MO Board of Pharmacy COVID-19 Update
Missouri DCI sent this bulletin at 03/31/2021 03:53 PM CDT|
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STATE OF EMERGENCY EXTENSION
Governor Parson has extended the COVID-19 State of Emergency until August 31, 2021 (see Executive Order 21-07). At this time, all previously issued Board waivers have been continued until August 31st. A full list of approved waivers are available on the Board’s COVID-19 webpage. Note: The Governor’s Office is reviewing all state agency COVID-19 waivers; Approved pharmacy waivers may change in the future.
RECENT DHHS PREP ACT CHANGES
On March 11, 2021, the U.S. Department of Health and Human Services (DHHS) issued their 7th amendment to their emergency PREP Act Declaration.
- DHHS’ amended PREP Act Declaration allows inactive, expired, and lapsed pharmacists to administer COVID-19 vaccines, if the individual’s pharmacist license was previously active in a U.S. state/territory within the last five (5) years. No additional Board licensure or notification is required under the federal Declaration. Inactive, expired and lapsed pharmacists should review DHHS’ emergency Declaration to ensure compliance (additional DHSS restrictions/requirements apply). DHHS’ authorization only applies to COVID-19 vaccines. The Board is requesting that inactive, expired and lapsed pharmacists administering COVID-19 vaccines in Missouri file an Emergency Practice Notification form with the Board (available on the Board’s website).
- Non-resident pharmacists, intern pharmacists, and pharmacy technicians who are not licensed in Missouri can provide COVID-19 vaccines under DHHS’ emergency Declaration, “in association with a COVID-19 vaccination effort by a federal, State, local Tribal or territorial authority, or by an institution in the State in which the COVID-19 vaccine covered countermeasure is administered.” The Board is requesting that non-resident pharmacists, intern pharmacists, and pharmacy technicians practicing in Missouri pursuant to the emergency Declaration file an Emergency Practice Notification form with the Board (available on the Board’s website).
COVID-19 VACCINE TRAINING
Pharmacists, intern pharmacists and pharmacy technicians administering COVID-19 vaccines under DHHS’ emergency PREP Act Declaration, should comply with the training requirements identified in DHHS’ declaration (see Attached DHHS Chart). Training questions should be addressed to DHHS. Questions regarding the state standing orders should be addressed to the Missouri Dept. of Health.
DHHS COVID-19 Vaccine Chart.pdf
AMENDED STATE STANDING ORDERS
The Missouri Department of Health and Senior Services (DHSS) has amended the statewide standing orders for COVID-19 vaccines, effective March 22, 2021. The amended orders are available on DHSS’ website at: https://health.mo.gov/living/healthcondiseases/communicable/novel-coronavirus/statewide-orders.php
USE OF OTHER HEALTHCARE PROFESSIONALS FOR COVID-19 VACCINES
The Board has been asked if pharmacies can use non-pharmacy healthcare providers to provide COVID-19 vaccine to patients.
Missouri law does not prohibit pharmacies from using non-pharmacy healthcare providers to provide COVID-19 vaccines (e.g., nurses). Licensees should verify that the non-pharmacy healthcare provider is authorized to administer COVID-19 vaccines either under the provider’s scope of practice, DHHS’ emergency Declaration, or the statewide COVID-19 standing orders.
- The pharmacy may use their pharmacy software system to conduct billing/vaccine reporting for administrations provided by a non-pharmacy healthcare provider. If a prescription number is assigned to the billing/reporting record, the computer record and any hard copy or image should clearly indicate that it is a billing record and not a prescription record.
- Non-pharmacy healthcare providers administering COVID-19 vaccines do not have to be registered as pharmacy technicians, unless the non-pharmacy healthcare provider will have independent access to drug inventory (e.g., without a pharmacist present and supervising).
PROTOCOLS?
The Board has received multiple questions asking if pharmacists need to have a physician protocol to administer COVID-19 vaccines. Pharmacists administering COVID-19 vaccines under DHHS’ emergency Declaration or under the statewide standing orders do not need a physician protocol. Pharmacists may choose to use a protocol, but a protocol is not required.

