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The Next Public Board Meeting will be held on October 16 , 2024 at 9:30 AM.
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Comments, questions or suggestions can be emailed to All email will be read, but a response is not guaranteedMaryland Overdose Response Program
Statewide Naloxone Standing Order
Guidance for Pharmacy Dispensing
Updated April 2024
Summary
Laura Herrera Scott, MD, MPH, (NPI # 1285684274), Secretary of the Maryland Department of Health (MDH), has issued an updated statewide standing order allowing all Maryland-licensed pharmacists to dispense any formulation of naloxone, including any necessary supplies for administration, to any individual. This document was created by the MDH Overdose Response Program (ORP) and provides information for pharmacists who wish to dispense naloxone under the statewide standing order.
Many individuals mayb e lawfully prescribed naloxone directly by their healthcare provider. These prescriptions should be dispensed in the usual course of business and a pharmacist's professional practice. This document provides guidance specific to naloxone dispensing under Dr. Herrera Scott's statewide standing order. Click here to continue reading.
"Prohibiting a health occupations board from requiring that an applicant provide proof that the applicant is lawfully present in the United States or have a Social Security number or Individual Taxpayer Identification Number as a condition for licensure, certification, or registration; . " To continue reading the document, click here to visit the website .
Effective April 25, 2024, Maryland law was amended (Chap. 232) to expand State vaccination authority for pharmacists. Specifically, Health Occ. Art., Sec. 12-508 now permits pharmacists to administer the following without a prescription:
Please note that pharmacists who vaccinate must still be registered with the Board and meet eligibility requirements, to include: a 20-hour ACPE practical training program; active CPR certification obtained through in-person instruction; and completion of 2 ACPE continuing education credits related to immunizations every renewal period after registration.
Existing recordkeeping and reporting requirements have not changed such as reporting to Immunet, vaccine-specific protocols, visit summary, patient referrals, patient consent and disclosures. Please reference Health Occ., Sec. 12-508 for the full text of the amended statute. The Board will be revising certain provisions in its vaccination regulations, COMAR 10.34.32, in order to align with the new legislation.
In accordance with Senate Bill 678/House Bill 1151, the Maryland Department of Health (MDH), will allow Medicaid-enrolled pharmacist providers to bill Maryland Medicaid for Pharmacist Professional Services (PPS) rendered within their lawful scope of practice.
Medicaid-enrolled pharmacists can bill Maryland Medicaid using billing and coding information according to the CMS 1500 Billing Instructions at https://health.maryland.gov/mmcp/provider/Pages/ffsclaims.aspx
To bill Fee-for-Service (FFS) Medicaid for PPS, a pharmacist must be actively enrolled with Maryland Medicaid as a participating provider type “PH" through Maryland Medicaid's online Electronic Provider Revalidation and Enrollment Portal (ePREP).
The link to the Pharmacist Providers ePREP instructions and training for the enrollment process is https://health.maryland.gov/mmcp/provider/Pages/eprepresources.aspx. These materials are available under the "By Provider Type" heading by selecting "Pharmacist".
Pursuant to Md. Code Ann., Health Occ. § 12-508(a)(3) and COMAR 10.34.32.03B-2, a licensed pharmacist registered with the Board may administer a vaccination listed on the Center for Disease Control and Prevention’s (“CDC”) Recommended Immunization Schedule to an adult without a prescription, subject to certain requirements. On September 22, 2023, the CDC released an addendum to the Schedule adding the RSV vaccine for pregnant people during weeks 32 to 36 of gestation and adults 60 years of age and older, as recommended by ACIP and adopted by the CDC. As such, a licensed pharmacist’s vaccination administration authority for adults currently includes the RSV vaccine administered to a pregnant person during weeks 32 to 36 of gestation or to an adult 60 years of age or older.
The DEA recently published a final rule , effective July 24, 2023, which amends the regulations regarding DEA Form 106, used by registrants to formally report thefts or significant losses of controlled substances. The final rule requires that all DEA Form 106s be submitted electronically. DEA will allow registrants 45 days from discovery of the theft or significant loss to submit the form, up from the agency’s original proposal of 15 days. (In comments to the proposed rule back in September 2020, NCPA requested a 60-day timeframe, and alternately supported the proposed 15-day timeframe if that was implemented after the COVID-19 PHE ended.) Notably, the final rule does not change the requirement that registrants preliminarily notify their area DEA Field Division Office of the theft or significant loss of any controlled substances in writing within one business day of discovering such loss or theft. Paper copies of DEA Form 106 will no longer be accepted once the final rule becomes effective.
E lectronic Prescribing of Controlled Substances
Effective January 1, 2022, Senate Bill 0166 (CH0299)/House Bill 0512 (CH0230) (2020) Drugs and Devices – Electronic Prescriptions – Controlled Dangerous Substances requires licensed health care providers to electronically prescribe prescriptions for controlled dangerous substances. The Health General Article, 21-220(C) provides exceptions to this requirement, and the requirement to request a waiver. A health care practitioner who is unable to electronically transmit prescriptions for controlled dangerous substance drugs may request a waiver from the electronic prescribing requirement under certain circumstances. A waiver, if granted, may not exceed one year.
A pharmacist may continue to accept handwritten prescriptions. This bill allowed for a waiver and multiple exceptions. Many of the exceptions would be difficult for a pharmacist to verify. Therefore, the bill stated that a pharmacy is not required to verify the ability of a provider to issue non-electronic prescriptions. While a pharmacist does not need to verify that the prescription is an authorized exception to the electronic prescription requirement, the pharmacist must still follow due diligence requirements to ensure the prescription is written for a legitimate medical purpose.
If you are a provider that is unable to issue controlled substance prescriptions electronically, please visit the OCSA website. On the left panel, select the “Electronic Prescribing Waiver Request". Please read the page completely to verify the need for a waiver. If you meet the criteria for one of the listed exceptions, you do not need to apply for a waiver or issue controlled substance prescriptions electronically. If you are required to apply for a waiver, click the link at the bottom of the page to submit an application for a waiver.
Maryland Implicit Bias Training Requirement: Definition and Resources
Pursuant to MD. Code Ann., Health Occ. § 1-225, all health practitioners must attest to completing an implicit bias training program approved by the Cultural and Linguistic Health Care Professional Competency Program on their first license renewal after April 1, 2022.
