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Michael D. Hogue, PharmD, FAPhA, FNAP, FFIP

Michael D. Hogue, PharmD, FAPhA, FNAP, FFIP

Michael D. Hogue is the 15th Executive Vice President and Chief Executive Officer of the American Pharmacists Association (APhA).

Read more about Michael 

Published on Thursday, December 7, 2023

Collaborative practice now allowed in all 50 states

CPAs

Lauren Howell, PharmD

On August 17, 2023, Delaware became the 50th state to pass legislation allowing pharmacists and prescribers to enter into collaborative practice agreements (CPAs) in which one or more pharmacists can provide patient care and drug therapy management services that are not otherwise permitted to be performed by a pharmacist. With the signing of this bill, every state now recognizes CPAs between pharmacists and prescribers.

CPAs allow prescribers and pharmacists to establish a formal relationship in which a prescriber can delegate tasks to a pharmacist under negotiated conditions. The prescriber is most often a physician, although a growing number of states are allowing for CPAs between pharmacists and other prescribers such as nurse practitioners. These tasks may include patient care delivery services, such as chronic care management, refill authorizations, initiation of therapy, and formulary management. The agreements serve as a way to allow patients more access to care, increase the efficiency of patient care, and use a pharmacist’s medication expertise to complement the services and knowledge that other members of the health care team provide.

Legislative and regulatory authority

In July 2015, the Collaborative Practice Workgroup, convened by NASPA and made up of representatives from NACDS, AACP, APhA, NCPA, AMCP, NABP, ASHP, ACPE, and ACCP, as well as state pharmacy associations, met to formalize recommendations for the key elements of legislative and regulatory authority. The group worked to recommend which elements of collaborative practice authority should be codified in state law or regulations and which elements are more appropriately defined by the parties who voluntarily enter into a CPA at the practice level.

This workgroup made recommendations concerning CPA participants, authorized services, and requirements and restrictions. The specific recommendations that the workgroup made can be seen in the infographic below.

Although these recommendations were made over 8 years ago, the need for standardization around these topics still exists today in order for the widespread adoption and implementation of these agreements to occur.

Table detailing laws and regulations related to collaborative practice agreements (CPAs) between pharmacists and prescribers.

Differences among states

While all 50 states now recognize CPAs between pharmacists and prescribers, there are many differences between what is permitted in each state.

Some of the differences in CPAs between states include requirements of continuing education, liability insurance, and documentation of services. Additionally, some states require patient involvement in the agreement. A patient may have to sign that they agree to receive services as part of the CPA, or they may be able to opt out of these arrangements. Some states have chosen to mandate that the agreements be approved by a state agency or have defined a length of time that the agreements may be valid. Adding to the confusion, some states have chosen not to address these issues at all in legislation, leaving prescribers and pharmacists to figure it out for themselves.

This lack of standardization makes implementation and scaling of these authorities difficult. It also creates complications for national organizations that want to put these authorities into practice, as they have to navigate the legality of each state individually instead of on an organizational level.

While the recognition of CPAs in all states is a huge win for pharmacy, it is imperative that national standardization occurs so that pharmacists, as drug experts, can practice at the top of their license to improve health outcomes for patients. ■

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