Standard of Care Regulatory Model
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The Standard of Care model has three parts.
"Standard of care" is a loaded phrase that carries at least three distinct — but reinforcing — meanings. Each is influential on its own; together, they form a complete model for how a modern, judgment-based pharmacy regulatory system can work.
How regulators discipline practitioners.
Borrowed from tort law: when a pharmacist's conduct is reviewed, the board considers what a reasonably prudent pharmacist with similar education, training, and experience would have done under similar circumstances. If conduct falls short of that standard, the board may discipline. This replaces rigid rule-checking with evidence-based comparison to peer practice.
Why pharmacy should want this: First, it's the same model already used to discipline physicians and nurses — pharmacists shouldn't be treated differently. Second, it's a powerful advocacy strategy: holding pharmacists to the same disciplinary standard as other providers neutralizes one of the loudest objections to expanded scope of practice.
"Same model. Same accountability. Same seat at the table."
How statutes are read.
State pharmacy associations are advocating for statutory language that directs regulators to interpret pharmacy practice acts as permitting any method of care delivery that meets three tests:
- The practice is not expressly prohibited by law.
- It falls within the individual pharmacist's education, training, and experience.
- It is performed within the accepted standard of care a reasonable, prudent practitioner with similar background would provide in a similar setting.
Paired with deregulation, this language ends the "mother-may-I" piecemeal approach to scope expansion — letting pharmacists practice not just at the top of their license, but at the top of their individual clinical ability.
"From asking permission, to exercising judgment."
What pharmacists are authorized to do.
The third meaning is full practice authority — explicit, broad statutory language defining the practice of pharmacy to include prescriptive authority and other clinical functions such as ordering, administering, and interpreting tests, and medication administration.
Technically, this could be achieved through interpretation language plus deregulation alone. But field experience suggests that explicit prescribing language matters — it removes ambiguity for both pharmacists and the public, and signals legislative intent clearly.
This approach is increasingly embraced by both pharmacy advocates and boards of pharmacy. NASPA, with support from McKesson, is helping state pharmacy associations advance it across state lines.
"Practice authority that matches clinical capability."
NASPA’s work developing resources about the standard of care regulatory model and convening the state pharmacy associations to learn from one another and accelerate innovation is made possible with the generous support of McKesson. Thank you!
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