REGULATION OF TELEPHARMACY SERVICES

To advocate that state governments adopt laws and regulations that standardize telepharmacy practices across state lines and facilitate the use of United States-based telepharmacy services; further,

To advocate that boards of pharmacy and state agencies that regulate pharmacy practice include the following in regulations for telepharmacy services: (1) education and training of participating pharmacists; (2) education, training, certification by the Pharmacy Technician Certification Board, and licensure of participating pharmacy technicians; (3) communication and information systems requirements; (4) remote order entry, prospective order review, verification of the completed medication order before dispensing, and dispensing; (5) direct patient-care services, including medication therapy management services and patient counseling and education; (6) licensure (including reciprocity) of participating pharmacies and pharmacists; (7) service arrangements that cross state borders; (8) service arrangements within the same corporate entity or between different corporate entities; (9) service arrangements for workload relief in the point-of-care pharmacy during peak periods; (10) pharmacist access to all applicable patient information; and (11) development and monitoring of patient safety, quality, and outcomes measures; further,

To identify additional legal and professional issues in the provision of telepharmacy services to and from sites located outside the United States.

Rationale

In light of continuing advances in technology, there an increasingly urgent need for state board of pharmacy regulation of the provision of pharmacist care services from offsite locations through electronic technology, which is often referred to, especially in regulation, as telepharmacy. In the ASHP Statement on Telehealth Pharmacy Practice, ASHP explains why it prefers the term telehealth pharmacy practice to describe both the provision of team-based patient care and oversight of aspects of pharmacy operations (e.g., remote dispensing, order verification, supervision of staff) by pharmacists using electronic information and telecommunications technology.

It is important to acknowledge the regulatory purview of state boards of pharmacy regarding the use of telepharmacy and recognize that the intent of such regulations should be to balance protection of the public health with the increased patient access to the patient care services of pharmacists provided by telepharmacy. Although such regulations should allow for various arrangements across state borders and within or between health systems, they all need to address a number of common concerns.

ASHP advocates that the provision of medication therapy management and other direct patient care services be addressed in any regulation of telepharmacy services and that patient safety, quality, and outcomes measures for these services be developed and monitored. Further, ASHP urges state governments to harmonize the practice of pharmacy across state lines and to require that pharmacy technicians providing telepharmacy services be certified by the Pharmacy Technician Certification Board and licensed by the state board of pharmacy. Finally, ASHP recognizes the need to continue efforts to identify additional legal and professional issues in the provision of international telepharmacy services.