Rhode Island Pharmacist Drug Administration Expansion

In a move signaling the increasing importance of pharmacists in the overall continuum of patient care, Rhode Island (RI) recently enacted new statutory language that expands pharmacists’ ability to administer medications directly to patients. Although the parameters of this expansion are still largely undefined, pharmacists practicing in the state are set to become more involved in direct patient care moving forward.

The recently passed Senate Bill 0879A updates the “practice of pharmacy” definition in RI ST § 5-19.1-2(x) to include:

“. . . the administration of adult immunizations and, medications approved by the department of health in consultation with the board of pharmacy for administration by a pharmacist except as provided by § 5-25-7, pursuant to a valid prescription or physician-approved protocol and in accordance with regulations, to include training requirements as promulgated by the department of health.” (emphasis added).

Please note that the pharmacist’s ability to administer medications:

• Excludes veterinary medications as defined in § 5-25-7 of the state’s statutes;
• Will be dependent upon which medications are specifically approved by the RI Department of Health (RIDOH) in consultation with the Rhode Island Board of Pharmacy (RIBOP); and
• Must still be pursuant to a valid prescription or a physician-approved protocol.

At this stage, the RIDOH and RIBOP have not yet finalized which medications will be eligible for pharmacist administration. However, the RIBOP has begun to at least consider which types of medications would or should be approved based on publicly available board meeting minutes from earlier this year. Specifically, the board envisions “medications for OUD, antipsychotics, vitamin B12, anticoagulants, HIV prevention medications, other injectables” to potentially be approved. It is also unclear how pharmacist-administered medications would be reimbursed, and if that reimbursement would be less than if the drugs were administered by other provider types.

While the scope of approved medications and reimbursement parameters are still unclear, this pharmacy practice expansion signals the state’s willingness to allow pharmacists to be more directly involved in certain aspects of patient care, and will likely allow health systems to leverage employed pharmacists to more efficiently service its patients along the entire continuum of care. Based on other recent legislative activity, this appears to be a concerted push by some within the state — Rhode Island is also considering another Senate bill (S.B. 490) that would expand the “practice of pharmacy” to include the authority to prescribe certain drugs and devices (NOTE: this bill has been held for further study and has not been passed or otherwise enacted into law).

Quarles & Brady will continue to closely track additional developments and provide further guidance once the approved list of medications is established.

For any immediate questions on how these changes may affect your entity, please contact your Quarles & Brady attorney or:

• Simone Colgan Dunlap: (602) 229-5510 / simone.colgandunlap@quarles.com
• Michael French: (312) 715-5261 / michael.french@quarles.com