Depending on the applicant’s overall qualifications, a CPP must have two (2), three (3), or five (5) years of Clinical Experience prior to approval. 21 NCAC 46.3101(b). Clinical Experience is measured as follows:

• International Candidates: “experience” begins at the time a license to practice pharmacy in the United States is obtained.

• Per decision of the CPP Joint Subcommittee, Advanced Pharmacy Practice Experiences (APPEs) during the final year of a pharmacy school’s PharmD program count as one year of experience.

• Each year of residency training counts as one year of experience.

• Each year of patient-contact pharmacy practice post-licensure counts as a year of clinical experience.

Pharmacy Rule 21 NCAC 46.3101(b)(1)(B)(ii) designates the North Carolina Center for Pharmaceutical Care (NCCPC) and the American Council on Pharmaceutical Education (ACPE) as approved providers of certificate programs in the area of practice covered by the CPP agreement:

  • ACPE-accredited courses (whose ACPE number is followed by a “C”) that relate to an area of practice are acceptable.

  • The NCCPC no longer exists. 

• A “site-specific” supervising physician. G.S. § 90-18.4(e1). The supervising physician shall determine the location(s) at which the CPP may provide health care services, and the CPP may – as determined by the supervising physician – be fully or partially embedded at the site-specific practice(s). G.S. § 90-18.4(f).

• Include the agreed-upon “health care services” (again, defined as “medical tasks, acts, or functions”) “such as initiating, changing, or discontinuing drugs, or ordering tests or devices, to assist with drug therapy, disease, or population health management.” G.S. § 90-18.4(e)(4).

• Include, if the CPP and supervising physician intend to allow it, a “statement of authorization” allowing the CPP to “conduct drug substitutions within the same therapeutic class or for biosimilar medications based upon the health plan’s drug formulary for a patient.” G.S. § 90-18.4(e)(5).

• A supervising physician may include Physician Assistants and Nurse Practitioners that the physician also supervise in a CPP collaborative practice agreement. Evaluation and supervision of the CPP remains with the supervising physician, however. G.S. 90-18.4(f).

• A supervising physician may collaborate with “any number of clinical pharmacist practitioners” that the supervising physician “deems can be safely and effectively supervised.” G.S. § 90-18.4(e)(3).

• Institutional and group practices may implement site-specific, multi-provider practice agreements for care of their patients. The institution must develop an oversight policy and CPPs operating under the agreement must be evaluated by a supervising physician. G.S. § 90-18.4(c2).

• Include a pre-determined plan for emergency services. 21 NCAC 46.3101(f)(5).

• Require that the patient be notified of the collaborative relationship under the collaborative practice agreement. 21 NCAC 46.3101(f)(7).

• For the first six months of the collaborative practice agreement, include a plan and schedule for monthly meetings to discuss operation of the agreement (i.e., the services provided and the manner in which the CPP has provided them) with the supervising physician, and thereafter a plan and schedule for such meetings at least once every six months. 21 NCAC 46.3101(f)(6); see G.S. § 90-18.4(e)(2) (“The supervising physician shall conduct periodic review and evaluation of the health care services provided by the clinical pharmacist practitioner.”).

• Approved and signed by the supervising physician(s) and maintained at the CPP’s practice site for inspection. 21 NCAC 46.3101(f)(1).

In general, no. Given the authority conferred upon CPPs and supervising physicians to tailor an agreement to provide “health care services”, the CPP application process does not include a detailed review of the collaborative practice agreement itself. The CPP and supervising physician(s) are responsible for the practice agreement meeting all legal requirements and restrictions in its form and operation.

CPPs and supervising physicians must maintain their agreements at practice site(s) for inspection. And Board staff can (and will) respond to complaints that a CPP practiced beyond the authority granted by the CPP statute and/or engaged in negligent or unprofessional conduct while practicing as a CPP. See generally G.S. § 90-85.38(a).

The CPP’s Supervising Physician(s) must sign the practice agreement. Electronic signatures are permitted.

No. 21 NCAC 46.3101(g)(2) specifies that a Supervising Physician (Primary or Back-Up) shall not be serving in a postgraduate medical training program.

Yes. Once you’ve renewed your license to practice pharmacy, you may renew your CPP credential. Click the CPP tile in your Board Licensure Gateway profile, then click Renew. You will be redirected to the CPP renewal application. The renewal fee is $50. Follow this link for additional FAQs regarding renewal of your CPP license.

A CPP must earn 35 hours of CPP-practice relevant continuing education each year. 21 NCAC 46.3101(d).

All CPPs must, of course, earn 15 hours of qualifying continuing education to renew their license to practice pharmacy each year. 21 NCAC 46.2201. Any (or all) of those hours may count toward the CPP-specific continuing education requirement as long as they are practice-relevant.

The remaining 20 hours of CPP-specific, practice-relevant continuing education are satisfied by ACPE-accredited continuing education coursework. 21 NCAC 46.3101(a)(8). Though the CPP rule defines “continuing education” as “courses . . . approved for credit by [ACPE],” it has long been the practice to accept ACCME-accredited, practice-relevant continuing education credits for CPP credential renewal.

NOTE: ACCME-accredited continuing education does NOT satisfy the general CE requirement for pharmacist licensure renewal. Board rule specifies that three types of continuing education may be used for purposes of pharmacist license renewal: (a) CE courses approved by ACPE; (b) CE courses approved by the North Carolina Association of Pharmacists; and (c) Precepting, for at least 160 hours, a student enrolled in the University of North Carolina Eshelman School of Pharmacy, the Campbell University College of Pharmacy and Health Sciences, the Wingate University School of Pharmacy, or the High Point University Fred Wilson School of Pharmacy as part of these schools’ academic program. 21 NCAC 46.2201(e).

When a CPP discontinues working under an approved CPP Agreement, the CPP must notify the Board of Pharmacy within 10 days. The CPP approval terminates automatically and is placed on inactive status until a new CPP application and protocol are approved. 21 NCAC 46.3101(b)(1).

You must submit a CPP Practice Update when you add/remove a practice site or add/remove a supervising physician. To submit a CPP Practice Update you’ll log in under your personal profile. Once logged in, click on your CPP tile and then click on the PRACTICES tile. Then, you will make the changes, keeping in mind that everything listed online needs to be listed on your collaborative practice agreement. All sites/physicians being deleted will turn red. All sites that are being added, will turn green. All physicians being added will turn yellow/gold.

The CPP and supervising physician(s) are responsible for ensuring that the practice agreement accurately describes the CPP’s practice and complies with all regulatory requirements. The CPP and supervising physician(s) must update the practice agreement whenever necessary, ensure that it is signed, and maintain the agreement at the practice site(s) for inspection.

When a change of supervising physician(s) occurs, the CPP and new supervising physician(s) must determine whether a return to monthly meetings for a period of six months is needed to ensure a proper, clinically appropriate supervisory relationship. 21 NCAC 46.3101(f)(6); see G.S. § 90-18.4(e)(2) (“The supervising physician shall conduct periodic review and evaluation of the health care services provided by the clinical pharmacist practitioner.”)

Yes. The CPP and supervising physician are responsible for ensuring that a conflict of interest does not exist, and that any laws or regulations that may be applicable (e.g., federal Stark Law or Anti-Kickback Statute; North Carolina prohibition on referral fees among health care providers) are complied with.

Yes. A CPP Agreement may include the CPP’s administration of vaccines beyond those specified in the immunizing pharmacist provisions of the Pharmacy Practice Act.