Revisiting the continuum of pharmacist prescriptive authority

Empowering Pharmacy Graduates to Diagnose and Prescribe

This commentary underscores the diagnosis and prescribing skills essential to the pharmacists' role on the healthcare team. It advocates for the integration of these skills into pharmacy curricula and emphasizes the urgent need for collaboration among pharmacy educators and the academy to address the omission of diagnosis and prescribing from key frameworks and standards, including the Pharmacists' Patient Care Process (PPCP), the Curricular Outcomes and Entrustable Professional Activities (COEPA), and the Accreditation Council for Pharmacy Education (ACPE) Draft Accreditation Standards 2025. The commentary draws on a case study of one college of pharmacy's integration of diagnosis and prescribing skills into its PharmD curriculum, in a state where pharmacists were granted full diagnostic and prescriptive authority. The integration was achieved through faculty-led modifications to the PPCP and COEPA, making diagnosis and prescribing an explicit part of the curriculum. The commentary concludes with a call to action for educational organizations to recognize and include these aspects in educational outcomes, accreditation standards, and practice frameworks. By doing so, the future of pharmacy education can be reshaped to improve patient care and advance the profession forward.

Words matter: Comments in support of diagnosis education in pharmacy

Diagnosis education is explicitly included in the Draft Accreditation Standards 2025 and should be wholeheartedly supported. To address the staggering number of diagnostic errors in the US, the National Academy of Medicine advocates for diagnosis education for all health professions. Misperceptions of pharmacists' involvement in diagnosis are exacerbated by use of implicit language and euphemisms, and it's long overdue that we provide clarity. Pharmacists are engaged in diagnosis and diagnostic reasoning in everyday practice whether realized or not. Diagnosis education is implicitly included in US pharmacy curricula in the Pharmacists' Patient Care Process, and it is time to give students the language to engage in it responsibly to be practice-ready in all states. The explicit inclusion of diagnosis in the Draft Standards 2025 has positive implications for education, practice, and graduates.

Pharmacists' current and potential prescribing roles in primary care in the Netherlands: a case study

In some countries, pharmacists have obtained prescribing rights to improve quality and accessibility of care and reduce physician workload. This case study explored pharmacists' current roles in and potential for prescribing in primary care in the Netherlands, where prescribing rights for pharmacists do not exist. Participatory observations of pharmacists working in either general practice or community pharmacy were conducted, as were semi-structured interviews about current and potential practice. The latter were extended to patients and other healthcare professionals, mainly general practitioners, resulting in 34 interviews in total. Thematic analyses revealed that pharmacists, in all cases, wrote prescriptions that were then authorized by a physician before dispensing. General practice-based pharmacists often prescribed medications during patient consultations. Community pharmacists mainly influenced prescribing through (a) medication reviews where the physician and/or practice nurse often were consulted to make treatment decisions, and (b) collaborative agreements with physicians to start or substitute medications in specific situations. These findings imply that the pharmacists' current roles in prescribing in the Netherlands resemble collaborative prescribing practices in other countries. We also identified several issues that should be addressed before formally introducing pharmacist prescribing, such as definitions of tasks and responsibilities and prescribing-specific training for pharmacists.

Investigating practice integration of independent prescribing by community pharmacists using normalization process theory: a cross-sectional survey

BACKGROUND

Independent prescribing (IP) has not been extensively investigated in community pharmacy (CP). Normalization process theory (NPT) constructs help explain how interventions are integrated into practice and include: 'coherence' (understanding), 'cognitive participation' (what promotes engagement), 'collective action' (integration with existing systems), and 'reflexive monitoring' (evaluation).

AIM

To use NPT to investigate the integration of pharmacist IP in CP.

METHOD

NHS Scotland Pharmacy First Plus (PFP) is a community pharmacy IP service. Questionnaire items were developed using the NPT derived Normalisation MeAsure Development (NoMAD) tool for an online survey of all PFP IP pharmacists. Demographic data were analysed descriptively and scale scores (calculated from item scores for the 4 NPT constructs) were used for inferential analysis.

RESULTS

There was a 73% (88/120) response rate. Greater than 90% 'strongly agreed'/'agreed' to NoMAD items relating to most NPT constructs. However, responses to 'collective action' items were diverse with more participants answering 'neither agree nor disagree' or 'disagree'. A statistically significant difference in NPT construct scale scores with significant p-values (ranging from p < 0.001 to p = 0.033) was shown on all the NPT constructs for the variable 'On average, how often do you consult with patients under the PFP service?'.

CONCLUSION

This theory-based work offers perspectives on IP integration within CP. Despite its geographic focus this work offers insights relevant to wider contexts on IP integration. It shows 'collective action' focused 'organisation' and 'group process' challenges with a need for further work on staff training, resource availability and utilisation, working relationships, communication and management.

Tiered Licensure for Pharmacy Technicians: Is the Advanced Pharmacy Technician (APhT) License the Model for State Regulators?

Two states-Connecticut and New Hampshire-have created or attempted to create advanced pharmacy technician (APhT) licenses. Both licenses, proposed and actual, have high barriers to entry, such as requiring 1 to 3 years of prior technician experience and passage of various assessments or trainings, such as a state-specific jurisprudence exam. Those obtaining APhT licensure are granted additional authority, such as performing final product verification (e.g., tech-check-tech) and vaccine administration. Compared with practices in other states, the APhT role in CT and NH provides minimal scope gains relative to the requirements imposed; as a result, there has been limited uptake (<1%) among current technicians. As such, it appears unlikely that tiered licensure for technicians will be the preferred mechanism for states to expand the role of pharmacy technicians in the future.

Regulating Pharmacist Clinical Services: Is Legal Silence Golden or Deafening?

In the United States, the scope of practice of pharmacists is determined primarily at the state level. Not all state laws expressly permit or prohibit pharmacists from providing certain services; in between is a grey area of legal silence. Does legal silence permit pharmacists to perform a service that is not specifically permitted, but not expressly prohibited? Point-of-care testing provides a useful case study in legal silence: there are 1536 pharmacies currently holding a CLIA-waiver to administer tests in states reporting that pharmacists are not expressly permitted to administer tests. Legal silence may even provide a better framework for pharmacy based testing as it is naturally inclusive of any point-of-care test and no laws need updated when a new test comes to the market. Other health professions navigate this legal silence by governing according to a "standard of care." Rather than specifying a list of services a health professional can or cannot provide in law, it provides a flexible framework for the health professional to provide any service that other similarly situated health professionals would provide in the same or similar situation. A standard of care regulatory framework should thus be the target of the pharmacy profession in order to advance patient care.

Evaluating trends in pharmacist e-prescribing: 2019-2022

BACKGROUND

Pharmacists have some prescriptive authority in all fifty states through dependent and independent prescribing. Data describing the volume and characteristics of pharmacist prescribing are not widely available, and these insights are critical to gauge the impact of regulations supporting pharmacist prescriptive authority.

OBJECTIVE

To identify trends in pharmacist prescribing and compare them to primary care provider (PCP) prescribing trends by analyzing e-prescriptions initiated from electronic health records systems from 2019 through 2022.

METHODS

This cross-sectional study used e-prescriptions from a national health information network to identify e-prescriptions ordered by pharmacists and PCPs from January 7, 2019, to January 1, 2023. E-prescriptions ordered by pharmacists and PCPs were analyzed to identify annual volume by prescriber type and most prescribed therapeutic classes. States with the highest volume of e-prescriptions ordered by pharmacists were identified.

RESULTS

The number of e-prescriptions prescribed by a pharmacist increased 47% from 2019 (n = 814,726) to 2022 (n = 1,199,601). The number of pharmacists prescribing in 2019 was 1650, and this increased by 122% to 3664 in 2022. The number of e-prescriptions prescribed by PCPs increased by 4% from 2019 (n = 927,890,123) to 2022 (n = 965,803,376) while the number of PCPs prescribing increased by 8% from 2019 (n = 364,995) to 2022 (n = 394,753).

CONCLUSION

Pharmacist e-prescribing increased across the 4 years studied while PCP e-prescribing modestly increased. Factors like access to technology, such as electronic health records, state regulations, and reimbursement impact a pharmacist's ability to prescribe.

Potential for pharmacist prescribing in primary care: A Dutch citizen perspective

Background

Medication prescribing by pharmacists is a task shifting approach to help ensure quality and accessibility of healthcare. In many countries, like the Netherlands, pharmacist prescribing is not legally ensured, and it is unknown what citizens think of its potential introduction.

Objective

To investigate citizen perspectives on the potential role of pharmacists in prescribing in primary care.

Methods

A Citizen Platform with citizens (>18 years) from the Netherlands was conducted in October 2022. This consisted of a one-day program in which the participants were engaged in interactive assignments and received expert presentations to foster the development of informed opinions. In the final assignment, 3 participant groups designed their ideal future scenario including preconditions regarding the role of the pharmacist in prescribing in primary care. All assignments were recorded, and notes were taken. The researchers then consolidated the 3 scenarios into one version and categorized the preconditions. The Citizen Platform results were summarized and subsequently discussed in 2 online focus groups with other citizens in February 2023 to investigate the perspectives of less informed citizens. Focus group discussions were audio-recorded, transcribed, and thematically analyzed.

Results

The Citizen Platform (n = 10) resulted in a shared scenario involving a primary care center where general practitioners (GPs) pharmacists and other healthcare professionals collaborate as a team. In this scenario, pharmacists can modify treatment in certain chronic diseases, manage minor ailments and support GPs with the care for patients with complex needs. Preconditions needed to realize this scenario include having shared medical records, the GP retaining the overview of the care for the patient and additional training for pharmacists. The focus groups (n = 6, in total) yielded 5 themes which acknowledge potential pharmacist prescribing but depict a more skeptical view towards pharmacist prescribing and include several concerns, for example pharmacists' potential conflict of interest.

Conclusions

Citizens that are informed about opportunities for pharmacy prescribing are capable of sketching potential scenarios for pharmacist prescribing in a collaborative primary care context. Less informed citizens seem more skeptical towards pharmacist prescribing.

Pharmacy-based CLIA-waived testing in the United States: Trends, impact, and the road ahead

BACKGROUND

Federal authorization of the use of Clinical Laboratory Improvement Amendments of 1988 (CLIA) waived point-of-care tests for SARS-CoV-2 by pharmacists during the pandemic resulted in a dramatic rise in the number of community pharmacies that became CLIA-waived test sites. Now as we exit the pandemic, the wide-ranging expansion of the scope of practice facilitated currently by the PREP Act is set to expire in fall 2024. As a result, American pharmacists' ability to offer CLIA-waived testing services will revert to a patchwork of state laws.

OBJECTIVE

This study aims to examine both the number of pharmacies in the United States with CLIA Certificates of Waiver before and after the SARS-CoV-2 pandemic and the state-by-state differences in the percentage of pharmacies with CLIA Certificates of Waiver.

METHODS

Data were collected from the U.S. Centers for Disease Control and Prevention CLIA Laboratory Search website on May 3rd, 2015, August 4th, 2019, November 26th, 2020, October 6th, 2021, November 23rd, 2022, and December 4th, 2023. The website allows for the exportation of demographic data on all CLIA-waived facilities by state.

RESULTS

The total number of pharmacies with a CLIA-waiver grew from 10,626 (17.9%) locations in 2015 to 12,157 (21.4%) locations in 2019, to 15,671 (27.6%) locations in 2020, and to 29,011 (51.6%) locations in 2023. States demonstrated considerable variability in the percentage of pharmacies possessing a CLIA certificate of waiver in 2023, with a range of 10.7%-87.9%.

CONCLUSIONS

Use of CLIA-waived tests in pharmacies has grown by 140% since 2019. The time period from 2019 to 2021 witnessed a 92.5% increase in pharmacies that possessed a certificate of waiver which was largely driven by the pandemic. Interestingly, from 2021 to 2023 the was continued growth in the market of 31.6%. This suggests that pharmacies continue to see opportunity in offering CLIA-waived testing services beyond those that had been extended as a result of the pandemic.

Pharmacist Prescribing Models for HIV Pre-exposure and Post-exposure Prophylaxis

State strategies for pharmacist prescribing exist on a continuum from most restrictive to least restrictive. Using human immunodeficiency virus (HIV) pre-exposure prophylaxis and post-exposure prophylaxis as a case study, there are 3 viable pharmacist prescribing models: (1) population-based collaborative practice agreements; (2) government protocols; and (3) standard of care prescribing. The advantages and disadvantages of these 3 models are reviewed.

How to implement a "standard of care" regulatory model for pharmacists

National pharmacy associations have increasingly explored regulation according to a "standard of care." In such a model, pharmacists can provide a wide range of clinical services aligned with their education and training. Based on Idaho's experience implementing this model, there are five critical steps states must take to enact a standard of care: 1) Adopt a broad definition of "practice of pharmacy;" 2) Allow elasticity for practice innovation over time; 3) Decide which limited instances still necessitate prescriptive regulation; 4) Eliminate all unnecessary regulations; and 5) Strengthen accountability for deviations from the standard of care. States wishing to adopt a standard of care approach can follow this five-step process to enhance patient care and mitigate the lag that is otherwise constant between laws and practice.

Implementation of the California advanced practice pharmacist and the continued disappointment of tiered licensure

The Advanced Practice Pharmacist (APh) designation in California was created via legislation 10 years ago. California pharmacists who meet certain criteria can be designated as an APh and unlock additional practice authority. Just 1065 pharmacists, or 2% of licensed California pharmacists, have obtained the APh designation through 2022. APhs did not report benefiting from the designation as it relates to expanded scope of practice. This experience of low uptake and minimal benefit mirrors the tiered licenses created by three other states. More recent legislation broadened the independent prescriptive authority of APhs, but this increased value proposition aligns with the practice authority adopted by other states who have imposed fewer barriers to entry. Given the track record observed to date, we doubt that tiered licensure will ever prove successful in the pharmacy profession. Instead, state policymakers and pharmacy advocates should consider adopting a "standard of care" regulatory approach to improve patient access to safe and beneficial pharmacist services.