.

What is a standing order?

How does it impact pharmacists' prescriptive authority?

Another circumstance in which a pharmacist may dispense prescription medications without a prescription is a Standing Order. A standing order is a pre-written order from a licensed practitioner (often a Medical Doctor) to dispense a medication in clearly defined circumstances.

Most states have a state-wide standing order for pharmacists to dispense naloxone. Naloxone is an opioid antagonist that works by blocking the effects of opioids in the brain. Naloxone can be a life-saving medication in the event of an opioid overdose. Standing orders have been put in place to increase access to this life-saving medication and even allows for people to purchase the medication online.

Another common example of standing orders is the use of emergency medications by Emergency Medical Services personnel for life support. These orders are in place for situations where a delay in treatment could result in harm to the patient.

Wrapping up: does my pharmacy have prescriptive authority?

By understanding the regulations that apply to pharmacists’ prescriptive authority in each state, pharmacies can begin to pursue the addition of specific clinical services to their service offerings.

These clinical services don’t just have the potential to bring in thousands of additional revenue for pharmacies each year, but also better serve communities increasingly facing physician shortages and long wait times to receive treatment. Pharmacists expanding their scope of practice makes communities healthier.

If you’re a pharmacist beginning to investigate offering prescriptions directly to your patients, we can help. We can answer any state- or treatment-specific questions you have via a free consultation.



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