10.2 Collaborative Drug Therapy Management
Key Takeaways
- CGS § 20-631 distinguishes a collaborative drug therapy management agreement (qualified pharmacist plus prescribing practitioner), a care-giving institution’s collaborative drug therapy management policy, and a collaborative drug therapy care plan that memorializes the agreed approach to a desired health outcome.
- A prescribing practitioner must first establish a provider-patient relationship — medical complaint, medical history, physical examination, and a logical connection to any drug or device prescribed — before CDTM begins.
- Each patient’s drug or device management must rest on that practitioner’s diagnosis or on a specific test set out in the agreement or policy; the pharmacist does not independently diagnose.
- A qualified pharmacist may be authorized to initiate, modify, continue, discontinue, or deprescribe drug therapy, manage devices, order associated laboratory tests, and administer drugs, but may not establish a port to administer parenteral drugs.
- If therapy is discontinued or deprescribed, the pharmacist must notify the prescribing practitioner not later than 24 hours; RCSA § 20-631-1 lists competency routes including a Pharm.D. or a B.S. in pharmacy with 10 years of clinical experience.
10.2 Collaborative Drug Therapy Management
Quick Answer: CGS § 20-631 lets qualified pharmacists manage drug therapy and devices under a collaborative drug therapy management agreement (with a prescribing practitioner) or a collaborative drug therapy management policy (adopted by a care-giving institution). The practitioner must first have a provider-patient relationship. Management rests on the practitioner’s diagnosis or a specific test named in the agreement or policy. Inside a written protocol or care plan, the pharmacist may initiate, modify, continue, discontinue, or deprescribe therapy, manage devices, order associated laboratory tests, and administer drugs — but not establish a port for parenteral drugs. Notify the practitioner within 24 hours after discontinue or deprescribe.
NABP Competency 2.2 includes collaborative practice. Connecticut’s 2022 rewrite (P.A. 21-192; P.A. 22-118) expanded CDTM beyond the old physician-only, patient-specific model. Teach the current definitions. CGS § 20-631b is only a grandfather clause: agreements entered before October 1, 2010 still follow the September 30, 2010 version of § 20-631.
Agreement, policy, care plan — pick the instrument that matches the setting
§ 20-631(a) is a defined-term statute. Using the wrong noun is how candidates fail easy items.
| Instrument | Who creates it | What it does |
|---|---|---|
| Collaborative drug therapy management agreement | One or more qualified pharmacists and one or more prescribing practitioners | Manage drug therapy and devices of individual patients or a patient population, based on a written protocol or a care plan |
| Collaborative drug therapy management policy | A care-giving institution (same meaning as CGS § 20-571) | Same management authority, under a written institutional policy, based on a protocol or care plan |
| Collaborative drug therapy care plan | Qualified pharmacist(s) and prescribing practitioner(s) who discuss, review, and agree | A written document memorializing the agreed approach to a patient’s desired health outcome |
Community (and other non-institution) practice uses the agreement. A hospital, nursing home, or other care-giving institution uses the policy. Either may be patient-specific or population-based. The care plan is the clinical work-product, not a substitute for the agreement or policy that authorizes it.
Prescribing practitioner and device take their § 20-571 meanings. CDTM is not limited to physicians. APRNs and other prescribing practitioners who can form a provider-patient relationship are inside the current statute — a change from older Connecticut CDTM law that limited the collaborating prescriber list.
Provider-patient relationship and diagnosis — the door that must open first
§ 20-631(b) is a sequence, not a slogan. Except for grandfathered § 20-631b agreements, qualified pharmacists may enter an agreement or manage under a policy. In order to enter an agreement or care plan, or operate under a policy, the prescribing practitioner shall first establish a provider-patient relationship with the patient or patients who will receive collaborative drug therapy or devices.
Provider-patient relationship in § 20-631(a)(9) means all four of the following:
- The patient has made a medical complaint.
- The patient has provided a medical history.
- The patient has received a physical examination.
- There exists a logical connection between that complaint, history, and examination and any drug or device prescribed for the patient.
Each patient’s collaborative drug therapy or device management shall be based on a diagnosis made by that patient’s prescribing practitioner or a specific test set forth in the agreement or policy. The pharmacist does not independently diagnose hypertension in a walk-in and start lisinopril “under CDTM.” The diagnosis (or the named test) is the practitioner’s. A population protocol for “all inpatients with a positive MRSA PCR” is the specific-test path; it is still not a pharmacist-made diagnosis.
What the protocol may authorize — and the parenteral-port wall
§ 20-631(c) is the authority list. An agreement or policy may authorize a qualified pharmacist to:
- Initiate, modify, continue, discontinue, or deprescribe a drug therapy.
- Initiate, continue, or discontinue use of, or deprescribe, a device that has been prescribed for a patient.
- Order associated laboratory tests.
- Administer drugs.
All of that must stay in accordance with a patient-specific or population-specific written protocol or care plan. The same subsection shall not authorize a qualified pharmacist to establish a port to administer parenteral drugs. Starting a vancomycin protocol, adjusting the dose from a trough, or giving an intramuscular injection the protocol names is one thing. Placing a central line or other parenteral port is outside CDTM.
The agreement or policy may specifically address medication-reconciliation issues and polypharmacy concerns that enable an authorized pharmacist to initiate, modify, continue, discontinue, or deprescribe. When drug therapy is discontinued or deprescribed, the pharmacist shall notify the prescribing practitioner not later than twenty-four hours after that action. Silence until the next monthly meeting is not the statute.
Each written protocol or care plan shall contain detailed direction concerning the actions the pharmacist may perform, including but not limited to:
- The specific drug or drugs, therapeutic class or classes, or devices to be managed.
- The terms and conditions under which therapy or device use may be initiated, modified, continued, discontinued, or deprescribed.
- The conditions and events upon which the pharmacist must notify the prescribing practitioner.
- The laboratory tests that may be ordered.
- A definition of the patient population included.
All CDTM activities shall be documented in the patient’s medical record in accordance with the prescribing practitioner’s policies or, in a care-giving institution, that institution’s policies. Each agreement, policy, written protocol, and care plan shall be available for inspection by DCP and DPH. A copy of the protocol shall be filed in the patient’s medical record.
Who is a qualified pharmacist — statute plus RCSA § 20-631-1
Qualified pharmacist means a pharmacist who (A) is deemed competent under regulations adopted under subsection (e) and (B) has reviewed the latest edition of the Pharmacists’ Patient Care Process published by the Joint Commission of Pharmacy Practitioners. Subsection (d) makes the pharmacist responsible for demonstrating that competence, including that PPCP review, for each agreement, policy, and care plan the pharmacist wants to join. Reading PPCP once in 2014 and never again is not “the latest edition.”
RCSA § 20-631-1 (effective January 2, 2013) still supplies the competency menu. The pharmacist must be licensed in this state and meet at least one of the following:
- Bachelor of Science degree in pharmacy with 10 years of clinical experience, or a Pharm.D. degree.
- Certification by the Board of Pharmaceutical Specialties.
- Certification by the Commission for Certification in Geriatric Pharmacy.
- A credential in disease-state management from the National Institute for Standards in Pharmacist Credentialing.
- A pharmacy residency accredited by ASHP.
- Completion of an ACPE-approved disease-state management certification program.
RCSA § 20-631-2 lists minimum agreement content (types of prescriptive decisions; eligible patients; diseases, drugs, or categories — with no limitation on disease states; decision criteria; required training; periodic review and quality assurance; documenting prescribing decisions). Subsection (e) of the statute directed DCP, in consultation with DPH, to amend those regulations on or after July 1, 2022 to cover policies, care plans, and written protocols. Until a stem quotes a newer regulation, apply the statute’s protocol elements plus this competency menu. Do not tell the exam CDTM is limited to diabetes or anticoagulation; § 20-631-2 says there are no disease-state limitations.
Realistic Connecticut scenario
A New Haven internist has an established adult with atrial fibrillation, documented history and examination, and a warfarin diagnosis. The internist and a Pharm.D. who has reviewed the current PPCP sign a CDTM agreement with a protocol that names warfarin, INR goals, dose-adjustment rules, when to call, and the patient population. The pharmacist increases the weekly dose after an INR of 1.6 and documents it in the medical record. That is § 20-631.
A community pharmacist without any agreement starts lisinopril because the patient’s blood pressure is high at the counter. There is no provider-patient relationship established by a prescribing practitioner for this purpose, no diagnosis or named test in a protocol, and no qualified-pharmacist file. That is not CDTM. Immunization, naloxone, and contraception authorities in this chapter are separate statutes; they do not create a general CDTM license.
A hospital policy lets qualified pharmacists manage vancomycin for inpatients with a listed culture result. The pharmacist discontinues vancomycin when cultures are negative. Notice to the prescribing practitioner is due within 24 hours. Filing it only in the pharmacy system is not notice.
The same protocol cannot authorize the pharmacist to place a PICC so that vancomycin can be given. No parenteral port.
Official anchors
- CGS § 20-631 (2025) — definitions, provider-patient relationship, authority list, 24-hour notice, inspection.
- CGS § 20-631b — pre–October 1, 2010 agreements keep the September 30, 2010 statute.
- RCSA § 20-631-1 — competency routes.
- RCSA § 20-631-2 — agreement content; no disease-state limitation.
Before a qualified pharmacist may manage a patient’s drug therapy under a CGS § 20-631 agreement or policy, which condition must already be true?
Which set of actions may a CGS § 20-631 collaborative drug therapy management agreement or policy authorize a qualified pharmacist to perform?
How does current CGS § 20-631 treat community practice versus a hospital or other care-giving institution?