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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:
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 pharmacy.
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 pharmacy. 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 pharmacist.
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 requirement.
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 agreement.
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 pharmacist.
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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