Liz MacMenamin: Regulatory Update (Board of Pharmacy)

The Nevada Board of Pharmacy meet on July 14-15, 2021, via zoom. While the board members are meeting in person, they have decided not to open the meeting room to the public at this time but allow the public to view and comment on zoom platform. The board may be allowing the public access to the meeting room at the meeting in September.
Proposed regulations discussion during workshop on July 15, 2021:

  1. Amendment to NAC 639 – language allows a pharmacist to dispense and sets up a protocol under which a pharmacist may dispense self-administered hormonal contraceptives.

This language sets out the guidelines for a pharmacist who is dispensing the self-administered contraceptives. The language will require 2-hour education course approved by ACPE (Accreditation Council for Pharmacy Education) or American College of Obstetricians and Gynecologists regarding the self-administered contraceptives. Dr. Christina Madison asked the board to consider the current curriculum being taught at Roseman University School of Pharmacy, which is a 6-hour course, as a pharmacist having obtained these required 2 hours.

Industry also asked that the board consider that once the prescription is initiated, any pharmacist may provide the refills even though this pharmacist may not necessarily be certified to initiate this medication. The board was also asked to allow the industry to structure their own risk assessment questionnaire using all the questions that board staff created in the example set out in this language.

Board staff was directed by the board to incorporate the recommended changes and bring these back to the board. The pharmacist must notify the board of their intent to dispense, and the board will create a list of these providers to be added to the board website for patients.

  1. Amendment to NAC 639 – regulation relating to establishing a protocol authorizing pharmacist to prescribe, dispense, and administer drugs to prevent the acquisition of human immunodeficiency virus and perform certain laboratory tests. This language creates a new section in Nevada Administrative Code to implement provisions of Senate Bill 325.

The regulation will require 2 hours of an ACPE approved course regarding treatment of PrEP (Pre-exposure Prophylaxis) and PEP (Post Exposure Prophylaxis) and requires certification be kept and readily retrievable during time of dispensing and for 2 years after dispensing treatment has ended. There was discussion about the fact that recently educated pharmacists have received as much as 6 hours of training for this disease state prior to obtaining their doctorate and thus the two hours would be unnecessary. Board staff agreed to incorporate this into the language.

Staff was also directed to incorporate language which will require only the pharmacist who initiates the first fill be required to prove training. This will not be required for refills. The regulation also requires assessments be done by the initiating pharmacists following the current Centers for Disease Control guidelines. Board staff has also incorporated the necessary counseling guidelines for the product being dispensed.

This language will be sent to LCB (Legislative Council Bureau) and the returned to the board to review all changes being made.

Retail Association will be following this language through the process to final implementation for members. If you have any questions about the language, please contact Liz MacMenamin at or call at 775-720-2528.