State Pharmacy Associations Tackle Pharmacist Vaccination Abilities, Provider Status

In an interview with Pharmacy Times, Anthony Pudlo, PharmD, MBA, executive director of the Tennessee Pharmacists Association, discussed his presentation at the National Association of Chain Drug Stores (NACDS) 2023 Regional Chain conference. Pudlo’s presentation focused on key shifts in chain pharmacies, including pharmacy benefit manager (PBM) reform, pharmacist-administered vaccine trends, and provider status.

Q: The PREP Act is set to expire this year, which could affect pharmacy vaccinations in some states. How would that affect vaccination access?

Anthony Pudlo, PharmD, MBA: Yeah, it's a great question. And I think, you know, the work and what we saw from the PREP Act has really helped streamline and even standardize the expectations of the public for where and how they can receive vaccinations from their local pharmacy, whether that is by the pharmacists, student pharmacists, or pharmacy technicians. And I know a lot of states throughout the pandemic have had to have that thorough conversation in their state to say, how do we ensure a lot of this is still able to occur? So many practice settings have worked really diligently to make vaccines a core function, a core service within their communities. And so, if you all of a sudden go and tell pharmacies, we're not going to do that now because the authority isn't there, we're going to take a lot of steps back as a profession. And so, I know a lot of state associations, mine included, were actively looking to say, where is there opportunities? Do we need to pass legislation? Or is the act of actually giving vaccines broad enough in your state code? That maybe this is just a regulatory question, and asking assistance of your board of pharmacy to update rules? Or if it's actually more of an emergency order, an ongoing order by your health department, to grant pharmacists that authority?

And I think at the same time, while authority to do these things is great, it's the payment side. So how are we ensuring that pharmacists are properly being given not just reimbursement for the vaccine itself and the administration, but there's a service. There's an evaluation of need, and even many times pharmacies are doing a comprehensive vaccine assessment with those consultations, if it's just their COVID-19 vaccine or their influenza vaccine. And so how do we ensure that payers are seeing the value of pharmacists actually moving the needle in our states from the public health perspective.

That's something we’re going to talk about, as well, is that we're driving some of those initiatives here in the state of Tennessee as well. We had an initiative with our health department that is looking to see where pharmacies can really help move the needle for overall vaccine effort. We've targeted 75 pharmacies in some of our most rural communities in the state, where rates have really been pretty dismal from not just COVID-19 vaccinations but other vaccinations as well. So, using and leveraging that trusted relationship that the pharmacist has with their community to help drive and really try to overcome the misinformation and hesitation towards vaccination.

So, there's the scope piece, there's the reimbursement piece, and there really is just that ongoing question of how do we help continually drive and educate on vaccinations across all the various CDC and FDA approved vaccinations on the market?

Q: What are possible solutions or approaches to this issue?

Anthony Pudlo, PharmD, MBA: I would say what really it comes down to is state authority. Vaccine authority has always been really granted and leveraged at the state level, so I think that's really the conversation that pharmacists are having and the associations are having. Is the scope the full scope? You know, is there an age limitation, what are all the steps that pharmacists need, and technicians might need to really be able to drive this. So, everything really has happened at the state level that take what the PREP Act is done. So, then what happens before it expires to see what we can do at the state level. So, hopefully that answers your question on that.

Q: Provider status has been an area with lots of action in recent years. Do you see real shifts in this area?

Anthony Pudlo, PharmD, MBA: You know, I feel like every anytime I talk about provider status, I'm trying not to jinx myself or our efforts that we're seeing in our state. Because, you know, provider status as I referenced earlier, provider statuses is kind of this trinity. When you think about it, there's literally just being knighted, if you will, appointed if you will, that pharmacists are truly recognized as health care providers in code. There's whether it's to be listed in your state law, when anytime there's a reference to providers, pharmacist, it should be known that they’re providers, there's that side of it. There's the scope side of it, so there's obviously some limitations and how some state laws are written in terms of what pharmacists can do, and what they can do independently or what they can do in conjunction with a supervising provider, or prescriber. And then there's the payment side, right? And so, I think a lot of states are having successes in really all of those areas, with more and more of the focus being on the payment for services. And states like Tennessee and Washington State are having some great success that we're sharing as much as we can with other states. I was just having conversations this last week with some counterparts in one of my neighboring states about some of our lessons learned over the over the years.

So, there's that side, but we're having more success right now with our commercial plans. A lot of states are seeing more and more efforts with their state Medicaid programs, to be recognized and be able to be paid for services. And that's outside of your standard, like, MTM consultation, comprehensive medical review type session. This is actually having pharmacists get paid for true interventions, direct interventions, almost fee-for-service in that regard. And so, you know, that's where I think even the states like Tennessee, we can see some more movement in that regard. But I think any pharmacist that's working with their patients probably knows that your standard Medicaid beneficiary is sometimes the most vulnerable population and that you can really make a difference in their life. And so, you know, I think it's a lot easier type of message to pitch to your state Medicaid programs that the work that pharmacists are doing are actually saving lives, and we need to recognize and pay them for it. And so that's where I think and probably why we're having better success with some of our state Medicaid programs.

And the more and more we can see done at the state level for Medicaid reimbursement for commercial plans then makes this bigger ask, it creates this groundswell that we can really move CMS and Medicare at the federal level to recognize pharmacists in the Social Security Act. So, you know, I do think we still need more to occur at the state level that I think will continue to carry that message. But I still feel like we're a boiling pot of water that's ready to start really getting to that point where we can see it done at the federal level. So, again, I don't want to jinx myself, but I do think we're getting there.

Q: What would provider status mean for pharmacists, their reimbursement, and patients?

Anthony Pudlo, PharmD, MBA: You know, I think provider status means a lot of different things to a lot of people. But what ultimately it comes down to is it really starts shifting the pharmacy business model to be a more service-based model. Right now, we all know the majority of how pharmacies make money is from the dispensing of medications, from making a small amount of profit from just the purchasing and sale of a medication to dispensing of that. That's where pharmacies make money. But as we start seeing more and more of these opportunities on the service side, by being recognized as providers, I think it really starts making pharmacies rethink how much they invest in their staff time, their technology, how they engage with their patients, what that experience really looks like when they come in to, say, a local community pharmacy, or even if it's into a physician practice that employs pharmacists. There's going to be a real shift in, I think, the health care system by letting pharmacists do this more, and really letting those skills and the knowledge of a pharmacist be on full display to the public and to other health care providers. So, the shift will, I think, have rippling effects across everywhere, but I think it'll really have an ultimate change in the traditional community-based model. And let community pharmacies really start being seen as a service destination instead of just a product-based destination for pharmacy services.

Q: Is there anything you would like to add?

Anthony Pudlo, PharmD, MBA: You know, I think what I would just offer is, for whoever's reading and listening, is just getting involved. I always preach to new graduates and student pharmacists and really anybody that it's so important to get involved [and] get involved locally. First and foremost, there's usually many times a local pharmacy association that is a mechanism for people to get connected with other pharmacists outside of the 4 walls of your community pharmacy, 4 walls in your hospital, and start having these conversations locally about what we can do better. And then from there, that grows into and hopefully creates confidence to get more involved at the state level. So, everybody should be involved in their state of pharmacy association. And then from there that leads into how we actually support and drive efforts nationally as a profession. So, it starts locally, but it builds. So I encourage everybody to get involved locally, join your state pharmacy association, join a national pharmacy association as well, and let's help really drive change in our profession.