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Colorado: A framework for protocols

Key developments, including the creation of an infrastructure for statewide protocols in 2016 and a provider status bill, have expanded pharmacists’ scope of practice.
Mark Hamstra

Colorado has been expanding the scope of practice for pharmacists in the state for several years, including the 2016 creation of an infrastructure for statewide protocols.

“That was really the beginning of independent prescriptive authority for Colorado pharmacists because it created in statute that a statewide protocol could be developed amongst the board of pharmacy, the board of medicine, the board of nursing and the public health department,” said Emily Zadvorny, executive director of the Colorado Pharmacists Society.

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While the statute itself did not spell out what specific protocols pharmacists could perform, it outlined a process for pharmacists to prescribe independently in certain situations. Hormonal contraception and smoking cessation were among the first protocols created, and since then protocols have also been developed for other activities, including HIV pre- and post-exposure prophylaxis (PrEP and PEP). Recently pharmacists gained the ability to prescribe statins for certain high-risk patients.

Hormonal contraception has had the most uptake by pharmacies, Zadvorny said, citing the ability for pharmacists to be reimbursed.

Last year, Colorado pharmacists gained additional authority when the state reconsidered its regulation of the pharmacy practice as part of its “sunset” process that takes place every 10 years. In the update, Colorado modeled some language after an Idaho rule that expanded the scope of pharmacist services, including the ability for pharmacists to prescribe beyond the protocols under certain conditions for patients older than 12 years old. Pharmacists can now prescribe medications to patients with self-limiting conditions, such as cold sores or head lice, that have not responded to OTC treatments, or do not require a new diagnosis, for example. 

[Read more: Iowa: Practicing far afield]

Another key development has been the ability for pharmacists to be reimbursed for more services. Despite the expanded scope beginning in 2016, many pharmacists had not been performing those services because of reimbursement challenges, Zadvorny said. However, last year the state passed a provider status bill, allowing Colorado’s Medicaid plan to pay for all of the protocols as well as services provided under collaborative practice agreements. “That has really kicked things into gear as far as people being willing to start new services and get paid for them,” Zadvorny said.

Scope of practice


  • The recent passage of Senate Bill 94, part of the state’s “sunset” review of pharmacy practice, greatly expanded the scope of services that pharmacists in the state can provide, including prescribing certain drugs for limited conditions, ordering and evaluating laboratory tests, and performing limited physical assessments;
  • It also adds functions to the scope of practice of a pharmacy technician, such as documenting medical history and replenishing automated dispensing devices;
  • In addition, pharmacists in the state have long been able to prescribe hormonal contraceptives and provide tobacco cessation aids; and
  • Pharmacists in the state have been able to dispense naloxone without a prescription since 2015.
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