Therapeutic Interchange Drug shortages MCO requirementsno ability to

Therapeutic Interchange • Drug shortages • MCO requirements/no ability to contact prescriber • Example: Arkansas BOP waiver April 15: the pharmacist can discuss with the patient and substitute with a notice sent to the prescriber of the substitution due to emergency when the prescriber is unavailable. • Ex: albuterol or levalbuterol inhalers • Similar ruling in South Dakota April 1, Iowa April 6, Michigan March 26, Minnesota May 27 2

State licensure • Waiving/relaxing licensure regulations to allow pharmacists and technicians licensed in other states to practice in the state – designed as response to potential workforce shortage issues • 12 states currently recognize NABP Passport for temporary licensure (additional 5 states were using the program; now expired) • Increase in discussion about licensure compacts and/or permanent relaxation of certain licensure regulations between states 3

Telehealth • Expansion of telehealth in nearly every state, suspending statutes that previously prevented and allowing reimbursement by third party providers • https: //naspa. us/resource/covid-19 -telehealth/ 4

Virtual Work • Authorizing certain responsibilities/roles to be completed remotely • Examples • AL – offsite order entry in community pharmacies • AR – remote order entry, verification, etc. with pre-approval by board (case-bycase basis) • CO – emergency rule authorizing remote pharmacy practice • KS – temporary authorization for pharmacists and technicians to perform certain work remotely • Texas State Board of Pharmacy Inspections • TSBP moving compliance inspections to virtual platform 5

Testing • HHS allows testing in all states with statement May 19: https: //naspa. us/wp-content/uploads/2020/05/prep-act-advisoryopinion. pdf • CLIA Waived pharmacist graphics: https: //naspa. us/resource/covid-19 -testing/ • Varying state authorizations March-May before HHS statement: https: //naspa. us/resource/covid-19 -testing/ 6

Vaccines • National letter to HHS requesting pharmacists to administer: https: //naspa. us/wp-content/uploads/2020/07/Pharmacy-COVID -vaccine-guidance-request-6 -29 -20 -FINAL-1. pdf • https: //naspa. us/resource/covid-19 -vaccines/ 7

Interns - ratios • On Monday, July 23 rd, the California State Board of Pharmacy issued a new waiver of pharmacy law that allows pharmacies to temporarily increase the ratio of intern pharmacists to pharmacists by one intern pharmacist under the following circumstances: • CA: Intern pharmacists providing immunizations under the provisions of this waiver may do so under the general supervision of a pharmacist at the discretion of the supervising pharmacist. 8

More information and resources • https: //naspa. us/resource/covid-19 -information-from-the-states/ 9