Tennessee Pharmacists Association

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  COMPREHENSIVE COLLABORATIVE PHARMACY PRACTICE CHECKLIST

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  General Collaborative Pharmacy Practice Resources
  TPA ad hoc Ambulatory Care / Pharmacy Practice Committee Resources
  Sample Collaborative Pharmacy Practice Agreements (CPPA's)
  Billing Resources for Pharmacist-Provided Patient Care Services
  National Provider Identifier (NPI) Number for Pharmacists

All pharmacists providing care pursuant to a CPPA are strongly encouraged to obtain a National Provider Identifier (NPI) number.

  Definition of Collaborative Pharmacy Practice

“Collaborative pharmacy practice” is the provision of patient care services through a valid, executed collaborative pharmacy practice agreement (CPPA) between one or more Tennessee-licensed pharmacists and one or more Tennessee-licensed prescribers. The CPPA can also be between one or more pharmacists and the chief medical officer, medical director, or a designated physician in an organized medical group.

  What Are the Minimum Required Elements for a CPPA?

  • Names and Titles of Collaborating Providers
  • Authorized Care and Services
  • Documentation and Communication
  • Override Clause
  • Expiration, Modification and Termination
  • Automatic Exclusions
  • Quality Assessment

Access TPA’s Collaborative Pharmacy Practice Checklist

  Pharmacist Qualifications to Engage in a CPPA

Pharmacists must meet one of the following two qualifications in order to engage in a CPPA:

  • Doctor of Pharmacy (PharmD) degree from a program accredited by ACPE
  • Bachelor of Science in Pharmacy (DPh) and be engaged in the active practice of pharmacy

“Active practice of pharmacy” means paid, unpaid, or volunteer activity which requires a pharmacist’s license under Tennessee law, for at least 2,000 hours within the 24-month period immediately preceding the date of the agreement. Active practice of pharmacy may include supervisory, educational or consultative activities or responsibilities for the delivery of such services.

  Scope of Practice and Authorized Services Under a CPPA

A CPPA allows a pharmacist to perform a broad range of patient care services in collaboration with prescribers as members of the patient’s healthcare team.
Scope: The CPPA shall define the scope of practice and services that the pharmacist(s) is/are authorized to provide.
Services: The services provided by the pharmacist under a CPPA must be services that the authorizing physician generally provides to his or her patients in the normal course of his or her clinical medical practice.
Ultimate Authority: The authorizing prescriber(s) shall retain the ultimate authority regarding the scope of services provided by pharmacists under a CPPA.

  Tennessee Board of Pharmacy Policy Statement on Preventive Care

On March 12, 2019, the Tennessee Board of Pharmacy adopted a policy statement on preventive care. “This Tennessee Board of Pharmacy policy is intended to provide guidance to pharmacists regarding collaborative pharmacy practice agreements with prescribers authorizing the provision of preventive care which promotes patient health and does not require diagnosis appropriately made and documented by the physician, advanced practice nurse or physician assistant, as identified in Tennessee Board of Pharmacy Rule 1140-03-.17 (5)(b).”

  Patient/Provider Relationship

The pharmacist should only provide care and services to patients whom the authorizing physician or collaborating prescriber routinely treats in the course of his or her clinical medical practice.

The “authorizing physician” of a CPPA must meet one of the following requirements:

  • Have a direct provider/patient relationship with the patients served under the CPPA;
  • Serve as the supervising physician of an advanced practice nurse or physician assistant who has a direct provider/patient relationship with the patients served under the CPPA; OR
  • Serve as the representative or chief responsible for particular specialty care within a multi-specialty practice.

The “collaborating prescribers” (physicians, advanced practice nurses, and/or physician assistants) must have a direct provider/patient relationship with the patient(s) covered under the CPPA and must have prepared a patient-specific, drug-specific, disease- or condition-specific plan of care based on a physical examination of the patient.

The following patient care services do not require a patient-specific CPPA:

  • Preventative Health Services
  • Screening and Testing
  • Immunizations
  • Naloxone through Tennessee’s Statewide CPPA
  • Contraceptives through Public Chapter 942
  Prescribing of Prescription Drugs

Pharmacist Prescribing of Prescription Drugs: According to Tennessee Code Annotated 63-10-204, pharmacists are authorized by law to prescribe prescription drugs, including the selection, initiation, modification, or discontinuation of medication therapy, as well as order laboratory tests, under one of the following conditions:

  • Pursuant to a medical order by the attending prescriber for each patient
  • Pursuant to a CPPA jointly agreed upon by pharmacists and prescribers

A CPPA which grants the collaborating pharmacist prescriptive authority, including authority for initiation and discontinuance of drug therapy, must be specifically included under the authorized care and services portion of the agreement and must contain a listing of the drugs or categories of drugs that may be prescribed by the collaborating pharmacist.

Pharmacist Prescribing of Controlled Substances: Under a CPPA, Tennessee-licensed pharmacists are authorized to prescribe controlled substances in “institutional-based pharmacy settings” and for hospice patients. “Institutional-based pharmacy settings” are defined as any institutional facility, long-term care facility, or academic healthcare institution, where the pharmacist is responsible for the care of patients within that facility. Pharmacists prescribing controlled substances through a CPPA should obtain their own unique DEA prescriber number. Get your DEA number here.

Pharmacists who hold a current federal DEA license to prescribe must complete a minimum of two (2) hours biennially of continuing education related to controlled substance prescribing. Pharmacists practicing outside of institutional-based pharmacy practice settings are not authorized to prescribe controlled substances under a CPPA.

  Notification to Licensing Boards and Maintenance of a CPPA

All licensing boards of the signatories must be notified of the executed CPPA no later than 30 days following the effective date. Pharmacists and prescribers should send a communication to their respective licensing boards notifying the Board of the executed CPPA. However, pharmacists are not required to send a copy of the entire CPPA to the Tennessee Board of Pharmacy. Any amendments to the authorized care and services not involving an “institutional-based pharmacy setting” which institute substantive additions or reductions to the scope of patient care services, including new therapeutic classes of drugs to the authorized formulary, must be provided to the appropriate licensing boards no later than thirty (30) days from the effective date of the amendment.
Any pharmacist who is a participant in a collaborative pharmacy practice agreement must be provided with a copy of the agreement. The agreement must include the names of all participants, an effective date, and a description of the scope of practice. Pharmacists and prescribers involved in collaborative pharmacy practice must maintain a copy of the collaborative pharmacy practice agreement on file at their places of practice.

  General Consent Requirement
  Required Documentation and Communication

Any patient care services provided by a pharmacist pursuant to a CPPA shall be either documented in a patient record accessible by the pharmacist and the prescriber or communicated to the prescriber(s) within three (3) business days. All such records shall be maintained by the collaborating prescriber(s) and pharmacist(s) for a period of not less than ten (10) years from the date of the last patient contact.

  Review and Renewal of a CPPA

Collaborative pharmacy practice agreements are required to be reviewed and renewed every two years (biennially) at a minimum.

  Quality Assessment Reviews

The authorizing physician(s) and pharmacist(s) are required to create written measurable and objective performance goals for evaluating the quality of care provided for the patients treated pursuant to the CPPA, and the following conditions must be met:

  • Data must be aggregated and reviewed at least quarterly.
  • Monthly patient record review by the authorizing physician(s) of at least 5% of the patients treated.
  • Review must be properly documented, retained, and available for review by the respective licensing boards for at least ten (10) years.

No retail pharmacy may employ a prescriber for maintaining, establishing or entering into a CPPA. However, a pharmacy or pharmacist may employ a physician or licensed medical practitioner to conduct quality assessment reviews.

  Professional Liability

Pharmacists, physicians, advanced practice nurses, and physician assistants engaging in collaborative pharmacy practice must each hold an active, unencumbered license in Tennessee and possess professional liability insurance coverage of at least one million dollars ($1,000,000) per occurrence.

  How TPA Members are Utilizing Collaborative Pharmacy Practice