Regulations Adopt MSNJ Suggestions for Collaborative Practice with Pharmacists
MSNJ has advocated for changes to the regulatory proposals which would allow collaborative practice agreements between physicians and pharmacists over the last two years. On February 4 the State Board of Medical Examiners and State Board of Pharmacy adopted regulations that addressed many of our concerns. The boards clarified in the preamble to the adopted regulations that “pharmacists do not have prescriptive authority” and may not engage in therapeutic interchange without the express consent of the physician and patient. [44 N.J.R. 213(b), Response to Comment 6]. Specific provisions for which MSNJ advocated include:
- Pharmacists may modify, continue or discontinue drug therapy, but may not initiate;
- Collaborative practice arrangements are limited to individual pharmacists (and may not be with a pharmacy or a chain);
- There must be a bona fide relationship for a physician and pharmacists to enter into a collaborative practice arrangement;
- The pathways for pharmacists to participate in collaborative agreements has been better defined; a voucher of 2,000 hours of training is not sufficient;
- Covering physicians and pharmacists must meet the same standards as the individuals entering into the arrangements;
- Specific conditions/diseases must be specified in the collaborative agreement; and
- Pharmacists must complete ten hours of continuing education on the specific disease states or conditions covered by the collaborative agreement which may require more than the minimum 30 hours, biennial, of continuing education depending on the number of conditions/disease states covered; physicians may customize the disease specific training required for the treatment of his/her patients.
MSNJ appreciates the careful consideration given to our concerns and the responsiveness of the Boards of Medical Examiners and Pharmacy to our comments.