COLLABORATIVE DRUG THERAPY AGREEMENT
Who is eligible to partner with for a CDTA?
It is important for the local health department to understand the collaborative drug therapy laws and regulations for pharmacists in their state. Pharmacy practice is legislated and regulated at the state level, and therefore each state’s laws vary.
At present, in all but eight states*, pharmacists may initiate, modify and/or discontinue medication therapies pursuant to Collaborative Drug Therapy Agreements (CDTA) or Protocols. In the majority of states, local, and state public health departments can partner with pharmacists in the community to better respond to emergencies through a CDTA. In all 50 states and the District of Columbia, an emergency order may be issued to expand the scope of the pharmacist when there is an outstanding need. The remainder of this discussion will focus on states that have allowances for CDTAs.
States differ in which pharmacists may participate in CDTA. For example, in Indiana, Nevada, and New Hampshire only pharmacists practicing in a hospital setting may participate in a CDTA. These CDTAs usually target renal dosing, formulary changes or “dosing per pharmacy” protocols. In New Mexico pharmacists must have the special designation of “pharmacist clinician” to prescribe medications; in North Carolina a separate license is required to prescribe medications. While there are restrictions on pharmacists that can directly prescribe to patients in these states, there is some allowance for CDTAs, and this may allow for flexibility during an emergency. In Oregon and Minnesota pharmacists can prescribe for patients, but only if the patients are seen by the prescriber who co-signs on the CDTA. Also in Minnesota, and in Ohio, pharmacists can only modify existing therapy under a CDTA, which is effective for titrating doses of medications, but may not be helpful when the LHD needs them to initiate antiviral therapy.
In each state different primary prescribers can enter into the agreement with the pharmacist. Most commonly across the board MDs may enter into the agreements. Most states also allow DOs and some allow ARNPs to enter into the CDTA. If you have a provider other than an MD who will be authorizing the CDTA, check with the state board of pharmacy to ensure that it is allowed.
Ultimately, CDTA prescribing for public health events, including emergency response events, is somewhat different than CDTAs for other types of prescribing. The foundation for this, although not upheld by any legal codes, centers on an understanding of the potential need for rapid response during public health events when a community faces imminent danger to its health. When partnering to develop public health CDTAs, recognizing the need for rapid response should be incorporated into discussions on safety and accountability.
*Alabama, Delaware, District of Columbia, Illinois, Kansas, New York, Oklahoma, and South Carolina do not have allowances for pharmacists to initiate, modify or discontinue medication therapy.