Pharmacist Collaborative Practice Agreement Certificate FAQ » Continuing Pharmacy Education » College of Pharmacy

Disclaimer: The following answers are provided by the instructor as general information only and should not be considered legal advice. Only an attorney representing you or your organization can provide you with legal advice.

Information

What is a collaborative pharmacy practice agreement?

A collaborative pharmacy practice agreement is a written agreement between a physician and pharmacist which allows the pharmacist to provide specific patient care services to the physician’s patients. Services provided by the pharmacist are outlined in the written agreement and must be in accordance with Florida law. Collaborative practice agreements within the State of Florida allow the pharmacist to provide specific patient care services for chronic health conditions to specific patients as outlined by the supervising physician.

It is important to note that this agreement is specific to an individual physician and pharmacist; not a physician and a pharmacy.

How is a collaborative pharmacy practice agreement defined by the State of Florida?

“Collaborative pharmacy practice agreement” means a written agreement between a pharmacist who meets the qualifications of Section 465.1865 F.S. and a physician licensed under chapter 458 or chapter 459 in which a collaborating physician authorizes a pharmacist to provide specified patient care services to the collaborating physician’s patients.

What chronic health conditions can licensed Florida pharmacists who enter into a collaborative pharmacy practice agreement treat under Section 465.1865 of the Florida Statutes?

Pursuant to Section 465.1865, F.S., the Board hereby adopts the following list of chronic health conditions for which a pharmacist certified pursuant to Section 465.1865, F.S., can provide specified patient care services to patients of a collaborating physician pursuant to a pending Collaborative Pharmacy Practice Agreement:
(1) Hyperlipidemia:
(2) Hypertension;
(3) Anti-coagulation management;
(4) Nicotine Dependence;
(5) Opioid use disorder;
(6) Hepatitis C
(7) Those chronic health conditions enumerated in Section 465.1865(1)(b), F.S.

Arthritis;
Asthma;
Chronic obstructive pulmonary diseases;
Type 2 diabetes;
Human immunodeficiency virus or acquired immune deficiency syndrome;
Obesity

What requirements must a pharmacist meet to enter into a collaborative pharmacy practice agreement in the State of Florida?

To provide services under a collaborative pharmacy practice agreement, a pharmacist must be certified by the board, according to the rules adopted by the board in consultation with the Board of Medicine and the Board of Osteopathic Medicine. To be certified, a pharmacist must, at a minimum:

Hold an active and unencumbered license to practice pharmacy in the State of Florida.
Have earned a degree of doctor of pharmacy or have completed 5 years of experience as a licensed pharmacist.
Have completed an initial 20-hour course approved by the board, in consultation with the Board of Medicine and Board of Osteopathic Medicine.
Maintain at least $250,000 of professional liability insurance coverage. However, a pharmacist who maintains professional liability insurance coverage pursuant to s. 465.1895 satisfies this requirement.
Have established a system to maintain records of all patients receiving services under a collaborative pharmacy practice agreement for a period of 5 years from each patient’s most recent provision of service.

For more information on these requirements, visit the Florida Board of Pharmacy website – Pharmacist Collaborative Practice Agreement.

Is there anything a pharmacist cannot do once he/she becomes licensed to enter into a collaborative pharmacy practice agreement?

Yes. A pharmacist acting under a collaborative practice agreement may not:

Modify or discontinue medicinal drugs prescribed by a health care practitioner with whom he or she does not have a collaborative pharmacy practice agreement.
Enter into a collaborative pharmacy practice agreement while acting as an employee without the written approval of the owner of the pharmacy.

Note: A physician may not delegate the authority to initiate or prescribe a controlled substance as described in s. 893.03 or 21 U.S.C. s. 812 to a pharmacist.

What items must be included in a collaborative pharmacy practice agreement between a supervising physician and a pharmacist?

A collaborative pharmacy practice agreement must include the following:

Name of the collaborating physician’s patient or patients for whom a pharmacist may provide services.
Each chronic health condition to be collaboratively managed.
Specific medicinal drug or drugs to be managed by the pharmacist for each patient.
Circumstances under which the pharmacist may order or perform and evaluate laboratory or clinical tests.
Conditions and events upon which the pharmacist must notify the collaborating physician and the manner and timeframe in which such notification must occur.
Beginning and ending dates for the collaborative pharmacy practice agreement and termination procedures, including procedures for patient notification and medical records transfers.
A statement that the collaborative pharmacy practice agreement may be terminated, in writing, by either party at any time.

Does the individual collaborative pharmacy practice agreement need to be updated and resubmitted to the Board of Pharmacy every two years?

Yes, under Florida Statute 465.1865(7)(b), a collaborative pharmacy practice agreement shall automatically terminate 2 years after execution if not renewed. Board rule 64B16-31.005 provides that immediately after the renewal of such Agreement, the Pharmacist shall submit the executed Agreement to the Board Office through the pharmacist’s online licensure account at http://flhealthsource.gov or via U.S. Mail to 4052 Bald Cypress Way, Bin C-04, Tallahassee, FL 32399.

When adding new patients to a CPA, do those changes need to be submitted to the Board of Pharmacy?

No. In the event of an addendum to the material terms of an existing collaborative pharmacy practice agreement, the pharmacist shall maintain a copy of the addendum and the initial agreement pursuant to Section 465.1865(3)(c), F.S. Material terms shall be defined as those terms enumerated in Section 465.1865(3)(a), F.S. For example, since patient name is a required element, adding additional patients to the agreement must be documented in an addendum, but that addendum does not need to be sent to the Board of Pharmacy.

What if pharmacist A and physician B have entered into a collaborative pharmacy practice agreement, and Physician B has the potential to see 1000+ patients. Would all these patients need to be included in the agreement?

Yes. Under Florida Statute 465.1865(3)(a), the agreement must include the name of the collaborating physician’s patient or patients for whom a pharmacist may provide services. As additional patients are added to the agreement, they can be listed in an addendum to the initial agreement.

Is there a limit to the number of patients that can be included in a collaborative pharmacy practice agreement?

No. There is no limit to the number of patients that can be included in a collaborative pharmacy practice agreement.

The requirements for a collaborative pharmacy practice agreement include the name of the collaborating physician’s patient or patients for whom a pharmacist may provide services. Is this a violation of HIPAA?

No. HIPAA permits a covered entity to disclose protected health information such as a patient’s name as necessary to comply with state law. In addition, no minimum necessary determination is required for such a disclosure. See 45 CFR 164.512(a) and 45 CFR 164.502(b).

Does a pharmacist need to enroll in Test and Treat to be able to be able to initiate HIV treatment?

No, the Test and Treat law only applies to minor, non-chronic conditions and would not include a chronic condition such as HIV. Under a collaborative pharmacy practice agreement, a pharmacist may order or perform and evaluate laboratory or clinical tests under the circumstances the pharmacist and physician have outlined in the terms and conditions of the agreement. Therefore, if the agreement terms and conditions include performing tests needed to initiate HIV treatment, this can be accomplished by a pharmacist under a CPA.

Will I be able to enter into a collaborative pharmacy practice agreement outside of the State of Florida?

This program is specific to the requirements outlined by the Florida Board of Pharmacy. You will need to consult other state board of pharmacies to learn more about their requirements.

Can a pharmacist enter into a collaborative pharmacy practice agreement with more than one physician if stated in the agreement, or does there have to be an individual agreement for each Physician-Pharmacist collaboration?

A collaborative pharmacy practice agreement is specific to one pharmacist and one supervising physician. A pharmacist cannot provide or implement patient care services with multiple physicians or with a physicians group under a single agreement. The agreement is specific to the relationship between the pharmacist and individual supervising physician. A separate agreement is needed for each physician.

How does the Collaborative Practice Agreement certificate program compare to the Ambulatory Care certificate program?

The Collaborative Practice Agreement training program meets the requirements outlined by the State of Florida for pharmacists who wish to enter into a collaborative practice agreement with a supervising physician. Health conditions covered in this program include those pharmacists are allowed to manage according to the Florida law plus incorporates elements of the Florida rules and regulations for establishing a collaborative practice agreement, business principles necessary to assist with development of a practice site, and guidance on drafting a collaborative practice agreement protocol. In addition, this program contains a self-study portion as well as a live, interactive portion to meet Florida law requirements.

The Ambulatory Care certificate training program is designed as a resource to help prepare the pharmacist provide patient-centered care in a wide variety of ambulatory care settings with the goal of improving patient outcomes. It is also designed to serve as a starting point to help the pharmacist prepare for the Ambulatory Care board certification exam. The health conditions covered may include those covered in the Collaborative Practice Agreement training program; however, additional disease states are included that are not covered. This program is self-paced and fully online.

Some of the content may overlap between the programs; however, they are structured differently and the content overall is different.

Continuing Education Requirements

Does this program meet the requirements for a licensed Florida pharmacist to enter into a Collaborative Practice Agreement as outlined in Section 465.1865 of the Florida Statutes?

Yes. This program meets the initial 20.0-hour course requirements outlined in Section 465.1865(2)(c) of the Florida Statutes.

Where do I upload my signed collaborative pharmacy practice agreement?

Do not send your agreement directly to the Florida Board of Pharmacy. Your agreement is to be uploaded to the MQA Online Services web portal.

Do I have to complete additional continuing education programs to maintain this license?

Yes, per Section 465.1865, Florida Statutes, a pharmacist who practices under a collaborative pharmacy practice agreement must complete an 8-hour continuing education course approved by the board that addresses issues related to collaborative pharmacy practice each biennial licensure renewal in addition to the continuing education requirements under s. 465.009. A pharmacist must submit confirmation of having completed such course when applying for licensure renewal. A pharmacist who fails to comply with this subsection shall be prohibited from practicing under a collaborative pharmacy practice agreement under this section.

How many hours of continuing education must be completed to maintain my licensure?

To maintain your certification, you must complete 8 hours of board-approved continuing education that addresses issues related to collaborative pharmacy practice every two years. This 8-hour requirement is in addition to the 30 contact hours required, every two years, to maintain your general license within the State of Florida.

The Collaborative Practice Certification is automatically renewed with your Pharmacist License Renewal. If you have completed the requisite 8-hour continuing education (CE) course related to collaborative pharmacy practice approved by the board in addition to your required pharmacist hours, you will be able to renew your pharmacist license with the collaborative practice certification.

When renewing my license, I am asked about professional liability insurance coverage. What happens if I select “No”?

Section 465.1865 FS provides that a pharmacist wishing to practice under a collaborative practice agreement must maintain at least $250,000 of professional liability insurance coverage. However, a pharmacist who maintains professional liability insurance coverage pursuant to s. 465.1895 satisfies this requirement. If you answer “no” to professional liability insurance coverage, your license will be flagged during the renewal process and you will be prevented from renewing your license.

I am no longer practicing under a collaborative pharmacy practice agreement. Do I still need to complete the 8.0-hour recertification course?

If you no longer wish to hold the collaborative practice certification, please notify the Florida Board of Pharmacy office in-writing to have the distinction will be removed from your license. Once the distinction is removed from your license, your renewal hours will be adjusted within CE Broker so that your license is not flagged during renewal.

Registration

Are there any pre-requisites to register for the program?

You must be a licensed pharmacist in the State of Florida with a license that is in active and good standing.

Is there a deadline to register?

Yes. Registration will close at 4pm Eastern time the day before the live session.

Who do I contact if I am having issues with the registration system?

Contact the Office of Continuing Pharmacy Education.

I registered late and I am unable to complete the home study material before the live session. Can I still attend the live session?

Yes. You are strongly encouraged to complete the home study material prior to attending the live session, but it is not required. However, you will be expected to complete the home study material prior to being granted access to the final assessment.

What does my registration include?

Your registration includes access to the 12-hour self-paced, online home study content and access to the 8-hour live session.

When and where will the live session be held?

We offer live sessions at various times throughout the year. At the time of registration, you will select a live session from a list of available dates. Each session will be held virtually via Zoom from 8am-5pm Eastern time.

What if something comes up and I am unable to attend my selected live session?

If you are unable to attend your selected live session, you may transfer to a different live session. Please contact our office to complete your transfer.

Note: No shows will not be automatically transferred to the next available live session.

Who do I contact if I am having issues with Canvas?

Contact the Office of Continuing Pharmacy Education.

Receiving Credit

What are the program requirements?

To be awarded 20.0 hours of general continuing education credits for this program, you must complete the following:

View the 12.0-hour home study content and pass the comprehensive assessment with a score of 70% or greater.
Attend the 8.0-hour live seminar with active engagement in polling questions and breakout rooms.
Pass the final assessment with a score of 70% or greater.

Will partial credit be provided?

No. Partial credit will not be provided. Credit will only be awarded once all of the program requirements are satisfied.

Which license will the 20 hours of continuing pharmacy education credit be awarded to?

Upon successful completion of the program, credit will be awarded to your Florida Pharmacist License and your NABP e-profile ID.

How can I access my certificate of completion?

As of May 2024, certificates of completion will be awarded through Credly. To access your certificate of completion, please follow the instructions listed here. Additional information on the Credly platform is available here.

I have completed the 20-hour required continuing pharmacy education Collaborative Practice Agreement Program. Now what?

You can apply online through the MQA Online Services web portal if you have satisfied the requirements outlined here.