Connecticut

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LAPPA Legal Analysis (as of October 2024)

  • Short Answer: No, based on the information described below.

    • The definition of the “practice of pharmacy” in Connecticut law refers only to “the distributing, dispensing and use of drugs and devices.” CONN. GEN. STAT. ANN. § 20-571(30) (West 2024).

    • Although not in the practice of pharmacy definition, Connecticut pharmacists can prescribe opioid antagonists, epinephrine injectors, and certain HIV prophylaxis medications.

    • Also, pharmacists are ineligible to obtain a state controlled substance registration for prescribing controlled substances, as pharmacists are not included in the definition of “practitioner” under the Connecticut statutory provisions for controlled substance registration. CONN. GEN. STAT. ANN. § 21a-316 (West 2024).

    • The above points are consistent with DEA information that registered pharmacists in Connecticut cannot obtain the DEA’s mid-level practitioner registration to prescribe controlled substances. (Mid-level Practitioners Authorization by State, Drug Enforcement Admin. 1; Nov. 7, 2024)

  • Short Answer: No, based on the information described below.

    • A pharmacist can “initiate, modify, continue, discontinue or deprescribe a drug therapy” as part of a collaborative drug therapy management agreement, collaborative drug therapy management policy, and collaborative drug therapy care plan (collectively, CDTMA/P/CP). CONN. GEN. STAT. ANN. § 20-631(c) (West 2023). Connecticut regulations make clear that “initiate, modify, continue, discontinue or deprescribe a drug therapy” includes making “prescriptive authority decisions.” CONN. AGENCIES REGS. § 20-631-2(1) (2024).

    • However, Connecticut law and regulations do not expressly specify whether the pharmacist’s prescriptive authority under a CDTMA/P/CP includes controlled substances.

    • Moreover, Connecticut laws and regulations governing CDTMA/P/CP does not account for the fact that a Connecticut pharmacist cannot obtain a state controlled substance registration (if any) or a federal DEA mid-level practitioner registration, which precludes the pharmacist from prescribing buprenorphine regardless of what the CDTMA/P/CP directs.

    • In summary, Connecticut laws and regulations do not expressly prohibit a pharmacist from prescribing drugs under a CDTMA/P/CP. Even if prescribing buprenorphine is theoretically allowed, however, as a practical matter, there is no way to do it because a Connecticut pharmacist cannot obtain the state/DEA controlled substance registrations necessary.

  • Short Answer: No, based on the information described below.

    • The definition of the “practice of pharmacy” in Connecticut law refers only to “the distributing, dispensing and use of drugs and devices.” CONN. GEN. STAT. ANN. § 20-571(30) (West 2024). The definition does not expressly refer to administering drugs or medications.

    • Although administration is not addressed in the practice of pharmacy definition, Connecticut pharmacists can administer certain vaccines and “epinephrine cartridge injectors.” CONN. GEN. STAT. ANN. § 20-633 (West 2024). This is the only express reference to administering drugs or medications in Connecticut pharmacy laws outside of collaborative drug therapy management agreement, collaborative drug therapy management policy, and collaborative drug therapy care plan (collectively, CDTMA/P/CP).

  • Short Answer: Yes, based on the information described below.

    • A pharmacist can “administer drugs” if it is authorized as part of a CDTMA/P/CP. CONN. GEN. STAT. ANN. § 20631(c) (West 2024).

    • The only limitation expressly placed on this authorization is that a CDTMA/P/CP cannot authorize a pharmacist “to establish a port to administer parenteral drugs.” CONN. GEN. STAT. ANN. § 20-631(c) (West 2024).

    • Yes, but based on the information described below, the authorization is limited and may not cover the types of tests necessary for patients undergoing SUD treatment with buprenorphine.

    • The definition of the “practice of pharmacy” in Connecticut law refers only to “the distributing, dispensing and use of drugs and devices.” Conn. Gen. Stat. Ann. § 20-571(30) (West 2024). The definition does not expressly refer to ordering or evaluating lab tests.

    • However, a separate Connecticut law provides that a pharmacist may order and administer COVID-19 related tests, influenza-related tests, and HIV-related tests. Conn. Gen. Stat. Ann. § 20-633f (West 2024), as enacted by 2024 Conn. Acts. 24-73, § 10 (West).

    • Yes, but based on the information described below, the authorization only applies to ordering lab tests.

    • A CDTMA/P/CP may authorize a pharmacist to “order associated laboratory tests.” Conn. Gen. Stat. Ann. § 20-631(c) (West 2024).

    • However, Connecticut laws and regulations governing CDTMA/P/CP do not expressly authorize a pharmacist to evaluate test results.

    • Yes, based on the information described below, but note the restriction related to controlled substance prescribing (see below).

    • Under Connecticut’s general telehealth/telemedicine practice law, pharmacists are one of the types of providers expressly authorized to provide “health care or other health services through the use of telehealth within such person’s scope of practice and in accordance with the standard of care applicable to the profession.” Conn. Gen. Stat. Ann. § 19a-906(12) (West 2024). 

    • Generally, “no telehealth provider shall prescribe any schedule I, II or III controlled substance through the use of telehealth.” Conn. Gen. Stat. Ann. § 19a-906(c) (West 2024).

    • However, the prohibition just above does not apply to the prescribing of “a schedule II or III controlled substance other than an opioid drug, as defined in section 20-14o, in a manner fully consistent with the Ryan Haight Online Pharmacy Consumer Protection Act, 21 USC 829(e), as amended from time to time, for the treatment of a person with a psychiatric disability or substance use disorder, as defined in section 17a-458, including, but not limited to, medication-assisted treatment.” Conn. Gen. Stat. Ann. § 19a-906(c) (West 2024). Whether this provision allows for prescribing buprenorphine via telehealth is unclear, as Connecticut law defines the word “opioid drug” by referring to federal opioid treatment program regulations, but the 2024 changes to those federal regulations eliminated the defined term “opioid drug.” 

    • Connecticut laws governing telehealth include – Conn. Gen. Stat. Ann. § 19a-906 (West 2024) (telehealth generally); Conn. Gen. Stat. Ann. § 17b-245g (West 2024) (Medicaid); Conn. Gen. Stat. Ann. §§ 38a-499a, 38a-526a (West 2024) (insurance).

  • Short Answer: No

    References: 

  • Short Answer: No

    Connecticut Department of Social Services regulations governing the Connecticut Medicaid program do not mention the word “pharmacist” except in once instance related to an interdisciplinary hospice team. See Conn. Agencies Regs. §§ 17b-3-1 to 17b-349e-9 (2024).

    References: 

  • No

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Suggestions for Policy Makers:

Updating state laws to empower community pharmacists to independently prescribe, monitor, and bill for MOUD would eliminate the cumbersome hurdles of collaborative practice agreements (CPA) —each of which requires forging and maintaining a unique partnership with every patient’s prescriber—and unlock immediate access to OUD care at the neighborhood pharmacy. By removing the need for a formal CPA with a distant clinician, pharmacists could leverage their deep expertise and accessibility to initiate lifesaving treatment the moment someone is ready for help. This approach honors pharmacists working at the top of their license, slashes unnecessary administrative barriers, and expands capacity for evidence-based OUD care exactly where patients already go for health services.

    • Expand the Connecticut practice of pharmacy to include prescribing drugs and medications, or at least prescribing buprenorphine for SUD treatment.

    • Allow Connecticut pharmacists to obtain the federal DEA mid-level practitioner registration needed to prescribe controlled substances.

    • Expand the Connecticut practice of pharmacy to expressly include administering buprenorphine for SUD treatment.

    • Expand the practice of pharmacy in Connecticut to allow pharmacists to order and evaluate the results of the types of lab tests necessary for patients undergoing SUD treatment with buprenorphine.

    • Revise Connecticut laws and/or regulations to allow pharmacists to prescribe controlled substances under CDTMA/P/CPs.

    • Expressly specify in Connecticut laws and regulations how prescriptions for controlled substances (or at least buprenorphine) work under CDTMA/P/CPs.

    • Allow Connecticut pharmacists to obtain the federal DEA mid-level practitioner registration needed to prescribe controlled substances.

    • Expressly specify in Connecticut laws and/or regulations that under CDTMA/P/CP, a pharmacist can evaluate the results of the types of lab tests necessary for patients undergoing SUD treatment with buprenorphine.

    • Allow pharmacists to have “full provider” status under the Connecticut Medicaid program.

    • Specify in Connecticut laws and/or regulations that pharmacist services provided under a CDTMA/P/CPs are covered under the Connecticut Medicaid program.

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