FAQ – Collaborative Practice Agreement

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.

What is a Collaborative Practice Agreement (CPA)?

• A collaborative 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 Practice Agreement defined by the State of Florida?

• “Collaborative pharmacy practice agreement” means a written agreement between a pharmacist who meets the qualifications of this section 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. To learn more view the 2020 Florida Statutes .

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

• Yes. As of February 4, 2021, this 20-hour course is the only board-approved program in the State of Florida pharmacists can take to meet the requirements for entering into a Collaborative Practice Agreement with a supervising physician.

What chronic health conditions can licensed Florida pharmacists who enter into a Collaborative Practice Agreement treat under Section 465.1865 of the Florida Statutes?

What requirements must a pharmacist meet to enter into a Collaborative Practice Agreement in the State of Florida?

• Hold an active and unencumbered license
• Must have earned a degree of doctor of pharmacy or have completed 5 years of experience as a licensed pharmacist
• Must have completed an initial 20-hour course approved by the board
• Maintain at least $250,000 of professional liability insurance coverage. A pharmacist who maintains professional liability insurance coverage pursuant to s. 465.1895 satisfies this requirement.
• Must 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, 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 practice agreement?

• Yes.  As of February 2021, the list below outlines what a pharmacist cannot do.  Visit the Florida Board of Pharmacy website to learn more.
• Modify or discontinue medicinal drugs prescribed by a health care practitioner with whom he or she does not have a collaborative practice agreement.
• Enter into a collaborative pharmacy practice agreement while acting as an employee without the written approval of the owner of the pharmacy.
• 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 are the continuing education requirements for initial certification?

• Complete a 20-hour board-approved continuing pharmacy education program with no fewer than 8-hours of live instruction.

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.

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

•  You can apply online on the MQA Online Services site if you have satisfied the requirements outlined here.

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

• This program is specific to Florida. You will need to consult other state board of pharmacies to learn more about their requirements.

What items must be included in a Collaborative Practice Agreement between a supervising physician and a pharmacist?

• The written agreement must include the following:
  • Identify the specific patients the pharmacist can provide services
  • List the chronic conditions and medicinal drugs or drugs that may be managed by the pharmacist
  • Circumstances that permit the pharmacist to order, perform, and evaluate laboratory or clinical tests
  • Terms that require the pharmacist to notify the physician
  • Dates that the written agreement is active (e.g., beginning and end dates) and termination procedures
  • Statement that the agreement can be terminated by either party

What does my registration include?

• Your registration includes the following:
  • Access to 12 hours of self-paced, on-demand content
  • A reserved spot for the 8-hour live program offered via Zoom
  • A virtual certificate of completion to be used as proof of completion when you apply to the board

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.

What are the program requirements?

• The learner must complete all three of the parts listed below to successfully complete the program and be eligible for a certificate of completion.
  • Part 1: 12-hour, self-paced and fully online education program that requires the learner to complete a 100-question self-study with a score of at least 70%.
  • Part 2: 8-hour, live seminar that requires the learner to be actively engaged and participate in the program.
  • Part 3: Complete and pass a 50-question exam with a score of at least 70% based on the knowledge gained in parts 1 and 2.

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.

Can I purchase a printed certificate?

• Yes. We are happy to mail you a printed certificate of completion for an additional $25.00.  Contact us for more information.

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

• Contact the Office of Continuing Pharmacy Education.

Will you be offering continuing education courses for CPAs so I can maintain my license?

• Yes. We will be offering the required educational courses to maintain your certification.

When a CPA needs to be amended does that have to be approved by the board each time?

• No. per rule 64B16-31.005(2), if an addendum is made to material terms of an existing CPA, the pharmacist shall maintain a copy of the addendum and the initial agreement.  There is no requirement to have the addendum approved by the Board.

Can a pharmacist (or pharmacists) enter into a CPA with more than one physician if stated in the CPA or do you have to have an individual CPA for each Physician-Pharmacist collaboration?

• A CPA is specific to one pharmacist and one supervising physician.  A pharmacist cannot enter into a CPA with multiple physicians or with a physicians group under a single CPA.  The CPA is specific to the relationship between the pharmacist and individual supervising physician.

Which license will the 20 hours of continuing pharmacy education credit be applied toward?

• Upon successful completion of the program credit will be applied toward your Florida License (PS) and your NABP e-profile ID.

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 the individual CPA need to be updated and resubmitted to the Board of Pharmacy every two years?

• Yes, under Florida Statute 465.1865(7)(b) a CPA automatically terminates 2 years after execution if not renewed and Board rule 64B16-31.005 provides that immediately after the renewal of a CPA, 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. Any material change to a CPA must be made in an addendum to the CPA but that addendum does not need to be provided to the Board of Pharmacy. The pharmacist must keep a copy of the addendum, but does not need to submit the addendum to the Board of Pharmacy. See rule 64B31.005. Material terms of the CPA are defined as any of the required elements of the CPA found in Florida Statute 465.1865(3)(a). Since patient name is a required element, adding additional patients to the CPA does need to be documented in an addendum, but that addendum does not need to be sent to the Board of Pharmacy.

If pharmacist A and physician B are entered into a CPA and physician B has the potential to see 1000+ patients do all these patients need to be included in the CPA? Is there a limit to the number of patients that can be included?

• There is no limit to the number of patients that can be included in a CPA. All patients that are part of the initial CPA must be included in the CPA. As additional patients are added to the CPA, they can be listed in an addendum to the CPA.

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. However, under a CPA, a pharmacist may perform or evaluate laboratory or clinical tests so if your CPA includes performing tests needed to initiate HIV treatment, this can be accomplished by a pharmacist under a CPA.

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.