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The chart below includes NASPA’s compilation of state actions regarding testing. This is a work in progress.
Please Note: Several states allow pharmacists to order and/or administer COVID-19 tests under pre-existing scope of practice authority. The information below only includes specific authority provided via executive orders or other emergency orders/waivers. It does not cover pre-existing authority. Please check with your state association and state board of pharmacy for details on pre-existing authority.
The following are other relevant links:
- HHS Releases Statement on Pharmacist Testing Authority Under the PREP Act
- HHS Announces New Laboratory Data Reporting Guidance for COVID-19 Testing/ New CDC Guidance on the Way
|Alabama||4/16/2020||Pharmacists may now take part in COVID-19 testing that involves the use of point-of-care tests that have an Emergency Use Authorization approved by the FDA. As of April 16, 2020, none of the serology tests approved by the FDA are considered to be point-of-care tests.
Pharmacies are reminded that in order to do any CLIA-waived testing they also must have a CLIA Certificate of Waiver. That has been a long-standing requirement.
Testing must be conducted in compliance with CDC recommendations.
Only pharmacists, and pharmacist interns under the immediate supervision of a pharmacist, can perform the allowed tests. Self-administered swabbing by patient is optimal to reduce opportunity for exposure.
Pharmacy technicians can only be involved in completing required paperwork, including the required reporting.
Before they can perform tests, pharmacists and pharmacist interns must have appropriate training.
Pharmacies must also provide staff with appropriate personal protective equipment.
Testing must be conducted outside the physical area of the pharmacy (i.e. parking lot, separate closed door exam room, etc.)
The Alabama Department of Public Health (ADPH) has an information page for Healthcare Providers on reporting requirements. Pharmacists conducting COVID-19 tests are subject to the reporting requirements specified on that Web page.
|Alaska||4/15/2020||Licensed pharmacists who order or administer FDA-authorized COVID-19 testing under the HHS guidance should apply Alaska’s latest testing priorities. The Alaska PHN testing priorities can be found here:
http://dhss.alaska.gov/dph/Epi/Pages/phan/default.aspx. This guidance is updated as the state’s situation evolves.
|California||May 12||Pursuant to Executive Order N-39-20, the Director waives Business and Professions Code section 4051, subdivision (b) and section 4052, subdivision (a)(12), to the extent those provisions would otherwise prohibit pharmacists from ordering or otherwise authorizing tests for the presence of the virus SARS-CoV-2 (“COVID 19 tests”) in individual patients, and without coordination with the patient’s primary care provider or diagnosing prescriber. Those provisions are also waived to the extent they would otherwise prohibit pharmacists from physically collecting (such as through the use of nasopharyngeal swabs or other means) specimens necessary to perform such COVID19 tests. This waiver does not authorize the analysis or testing of samples collected, to the extent such analysis or testing is not otherwise authorized by law. The waiver is subject to the following conditions: The test is authorized by the United States Food and Drug Administration (FDA) and is processed in a public health, commercial, or clinical laboratory pursuant to state and federal rules; and, The pharmacist is competent and trained to collect the specimen necessary to perform the test, and the specimen is collected consistent with the provisions of an Emergency Use Authorization issued by the FDA. Pharmacists acting within the scope of this waiver may order and collect specimens for authorized COVID-19 tests. This order terminates 60 days from the date of the order, unless further extended.|
|Colorado||3/25/2020||In addition to foregoing existing statutory authority for emergency assistance by healthcare professionals, and in light of the Governor’s directive to take action to expand the healthcare workforce so as to address the Disaster Emergency, DORA has identified the following specific statutes and regulations as preventing, hindering, or delaying necessary action in coping with the Disaster Emergency identified in the Governor’s Executive Order 20-003 and which therefore are temporarily suspended pursuant to § 24-33.5-704(7)(a), C.R.S.:
Suspension of Pharmacy Board Rule 6.00.30, which sets forth the qualifications for pharmacists to engage in drug therapy management and thereby restricts pharmacists from conducting screening tests for the Coronavirus, so as to ensure that pharmacists may conduct screening tests in pharmacies and other testing centers.
|Connecticut||May 7||Notwithstanding any provision of the Connecticut General Statutes or Regulations of Connecticut State Agencies, Section 19a-36-D29 of the Regulations of Connecticut State Agencies is modified to provide that pharmacists licensed pursuant to Chapter 400j of the Connecticut General Statutes are expressly permitted to order COVID-19 diagnostic tests consistent with Clinical Laboratory Improvement Amendments (CLIA), including serology tests that do not require venipuncture, that the Food and Drug Administration (FDA) has authorized. Pharmacists shall report all testing activities and any other information required by DPH in accordance with applicable orders, guidelines or other directives issued by the Commissioner of Public Health or her designees. Unless otherwise specified herein, this order shall take effect immediately and remain in effect for the duration of the public health and civil preparedness emergency, unless earlier modified, extended or terminated.|
|District of Columbia|
|Florida||4/24/2020||Governor Ron DeSantis announced at a press conference that he was requesting the state’s surgeon general, Dr. Scott Rivkees, under his emergency authority, work to allow Florida licensed pharmacists to order and administer COVID-19 testing.|
|Illinois||4/10/2020||“1. An Illinois licensed pharmacist’s scope of practice under the Pharmacy Practice Act is expanded to screen patients, order, administer, read, and report the findings of tests waived under the Clinical Laboratory Improvement Amendments of 1988 (CLIA) for COVID-19. Such licensees must be appropriately trained to administer COVID-19 tests and are subject to all provisions of the Pharmacy Practice Act and its Rules, as applicable, relating to the standards of care. Such licensees are limited to working in (a) a CLIA-certified lab or a facility with a CLIA certificate of waiver; (b) in a state-licensed long-term care facility, state regulated hospital, or federally qualified health center (FQHC); or (c) under the direction of the Illinois Emergency Management Agency (IEMA) or the Department of Public Health (DPH).”|
|Iowa||4/23/2020||“Pursuant to the Public Readiness and Emergency Preparedness Act (PREP Act) and Guidance issued by the United States Department of Health and Human Services, Office of the Assistant Secretary for Health on April 8, 2020, licensed pharmacists are authorized to “order and administer COVID-19 tests, including serology tests, that the Food and Drug Administration (FDA) has authorized.” The authority of pharmacists to order and administer COVID-19 tests extends only through the federal government’s designation of the public health disaster. Pharmacist administration of COVID-19 testing beyond the federal public health disaster must be pursuant to an order by a licensed health care practitioner who is authorized to prescribe. The Board provides this Guidance for pharmacists who engage in COVID-19 testing.”
(Guidance is extensive; please click link to the left for complete details.)
|Kentucky||4/24/2020||“1. During the State of Emergency under Executive Order 2020-215, the “practice of pharmacy” shall also include the initiating, ordering, and administering of COVID-19 tests under the following conditions:
a. the pharmacists has received the appropriate education and training on COVID-19 testing;
b. the ordering and administering of COVID-19 tests are performed at a pharmacy which holds an active CLIA certificate of waiver, if such waiver is required by Centers for Medicare & Medicaid Services (CMS) and/or the Kentucky Cabinet for Health and Family Services (CHFS);
c. the ordering and administering of COVID-19 tests are performed according to testing priorities set forth by the Kentucky Department for Public Health;
d. the pharmacist orders and administers COVID-19 tests, including serology tests, authorized by the US Food and Drug Administration; and
e. policies and procedures are in place to address colection, storage and transport of samples as appropriate to testing performed.”
|Louisiana||4/15/2020||“Effective 11:59 p.m. on April 15, 2020, and continuing through the declared public health emergency in Louisiana, licensed pharmacists shall be permitted to order FDA-authorized COVID-19 laboratory tests in Louisiana.
Further, the Louisiana Board of Pharmacy has previously ruled that licensed pharmacists can perform moderately complex tests; the screening, administration, and reporting related to the COVID-19 testing would be covered under that previous ruling by the Louisiana Board of Pharmacy.”
|Maine||4/17/2020||Can pharmacies / pharmacists order and administer COVID-19 tests?
Yes. Please refer to U.S. DHHS April 8, 2020 Guidance for Licensed Pharmacists, COVID-19 Testing, and Immunity under the PREP Act.
|Maryland||5/19/2020||a. A Licensed Pharmacist may:
i. order COVID-19 Tests for patients, in accordance with CDC Screening Guidance and all Secretary’s Directives (defined below); and
ii. collect or supervise the collection of specimens from patients for the purpose of COVID-19 Testing, in accordance with all Secretary’s Directives.b. A laboratory may perform a COVID-19 Test based on the written or electronic authorization of a Licensed Pharmacist.
|Minnesota||4/16/2020||Pharmacists may now be involved in certain types of COVID-19 testing. The FDA recently clarified that, when it grants an Emergency Use Authorization (EUA) for a point-of care test, the test is deemed to be CLIA-waived. That is an important clarification because, pursuant to Minn. Stats. §151.01, subd. 27, pharmacists can only be involved in CLIA-waived tests. Pharmacists may now take part in COVID-19 testing that involves the use of point-of-care tests that have an Emergency Use Authorization approved by the FDA.
Pharmacies are reminded that in order to do any CLIA-waived testing they must have a CLIA Certificate of Waiver. That has been a long-standing requirement.
Only pharmacists, and pharmacist interns under the immediate supervision of a pharmacist, can perform the allowed tests. Pharmacy technicians can only be involved in completing required paperwork, including the required reporting to MDH, as noted below. Before they can perform tests, pharmacists and pharmacist interns must have appropriate training. Pharmacies must also provide staff with appropriate personal protective equipment.
The Minnesota Department of Health (MDH) has a page named Reporting COVID-19/SARSCoV-2 Infections. Pharmacists conducting COVID-19 tests are subject to the reporting requirements specified on that Web page. Both positive and negative tests must be reported. A reporting form is available on the MDH reporting Web page.
|Mississippi||HHS recently authorized pharmacists to order and administer COVID-19 tests. Pharmacies will need a CLIA Certificate of Waiver from the Mississippi State Department of Health (MSDH) to participate in testing. It will be up to the pharmacy and the pharmacist-in-charge to deem all appropriate training for the testing to be completed. For anyone interested in conducting COVID-19 testing, please stay alert for any changes made by the FDA, HHS, MSDH, or MSBOP. Positive test results must be reported to MSDH with patient information; negative results must be reported daily in aggregate (number) without patient information.|
|Missouri||4/13/2020||To protect patients, pharmacists ordering/administering COVID-19 testing pursuant to HHS’ authorization should be appropriately educated/trained to perform the services provided and comply with professional standards of practice. Permit holders should also ensure testing services provided at or on behalf of the pharmacy comply with
all applicable law and practice standards. Additionally:
• The Board recommends documenting the patient care services provided. Patients should be referred to their primary care provider for additional treatment/medical care when appropriate.
• Pursuant to § 338.035.4, intern pharmacists may assist with COVID-19 testing under the direct supervision of a pharmacist.
• COVID-19 testing is a non-dispensing function that can be performed outside of a licensed pharmacy pursuant to 20 CSR 2220-6.055. A Board medication therapeutic services (MTS) certificate is not required to order/administer COVID-19 testing pursuant to DHHS’ authorization.
To ensure patient safety, licensees administering testing should take necessary precautions to ensure proper sanitation and prevent unnecessary exposure. Licensees and permit holders should review the CDC’s “Considerations for Pharmacies During the COVID-19 Pandemic” guidance document for cautionary measures to help minimize risk to patients and pharmacy staff.
Licensees should consult with legal counsel to ensure compliance with applicable state and federal laws, including, the Clinical Laboratory Improvement Amendments of 1988 (CLIA). At this time, the federal government has not waived CLIA requirements.
|Nevada||3/17/2020||For the purposes of this partial waiver, “testing” means nasal swab, throat, or any other approved and effective testing for COVID-19.
Pharmacists are permitted to oversee, perform, and/or handle testing for COVID-19 in accordance with the following. Intern pharmacists or pharmaceutical technicians are permitted to perform and/or handle testing for COVID-19 in accordance with the following:
• The pharmacist must be registered with the Board, either employed or a contract employee of a Nevada-licensed pharmacy, who oversees, performs, or handles the testing
for COVID-19 to be conveyed to the laboratory for analysis.
• The intern pharmacist or pharmaceutical technician must be registered with the Board, either employed or a contract employee of a Nevada-licensed pharmacy, who either
performs or handles the testing for COVID-19 to be conveyed to the laboratory for analysis.
• The pharmacist, intern pharmacist, and pharmaceutical technician may perform or handle the test and must be trained on the pharmacy’s policies and procedures relating to the test and/or handling of the test.
• The pharmacy must maintain or have access to a readily retrievable record of the name and registration number of each pharmacist, pharmacist intern, and pharmaceutical
technician performing the test.
• Each test record must comply with all record-keeping requirements for pharmacies, along with any State and Federal Laws.
This guidance is in effect until May 29, 2020.
|New Hampshire||5/21/2020||1. During the State of Emergency, the “practice of pharmacy” as defined in RSA Chapter 318 shall include the initiating, ordering, administering, and analyzing of FDA approved Emergency Use Authorization SARS-CoV-2 (COVID-19) point-of-care diagnostic kits (COVID-19 tests or test kits) to detect SARS-CoV-2 or its antibodies. 2. Pharmacists, licensed pursuant to RSA Chapter 318 and the administrative rules promulgated thereunder, may initiate, order, administer, and analyze the COVID-19 test kits under the following conditions: a. The pharmacist has received the adequate education and training to initiate, order, administer, and analyze COVID-19 test kits; b. The COVID-19 tests are administered at a pharmacy that holds the appropriate clinical laboratory improvement admendments (CLIA) certificate and a New Hampshire laboratory license issued by the Health Facilities Administration of the New Hampshire Department of Health and Human Services (DHHS). Alternatively, tests may be administered at a pharmacy with a DHHS waiver, pursuant to DHHS’s authority to licensure requirements when it deems appropriate health and safety standards are met; and c. The pharmacy creates and implements policies and procedures to address the collection, storage, transport, and analysis of samples collected as a result of administering and analyzing COVID-19 test kits. Such policies and procedures shall be in line with the manufacturer’s instructions and supplemented as needed.|
|New Jersey||May 13||Notwithstanding any provision of N.J.S.A. 45:14-41, N.J.S.A. 45:14-61, N.J.S.A. 45:14-62, N.J.A.C. 13:39-13.1 to -13.9, or N.J.A.C. 13:35-6.27(k), licensed pharmacists are authorized to do the following, without entering into a collaborative practice agreement or protocol and without a prescription, standing order, or supervision from a physician, subject to the conditions and limitations in paragraph 2 of this Order, and to the extent permitted by federal law: a. Order testing for the SARs-CoV-2 virus, the virus that causes COVID-19 (COVID-19), or its antibodies; b. Collect specimens to test for COVID-19 or its antibodies, or oversee or supervise such collection, at or immediately outside of a registered pharmacy; c. Perform tests for COVID-19 or its antibodies at or immediately outside of a registered pharmacy; d. Interpret and analyze COVID-19 or COVID-19 antibody test results and provide the results to patients; and e. Collect, analyze and monitor patient data relating to COVID-19 or COVID-19 antibody testing, subject to the conditions and limitations in paragraph 3 of this Order. (Guidance is extensive; please click link to the left for complete details.)|
|New Mexico||May||In accordance with the HHS Guidance, pharmacists may administer FDA-authorized tests that can be performed in a patient care setting operating under a CLIA (Clinical Laboratory Improvement Amendments) Certificate of Waiver. (Guidance is extensive; please click link to the left for complete details.)|
|New York||4/25/2020||“… I hereby temporarily suspend or modify, for the period from the date of this Executive Order through May 25, 2020 the following:
Section 6801 of the Education Law, to the extent necessary to authorize licensed pharmacists to order COVID-19 tests, approved by the Food and Drug Administration (FDA), to detect SARS-CoV-2 or its antibodies, and to administer COVID-19 tests subject to certificate of waiver requirements pursuant to the federal clinical laboratory improvement act of nineteen hundred eighty-eight, in patients suspected of a COVID-19 infection, or suspected of having recovered from COVID-19 infection, subject to completion of appropriate training developed by the Department of Health;
Subdivision (6) of section 571 of the Public Health Law, to the extent necessary to permit licensed pharmacists to be designated as a qualified healthcare professional for the purpose of directing a limited service laboratory, pursuant to subdivision 579(3) of the Public Health Law, to test patients suspected of a COVID-19 infection or its antibodies provided that such test is FDA-approved and waived for use in a limited service laboratory; …”
|North Carolina||4/9/2020||Does North Carolina law prohibit a pharmacist from ordering and administering COVID-19 tests as authorized by HHS?
No. As long reported by Board staff, North Carolina law does not prevent pharmacists practicing from administering CLIA-waived tests. A COVID-19 test that has received an emergency use authorization (EUA) for use by health care providers at the point of care is deemed to be a CLIA-waived test and “for the duration of the emergency declaration, such tests can be performed in a patient care setting that is qualified to have the test performed there as a result of operating under a CLIA Certificate of Waiver or Certificate of Compliance.”
Critical to appropriate management of the pandemic is consistency in the who, what, when, where, and how of testing among health care providers. Pharmacists must follow NC DHHS guidance and policies, and should frequently check NC DHHS’ COVID-19 resource page for updates.
Pharmacists must report COVID-19 test results to the patient and the patient’s health care provider. Board staff will update this FAQ with any additional reporting requirements from DHHS or other public health authorities.
As is true for any health care worker, pharmacists administering COVID-19 tests must use “appropriate combinations of engineering and administrative controls, safe work practices, and personal protective equipment (PPE) to prevent worker exposures.” Furthermore, pharmacists-managers are reminded of their authority and responsibility to manage infection transmission risk in a pharmacy.
|North Dakota||3/21/2020||The authority to administer tests in North Dakota Century Code 43-15-25.3 is hereby extended to allow licensed pharmacists to administer COVID-19 testing, under guidance from the North Dakota Department of Health.|
|Ohio||5/27/2020||“A pharmacist, pharmacy intern, and certified pharmacy technician may administer FDA-authorized COVID-19 tests, under the following conditions.”
(Guidance is extensive; please click link to the left for complete details.)
|Oregon||4/22/2020||Per ORS 689.661, it is within a registered Oregon pharmacist’s scope to perform point-of-care CLIA-waived tests. Please refer to HHS and OHA Laboratory Regulation Division for regulations and requirements a pharmacist must follow to perform CLIA-waived COVID-19 tests. It is essential that the pharmacy has written policies and procedures and retains documentation of personnel training associated with lab tests. Further, it is expected that pharmacy employers implement infection control practices in their pharmacies to protect workers and patients, in accordance with the state’s social/physical distancing guidelines (see “Safe Work Environment and Routine Pharmacy Services” in OBOP’s 4/8/2020 update).|
|Pennsylvania||4/13/2020||To aid in the COVID-19 response effort, it would be helpful to allow pharmacists to administer Point-of-Care testing, e.g., strep throat and other diagnostic tests. Moreover, on April 8, 2020, the U.S. Department of Health and Human Services released critical guidance that authorizes licensed pharmacists to order and administer COVID-19 tests including serology tests.
There is nothing in the Pharmacy Act or the Board’s regulations that prohibits pharmacists from ordering and administering tests. A pharmacist is a healthcare practitioner who may administer tests if administration of the test is delegated by a medical doctor. Therefore, for the purposes of preparing for and mitigating any effect of COVID-19 testing, licensed pharmacy practitioners are granted the requisite authority needed to carry out end-to-end COVID-19 testing, including but not limited to: ordering; testing; and communicating results. This waiver/suspension shall end 90 days after the emergency has been terminated unless rescinded, superseded, amended or revised by additional orders of the Governor or the Department.
This request does not seek to exempt, waive or suspend any requirements of the Clinical Laboratory Act and its corresponding regulations, the Clinical Laboratory Improvement Amendments of 1988 and its corresponding regulations, and may not be interpreted as exempting, waiving, or suspending those requirements. Any person or entity conducting clinical laboratory testing, including Point-of-Care testing and COVID19 testing, must be authorized by the Pennsylvania Department of Health and the Centers for Medicare & Medicaid Services (CMS) to conduct such testing.
|U.S. Virgin Islands|
|Vermont||5/21/2020||Pursuant to Executive Order 01-20, 15-16, the Commissioner of Health and the Secretary of State authorize Vermont pharmacists to order and administer COVID-19 tests approved by FDA for pharmacy-based sample collection or administration. (Guidance is extensive; please click link to the left for complete details.)|
|Virginia||5/4/2020||Pharmacists, along with pharmacy technicians and pharmacy interns under the supervision of a pharmacist may perform CLIA-waived tests. Per CLIA requirements, training for how to collect the sample and perform the test must be documented. If the pharmacy is only collecting specimen samples and sending the samples to a laboratory for performing the test, then the pharmacy is not required to obtain a CLIA Certificate of Waiver. Proper training for collecting the sample or overseeing the patient’s self-collection is necessary to ensure validity of the process impacting the accuracy of test results and mitigating potential exposure to the virus.|
|Washington||4/24/2020||As part of its business meeting on April 24, 2020, the Pharmacy Quality Assurance Commission (PQAC) clarified some of the following as it relates to Washington licensed pharmacists ordering, administering and reporting results of COVID-19 testing to patients: Screening for patients receiving COVID-19 tests – A pharmacist or pharmacy intern, under the supervision of a pharmacist, may conduct this screening. It is not within the scope of practice for a Pharmacy Technician to perform discretionary functions. A Pharmacy Technician may only perform screening elements to the extent that could be described as non-discretionary function(s). If the screening includes any form of discretionary decision-making, these decisions must be reserved to the pharmacist or pharmacy intern. Pharmacy assistants cannot conduct screening. Ordering COVID-19 tests – PQAC will not take enforcement action against pharmacists who order COVID-19 tests consistent with the “Guidance for Licensed Pharmacists, COVID-19 Testing, and Immunity under the PREP Act” issued by the U.S. Department of Health and Human Services on April 8, 2020. PQAC will be maintaining this position until it is withdrawn at an open public meeting or Governor Jay Inslee issues a proclamation terminating the state of emergency declared by Proclamation 20-05 as amended. Administering COVID-19 tests – Pharmacists may administer COVID-19 tests. Reporting COVID-19 test results- Pharmacists may not diagnose a patient with COVID-19, unless the diagnosis is permitted under the terms of a collaborative drug therapy agreement (CDTA). In the absence of a CDTA, if a pharmacist communicates the COVID-19 test results, the pharmacist shall only provide the results of the COVID-19 test and recommend the patient contact their primary health care provider.|
|West Virginia||5/21/2020||The long standing position of the WV Board of Pharmacy is that the performance of CLIA-waived tests is within the scope of the practice of pharmacist care provided they are administered in accordance with the FDA’s CLIA requirements. Pharmacists, along with pharmacy interns under the supervision of a pharmacist, may perform CLIA-waived tests. Training for how to collect the sample and perform the specific CLIA-waived test must be documented per CLIA requirements. (Guidance is extensive; please click link to the left for complete details.)|
|Wisconsin||5/12/2020||Pharmacists may order and administer CLIA-waived tests. They may also order tests, including CLIA-waived tests, through a collaborative practice agreement with a physician (Wis. Stat. 450.033). This authority is independent of the COVID-19 public health emergency and therefore, does not require an executive order. The authority will continue when the public health emergency ends.|