Can a pharmacist independently administer buprenorphine? (i.e. without a collaborative practice agreement)

The purpose of this question is to see if any currently-in-force state pharmacy scope of practice laws and regulations are broad enough to allow a pharmacist to administer buprenorphine as a matter of general practice without the need to enter into a CPA or protocol with a supervising physician or other healthcare provider. To answer this question, LAPPA reviewed the state’s definition of the “practice of pharmacy” and looked for additional laws and regulations expressly governing pharmacist administration of drugs and medications, including vaccines/immunizations. 

The specificity with which a state’s definition of the practice of pharmacy addresses administration of drugs and medications varies considerably. This variability in laws and regulations results in five different upfront answers to this question. Moreover, even among the states falling within the same answer category, there can be differing reasons for why LAPPA placed it there.     

Can a pharmacist independently administer buprenorphine? (i.e. without a collaborative practice agreement)

• 18 states where the answer is “yes” as to all forms of buprenorphine: Arkansas, California, Colorado, Georgia, Hawaii, Idaho, Iowa, Kentucky, Missouri, Nebraska, New Mexico, North Dakota, Oklahoma, Oregon, Rhode Island, Tennessee, Washington, and Wisconsin. States fall into this category for one of two reasons.

  • One reason is that the state’s laws/regulations expressly authorize administering buprenorphine specifically, or MOUD more generally, without a CPA.

  • Alternatively, a state is a “yes” if the practice of pharmacy definition includes a general authorization related to drug and medication administration and LAPPA found no evidence in other pharmacy laws or regulations that would call into question interpreting this language as a broad authorization;

• Nine states where the answer is “yes” as to injectable forms of buprenorphine: Illinois, Maine, Maryland, Minnesota, New York, North Carolina, Ohio, Pennsylvania, and Utah. In these states, the pharmacy laws/regulations provide an express authorization to:

  • (1) administer injectable forms of MOUD; or

  • (2) categories of injectable medications that could include buprenorphine;

• 12 states where the answer is “unclear”: Alaska, Arizona, Delaware, Indiana, Mississippi, Nevada, New Hampshire, South Carolina, South Dakota, Vermont, Virginia, and Wyoming. In these states, the definition of the practice of pharmacy includes a general authorization related to drug and medication administration that could be interpreted broadly. However, state laws/regulations also contain more specific provisions related to the procedures and necessary training for administering a subset of drugs and medications that does not include buprenorphine (mostly typically, a provision related to vaccine/immunization administration). As a result, LAPPA could not determine if the language in the practice of pharmacy definition actually results in a broad authorization;

• Three states where the answer is “unclear” for the same reason as the above category, but pharmacists cannot administer buprenorphine under a CPA: Alabama, Louisiana, and West Virginia. As a result, LAPPA concludes that the more likely answer is “no” as practice under a CPA is unlikely to be more restrictive than a pharmacist’s general authority; and

• Eight states, the District of Columbia, and Puerto Rico where the answer is “no”: Connecticut, District of Columbia, Florida, Kansas, Massachusetts, Michigan, Montana, New Jersey, Puerto Rico, and Texas. In these states, the practice of pharmacy definition either does not address administration at all or the extent of a pharmacist’s general authority is specified sufficiently to conclude that it does not include buprenorphine.

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