Board of Pharmacy Response to Governor’s Proclamation

On August 21, 2020, Governor Kim Reynolds issued a new Proclamation of Disaster Emergency. In this Proclamation, Governor Reynolds extends the regulatory relief which applies to the practice of pharmacy. The suspension of regulatory provisions identified in the Proclamation is effective through September 20, 2020, unless otherwise extended or terminated by Governor Reynolds. 

In Section One, Governor Reynolds continues to encourage the protection of vulnerable Iowans, including those older than 65 and those with preexisting conditions, through limiting their visits to businesses and other in-person interactions. The Board encourages pharmacies to continue implementing procedures to ensure vulnerable Iowans are protected.

In Section Sixty-Six, Governor Reynolds extends the temporary suspension of Iowa Code § 155A.32 to allow a pharmacist to engage in therapeutic drug product substitution pursuant to Board guidance. The Board directs pharmacists to the guidance provided on April 6, 2020.

In Section Seventy-Two, Governor Reynolds extends the temporary suspension of administrative rules which prohibit the practice of a pharmacist or technician trainee after the license or registration has expired. 

• Through September 20, 2020, a pharmacist whose license has been inactive or expired for no more than 5 years may continue to engage in the practice of pharmacy with the inactive or lapsed license. Be reminded that the Governor’s action does not permit pharmacists whose licenses have been voluntarily surrendered or revoked to return to practice. A pharmacist returning to practice pursuant to this authorization does not need to contact the Board.

• Technician Trainees whose registration expires between March 18, 2020 and August 31, 2020 and who are unable to sit for the national technician certification exam are authorized to continue practicing as a technician trainee until such time as the trainee is able to take the national certification exam. 

  • The Board has been made aware that some testing sites have been reopened, at limited capacity, and that PTCB has initiated online testing options that include a remote proctor. 

  • The Board expects that technician trainees will make every effort to get scheduled for the exam at the earliest available testing site within 100 miles, including via remote proctoring. Technician trainees whose registration will expire through August 31, 2020 and who are unable to schedule an exam, including via online proctoring, must notify the Board of the barrier(s) to testing by email to dzenisa.duric@iowa.gov.

  • As long as a technician is able to demonstrate a barrier to test, the Board will exercise enforcement discretion and allow technicians subject to the Governor’s Proclamations and Board guidance to continue working as a technician. 

  • In the event that a technician fails a national certification exam after the technician’s registration has expired, the technician will not be authorized to perform the duties of a technician until the individual successfully passes the exam and registers with the Board as a certified pharmacy technician.

In Section Seventy-Three, Governor Reynolds extends the temporary suspension of administrative rules which require continuing education as a condition of license renewal when such requirements cannot be satisfied due to the disaster emergency. 

In Section Seventy-Four, Governor Reynolds extends the temporary suspension of administrative rules which apply to license and registration renewal during the  period of this disaster emergency. Licensees or registrants whose license or registration expires during this emergency period (March 22 through September 20) may continue to practice after the license or registration has expired if they are unable to renew the license or registration. The Board is continuing to process license and registration renewals and licensees and registrants are encouraged to utilize the Board’s online services for renewal. The Board will not assess late penalty fees for licenses and registrations which expire between March 22 and September 20 if they are renewed (or a renewal application is received in the Board office) within 30 days after the Proclamation expires or is terminated.

In Section Seventy-Five, Governor Reynolds extends the temporary suspension of administrative rules which require the completion of clinical, practical, or internship experience as a condition of obtaining pharmacist licensure. As noted in previous Board guidance in response to prior Proclamations, Iowa-registered pharmacist-interns who were unable to complete the college-based clinical program due solely to the COVID-19 pandemic will continue to be eligible for licensure, if all other licensure requirements are met.

In Section Seventy-Six, Governor Reynolds extends the temporary suspension of administrative rules which require the completion of a criminal history background check prior to licensure. As noted in previous Board guidance relating to deferred background checks, the Board will continue to process license and registration applications which are otherwise complete and will defer the background check until the expiration of the disaster emergency, currently scheduled to expire on September 20, 2020. Licensees and registrants will be provided with a fingerprint packet to complete and return within 60 days of the expiration of the disaster emergency. Failure to timely return the completed fingerprint packet may result in license or registration rescission. Failure to provide truthful information relating to criminal or disciplinary action history on the license application may result in disciplinary action, including license or registration revocation.

In Section Seventy-Seven, Governor Reynolds extends the temporary suspension of administrative rules which prohibit a pharmacist who is licensed in another state from engaging in the practice of pharmacy in Iowa prior to obtaining an Iowa pharmacist license due to requirements which are not able to be satisfied due to this disaster emergency.

• A pharmacist who is actively licensed in another state and who wishes to practice pharmacy in Iowa during this emergency period without first obtaining an Iowa pharmacist license: shall obtain temporary authorization through the National Association of Boards of Pharmacy Passport Program. Authorization to practice pharmacy in Iowa via the NABP Passport Program is limited to the duration of the Governor’s disaster emergency declaration (currently set to expire September 20, 2020).

• A pharmacist who is seeking to obtain an Iowa pharmacist license via license transfer: shall complete the National Association of Boards of Pharmacy License Transfer Application. Upon submission of a completed application, the Board may issue a pharmacist license and will temporarily defer the criminal history background check and completion of the MPJE-Iowa edition examination until the expiration of the emergency disaster (currently set to expire September 20, 2020).

  • Upon the expiration of the disaster emergency, the Board will provide a licensee who is subject to these provisions with a fingerprint packet to complete the criminal history background check which the licensee shall return within 60 days of the expiration of the disaster emergency.

  • Upon expiration of the disaster emergency, the licensee shall successfully complete the MPJE-Iowa edition examination within 120 days of the expiration of the disaster emergency. The Board will continue to monitor the availability of testing opportunities and may extend this deadline if warranted.

  • Failure of the licensee to submit the completed fingerprint packet or successfully complete the MPJE-Iowa edition examination within the prescribed time may result in license rescission.

  • Failure to provide truthful information relating to criminal or disciplinary action history on the license application may result in disciplinary action, including license or registration revocation.

In Section Seventy-Eight, Governor Reynolds extends the temporary suspension of administrative rules which require the completion of the background check and required examinations prior to issuance of an emergency pharmacist license to a recently graduated pharmacist-intern pursuant to Board guidance issued May 12, 2020.

In Section Eighty-Five, Governor Reynolds extends the suspension of administrative rules which require a pharmacist licensure candidate to complete all examination components within one year from the date the candidate passed the initial component. Board licensing staff will continue to identify licensure candidates who have completed one component and monitor examination completion during the emergency period.

The Board will continue to monitor the situation as additional information is available and make necessary adjustments to provide pharmacy professionals with the guidance needed to navigate the current public health emergency.