Protocol · PharmD · North Carolina
Practice Protocol for Pharmacists in North Carolina
Required. North Carolina law names the instrument a Written Collaborative Practice Agreement, and the clinical protocol is the content that instrument carries. Below: the board that governs it, what it must contain, and the terms it has to carry.
Represents NC's expanded 'Clinical Pharmacist Practitioner' (CPP) tier, not ordinary pharmacist licensure — base dispensing and statutory limited authority need no physician agreement and are out of scope here. CPP scope is permanently CPA-based, with no independence pathway. Qualification: BPS board certification, an ASHP-accredited residency plus 2 years' experience, or an approved certificate program. S.L. 2025-37 (eff. Oct. 1, 2025) removed the prior numeric cap on CPPs per physician — now 'any number' deemed supervisable — and reduced CPA review.
What a North Carolina Written Collaborative Practice Agreement must contain
Governed by the North Carolina Board of Pharmacy. Each numbered item is a statutory requirement the Written Collaborative Practice Agreement must satisfy.
The Pharmacist may be approved as a Clinical Pharmacist Practitioner ("CPP") under joint rules of the North Carolina Medical Board and Board of Pharmacy, as provided under N.C. Gen. Stat. § 90-18.4, and shall practice pursuant to a written collaborative practice agreement with the Physician as the supervising physician. The agreement shall be filed with, and approved by, the North Carolina Board of Pharmacy.
Source: N.C. Gen. Stat. § 90-18.4
Under the collaborative practice agreement, the Pharmacist may implement drug therapy predetermined by the Physician, modify a patient's drug therapy (including dosage, dosage form, and schedule), and order laboratory tests consistent with the agreement, as provided under 21 NCAC 46 .3101 et seq. The Physician shall remain reachable for consultation and shall countersign the Pharmacist's orders within seven (7) days.
Source: 21 NCAC 46 .3101 et seq.
Effective October 1, 2025, the Pharmacist may also order or perform CLIA-waived tests and initiate treatment for influenza pursuant to statewide protocols authorized by S.L. 2025-37, in addition to the Pharmacist's existing CPP authority described above.
Source: S.L. 2025-37 (Board of Pharmacy CPP guidance, effective October 1, 2025)
- The Written Collaborative Practice Agreement also carries 1 scope, 1 education, 1 registration and 1 authority clauses, authored in the document itself.
Statutes and rules these clauses cite
- N.C. Gen. Stat. § 90-18.4statute
Clinical Pharmacist Practitioner (CPP) designation, requiring joint Medical Board / Board of Pharmacy approval and a written collaborative practice agreement with a supervising physician.
- 21 NCAC 46 .3101 et seq.regulation
Board of Pharmacy rules on CPP approval, scope (implementing predetermined drug therapy, modifying drug therapy, ordering laboratory tests), and physician countersignature of CPP orders.
- S.L. 2025-37 (Board of Pharmacy CPP guidance, effective October 1, 2025)board guidance
Board of Pharmacy guidance on new CPP authority to order/perform CLIA-waived tests and initiate treatment for influenza under statewide protocols.
Terms it has to carry
Ratio, proximity, chart review, meeting and prescribing terms the Written Collaborative Practice Agreement has to carry, from North Carolina's supervision rules.
Proximity
Not codified — left to the agreement
Supervision ratio
Not codified — no cap on file
Chart review
Not codified — left to the agreement
Meeting cadence
first 6 months of the collaborative practice agreement: Monthly
21 NCAC 46 .3101(f)(6). Modality (in-person vs. telehealth) is not specified.
ongoing, after first 6 months: Every 6 months
If the supervising physician changes, the parties decide whether to restart the monthly-meeting period.
Prescriptive authority
Covered by the practice agreement · controlled substances permitted
Controlled-substance schedule limits are not specified in NC statute/rule for CPPs; a CPP with individual DEA registration may handle controlled substances per that registration — treat as uncertain/not schedule-restricted rather than assuming a specific limit.
Written agreement
Required
Practice ownership (corporate practice of medicine)
Non-licensee ownership permitted — No pharmacist-ownership requirement — pharmacy permits (N.C. Gen. Stat. § 90-85.21; 21 NCAC 46 .1601) issue jointly to the owner (who may be a non-pharmacist/corporate entity) and a licensed pharmacist-manager, who must retain professional/operational control over dispensing.
Materially more permissive than the medical corporate-practice rules governing PAs, NPs, CRNAs, CNMs, CNSs and RNs. Whether any additional ownership restriction applies specifically to Clinical Pharmacist Practitioner (CPP) practice is not spelled out.
Sources for the supervision rules (5)
- N.C. Gen. Stat. § 90-18.4 — Clinical Pharmacist Practitioners
- 21 N.C. Admin. Code 46 .3101 — Clinical Pharmacist Practitioner Approval
- NC Board of Pharmacy — Clinical Pharmacist Practitioner overviewsecondary
- NC Board of Pharmacy — Guidance on New CPP Authority (Aug. 25, 2025)secondary
- S.L. 2025-37 — CPP statutory reforms effective Oct. 1, 2025
About North Carolina's rules
The NP SAVE Act (full practice authority) has failed every session since 2021, most recently as S.B. 966 (2026); North Carolina NPs have no independent-practice pathway. PA team-based practice (S.L. 2025-37, H.B. 67) is now in force: its June 30, 2026 trigger has passed, regardless of whether the Medical Board's conforming rules were finished by then. Several categories below (CRNA proximity, ratio and chart review; CNM proximity) have no codified numeric standard; confirm with the board rather than reading them as an absence of any requirement.
Other clinicians in North Carolina: see the state overview.