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12/21/2021    Robert G.Smith DPM, MSc, RPh

No Sane Rationale for Prohibiting DPMs to Vaccinate (Elliot Udell, DPM)

First early in my podiatric career, I wrote and
requested a declaratory statement centered on
giving tetanus vaccines and boosters to the Florida
Board of Podiatric Medicine and received a positive
clarification validating my belief. My hope is
that the readership will understand that the
nationwide push for pharmacists to be allowed to
vaccinate patients was orchestrated by both state
and national pharmacy associations and endorsed by
large chain pharmacy companies. Florida Medicare
pays the pharmacy not the individual pharmacist
$66.43 for the medication as well as $16.59
administration fee for a total of $83.02.

Prior to going to podiatric medical school as a
pharmacist, I worked with the Florida state
Pharmacy board and state associations (FPA, FHSP)
and at the time U of Fla (my employer) to enhance
the pharmacist’s midlevel role. I helped usherd in
the action that consultant pharmacists were
legislatively empowered to order and evaluate lab
values under protocols approved by attendings of
nursing home agencies. Further, I worked closely
in assisting with the present vaccination protocols
Below is the requirement per Section 465.189, F.S.

To become certified to administer immunization and
epinephrine, a PHARMACIST must meet the following

Requirements for Pharmacist Immunization
Administration Certification.

Must hold a Florida pharmacist license that is
active and in good standing.

Must successfully complete an immunization
administration certification program of at least 20
hours, approved by the Florida Board of Pharmacy.
Must enter into a protocol under a supervisory
practitioner who is a physician licensed under
chapter 458 or chapter 459, F.S. Each protocol must
include particular terms and conditions imposed by
the supervising physician upon the pharmacist
relating to the administration of immunizations by
the pharmacist. The written protocol shall include,
at a minimum, specific categories and conditions
among patients for whom the supervising physician
authorizes the pharmacist to administer
immunizations and epinephrine.

The terms, scope, and conditions set forth in the
written protocol between the pharmacist and the
supervising physician must be appropriate to the
pharmacist’s training and certification for
immunization. Supervising physicians shall review
the administration of immunizations by the
pharmacists under such physician’s supervision
pursuant to the written protocol, and this review
shall take place as outlined in the written
protocol. The process and schedule for the review
shall be outlined in the written protocol between
the pharmacist and the supervising physician.

Must maintain at least $200,000 of professional
liability insurance.

Must obtain written permission from the pharmacy
owner, if the applicant is to administer
immunizations while acting as an employee of a

Once certified, must report immunizations
administered to the state registry of immunization
information, Florida SHOTS. If a pharmacist is
planning to administer immunizations outside a
pharmacy practice setting, the pharmacist must
register with Florida SHOTS as an individual. If a
pharmacist is administering immunizations as an
employee of a pharmacy, the pharmacy practice
location (permittee) must designate one pharmacist
certified to administer immunizations to register
and be responsible for maintenance of the
pharmacy’s Florida SHOTS account. Please check with
your pharmacy’s Prescription Department Manager to
determine who will submit this information for your

Lastly, to give your readership an appreciation of
heighten duties and responsibilities of pharmacists
in Florida (the seeds for this action was sowed by
interested parties over 30 years ago by stake
holders like myself while I was a pharmacist.)
please see below:

Section 465.1865, Florida Statutes, provides that a
pharmacist wishing to practice under a
collaborative practice agreement must meet the
following requirements:

Hold an active and unencumbered license to practice
pharmacy in this state.
Have earned a degree of Doctor of Pharmacy or have
completed 5 years of experience as a licensed

Have completed an initial 20-hour course approved
by the board, in consultation with the Board of
Medicine and Board of Osteopathic Medicine.
Maintain at least $250,000 of professional
liability insurance coverage. However, a pharmacist
who maintains professional liability insurance
coverage pursuant to s. 465.1895 satisfies this

Have established a system to maintain records of
all patients receiving services under a
collaborative pharmacy practice agreement for a
period of 5 years from each patient’s most recent
provision of service.

A pharmacist acting under a collaborative practice
agreement may not:

Modify or discontinue medicinal drugs prescribed by
a health care practitioner with whom he or she does
not have a collaborative pharmacy practice

Enter into a collaborative pharmacy practice
agreement while acting as an employee without the
written approval of the owner of the pharmacy.
A physician may not delegate the authority to
initiate or prescribe a controlled substance as
described in s. 893.03 or 21 U.S.C. s. 812 to a

My hope is that podiatric stakeholders to include
myself will work with state and national
organizations to foster moving closer to being
deserving of equal status with all physicians.

Robert G.Smith DPM, MSc, RPh

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