- Drug Control Program
To: Massachusetts Licensed Pharmacists, Primary Care Practitioners, and
Reproductive Health Care Practitioners
From: James G. Lavery, Director, Bureau of Health Professions Licensure
Date: November 1, 2023
Re: Pharmacist prescribing and dispensing of hormonal contraceptive patches and self-administered oral hormonal contraceptives.
M.G.L. c. 94C, § 19F, as implemented by 105 CMR 700.004(B)(15), authorizes Massachusetts-licensed pharmacists to prescribe and dispense hormonal contraceptive patches and self-administered oral hormonal contraceptives. Although there is no requirement to prescribe contraceptive products, the purpose of this circular letter is to provide guidance to those pharmacists who choose to do so. A pharmacist is not required to obtain a Massachusetts Controlled Substance Registration (MCSR) in order to prescribe these medications.
A pharmacist may prescribe FDA-approved hormonal contraceptive patches and self-administered oral hormonal contraceptives (regardless of whether the product is over-the-counter or prescription-only) to patients of any age, provided that:
- Evidence that an approved training program has been completed is readily available (see below);
- Prior to prescribing, the patient completes a pharmacy-provided self-screening risk assessment tool based on the current United States Medical Eligibility Criteria for Contraceptive Use;
- Patient counseling and education are conducted on the proper use, risks, and side effects of the selected product;
- The FDA-approved hormonal contraceptive patch or self-administered oral hormonal contraceptive is prescribed only in accordance with the manufacturer’s approved labeling;
- A valid prescription for up to, but not more than, a 12-month supply is generated;
- The patient is provided a written record of the product that has been prescribed and dispensed;
- The product is dispensed as soon as practicable after the pharmacist issues the prescription;
- All activities related to the prescribing and dispensing of hormonal contraceptive products are documented and readily available;
- The patient is referred to, or advised to consult with, a primary care practitioner or reproductive health care practitioner upon the prescribing and dispensing of the selected product;
- If the patient provides consent, the pharmacist should notify the patient's primary care practitioner or reproductive health care practitioner that the pharmacist has prescribed and dispensed a hormonal contraceptive product;
- A clinical visit with a primary care practitioner or reproductive health care practitioner does not preclude a pharmacist from issuing prescriptions with refills; and
- The pharmacist obtains a National Provider Identifier (NPI).
Pharmacists are encouraged to enroll in MassHealth for the limited purpose of ordering and referring services covered by MassHealth in order to allow for MassHealth reimbursement for pharmacists’ prescriptions of hormonal contraceptives to MassHealth enrollees.
A scheduled appointment with the pharmacist shall not be required for the purpose of the prescribing or dispensing of a hormonal contraceptive patch or self-administered oral hormonal contraceptive.
In order to prescribe these medications, a pharmacist must participate in a training program that is accredited by the American Council on Pharmaceutical Education (ACPE) or Interprofessional Continuing Education (IPCE) that addresses the objectives outlined below. One such training program may be found here.
1. Describe the mechanism of action and differentiate between types of hormonal contraceptive products.
2. Assess patient eligibility for hormonal contraceptive use and recommended products.
3. Educate patients on proper use, risks, and benefits of various contraceptive products.
4. Educate patients on strategies to reduce risk of sexually transmitted infections.
5. Document patient care visits related to hormonal contraceptive products.
A pharmacist must maintain continued competency regarding current guidelines. Continuing education programs are one way to maintain competency.
Please direct any questions or concerns to the Drug Control Program: firstname.lastname@example.org