6.2 Pharmacist Prescribing: Statewide Protocols, the Formulary & General Requirements
Key Takeaways
Oregon pharmacists prescribing under the formulary or a protocol must notify the patient's primary care provider within five business days and keep records for seven years.
An Oregon pharmacist may not prescribe under the formulary or a protocol to themselves, or when the protocol requires referral (OAR 855-115-0335).
Oregon formulary items such as diabetic supplies, CGMs, spacers and epinephrine are prescribed pursuant to a qualified practitioner's diagnosis, with the diagnosis code documented.
As of October 2026, Oregon's protocols cover continuation of therapy, cough and cold, COVID-19, contraception, emergency contraception, tobacco, travel, PrEP/PEP, STI PEP, naloxone, MOUD and vaccines.
ORS 689.704 lets Oregon pharmacists prescribe HIV PrEP, including up to a 30-day supply based solely on the pharmacist's reading of a negative HIV test.
Why this matters
Oregon gives pharmacists unusually broad independent prescribing authority through a formulary and a set of statewide drug therapy management protocols. These are recommended by the Public Health and Pharmacy Formulary Advisory Committee (PHPFAC) and adopted by the Board (ORS 689.645 and 689.649). The MPJE tests which products are covered, the general conditions for any pharmacist prescribing, and the documentation and notification duties.
General conditions for all formulary and protocol prescribing (OAR 855-115-0330)
A pharmacist licensed and located in Oregon may prescribe an FDA-approved drug or device under the formulary or a protocol only if they:
- Complete any required training first and keep proof (six years under OAR 855-104-0055, or uploaded to eGov).
- Follow the protocol's standardized assessment and care pathway. Required physical assessments must happen in a face-to-face, in-person interaction.
- Create an individualized, patient-centered care plan and monitor its effectiveness.
- Provide notification to the patient's identified primary care provider or other care providers, when applicable, within five business days of prescribing.
- Document the encounter and keep prescribing records for seven years.
The prohibitions in OAR 855-115-0335 are tested as well. A pharmacist may not prescribe under the formulary or a protocol to themselves, or when the formulary or protocol requires referral to a non-pharmacist provider. For hormonal contraception, a pharmacist may not require an appointment, though one may be allowed.
The formulary (OAR 855-115-0340)
The formulary covers post-diagnostic drugs and devices. The pharmacist prescribes them pursuant to a diagnosis made by a qualified practitioner and documents the diagnosis code. The current formulary covers:
- Diabetic blood glucose testing supplies and continuous glucose monitors.
- Injection supplies, nebulizers and supplies, inhalation spacers and peak flow meters.
- INR testing supplies, enteral nutrition supplies and ostomy supplies.
- Non-invasive blood pressure monitors.
- Epinephrine, added effective January 23, 2026.
The protocol compendium (OAR 855-115-0345)
Protocols are assessment-based: the pharmacist follows the Board's standardized intake form and care pathway. As of October 2026 the compendium included:
| Category | Protocols |
|---|---|
| Continuation of therapy | Continuation of therapy, including emergency refills of insulin and early refills of opioid use disorder medications (see section 8.4) |
| Conditions | Cough and cold symptom management (benzonatate, intranasal corticosteroid, short-acting beta-agonist); COVID-19 antigen self-testing; SARS-CoV-2 antivirals |
| Preventive care | Contraception; emergency contraception; condoms; tobacco cessation; travel medications; HIV pre-exposure (PrEP) and post-exposure (PEP) prophylaxis; sexually transmitted infection PEP; short-acting opioid antagonists |
| Opioid use disorder | Medications for opioid use disorder (MOUD): initiation of therapy, and continuation or modification of therapy |
| Vaccines | Standard protocols for adults 18 and older and for persons 7 through 17; managing adverse reactions; separate COVID-19, influenza and respiratory syncytial virus (RSV) protocols |
There is no statewide influenza or group A strep test-and-treat protocol. ORS 689.645(6)(b) lists rapid strep tests among items the formulary may include, and ORS 689.662 authorizes COVID-19 test-and-treat. A pharmacist may prescribe only what the Board has actually adopted, and the current formulary does not include strep testing.
HIV PrEP and PEP (ORS 689.704)
A pharmacist may prescribe, dispense and administer HIV PrEP, and PEP under Board rules. The pharmacist may perform an HIV test or order one from a laboratory, complying with ORS 433.045. The rules must allow up to a 30-day supply of PrEP based solely on the pharmacist's reading of an HIV-negative test.
COVID-19 (ORS 689.662)
A pharmacist may test for SARS-CoV-2 using a CLIA-waived or FDA-approved test the Board approves. They may then prescribe, dispense and administer treatment under the protocols, and may delegate the technical testing tasks to a supervised technician or intern.
Travel medications and cough/cold
These protocols use standardized assessments, with references to CDC Yellow Book travel guidance and Board care pathways. As with every protocol, a finding outside the pathway, such as red-flag symptoms, requires referral.
How the Board keeps the compendium current
The Board adopts each protocol by version date. It often uses temporary rules when federal guidance changes, as it did for several 2025–2026 vaccine protocols, followed by permanent rules. Pharmacists may submit protocol concepts or formulary additions to the PHPFAC on Board forms (ORS 689.645(1)(c); ORS 689.649(8)). Pharmacies document their prescribing services on the annual self-inspection form.
Tip
When an exam item asks whether a pharmacist may "prescribe X," check three things. Is X on the formulary (with a diagnosis), or covered by an adopted protocol (with an assessment)? Does a statute authorize it, as with contraception, insulin, PrEP/PEP, MOUD or naloxone? Is anything prohibited, such as self-prescribing or a required referral?
Exam scenario
A patient with a physician diagnosis of type 2 diabetes asks an Oregon pharmacist for a continuous glucose monitor because their prescription lapsed. CGMs are on the formulary, so the pharmacist may prescribe one pursuant to the documented diagnosis, recording the diagnosis code. The pharmacist notifies the patient's primary care provider within five business days and keeps the record for seven years. If the same patient asked for metformin, the formulary would not apply. The pharmacist would look to the continuation-of-therapy protocol, which needs evidence of a previous prescription.
After prescribing under an Oregon statewide protocol, within what time must the pharmacist notify the patient's identified primary care provider, when applicable?
Within 24 hours
Within 15 days
Within 30 days
Within five business days
A pharmacist wants to prescribe a peak flow meter for a patient with physician-diagnosed asthma. Which statement is correct?
A peak flow meter is a formulary item the pharmacist may prescribe pursuant to the documented diagnosis
Pharmacists may prescribe peak flow meters only under a CDTM agreement
A peak flow meter requires the asthma protocol's in-person spirometry first
Devices cannot be prescribed by Oregon pharmacists
A pharmacist with a sore throat performs a rapid strep test on themselves and plans to prescribe amoxicillin under a protocol. Why is this impermissible?
Rapid strep tests are banned in Oregon pharmacies
Oregon has no group A strep test-and-treat protocol, and OAR 855-115-0335 bars pharmacists from prescribing to themselves
Only interns may perform rapid strep tests
Antibiotics may be prescribed by protocol only to minors
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