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APhA Policy Manual

LICENSURE, REGISTRATION, AND REGULATION

Browse policies organized by category. Select a category to view the related policy statements.

5 categories • 30 policies

Composition of State Boards of Pharmacy

1 Policies
Boards of Pharmacy: Consumer Representation

APhA encourages state pharmaceutical associations to actively seek appointment of public members to their respective boards of pharmacy and other health profession licensing and regulatory agencies.

Licensure and Registration of Personnel

5 Policies
Expanding Technician Roles

  1. APhA encourages state boards of pharmacy to develop laws, regulations, and policies allowing expanded pharmacy technician roles that allow both technicians and pharmacists to practice at the top of their training and license or certification.
  2. APhA supports state board of pharmacy regulations that standardize and set minimum didactic and experiential standards for technicians to allow for functioning in expanded roles.

Pharmacy Technician Education, Training, and Development

  1. APhA supports the following minimum requirements for all new pharmacy technicians: (a) Successful completion of an accredited or state-approved education and training program. (b) Certification by the Pharmacy Technician Certification Board (PTCB).
  2. APhA supports state board of pharmacy laws, regulations, and policies that require pharmacy technicians to meet minimum standards of education, training, certification, and recertification. APhA encourages state boards of pharmacy to develop a phase-in process for current pharmacy technicians. APhA also encourages boards of pharmacy to delineate between pharmacy technicians and student pharmacists for the purposes of education, training, certification, and recertification.
  3. APhA recognizes the important contribution and role of pharmacy technicians in assisting pharmacists and student pharmacists with the delivery of patient care.
  4. APhA supports the development of resources and programs that promote the recruitment and retention of qualified pharmacy technicians.
  5. APhA supports the development of continuing pharmacy education programs that enhance and support the continued professional development of pharmacy technicians.
  6. APhA encourages the development of compensation models for pharmacy technicians that promote sustainable career opportunities.

Continued Competence Assessment Examination

  1. APhA should develop, in cooperation with other state and national associations, a voluntary process for self-assessing pharmaceutical care competence.
  2. APhA opposes regulatory bodies utilizing continuing competence examinations as a requirement for renewal of a pharmacist’s license.
  3. APhA supports programs that measure and evaluate pharmacist competence based on established valid standards.

Reciprocity

APhA supports systems of reciprocity that recognize a current license issued by any state and eliminate the requirement for pharmacists to maintain active practice licenses in the states of initial licensure.

Licensure, Registration and Inspection of Facilities

12 Policies
Pharmacy Jurisprudence Competency Assessment

  1. APhA affirms pharmacy personnel must have knowledge and understanding of laws, regulations, and policies that affect their roles in the practice of pharmacy.
  2. In the interest of protecting public health and safety, APhA supports the assessment of knowledge regarding pharmacy laws, regulations, and policies as a component of pharmacist licensure or registration.
  3. To mitigate barriers to licensure, APhA advocates for state boards of pharmacy to work with relevant parties to design and implement optimal methods for assessing minimum pharmacy jurisprudence competency.
  4. APhA encourages National Association of Boards of Pharmacy (NABP) to collaborate with pharmacy educators to formulate measurable competency statements for use in developing pharmacy jurisprudence assessments.
  5. APhA advocates for ongoing, timely, and transparent quality assurance and control for jurisprudence assessments.
  6. APhA encourages state boards of pharmacy to publicly communicate when changes in laws, regulations, and policies will be reflected in jurisprudence assessments.
  7. APhA encourages boards of pharmacy to provide free, timely, and readily accessible educational updates regarding changes in pharmacy laws, regulations, and policies.

Registration of Facilities

APhA supports laws, regulations, and policies that require registration with the state boards of pharmacy of all facilities involved in the storage, wholesale distribution, and issuance of legend drugs to patients, provided that such registration does not restrict the pharmacists from providing professional services independent of a facility.

Registration of Facilities Involved in the Storage and Issuing of Legend Drugs to Patients

APhA supports enactment of laws, regulations, and policies that would require registration with the state boards of pharmacy of all facilities involved in the storage and issuing of legend drugs to patients, provided that such registration does not restrict the pharmacist from providing professional services independent of a facility.

Regulation of Mobile Facilities

APhA supports enactment of laws, regulations and policies which would govern the dispensing and issuing of legend drugs from mobile facilities.

Controlled Substances Regulation and Patient Care

  1. APhA encourages the Drug Enforcement Administration (DEA) and other regulatory agencies to recognize pharmacists as partners that are committed to ensuring that patients in legitimate need of controlled substances are able to receive the medications.
  2. APhA supports efforts to modernize and harmonize state and federal controlled substance laws.
  3. APhA urges DEA and other regulatory agencies to balance patient care and regulatory issues when developing, interpreting, and enforcing laws and regulations.
  4. APhA encourages DEA and other regulatory agencies to recognize the changes occurring in health care delivery and to establish a transparent and inclusive process for the timely updating of laws and regulations.
  5. APhA encourages the U.S. Department of Justice to collaborate with professional organizations to identify and reduce (a) the burdens on health care providers, (b) the cost of health care delivery, and (c) the barriers to patient care in the establishment and enforcement of controlled substance laws.

Pharmacy Practice Accreditation

  1. APhA should lead the creation of consensus-based, pharmacy profession-developed accreditation standards and methods of evaluation to optimize the quality and safety of patient care and promote best practices.
  2. APhA urges that accrediting bodies use profession-developed standards for pharmacy.
  3. APhA supports only those pharmacy accreditation processes that are voluntary, transparent, consensus-based, reasonably executable, and affordable, while avoiding duplication and barriers to patient care.
  4. APhA opposes mandatory pharmacy accreditation.
  5. APhA shall assume the leadership role among stakeholders on the design and implementation of an appropriate process for any new pharmacy accrediting program.
  6. APhA supports the appropriate use of data gathered from pharmacy practice monitoring processes to facilitate the advancement of pharmacy practice and quality of patient care.

Discontinuation of the Sale of Tobacco Products in Pharmacies and Facilities That Include Pharmacies

  1. APhA urges pharmacies and facilities that include pharmacies to discontinue the sale of tobacco products.
  2. APhA urges the federal government and state governments to limit participation in government-funded prescription programs to pharmacies that do not sell tobacco products.
  3. APhA urges state boards of pharmacy to discontinue issuing and renewing licenses to pharmacies that sell tobacco products and to pharmacies that are in facilities that sell tobacco products.
  4. APhA urges colleges of pharmacy to only use pharmacies that do not sell tobacco products as experience sites for their students.
  5. APhA urges the Accreditation Council for Pharmacy Education (ACPE) to adopt the position that college-administered pharmacy experience programs should only use pharmacies that do not sell tobacco products.
  6. APhA urges pharmacists and student pharmacists who are seeking employment opportunities to first consider positions in pharmacies that do not sell tobacco products.

Pharmacy Compounding Accreditation

  1. APhA reaffirms the 1992 Compounding Activities of Pharmacists policy, which states that APhA affirms that compounding pursuant to or in anticipation of a prescription or diagnostic preparation order is an essential part of health care that is the prerogative of the pharmacist.
  2. APhA supports compounding as defined by the Pharmacy Compounding Accreditation Board (PCAB) as a means to meet patient drug therapy needs.
  3. APhA opposes compounding when identical medications are commercially and readily available in strength and dosage form to meet patient drug therapy needs.
  4. APhA asserts that compounding is subject to regulations and oversight from state boards of pharmacy. APhA urges state boards of pharmacy to identify and take appropriate action against entities who are illegally manufacturing medications under the guise of compounding.
  5. APhA supports accreditation of compounding sites by PCAB to ensure patient safety. APhA encourages state boards of pharmacy to recommend accreditation for those sites that engage in more than basic non-sterile compounding as defined by PCAB.
  6. APhA supports the development of education, training and recognition programs that enhance pharmacist and student pharmacist knowledge and skills to engage in compounding beyond basic, non-sterile preparations as defined by PCAB.
  7. APhA encourages the exploration of a specialty certification in compounding through the Board of Pharmaceutical Specialties (BPS).

Regulatory Compliance/Regulatory Burden

APhA supports measures that protect the patient, public, and employees from pharmacy conditions that pose a threat to health.

Licensing Boards: Inspection of Pharmacies

  1. APhA supports that all non-criminal inspections of pharmacies shall be under the direct control of each state board of pharmacy.
  2. APhA recommends that state boards of pharmacy require that all pharmacy inspectors be licensed pharmacists who regularly update their knowledge of pharmacy practice.
  3. APhA encourages NABP to develop and maintain uniform guidelines and standards for non-criminal inspections of pharmacies.

Licensure/Registration of Drug Manufacturers

APhA supports the requirements that all drug manufacturers must obtain a federal license or registration, conditioned upon an inspection of the manufacturer’s facilities before manufacturing is begun.

State Boards of Pharmacy/Inspections

  1. APhA supports inspections of pharmacies and peer review of pharmacists that promote high-quality pharmaceutical service and thereby serve to improve public health.
  2. APhA opposes the use of criminal investigative techniques during routine noncriminal pharmacy inspections.
  3. APhA supports regulation and inspection by boards of pharmacy of all facilities within a state at which drugs are dispensed, stored, or offered for sale in the same manner as pharmacies.

Pharmacy Law and Practice Acts

11 Policies
Access to Comprehensive Reproductive Health Care

  1. APhA supports equitable patient access to evidence-based comprehensive reproductive health care, including, but not limited to, the management of pregnancy loss, ectopic pregnancy, infertility, pregnancy termination, contraception, and permanent contraception.
  2. APhA recognizes patient autonomy in choosing reproductive health care services and the essential role of all health care professionals in facilitating access and advancing informed decision making.
  3. APhA supports evidence-based laws, regulations, and policies that ensure patient access to comprehensive reproductive health care services.
  4. APhA opposes legal actions against pharmacies, pharmacists, and pharmacy personnel that provide patient access to, or information regarding, reproductive health care services that are within pharmacist scope of practice.

Contemporary Pharmacy Practice

  1. APhA asserts that pharmacists should have the authority and support to practice to the full extent of their education, training, and experience in delivering patient care.
  2. APhA opposes burdensome legal and regulatory requirements beyond continuing professional development for the provision of patient care services.
  3. APhA supports continuing efforts toward establishing a consistent and accurate perception of the contemporary role and practice of pharmacists by the general public, patients, and all persons and institutions engaged in health care policy, administration, payment, and delivery.
  4. APhA supports continued collaboration with stakeholders to facilitate adoption of standardized practice acts, appropriate related laws, regulations, and policies that reflect contemporary pharmacy practice.
  5. APhA supports the establishment of multistate pharmacist licensure agreements to address the evolving needs of the pharmacy profession and pharmacist-provided patient care.
  6. APhA urges the continued development of consensus documents, in collaboration with medical associations and other stakeholders, that recognize and support pharmacists’ roles in patient care as health care providers.
  7. APhA urges universal recognition of pharmacists as health care providers and compensation based on the level of patient care provided using standardized and future health care payment models.

Continuity of Care and the Role of Pharmacists During Public Health and Other Emergencies

  1. APhA asserts that pharmacists, student pharmacists, pharmacy technicians, and pharmacy support staff are essential members of the healthcare team and should be actively engaged and supported in surveillance, mitigation, preparedness, planning, response, recovery, and countermeasure activities related to public health and other emergencies.
  2. APhA reaffirms the 2016 policy on the Role of the Pharmacist in National Defense, and calls for the active and coordinated engagement of all pharmacists in public health and other emergency planning and response activities.
  3. APhA advocates for the timely removal of legal, regulatory, and policy restrictions; practice limitations; and financial barriers during public health and other emergencies to meet immediate patient care needs.
  4. APhA urges regulatory bodies and government agencies to recognize pharmacists' training and ability to evaluate patient needs, provide care, and appropriately refer patients during public health and other emergencies.
  5. APhA advocates for pharmacists’ authority to ensure patient access to care through the prescribing, dispensing, and administering of medications, as well as provision of other patient care services during times of public health and other emergencies.
  6. APhA calls for processes to ensure that any willing and able pharmacy and pharmacy practitioner is not excluded from providing pharmacist patient care services during public health and other emergencies.
  7. APhA calls on public and private payers to establish and implement payment policies that compensate pharmacists providing patient care services, including during public health and other emergencies, within their recognized authority.
  8. APhA advocates for the inclusion of pharmacists as essential members in the planning, development, and implementation of alternate care sites or delivery models during public health and other emergencies.
  9. APhA reaffirms the 2015 Interoperability of Communications Among Health Care Providers to Improve Quality of Care and encourages pharmacists, as members of the healthcare team, to communicate care decisions made during public health and other emergencies with other members of the healthcare team to ensure continuity of care.

Just Culture Approach to Patient Safety

  1. APhA calls for employers to adopt and implement just culture principles to improve patient safety and support pharmacy personnel.
  2. APhA encourages transparency between employers and employees by sharing deidentified medication error and near-miss data and trends as well as actions taken to promote continuous quality improvement.
  3. APhA urges the integration of non-disciplinary and non-punitive mechanisms for use by boards of pharmacy to promote just culture principles when addressing people, systems, and processes involved in medication errors.
  4. APhA encourages national and state associations to advocate for laws, regulations, and policies to provide protections to individuals utilizing error reporting systems to promote just culture.
  5. APhA encourages the creation of a mechanism for an industrywide effort to engage in confidential and transparent sharing of learnings and root cause findings helpful in reducing the risk of medication errors.
  6. APhA supports the integration of just culture principles in PharmD and pharmacy technician education, postgraduate training, and continuing professional development programs.

Multi-State Practice of Pharmacy

  1. APhA affirms that pharmacists are trained to provide patient care and have the ability to address patient needs, regardless of geographic location.
  2. APhA advocates for the continued development of uniform laws, regulations, and policies that facilitate pharmacists,' student pharmacists,' and pharmacy technicians’ timely ability to practice in multiple states to meet practice and patient care needs.
  3. APhA supports individual pharmacists’ and student pharmacists’ authority to provide patient care services across state lines whether in person or remotely.
  4. APhA supports consistent and efficient centralized processes across all states for obtaining and maintaining pharmacist, pharmacy intern, and pharmacy technician licensure and/or registration.
  5. APhA urges state boards of pharmacy to reduce administratively and financially burdensome requirements for licensure while continuing to uphold patient safety.
  6. APhA encourages the evaluation of current law exam requirements for obtaining and maintaining initial state licensure, as well as licensure in additional states, to enhance uniformity and reduce duplicative requirements.
  7. APhA urges state boards of pharmacy and the National Association of Boards of Pharmacy (NABP) to involve a member of the board of pharmacy and a practicing pharmacist in the review and updating of state jurisprudence licensing exam questions.
  8. APhA calls for development of profession-wide consensus on licensing requirements for pharmacists and pharmacy personnel to support contemporary pharmacy practice.

Pharmacists Roles in Sexually Transmitted Infection Prevention and Treatment in Underserved Patients

  1. APhA affirms that pharmacists play a vital role in improving outcomes in patients with or at risk of sexually transmitted infections.
  2. APhA supports the pharmacist's role in the development of education and resources for individuals with Sexually Transmitted Infections (STIs), Expedited Partner Therapy (EPT), Pre-Exposure Prophylaxis (PrEP), and Post-Exposure Prophylaxis (PEP) in order to increase awareness and access.
  3. APhA advocates for revision of state practice acts to permit pharmacists to independently prescribe for individuals with Sexually Transmitted Infections (STIs), Expedited Partner Therapy (EPT), Pre-Exposure Prophylaxis (PrEP), and Post-Exposure Prophylaxis (PEP) therapy.

Professional Practice Regulation

  1. APhA encourages the revision of pharmacy laws, regulations, and policies to assign the responsibility and accountability to the pharmacy license holder for the operations of the pharmacy, including but not limited to quality improvement, staffing, inventory, and financial activities. Further, APhA supports the responsibility and accountability of the pharmacist for dispensing of the pharmaceutical product and for the provision of pharmaceutical care services.
  2. APhA encourages the pharmacy license holder to provide adequate resources and support for pharmacists to meet their professional responsibilities, and for pharmacists to utilize the resources and support appropriately and efficiently. APhA encourages state boards of pharmacy to hold pharmacy license holders accountable for failure to provide such adequate resources and support.

Standards of Care Regulatory Model for State Pharmacy Practice Acts

  1. APhA requests that state boards of pharmacy and legislative bodies regulate pharmacy practice using a standard of care regulatory model similar to other health professions’ regulatory models, thereby allowing pharmacists to practice at the level consistent with their individual education, training, experience, and practice setting.
  2. To support implementation of a standard of care regulatory model, APhA reaffirms 2002 policy that encourages states to provide pharmacy boards with the following: (a) adequate resources; (b) independent authority, including autonomy from other agencies; and (c) assistance in meeting their mission to protect the public health and safety of consumers.
  3. APhA encourages NABP as well as state and national pharmacy associations to support and collaborate with state boards of pharmacy in adopting and implementing a standard of care regulatory model.
  4. APhA and other pharmacy stakeholders should provide educational programs, information, and resources regarding the standard of care regulatory model and its impact on pharmacy practice.

Controlled Substances Regulation and Patient Care

  1. APhA encourages the Drug Enforcement Administration (DEA) and other regulatory agencies to recognize pharmacists as partners that are committed to ensuring that patients in legitimate need of controlled substances are able to receive the medications.
  2. APhA supports efforts to modernize and harmonize state and federal controlled substance laws.
  3. APhA urges DEA and other regulatory agencies to balance patient care and regulatory issues when developing, interpreting, and enforcing laws and regulations.
  4. APhA encourages DEA and other regulatory agencies to recognize the changes occurring in health care delivery and to establish a transparent and inclusive process for the timely updating of laws and regulations.
  5. APhA encourages the U.S. Department of Justice to collaborate with professional organizations to identify and reduce (a) the burdens on health care providers, (b) the cost of health care delivery, and (c) the barriers to patient care in the establishment and enforcement of controlled substance laws.

Updating of State Pharmacy Practice Acts

  1. APhA recommends and supports enactment of state pharmacy practice act revisions enabling pharmacists to achieve the full scope of APhA’s Mission Statement for the Pharmacy Profession.
  2. APhA supports standards of pharmacy practice reflecting the APhA Mission Statement for the Pharmacy Profession.

National Framework for Practice Regulation

  1. APhA supports state-based systems to regulate pharmacy and pharmacist practice.
  2. APhA encourages states to provide pharmacy boards with (a) adequate resources, (b) independent authority, including autonomy from other agencies, and (c) assistance in meeting their mission to protect the public health and safety of consumers.
  3. APhA supports efforts of state boards of pharmacy to adopt uniform standards and definitions of pharmacy and pharmacist practice.
  4. APhA encourages state boards of pharmacy to recognize and facilitate innovations in pharmacy and pharmacist practice.

Privacy of Pharmacists’ Personal Information

  1. APhA supports protecting pharmacist, student pharmacist, and pharmacy technician personal information (e.g. home address, telephone, and personal email address).
  2. APhA opposes legal, regulatory, and policy requirements that mandate the publication of pharmacist, student pharmacist and pharmacy technician personal information (e.g., home address, telephone, and personal email address).
  3. APhA encourages state boards of pharmacy to remove from their websites personal addresses, phone numbers, email, and other non-business contact information of pharmacists, student pharmacists, and pharmacy technicians.

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