Protocol · PharmD · Pennsylvania
Practice Protocol for Pharmacists in Pennsylvania
Required. Pennsylvania law names the instrument a Written Collaborative 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 Pennsylvania's Collaborative Drug Therapy Management (CDTM) tier (Pharmacy Act § 9.3, added 2010), not ordinary licensure — base dispensing needs no physician agreement and is out of scope here. Participation is voluntary for both parties; CDTM scope is permanently agreement-based with no independence pathway.
What a Pennsylvania Written Collaborative Agreement must contain
Governed by the Pennsylvania State Board of Pharmacy. Each numbered item is a statutory requirement the Written Collaborative Agreement must satisfy.
The Pharmacist shall manage the patient's drug therapy in a non-institutional setting only pursuant to a written collaborative agreement with the Physician, as authorized by 63 P.S. § 390-9.3. Regimens for the management of drug therapy must be initiated by the Physician; the collaborative agreement does not authorize the Pharmacist to initiate a new drug therapy independent of the Physician's referral.
Source: 63 P.S. § 390-9.3
The collaborative agreement shall identify the Pharmacist and the Physician, describe the types of decisions the Pharmacist may make within the Physician's scope of practice (including adjusting a drug's dosage, strength, or frequency, changing its route of administration, administering drugs, and ordering related tests), set out a method for documenting those decisions, require the Pharmacist to notify the Physician of any change within seventy-two (72) hours, and provide a contingency plan for when either Party is temporarily unavailable. The collaborative agreement shall disclose the Pharmacist's role to the patient and permit the patient to decline participation, and either Party may terminate the collaborative agreement at any time.
Source: 49 Pa. Code § 27.302
- The Written Collaborative Agreement also carries 1 scope, 1 registration and 1 authority clauses, authored in the document itself.
Statutes and rules these clauses cite
- 63 P.S. § 390-9.3statute
Pharmacy Act provision authorizing a pharmacist to enter into a collaborative agreement with a physician to manage drug therapy in a non-institutional setting.
- 49 Pa. Code § 27.302regulation
Required contents and administration of a pharmacist collaborative agreement for management of drug therapy.
Terms it has to carry
Ratio, proximity, chart review, meeting and prescribing terms the Written Collaborative Agreement has to carry, from Pennsylvania'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
Not codified — left to the agreement
Prescriptive authority
Covered by the practice agreement · controlled substances permitted
Controlled-substance schedule limits for CDTM are not spelled out; treat them as uncertain rather than unrestricted.
Written agreement
Required
Practice ownership (corporate practice of medicine)
Non-licensee ownership permitted — No pharmacist-ownership requirement for standard pharmacy permits; materially more permissive than the physician-only corporate-practice rules, with a licensed pharmacist-in-charge as the typical control safeguard rather than an ownership restriction
Sources for the supervision rules (1)
About Pennsylvania's rules
Pennsylvania has no independent-practice pathway for CRNPs — SB 25-style full-practice-authority bills have been introduced every session without passing. PA (physician assistant) reform via Acts 78/79 of 2021 removed prior Board pre-approval of written agreements and the flat 100%-countersignature rule after the first year, but a written agreement and supervision remain mandatory. PA is a CPOM state: only licensed physicians may own a medical professional corporation.
Other clinicians in Pennsylvania: see the state overview.