Rhode Island

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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 Rhode Island law does not expressly include prescribing drugs or medications. R.I. GEN. LAWS § 5-19.1-2 (x) (West 2024).

    • Although not in the practice of pharmacy definition, Rhode Island law provides that a pharmacist “may prescribe and dispense all short-term, FDA-approved hormonal contraceptives.” R.I. GEN. LAWS § 5-19.1-36(a) (West 2024). This is the only pharmacy law or regulation expressly addressing prescribing drugs or medications.

    • The above points are consistent with DEA information that registered pharmacists in Rhode Island 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.

    • Rhode Island law authorizes a pharmacist to engage in collaborative pharmacy practice (CPP) pursuant to a CPA. R.I. GEN. LAWS § 5-19.2-3 (West 2024). The purpose of CPP is drug therapy management (DTM) of patients. R.I. GEN. LAWS § 5-19.2-2(a) (West 2024). 

    • DTM may include “initiating, adjusting, monitoring, or discontinuing drug therapy.” R.I. GEN. LAWS § 5-19.2-2(d) (West 2024). Although this provision uses the words “initiating” and “adjusting,” Rhode Island laws and regulations governing DTM do not expressly refer to “prescribing” drugs or medications.

    • Even if a CPA could allow a Rhode Island pharmacist to prescribe drugs, Rhode Island laws and regulations governing CPP do not account for the fact that an Rhode Island pharmacist cannot obtain a federal DEA mid-level practitioner registration, which precludes the pharmacist from prescribing buprenorphine regardless of what the agreement provides.

    • In summary, Rhode Island laws and regulations do not expressly prohibit a pharmacist from prescribing controlled substances as part of a CPA. However, even if prescribing buprenorphine is theoretically allowed, as a practical matter, there is no way to do it because a Rhode Island pharmacist cannot obtain the state/DEA controlled substance registrations necessary.

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

    • The definition of the “practice of pharmacy” in Rhode Island law includes “the administration of . . . medications approved by the department of health in consultation with the board of pharmacy for administration by a pharmacist.” R.I. GEN. LAWS § 5-19.1-2 (x) (West 2024).

    • Rhode Island regulation provides that a pharmacist can administer medications in 25 listed classes to any age group. 216-40 R.I. CODE REG. § 15-1.11.3(B) (2024). Buprenorphine is one of the drug classes listed.

    • Administration must be pursuant to a valid prescription or physician-approved protocol, including, but not limited to, a standing order. 216-40 R.I. CODE REG. § 15-1.11.3(A) (2024).

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

    Rhode Island laws and regulations do not clearly answer this question. However, given the answer to “Can a pharmacist administer buprenorphine independently (without entering a CPA)?” the answer is likely “yes.”

    • Rhode Island law authorizes a pharmacist to engage in CPP pursuant to a CPA. R.I. GEN. LAWS § 5-19.2-3 (West 2024). The purpose of CPP is DTM of patients. R.I. GEN. LAWS § 5-19.2-2(a) (West 2024).

    • DTM may include “initiating, adjusting, monitoring, or discontinuing drug therapy.” R.I. GEN. LAWS § 5-19.2-2(d) (West 2024). Although this provision uses the words “initiating” and “adjusting,” Rhode Island laws and regulations governing DTM do not expressly refer to “administering” drugs or medications.

    • As a result, Rhode Island laws and regulations governing CPAs are unclear about the extent to which a pharmacist can administer drugs. However, given that a pharmacist has the general authority to administer buprenorphine outside of a CPA, the most logical answer to this question is “yes.”

  • Short Answer: 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 Rhode Island law provides that a pharmacist can perform “clinical laboratory tests provided such testing is limited to limited- function tests as defined in this Part.” R.I. GEN. LAWS § 5- 19.1-2 (x) (West 2024).

    • Limited function tests are tests listed in the federal register as CLIA-waived tests. R.I. GEN. LAWS § 5-19.1-2 (p) (West 2024).

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

    • Rhode Island law authorizes a pharmacist to engage in CPP pursuant to a CPA. R.I. GEN. LAWS § 5-19.2-3 (West 2024). The purpose of CPP is DTM of patients. R.I. GEN. LAWS § 5-19.2-2(a) (West 2024). DTM expressly incudes “ordering and evaluating the results of laboratory tests directly related to drug therapy,” so long as the pharmacist is “under the supervision of, or in direct consultation with, one or more physician(s).” R.I. GEN. LAWS § 5-19.2-2(d)(4) (West 2024).

    • The authorization to evaluate results, however, “does not include any diagnostic component.” R.I. GEN. LAWS § 5- 19.2-2(d)(4) (West 2024).

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

    • Rhode Island does not have a general telehealth/telemedicine practice act. However, Rhode Island health insurance law provides that health insurers must provide coverage for “covered healthcare services provided through telemedicine.” R.I. GEN. LAWS § 27-81- 4(a) (West 2024).

    • “Telemedicine” means “the delivery of clinical healthcare services by . . . [technology that] facilitate assessment, diagnosis, counseling and prescribing treatment, and care management of a patient’s health care while such patient is at an originating site and the healthcare provider is at a distant site.” R.I. GEN. LAWS § 27-81-3(15) (West 2024).

    • “Healthcare provider” means a “healthcare professional” or a “healthcare facility.” A “healthcare professional” is “a physician or other healthcare practitioner licensed, accredited, or certified to perform specified healthcare services consistent with state law.” R.I. GEN. LAWS § 27- 81-3(4) (West 2024). This includes pharmacists.

  • Short Answer: It depends.

    Commercial insurance may cover a limited set of pharmacist services - coverage will vary based on each insurance plan’s policies.

    References: 

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

    • “Any individual health plan or group health plan and any health coverage through any commercial health plan shall cover hormonal contraceptives that are prescribed and dispensed by a pharmacist, including contraceptive counseling, if those contraceptives would otherwise be covered if prescribed by another type of healthcare provider.” R.I. GEN. LAWS § 5-19.1-36(e) (West 2024).

    • Every group health insurance contract, or every group hospital or medical expense insurance policy, plan, or group policy delivered, issued for delivery, or renewed in Rhode Island beginning January 1, 2024, must provide coverage for treatment of pre-exposure prophylaxis (“PrEP”) for the prevention of HIV and post-exposure prophylaxis (“PEP”) to prevent HIV infection. R.I. GEN. LAWS § 27-18-91(a) (West 2024) (accident and sickness policies); R.I. GEN. LAWS § 27-19-83(a) (West 2024) (nonprofit hospital service corporations); R.I. GEN. LAWS § 27-20-79(a) (West 2024) (nonprofit medical service corporations); R.I. GEN. LAWS § 27-41-96(a) (West 2024) (health maintenance organizations). For purposes of Rhode Island laws governing the “prevention and suppression” of HIV/AIDS, as of January 2024, a “health care provider” includes a pharmacist. R.I. GEN. LAWS § 23-6.3-2(16) (West 2024).

    References: 

  • Beyond the topics covered above (and excluding methadone) are there any other laws/ regulations governing the way MOUD is provided to patients that currently apply to pharmacists?

    No

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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.

Suggestions for Policy Makers:

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

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

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

    • Revise Rhode Island laws and/or regulations governing CPAs to allow pharmacists to prescribe controlled substances.

    • Expressly specify in Rhode Island laws and/or regulations how prescriptions for controlled substances (or at least buprenorphine) work under CPAs.

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

    • Although not completely necessary, expressly specify in Rhode Island laws and/or regulations that the activities allowed by a pharmacist under a CPA include administering medications, or at least administering buprenorphine for SUD treatment.

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

    • Specify in Rhode Island laws and/or regulations that pharmacist services provided under a under a CPA are covered under the Rhode Island Medicaid program.

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State Links and Resources (Coming Soon!)

  • Examples: Quick access for implementation questions. Board of Pharmacy contact; Medicaid pharmacy help desk; state MAT/MOUD coordinator. 

  • Examples:  PDMP statutes; board PDMP FAQs; registration portal. 

  • Lists state-mandated opioid or MOUD CE for pharmacists. Board CE rule; opioid-management CE links.

  • Contextual info patients/pharmacists may need. Syringe-service programs; state naloxone sites; recovery hotline(s). 

  • University or health-system toolkits; state opioid response project resources.