PHARMACY SERVICES IN A STATE OF EMERGENCY

To advocate that states grant temporary licensure, registration, or any other necessary state-mandated credentials to eligible pharmacies and members of the pharmacy workforce during states of emergency; further,

To encourage expedient licensure or registration for eligible members of the pharmacy workforce during states of emergency; further,

To advocate that state and federal regulatory agencies allow for flexibilities necessary to provide patient care during a declared state of emergency.

Rationale

During the COVID-19 pandemic, both state and federal policymakers scrambled to provide the regulatory flexibility necessary to allow patients to access pharmacist services. Although states are generally willing to be flexible about dispensing during a public health emergency, pharmacy services themselves are not subject to the same degree of flexibility. Specifically, pharmacists, more so than other clinicians, struggled to get temporary licensure across state lines, and pharmacy technicians experienced similar challenges in states that require registration. The lack of access to temporary licensure and registration impeded the ability of pharmacists and pharmacy technicians to move to areas of great need or to volunteer in states with patient surges. Further, pharmacy services require flexibility, particularly around inventory control and the ability to reallocate product and the ability to quickly establish alternate sites of care. During the COVID-19 public health emergency, remdesivir was allocated to the states, and then the state retained full control over distribution, which resulted in situations in which hospitals could not transfer product across state lines to other hospitals, even to related entities, that needed the product more.