4.4 Drug Administration & Collaborative Practice Agreements

Pharmacist Administration Authority

Pennsylvania expanded pharmacist administration authority under 49 Pa. Code §§ 27.401–27.408 and the Pharmacy Act amendment by Act 80 of 2022 (63 P.S. § 390-9.2). As amended effective April 11, 2026 (56 Pa.B. 1980), the Board's rules now provide:

• Pharmacists and pharmacy interns may administer injectable medications, biologicals, and immunizations to persons 8 years of age or older (§ 27.403(a)).
• Influenza and COVID-19 immunizations may be administered (by injection or needle-free device) to persons 5 years of age or older (§ 27.403(b)).
• Interns act under the direct and immediate personal supervision of an authorized pharmacist.
• Pharmacists may delegate administration of influenza and COVID-19 vaccines to CRNPs, PAs, RNs, and LPNs (§ 27.403(c)(1)), and to registered pharmacy technicians for influenza and COVID-19 vaccines to individuals 13 years or older, under direct and immediate supervision and with the technician's registration and training on file (§ 27.403(c)(2)).

The prior 18-year threshold (sometimes appearing in older exam-meta) is outdated — the current age is 8 years for general injectable/biologic administration and 5 years for influenza and COVID-19.

Administration Authority at a Glance

Requirements to Administer

To administer under § 27.403, a pharmacist must:

1. Be authorized by the Board (registration) for administration,
2. Have a valid order or operate under a written protocol issued by a licensed physician, CRNP, PA, or other authorized practitioner,
3. Hold a current CPR certification,
4. Have completed Board-approved training in administration,
5. Administer vaccines per the immunization schedule of the CDC/ACIP (and for COVID-19, per FDA-authorized schedules),
6. Report to the DOH immunization registry within 72 hours, and
7. For patients under 18, notify the parent or caregiver of the importance of a well-child visit.

A written protocol is valid for up to 2 years from the date of issue under 49 Pa. Code § 27.404. Pharmacists must keep the protocol on file and must not administer under an expired protocol.

Collaborative Practice Agreements — § 27.302

Pennsylvania authorizes collaborative practice agreements (CPAs) for drug therapy management in non-institutional settings under 49 Pa. Code § 27.302. Key requirements:

• The agreement must be between a physician (licensed by the PA Board of Medicine or Osteopathic Medicine) and a pharmacist licensed by the PA Board of Pharmacy.
• It must be in writing and identify the parties, the scope of drug therapy management, the drugs involved, and the duration.
• It must be voluntary — neither party may be required to enter into or remain in a CPA.
• It must be initiated on a written referral from the physician to the pharmacist for each patient.
• It is limited to non-institutional settings — CPAs are not a vehicle for inpatient hospital drug therapy management.

Under a CPA, the pharmacist may, within the scope of the agreement, adjust doses, discontinue medications, order lab tests, and manage chronic conditions (e.g., anticoagulation, hypertension, diabetes) per the agreement's terms.

CRNP Collaborative Agreements — § 21.285 — Not Pharmacist Scope

A common MPJE trap is confusing pharmacist collaborative practice with CRNP collaborative practice:

• CRNP prescriptive authority is governed by 49 Pa. Code § 21.285, not § 27.302. CRNPs must have a written collaborative practice agreement with a physician for prescriptive authority, including CII prescribing.
• A pharmacist may not serve as the "collaborating physician" for a CRNP — that role is restricted to a physician (MD or DO).
• A CRNP may not serve as the physician party to a pharmacist CPA under § 27.302 — that role is also restricted to a physician.

Practical Scenarios

Scenario 1: A pharmacist in a community pharmacy wishes to administer the seasonal influenza vaccine to a 6-year-old. This is permitted under § 27.403(b) (flu to ≥5 years), provided the pharmacist has Board authority, a current order or written protocol, current CPR, and training. The pharmacist must report to the DOH immunization registry within 72 hours and notify the parent/caregiver of the well-child visit.

Scenario 2: A pharmacist wishes to administer a non-flu, non-COVID injectable biologic to a 7-year-old. This is not permitted under § 27.403(a), which sets the age at 8 years for general injectable/biologic administration. The pharmacist must refer the patient to a physician or wait until the patient turns 8.

Scenario 3: A pharmacist enters a CPA with a physician to manage anticoagulation therapy for a referred patient. The pharmacist adjusts warfarin doses per INR results within the CPA's scope. This is lawful under § 27.302 because the agreement is in writing, between a physician and pharmacist, voluntary, and initiated by written referral.

Scenario 4: A CRNP wishes to enter a CPA with a pharmacist for diabetes management. Under § 27.302, the physician party must be a physician; a CRNP may not serve as the collaborating physician in a pharmacist CPA. The arrangement would require a physician as the named party to the CPA.