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Guide for Pharmacists Considering a Collaborative Practice Agreement (CPA)/Collaborative Drug Therapy Arrangement (CDTA) with a Provider

Updated

Introduction

A Collaborative Practice Agreement is a formal, written agreement between a pharmacist and a healthcare provider (e.g. physician, nurse practitioner, etc.) that allows the pharmacist to perform specific duties such as managing medications, conducting screenings, or treating minor health conditions in collaboration with the provider. This agreement is designed to enhance patient care, optimize medication therapy, and expand the role of pharmacists in healthcare teams. This type of agreement can sometimes be referred to by other names, such as a Collaborative Drug Therapy Arrangement (CDTA), however the same basic principles apply. 

This guide is intended to help pharmacists navigate the process of creating a CPA (or CDTA), highlighting key considerations such as state regulations, patient eligibility, communication procedures, and the inclusion of important elements in the agreement. It is important to note that entering into a CPA is a legally binding document, so please consult with your attorney throughout the process. This guide is not intended to provide legal advice.

 

Workflow Services’ Role

Workflow Services does not provide CPA services at this time. To support your conversations with providers, we provide workflow diagrams of our existing protocols to allow the providers to understand the decision support involved. If your CPA arrangement does not align with our existing protocols, our Clinical Visit Template feature allows you to build your own custom workflows. If you have questions on this, please contact support@imagemovermd.com.

Step 1: Understand State Regulations and Scope of Practice

Before considering a CPA, it’s essential to familiarize yourself with the state-specific regulations regarding pharmacists' roles in collaborative care. State laws and regulations differ, so understanding what is legally permissible in your jurisdiction is the first step.

  • State Regulations: Different states grant pharmacists varying levels of authority to participate in CPAs. Some states allow pharmacists to treat chronic conditions, adjust medications, and prescribe medications under certain conditions, while others limit the pharmacist’s role to minor health conditions or medication management. It is also important to understand the expectation as it relates to the provider’s relationship with the patient, as in some cases there is an expectation that the CPA has an existing relationship with each treated patient, while in other cases that is not required.
  • Pharmacist’s Scope of Practice: Most states define the scope of practice for CPAs, including what the pharmacist is authorized to do. This can include:
    • Administering vaccinations
    • Managing chronic conditions (e.g., diabetes, hypertension)
    • Treating minor, non-chronic health conditions
    • Conducting diagnostic testing, such as blood glucose monitoring, cholesterol screenings, etc.

Consult with your state Board of Pharmacy and your attorney, and review any relevant legislation or regulatory guidance to ensure that your CPA complies with local requirements.

Step 2: Identify the Right Provider Partner

A successful CPA requires a solid partnership between the pharmacist and the provider. Choosing the right provider is critical for effective collaboration.

  • Shared Care Philosophy: Look for a provider who values team-based care and is open to working with a pharmacist as part of the healthcare team.
  • Practice Areas: Ideal providers are those who work in areas where pharmacists can have a meaningful impact. These include practices focused on chronic disease management, preventative care, or minor health conditions like upper respiratory infections, allergies, or minor skin conditions.
  • Communication and Workflow: Ensure the provider is committed to clear and frequent communication, as this is key for monitoring patient progress and addressing any issues that arise.

Step 3: Determine Specific Categories of Patients and Treatments

As part of the CPA, you and the provider should agree on which patients the pharmacist can treat and how the treatment will be managed. This includes identifying the categories of patients who are eligible for care under the agreement, as well as the processes for managing these patients.

  • Categories of Patients:
    • The pharmacist may be authorized to test, screen, and treat minor, non-chronic health conditions such as:
      • Upper respiratory infections (e.g., sore throat, cough)
      • Allergic rhinitis
      • Influenza
      • Minor skin conditions (e.g., insect bites, rashes)
      • Urinary tract infections (UTIs)
    • The CPA should outline which patient populations can be treated under these conditions. This might include age restrictions, symptom severity, and exclusion criteria (e.g., patients with certain underlying conditions or allergies).
  • Obtain Relevant Patient Medical History:
    • The agreement must specify the process for obtaining patient medical history to identify disqualifying health conditions, contraindications, or potential adverse reactions to treatments. For instance, before administering an antibiotic for a suspected UTI or treating an allergic reaction, the pharmacist should assess the patient's:
      • History of allergies
      • Current medications
      • Medical conditions (e.g., renal disease, pregnancy, or immunocompromised states)
      • Any recent adverse reactions to treatments
    • This process is vital for ensuring patient safety and should be documented as part of the CPA, and is one reason that using a platform like Workflow Services to document clinical services can be critical when pharmacies are looking to expand the services they provide for patients.
  • Treatment Instructions for Minor, Nonchronic Conditions:
    • The CPA should outline specific instructions for the treatment of minor, non-chronic health conditions based on factors such as:
      • Patient age (children vs. adults)
      • Presenting symptoms (e.g., fever, cough, sore throat)
      • Test results (e.g., a positive strep test for a sore throat or a negative flu test)
    • The protocol should also specify what to do in the case of negative test results (e.g., if a test for strep throat is negative, alternative treatment or referral might be necessary).

Step 4: Set Processes for Communication and Physician Oversight

The CPA should include structured communication protocols and define how the pharmacist and provider will collaborate on patient care. These protocols help ensure effective monitoring, oversight, and patient safety.

  • Review of Pharmacist Actions by the Provider:
    • The CPA should define a process and schedule for the provider to review the pharmacist’s actions under the protocol. This could be:
      • Regular reviews (e.g., quarterly or biannually) to assess outcomes, evaluate effectiveness, and adjust treatment guidelines as needed.
      • Ad-hoc reviews if any concerns arise or if complex cases need escalation.
  • Notification Process for Pharmacist to Notify the Provider:
    • The agreement must establish a clear process and schedule for the pharmacist to notify the provider about patient conditions, treatments, test results, and other relevant information. This may include:
      • Documenting test results and treatment decisions in the patient’s medical record
      • Periodic updates on patient progress, especially if there is a change in symptoms or if complications arise
      • Direct communication (via phone, email, or secure messaging system) for urgent cases or situations where treatment deviates from the agreed protocol.

Step 5: Legal and Regulatory Compliance

  • Submission of Protocol to the Board:
    • As part of the legal requirements in some states, pharmacists who enter into a written protocol must submit a copy of the protocol to the state Board of Pharmacy for review and approval. Ensure that you are in compliance with this requirement to avoid any legal issues.

Step 6: Draft the Collaborative Practice Agreement (CPA)

Once the roles, responsibilities, and processes are clearly defined, you and the provider should draft the Collaborative Practice Agreement. The CPA should include the following:

  • Introduction: Identifying the parties involved, the purpose of the agreement, and its scope.
  • Patient Eligibility: Criteria for which patients can be treated, including conditions eligible for pharmacist intervention and patient exclusion criteria.
  • Pharmacist’s Scope of Treatment: Specific minor, non-chronic health conditions the pharmacist is authorized to test, treat, and manage.
  • Test and Screening Procedures: What tests or screenings can the pharmacist perform, and under what circumstances (e.g., rapid strep test, blood pressure screening).
  • Treatment Protocols: Clear instructions from the provider regarding treatment for minor conditions, including adjustments based on patient age, symptoms, or test results.
  • Review and Communication: The process for the provider to review the pharmacist’s actions and the schedule for communication between the pharmacist and provider.
  • Compensation and Insurance: If applicable, details on any financial arrangements, billing procedures, or reimbursement from insurance providers.
  • Patient Consent: How patient consent for treatment will be obtained and documented.
  • Termination: Conditions for the termination of the agreement and the process for modifying or updating it as necessary.

Sample Template for Collaborative Practice Agreement (This is intended as an example only. Please consult your attorney prior to entering into a CPA partnership. Workflow Services cannot provide legal advice.)

Collaborative Practice Agreement
Between [Pharmacist's Name], PharmD, and [Provider's Name], [Title]

Effective Date: [Insert Date]
Term: [Start Date] to [End Date or Ongoing]

1. Purpose

This Collaborative Practice Agreement (CPA) outlines the collaboration between [Pharmacist's Name] and [Provider's Name] for the management and treatment of minor, non-chronic health conditions, with a focus on improving patient outcomes and expanding the role of the pharmacist in healthcare.

2. Scope of Practice and Responsibilities

Pharmacist:

  • Screen and treat minor, non-chronic health conditions such as sore throat, cough, urinary tract infections, and allergic reactions.
  • Administer tests (e.g., strep, influenza) and provide treatment based on test results, patient age, and symptoms.
  • Monitor patient progress and report any significant changes to [Provider’s Name].

Provider:

  • Provide oversight and review of pharmacist's actions under this protocol.
  • Ensure patient medical history is reviewed to identify disqualifying conditions and contraindications.
  • Review patient progress and make treatment adjustments as necessary.

3. Patient Eligibility and Exclusion Criteria

Eligible conditions:

  • [List of conditions and symptoms]
    Exclusion criteria:
  • [List of exclusion criteria, such as age limitations, comorbidities]

4. Treatment Protocols

Treatment Based on Symptoms and Test Results:

  • Positive strep test: [Treatment protocol]
  • Negative flu test: [Alternative actions]

5. Communication and Review

  • Provider Review: [Frequency of review, e.g., quarterly]
  • Pharmacist Notification: The pharmacist will notify the provider via [communication method] when the treatment deviates from the protocol.

6. Submission of Protocol

A copy of this CPA will be submitted to the [State Board of Pharmacy] as required by law.

     

Signatures

______________________________                              ______________________________
                                              MD/APNP                                                                  Pharmacist

 

 

Additional Example:
Hyperlipidemia Management: Template

https://www.pharmacy.ca.gov/licensees/collaborative_practice.pdf

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