Understanding Policy Priorities and Advocacy Opportunities During COVID-19

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The fight against COVID-19 has demanded the federal government take action to allow pharmacists and other health care professionals to do more of what they are trained to do. By being more flexible about certain requirements and expanding scope of practice through new authorities, the federal government intends to make it easier for pharmacists to provide care to patients during the COVID-19 public health emergency. The problem is many of these flexibilities and authorities are not considered permanent and further action is needed to expand access to pharmacist provided services. 
 
 

             Why This Matters

 
 
If action is not taken, patients will not be able to receive needed care at pharmacies across the country now and once the public health emergency ends. In this short video, learn about the flexibilities and authorities extended to pharmacists to date and what work can still be done to achieve the key policy priorities outlined in the handout below and on this page.
 
 

How to Advocate for Pharmacy
COVID-19 has changed a lot in the policy landscape, including how pharmacists can be an advocate for the profession. Understand these changes and learn how to advocate for key priorities during COVID-19.

 
 
 
 

Immunizations
Expand pharmacists’ immunization authority to order and administer all FDA-approved vaccines, including the forthcoming novel vaccine for COVID-19, for all indicated populations.

 
Under the Public Readiness and Emergency Preparedness Act (PREP Act), pharmacists are authorized to order and administer, and pharmacy interns acting under the supervision of the qualified pharmacist are authorized to administer, COVID-19 vaccinations to persons aged 3 years or older, childhood vaccines to individuals ages 3 to 18 years old. These authorities must be maintained and expanded to ensure widespread vaccination, particularly against influenza and COVID-19.
 
 
Talking Points:
  • More than 360,000 pharmacists have been trained to administer vaccines across the lifespan and are integral members of the “immunization neighborhood.”
  • Pharmacists are playing an increasingly critical role in raising influenza vaccination rates across the United States with more than 25% of annual influenza vaccinations administered within pharmacies and more than 50% of shingles vaccines administered by pharmacists.
  • An additional 4.1 million additional adults were vaccinated in 2013 because states allowed pharmacists to administer the flu vaccine, which resulted in between 81,000-134,000 fewer influenza infections among adults in that year, depending on vaccine effectiveness.
 
Ways to Engage:
  • Take Action Now to urge Congress to authorize pharmacists to order and administer the forthcoming novel vaccine for COVID-19, for all indicated populations and to designate pharmacists as providers under Medicare Part B to ensure pharmacists are reimbursed for this service.
  • Depending on your state, you may need to contact your state representatives to expand pharmacists’ immunization authority. Visit NASPA’s COVID-19 Vaccines page to see where your state stands.
  • Join the Immunizing Pharmacists SIG to be among the first to learn about opportunities to shape pharmacists’ immunization practices through policy and volunteer leadership.
 
 
 
 

Testing
Establish a clear regulatory path to ensure payment for all the necessary and required services for all pharmacists and pharmacies to conduct COVID-19 testing and services (including patient assessment, ordering the test, specimen collection, performing the test, interpreting the results, and reporting the results to the patient and appropriate entities) for all patients.

 
Despite federal guidance authorizing pharmacists to test for COVID-19, there remains no clear regulatory path to ensure payment for all the necessary and required services to conduct testing for all patients.
 
 
Talking Points:
  • Expanding people’s access to care from pharmacists will multiply their health care access points. If action is not taken, the country may not be able to leverage these critical access points to testing and immunizations.
  • Like physician practices, hospitals, and other health care providers, pharmacists cannot be there for patients without fair and reasonable reimbursement for their services.
 
Ways to Engage:
  • Take Action Now to urge Congress to designate pharmacists as providers under Medicare Part B to ensure pharmacists are reimbursed for testing services.
  • Contact your state representatives to advocate for payment for testing under Medicaid. Visit NASPA’s COVID-19 Testing page to see where your state stands.
  • View APhA and NASPA’s Pharmacy Models for COVID-19 Testing practice resource for information about how to prepare to ramp up COVID-19 testing and current payment pathways.
  • Join the Pharmacists’ Response to COVID-19 ENGAGE community to stay connected with colleagues across the country and get the latest information about COVID-19 resources.
 
 
 
 
Telehealth

Codify the recent COVID-19-related telehealth flexibilities (location requirements, virtual supervision of “incident to” services) and expand enforcement discretion under Medicare and Medicaid, both through regulations and Congressional action, to permit and reimburse pharmacists for providing all services authorized under their state scope of practice the same as in-person services.

 
Flexibilities issued by HHS and CMS allow for the use of non-public-facing software, relaxed location requirements, and for pharmacists to provide telehealth services under “incident-to” arrangements with physician supervision provided virtually using real-time audio and visual technology.
 
 
Talking Points:
  • Telehealth is especially useful during the COVID-19 pandemic due to the necessity that people remain physically distant from one another to mitigate the spread of the disease.
  • With many cities limiting public transportation options, as well as the concerns many people now have with taking public transportation altogether, telehealth provides a way for people to have access to healthcare professionals without having to venture outside of their homes.
 
Ways to Engage:
 
 
 
 
Access to Medications

Preserve flexibility for pharmacists to compound all necessary medications in shortage under sections 503A and 503B of the Drug Quality and Security Act (DQSA) for hospitalized patients without patient-specific prescriptions to address shortages during a public health emergency.

 
FDA granted flexibilities for pharmacists to compound medications in shortage under 503A and 503B for hospitalized patients without patient-specific prescriptions.
 
 
Talking Points:
  • Compounding pharmacists are a great, and often underutilized, resource that can help fill in gaps when medications are near shortage levels by anticipating patients’ needs before the shortage occurs.
  • In order to prevent the breakdown of supply and demand for certain medications, pharmacists need to have pre-approved authority to compound certain medications before the shortage becomes widespread and backlogged.
 
Ways to Engage:
  • Personalize your message to Congress stating the importance of maintaining compounding flexibilities so that you can anticipate patients’ needs.
  • Join APhA–APPM’s Compounding SIG to connect with compounding leaders across the country and share strategies that have been successful.
  • Learn about recent compounding flexibilities in APhA’s COVID-19 webinar series that might affect pharmacists like you.
 
 
 
 
Pandemic Planning

Involve pharmacists in state emergency response planning and coordination, including the request process and distribution plan for personal protective equipment (PPE), ancillary medical supplies, and the Strategic National and state stockpiles.

 
Pharmacists must engage in pandemic planning activities on the local, state, and federal level to ensure pharmacists are able to fully respond to future pandemics.
 
 
Ways to Engage:
 
 
 
 
Provider Status

Designate pharmacists as providers under Medicare Part B to ensure that pharmacists are reimbursed for patient care services, including COVID-19 and influenza services, provided by pharmacists acting within their state scope of practice or as authorized under an emergency declaration with the ability to extend coverage to address future public health emergencies.

 
Congress must pass legislation that amends the Social Security Act to include pharmacists as eligible providers so pharmacists can bill Medicare directly for patient care services provided to seniors.
 
 
Talking Points:
  • Over 90% of Americans live within 5 miles of a pharmacy, making pharmacists the most widely accessible health care providers.
  • Pharmacists provide care and services in a wide variety of practice settings in communities across our nation – making them uniquely qualified to reduce clinical burdens and improve patient health.
 
Ways to Take Action:
  • Take Action Now: It only takes a few minutes to contact your Members of Congress!
 

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