10.3 Naloxone and Opioid Antagonist Access
Key Takeaways
- CGS § 20-633c lets a pharmacist who is trained and certified by a DCP-approved program prescribe an opioid antagonist in good faith, train the recipient, and keep a dispensing-and-training record; that prescribing authority may not be delegated.
- CGS § 20-633d is different: a prescribing practitioner and a pharmacy may file with DCP a medical protocol standing order so a similarly certified pharmacist may dispense FDA-approved intranasal or auto-injector opioid antagonist to a person at risk or to a family member, friend, or other person in a position to assist, and must send a copy of the dispensing record to that practitioner.
- P.A. 23-97 added CGS § 20-14o(f)(2): when issuing an opioid-drug prescription, the prescribing practitioner shall encourage the patient (and, if applicable, a present parent or guardian of a minor) to obtain an opioid antagonist.
- P.A. 23-52 expanded CGS § 21a-286 so a § 20-633c-certified pharmacist or a prescribing practitioner may agree with a host agency (including local law enforcement, EMS, government, community health, or a board of education) to stock public secure boxes or nasal-antagonist vending machines.
- Pharmacists who prescribe under § 20-633c or dispense under § 20-633d are deemed not to have violated a pharmacist standard of care; § 21a-286(f) adds civil, administrative, and criminal immunity for the pharmacist or practitioner as to the host agency’s later administration or dispensing.
10.3 Naloxone and Opioid Antagonist Access
Quick Answer: Prescribe under CGS § 20-633c. Dispense under a standing order under CGS § 20-633d. Both require a pharmacist trained and certified by a DCP-approved program, recipient training, and a record. § 20-633c cannot be delegated. P.A. 23-97 added CGS § 20-14o(f)(2): the prescribing practitioner who issues an opioid-drug prescription shall encourage the patient to obtain an opioid antagonist. P.A. 23-52 expanded CGS § 21a-286 so a certified pharmacist may agree with a host agency (police, EMS, government, community health, school board) to install public secure boxes or nasal-antagonist vending machines.
NABP Competency 2.2 will mix these files. A stem that says “the technician will just prescribe Narcan” fails § 20-633c(d). A stem that says “Connecticut has no standing-order path, only pharmacist prescribing” fails § 20-633d. A stem that says “pharmacists may only sell FDA’s OTC naloxone spray” ignores both statutes.
Prescribe versus dispense under protocol — two statutes
| Feature | CGS § 20-633c (prescribe) | CGS § 20-633d (standing-order dispense) |
|---|---|---|
| Who is the prescriber? | The certified pharmacist, in good faith | A prescribing practitioner (CGS § 20-14c) who is authorized to prescribe an opioid antagonist; the pharmacy holds the agreement |
| What product? | An opioid antagonist as defined in CGS § 17a-714a | FDA-approved antagonist given by intranasal application or auto-injection |
| To whom? | Not limited by a “person at risk” clause in § 20-633c itself | Any person at risk of opioid overdose, or a family member, friend, or other person in a position to assist |
| Training of the pharmacist | DCP-approved train-and-certify program | Same: DCP-approved program |
| Training of the recipient | Required, plus a dispensing-and-training record | Required, plus the record, and a copy of the dispensing record sent to the standing-order practitioner |
| Filing with DCP | Certification through the approved program | The pharmacy shall provide DCP a copy of every standing-order agreement |
| Delegation | No. The pharmacist may not delegate or direct any other person to prescribe or to train the recipient under subsection (a) | Dispensing is still the pharmacist’s certified act under the protocol |
| Standard of care | Deemed not to have violated any pharmacist standard of care | Same deeming language |
§ 20-633d(b) says the standing order shall be deemed issued for a legitimate medical purpose in the usual course of the prescribing practitioner’s professional practice. That sentence is how a non-patient-specific protocol still satisfies corresponding-responsibility vocabulary. It is not a statewide Department of Public Health standing order. Connecticut does not publish a single statewide naloxone standing order; each pharmacy that uses § 20-633d needs its own practitioner agreement on file with DCP.
DCP’s naloxone-prescribing page still lists approved pharmacist programs (UConn School of Pharmacy, Pharmacist’s Letter, Walgreens Connecticut naloxone training). Certification is personal. A new hire cannot use a colleague’s certificate.
Over-the-counter naloxone (FDA, 2023) is a federal nonprescription path for labeled OTC products. It does not repeal § 20-633c or § 20-633d. The prescription path still matters for insurance billing, for formulations that remain prescription, and for the training and record duties that attach when the pharmacist is the prescriber or standing-order dispenser.
Encourage an antagonist with the opioid prescription — P.A. 23-97
CGS § 20-14o(f), as amended by P.A. 23-97, binds the prescribing practitioner who issues an opioid-drug prescription to an adult or minor. That practitioner shall:
- Discuss the risks of the opioid, including addiction and overdose, and the dangers of combining opioids with alcohol, benzodiazepines, and other CNS depressants, and why the prescription is necessary (and, if applicable, have that discussion with a present parent, guardian, or legal custodian of a minor); and
- Encourage the patient (and that present parent or guardian, if applicable) to obtain an opioid antagonist.
That is not a mandatory co-prescription statute, and it is not written as a pharmacist-dispense mandate. It is a 2023 duty on the writer of the opioid prescription. The practical access point is still the pharmacy: a § 20-633c-certified pharmacist can prescribe the antagonist at the same visit, or a § 20-633d pharmacy can dispense it under the standing order. An MPJE stem that shows a new outpatient oxycodone with no antagonist discussion is testing § 20-14o(f) on the prescriber and the pharmacist’s ability to open one of the two pharmacist doors.
Public boxes, vending machines, and host agencies — CGS § 21a-286
P.A. 23-52 (effective June 13, 2023) rebuilt § 21a-286. A prescribing practitioner, or a pharmacist certified to prescribe an opioid antagonist under § 20-633c, may enter an agreement with a host agency related to distribution and administration. Host agency means a community health organization, emergency medical service provider, government agency, law enforcement agency, or local or regional board of education.
The 2023 expansion added public-access hardware:
- A secure box: a container securely affixed in a public location, accessible for public use, displaying DCP-required signage (P.A. 25-171 added an express DCP-signage subsection). The box holds an intranasally or orally administered antagonist. The agreement must address environmental controls, replenishment, expiration dating and disposal, and signs in the language or languages spoken in the community. Quantity may not exceed what is necessary to serve that community. If the host cannot maintain the box, it and its signs come down as soon as practicable, not later than five days after that discovery.
- A vending machine for nasal administration, kept at labeled storage temperature (or independently environmentally controlled), with clear display of overdose signs and symptoms, use instructions, Connecticut opioid-use-disorder treatment information, and a website or QR code covering overdose response.
- Placement in a container that also holds an AED or other emergency product is not prohibited.
- A syringe services program may include antagonist in its secured machine under a similar agreement. Test strips for pre-use checking may also be distributed from that machine.
The pharmacist or practitioner who signs the agreement shall provide training to persons who will distribute or administer under it. § 21a-286(f) then gives that pharmacist or practitioner immunity from civil damages and from administrative or criminal prosecution for the host agency’s later administration or dispensing.
CGS § 17a-714a is the broader opioid-antagonist immunity and standard-of-care statute. Its title is immunity and no violation of standard of care for prescribing, dispensing, or administering an opioid antagonist. A licensed health care professional may administer an opioid antagonist to any person to treat or prevent an opioid-related drug overdose. Pair that with § 20-633c(c) and § 20-633d(e) when the actor is a pharmacist.
Realistic Connecticut scenario
A certified Waterbury pharmacist sees a patient’s family member who wants naloxone “in case.” Under § 20-633c the pharmacist prescribes, trains, and records. The technician may not complete that prescribing or that training. If the same pharmacy instead holds a § 20-633d agreement with a local physician, the pharmacist dispenses the nasal or auto-injector product under that protocol, trains, records, and mails or transmits a copy of the dispensing record to that physician. DCP already has a copy of the agreement.
A Torrington police department wants a wall-mounted public naloxone box in the lobby. A § 20-633c-certified pharmacist may sign a § 21a-286 host-agency agreement covering storage, restocking, expiration, and bilingual signs. That is not a pharmacy standing order, and it is not CDTM.
An internist electronically sends a first-fill oxycodone and never mentions naloxone. § 20-14o(f)(2) is the internist’s 2023 encourage duty. The pharmacist can still offer to prescribe or standing-order dispense an antagonist at pickup. OTC spray on the shelf does not make the two Chapter 400j statutes optional knowledge.
Official anchors
- CGS § 20-633c — pharmacist prescribing; no delegation.
- CGS § 20-633d — medical protocol standing order; DCP copy; report back to the practitioner.
- CGS § 20-14o — P.A. 23-97 encourage-an-antagonist duty when issuing an opioid prescription.
- CGS § 21a-286 — host-agency agreements, secure boxes, vending machines (P.A. 23-52).
- DCP naloxone prescribing — approved training programs.
A certified Connecticut pharmacist wants to get naloxone to a patient’s roommate who is in a position to assist if an overdose occurs. Which statement correctly distinguishes CGS § 20-633c from § 20-633d?
A Bridgeport law-enforcement agency wants a publicly accessible naloxone box in its lobby. Which statute governs a certified pharmacist’s agreement to stock that box?
When a Connecticut prescribing practitioner issues an opioid-drug prescription after P.A. 23-97, what does CGS § 20-14o(f) require regarding opioid antagonists?