As part of Connecticut budget implementation bill (Act) Enacted earlier this month, the state made significant revisions to its laws regarding collaborative drug therapy management agreements between pharmacists and certain prescribing practitioners to expand (1) the types of arrangements permitted; (2) prescribers eligible to participate in collaborative agreements with pharmacists; and (3) the scope of authority of pharmacists under these arrangements. These revisions come into effect on July 1, 2022.
Pharmacotherapy Collaborative Agreements – Background
Collaborative medication therapy management (CDTM) agreements are agreements between one or more pharmacists and certain prescribing physicians for the purpose of managing a patient’s medication therapy. Under current law, only physicians and advanced practice registered nurses can enter into CDTM agreements with pharmacists. Current legislation sets out various requirements related to CDTM agreements and the relationship between a pharmacist and a collaborating practitioner. For example, a patient’s drug therapy must be managed according to a protocol established by the collaborating practitioner, and the collaborating practitioner must have an established provider-patient relationship with the patient whose drug therapy is being managed. These requirements remain largely unchanged by the Act, but now generally apply to other types of CDTM arrangements authorized by the Act.
Expansion of permitted arrangements
The law makes changes to the scope of permitted CDTM arrangements. In addition to CDTM agreements, the Act authorizes a new category of arrangement called a “collaborative medication therapy management policy”, which is a written policy adopted by a healthcare facility (see below) for the management of medication therapy in a patient or device and is based on a written protocol or “collaborative drug therapy plan of care”. A collaborative drug therapy care plan is a written document agreed between the prescribing practitioner and pharmacist outlining the agreed-upon approach to achieving the patient’s desired health outcome.
Expansion of eligible practitioners
In addition, the law expands the types of providers authorized to enter into these agreements with pharmacists to include “prescribing practitioners” and “care establishments”. Prescribing Practitioners are licensed practitioners in any jurisdiction of the United States authorized to write prescriptions within their scope of practice. Care facilities are facilities that provide medical services and are licensed, operated, certified, or approved by one of the departments of public health, developmental services, or mental health and addictions services.
Importantly, while the law expands the types of collaborating practitioners, it provides that only “qualified” pharmacists can enter into CDTM agreements. The law does not define this term, but rather requires the Department of Consumer Protection to promulgate regulations setting out the competency requirements for pharmacists who wish to enter into CDTM agreements.
Pharmacist scope of authority
Current law limits a pharmacist to managing drug therapy for individual patients under CDTM agreements. The law allows pharmacists, in accordance with the applicable CDTM agreement or CDTM policy and care plan, to manage not only the drug therapy of individual patients, but also (1) the drug therapy of patient populations; (2) devices prescribed to individuals and patient populations; and (3) therapeutic classes of drugs based on the patient or patient population involved. The current law allows pharmacists to modify, continue, interrupt and deprescribe a drug treatment. Under the Act, pharmacists can now also initiate drug therapy or a device. Notably, the law expressly prohibits pharmacists under CDTM from establishing a port to administer parenteral drugs.