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  • Can a pharmacist independently prescribe 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 so broad as to allow a pharmacist to prescribe buprenorphine independently and without the need to enter into a CPA or protocol with a supervising physician or other healthcare provider. Because buprenorphine is a schedule III controlled substance, the answer to the question is “yes” only if a state’s laws/regulations do three things.

    • First, there must be express authorization for a pharmacist to prescribe categories of drugs and medications that include either controlled substances generally, or MOUD specifically.

    • Second, the authorization cannot contain a condition requiring the pharmacist to operate under a CPA or other protocol with an individual healthcare provider.

    • Third, the state must clearly authorize and direct the pharmacist to obtain the DEA’s “mid-level practitioner” registration, which is a prerequisite before any individual other than a physician, dentist, veterinarian, or podiatrist can prescribe controlled substances. (Definition of mid-level practitioner in 21 C.F.R. § 1300.01 )

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

    • Three states in which the answer is “yes” without caveat; California, Idaho, and Nevada.

    • One state in which the authorization only extends to prescribing “early refills” of MOUD, as the law defines that term; Oregon.

    • The remaining 46 states, the District of Columbia, and Puerto Rico where the answer is “no.”

    The primary limiting factor in most “no” states is the lack of an express authorization in scope of practice laws to prescribe categories of drugs and medications that either include controlled substances generally, or MOUD specifically. As the findings related to the question of “Can a pharmacist prescribe buprenorphine under a CPA?” show, several additional states do allow pharmacists to prescribe buprenorphine under a CPA.

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