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Collaborative Practice Agreements
What you need to know about the new rules and the law Joe Bruno, MBA, RPh President, Maine Board of Pharmacy
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Know the difference between the law and the rules
The law was passed in 2013 – took until now to get the rules in place What took so long? It was stated in the law that was passed it would be rules developed by the Board of Pharmacy and the Board of Licensure in Medicine in conjunction and consultation with DHHS Title 32 Chapter 117 Maine Pharmacy Act Subsection A Definitions of Collaborative Drug Therapy Management and Practice Agreements
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Defined as: Therapy management-Initiating, monitoring, modifying and discontinuing a patient’s drug therapy by a pharmacist as authorized by a practitioner in accordance with a Collaborative Practice Agreement (CPA). Allows you to collect and review patient histories, doing vital signs that include pulse, temperature, BP, respiration. Ordering and evaluating results of laboratory tests related to drug therapy and can’t include a diagnostic component
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Practice Agreement Definition
Written signed agreement between one or more pharmacists with training and experience relevant to the scope of the collaborative practice and a practitioner that supervises or provides direct consultation to the pharmacist engaging in drug therapy management. It must define the collaboration and the scope allowed, have beginning and end dates, specific guidelines for the prescriptive practice of the pharmacist(s)
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Subsection Authority This grants a pharmacist licensed in this state to enter into a CPA if they meet all of the qualifications in section and meet the rules adopted by BOP. Also talks about scope of authority as we previously discussed-patient history, vital signs, lab tests and results, drug therapy!
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Qualifications Section 13842
License must be valid and unrestricted!! Training-it takes a lot! Possess certification from Board of Pharmacy Specialties or completed an accredited pharmacy residency. If the residency is not in the area of practice of the CPA requires 15 hours of CE in each clinical area covered by the CPA OR Graduated with a Pharm.D. from an accredited college, has 2 years of experience, 15 hours of CE in each clinical area OR BS Pharm, 3 years of experience, 15 hours of CE in each clinical area
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CPA – what you need to do Copy must go to both Boards-Pharmacy and licensing board of practitioner Procedure for review and revision of the CPA HIPAA compliant Any amendments must be signed and dated Must have liability insurance proof and how to measure and assess outcomes
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What must be in agreement
First 3 months is drug therapy only!! After 3 months practitioner and pharmacist are to meet and determine scope of CPA Date started and end date How can it be cancelled by either party The site and setting where the practice will occur Qualifications outlined of the participants What is the procedure for referral?
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Which conditions or diseases can be managed?
Conditions with generally accepted standards of care Prohibited from clinical or investigational trials Limited to what is specified in the agreement-there is no wiggle room! Hospital Pharmacists doing this with inpatients are not limited by this chapter
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Now let’s look at the rules
The rules all look back at the law that was enacted. Gives examples of disease states – you are not limited to those that are listed!!! Defines an unrestricted license-you can’t have a consent agreement affecting your scope of practice. The CE requirement must be met prior to signing an agreement. You have two years to gather the 15 hours
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Rules There will be an application form that must be submitted to the Board along with any other information the Board may require. Incomplete applications will be returned. The CPA must be submitted to the BOP and the licensing Board of the practitioner
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CPA Content 3 month start up period Who is in the agreement?
Either party may cancel with written notification Site and setting Qualifications of the participants What diseases and drugs and drug categories will be allowed How will patient’s be referred? No remuneration for referrals!!! Practitioner is not obligated to refer patients to the pharmacist Proof of liability insurance
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CPA content The treatment protocols must be included
CPA terminates if pharmacist no longer holds unrestricted license Death of either party results in termination How is the continuity of care handled if CPA is terminated suddenly
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Treatment protocol Describe all the activities that the pharmacist is authorized to engage in. At a minimum: Informed consent procedure-patient must sign giving their consent to sharing medical records Scope – what can the pharmacist do – what is the decision criteria? Documentation-everything must be written down Communication procedures with the practitioner-how frequent and content-one week for normal results and 24 hours for abnormal results or adverse drug results
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Protocol Supervision-practitioner can override any decision made by the pharmacist Must do periodic reviews with both practitioner and pharmacist
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Notifications 10 days to report to the Board any changes to the CPA to both Boards that were originally notified Modifications must be signed and dated by both parties Any amendments to the treatment protocol including a copy of the new amended protocol Any change in liability insurance including policy certificate
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Record Keeping Must be adhered to as defined in Chapter 24 of the Board’s rules Complaints about the CPA goes to both Boards and may be investigated by both Any disciplinary action to any party in a CPA must be reported within 10 days to the other participant
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Any questions???
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Self Assessment Questions
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Question 1 To whom does the collaborative practice agreement (CPA) need to be submitted? Board of Pharmacy The Board that licenses the practitioner Both Boards Neither Board
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Question 2 How much training is required for a pharmacist to enter into a CPA? Certification in the specialty area or an accredited residency program with a concentration in the area of the CPA 15 hours of CE in the clinical area of the CPA Pharm D degree, 2 years of experience, 15 hours of CE in area BS Pharm, 3 years of experience, 15 hours of CE All of the above
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Question 3 What can be done under a CPA? Collect patient history
Check vital signs Order and evaluate laboratory tests related to drug therapy Initiate, monitor, modify, and discontinue drug therapy All of the above
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Question 4 Which medical condition is NOT allowed in a CPA? Cancer
Thyroid disease Hypertension Diabetes All are allowed
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