• Can a pharmacist administer buprenorphine under a collaborative practice agreement (CPA)?

    State laws/regulations governing CPAs and practice under CPAs provide the state’s upfront answer. Similar to LAPPA’s findings with respect to prescribing drugs under a CPA, many states’ CPA-related provisions do not expressly authorize pharmacists to administer drugs or medications. Instead, the provisions utilize terms such as “initiating,” “adjusting,” or “modifying” drug therapy, but without defining or specifying the scope of activities that the terms encompass. As a result, the findings below show many states with an “unclear” answer. In the remainder of states, there is a clearer description about what pharmacist practice under a CPA entails.  

  • Can a pharmacist administer buprenorphine under a collaborative practice agreement (CPA)?

    • 10 states where the answer is “yes,” as to all forms of buprenorphine. In these states, there is an express authorization within laws/regulations governing CPAs to administer drugs and medications generally, or MOUD specifically; Alaska, Colorado, Connecticut, Maine, Montana, Nevada, New Jersey, New Mexico, Ohio, and Pennsylvania.

    • One state where the answer is “yes,” but only as to injectable forms; Minnesota.

    • 35 states, the District of Columbia, and Puerto Rico where laws/regulations governing CPAs do not clearly address administering drugs or medication and thus the answer is “unclear.”

      • However, in 21 of these 35 states, the information LAPPA obtained to answer the question “Can a pharmacists administer buprenorphine without a CPA?” indicates that pharmacists have authority to administer buprenorphine (in at least some forms) outside of a CPA which makes it more likely pharmacists have at least the same authority under a CPA; Arkansas, California, Georgia, Hawaii, Idaho, Illinois, Iowa, Kentucky, Maryland, Missouri, Nebraska, New York, North Carolina, North Dakota, Oklahoma, Oregon, Rhode Island, Tennessee, Utah, Washington, and Wisconsin.

      • In the other 14 states, the District of Columbia, and Puerto Rico, the answer to “Can a pharmacists administer buprenorphine without a CPA?” does not assist; Arizona, Delaware, District of Columbia, Florida, Indiana, Kansas, Michigan, Mississippi, New Hampshire, Puerto Rico, South Carolina, South Dakota, Texas, Vermont, Virginia, and Wyoming.

    • Four states where the answer is “no” because of limitations on what drugs/medications or disease states CPAs can cover; Alabama, Louisiana, Massachusetts, and West Virginia. Note that in Massachusetts, the restriction applies to CPAs in community/retail pharmacy settings. Otherwise, the answer is “unclear.”

    More details about each state’s laws and regulations can be found in the individual state charts.