Expanding the Pharmacist’s Role in Response to COVID-19

The rapid and wide spread of COVID-19, which has already resulted in thousands of deaths in the US, has put severe pressure on healthcare resources, including medical providers. While pharmacists may have the potential to play a larger role in the public health response to COVID-19 and reduce the burden on our health system, several considerations should be evaluated:

• COVID-19 vaccinations: 90% of Americans live within 5 miles of a retail pharmacy, where pharmacists have established themselves as reliable immunizers. However, pharmacies and pharmacists must assess whether they can sustain or economically afford a pharmacist-driven widespread vaccination for COVID-19 under current Medicare Part B reimbursement policies, which lacks clarity on reimbursement for pharmacist-administered COVID-19 immunizations. Without appropriate reimbursement, a pharmacist-driven approach to ensure widespread access to a vaccine may be challenging, especially in rural communities.
• COVID-19 diagnostic testing: Though most states do not allow pharmacists to administer diagnostic tests, recent federal guidance may allow national pharmacist testing for COVID-19. But pharmacists need to further assess how this guidance impacts scope-of-practice laws in their respective states, especially existing state laws relevant to pharmacist-administering diagnostic tests.
• Practicing across state lines: States regulate pharmacists’ scope of practice within their own borders, which precludes pharmacists offering their services in other states. However, pharmacists should also assess whether current state laws may prevent pharmacists from assisting communities hit hard by COVID in other states.

Evolving the Retail Pharmacy Model in Response to COVID-19

In response to the COVID-19 pandemic, face-to-face interactions with patients at retail pharmacies may need to evolve toward remote delivery and telehealth consultation. However, retail pharmacies should consider several factors before evolving their business models in response to COVID-19.

• Signature requirements: How can pharmacies best provide care to patients who are vulnerable to COVID-19 and practicing social distancing given that pharmacies are often required, under state and federal laws, to collect physical signatures (e.g., proof of patient consultation)?
• Contractual requirements: How do retail pharmacy contracts with plans that dictate terms around the delivery and mailing of medications impact pharmacy economics in an ever-changing environment? For example, though the federal government recently encouraged Medicare Part D plans to relax policies that discourage mail or home delivery, these changes are not mandatory, which may impact their implementation.
• Licensing requirements: Due to specific licensing definitions and requirements for entities like mail-order pharmacies, pharmacists should assess whether a significant increase in the delivery and mailing of medications across state borders may subject them to increased licensing scrutiny. For example, many states restrict services that a retail versus mail order pharmacy may offer, including interstate delivery and mailing of medications.

Avalere continues to monitor the COVID-19 pandemic and response at the federal and state levels. To learn more about how Avalere can support you in understanding the implications of COVID-19 on your practice, connect with us.

Check out our COVID-19 Intel Center.