AMA Scope Of Practice Response Letter Joint Pharmacy Organization View Series PLHR4M

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April 16, 2010

Michael D. Maves, M.D., M.B.A.

Executive Vice President, CEO

American Medical Association

515 N. State St.

Chicago, IL 60654

Re: American Medical Association (AMA) Scope of Practice Data

Series: Pharmacists

Dear Dr. Maves:

The American Pharmacists Association (APhA) collaborated with the American

Association of Colleges of Pharmacy (AACP), American College of Clinical

Pharmacy (ACCP), Accreditation Council for Pharmacy Education (ACPE),

American Society of Consultant Pharmacists (ASCP), National Alliance of State

Pharmacy Associations (NASPA), and National Association of Boards of Pharmacy

(NABP) to formulate the following response to the AMA Scope of Practice Data

Series: Pharmacists document. We were invited to provide requested input to the

AMA and to clarify any inaccuracies in the document. We conducted a thorough

analysis that resulted in the recommendations attached to this letter.

After reviewing the AMA Scope of Practice Data Series: Pharmacists document,

the collaborating organizations are deeply concerned with the accuracy and

completeness of the information presented. Today physicians and pharmacists are

collaborating to enhance patient care in innovative and effective ways. This

document is a regression and contrary to the recommendations and policy

pronouncements of the Institute of Medicine (IOM), the Patient-Centered Primary

Care Collaborative (PCPCC), the Joint Commission, the Association of Academic

Health Centers (AHC), and numerous other groups that support more and better

inter-professional collaboration to improve patient care.

We have serious concerns about the portrayal within the document of pharmacists’

scope of practice, the provision of collaborative drug therapy management (CDTM)

services, and the education and training of pharmacists. The suggestion in the

document -- that the evolving scope of practice of pharmacists serves primarily to

“compensate” for increased automation and utilization of pharmacy technicians -- is

simply wrong. Rather, pharmacy practice is being driven by substantial and

important changes in pharmacists’ education and training over the past two decades

to meet the needs of patients in using medications safely and more effectively. This

training allows pharmacists to engage in services for which they have the specific

education, training, and regulatory authority to positively impact patient outcomes,

especially with regard to the management of medication therapy and the unmet

needs of patients.

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It is within the scope of practice in all 50 states for pharmacists in all practice settings to obtain

medication histories, review the patient’s medications to identify medication-related problems, to

engage collaboratively with physicians to resolve identified problems, educate the patient about

proper use of medications, encourage adherence with prescribed medications, and document and

communicate information and recommendations to other providers on the patient’s health care team.

These medication therapy management activities are part of a pharmacist’s responsibility to ensure

optimal therapeutic outcomes for the patients they serve. Recognition of these services is missing in

the AMA document.

We have major concerns that the CDTM descriptions in the document inaccurately equate (and

therefore confuse) the practice of collaborative drug therapy management -- an inherently inter-

professional and interdependent practice activity -- with “efforts” to expand the scope of practice of

pharmacists into areas that are suggested to be exclusive to the practice of medicine. We

acknowledge the long-held view of AMA and others that the practice of medicine is quite expansive,

with a wide range of patient care activities and domains serving as its framework. However, that

does not mean that the performance of any one of those myriad functions or patient care activities by

another health professional who is appropriately educated and licensed to perform that function,

somehow constitutes the “practice of medicine.” There is substantial overlap in the regulated scopes

of practice of health care professionals. That does not make a physician a nurse if he/she performs a

service/task that is in the scope of practice of a nurse any more than it makes a pharmacist a

physician if he/she performs a service/task that also falls within the scope of practice of a physician.

The document omitted numerous changes in practice and training, including the most recent version

of the accreditation standards for the education of doctor of pharmacy (PharmD) students that have

been in place since July 1, 2007. The Accreditation Council for Pharmacy Education (ACPE), the

nationally recognized body that accredits degree programs of colleges and schools of pharmacy,

maintains rigorous requirements for didactic and experiential education and training of pharmacists.

ACPE undertakes this important role in collaboration with the entire pharmacy profession to ensure

that education and training programs, both pre and post-licensure, are designed to equip pharmacists

with the knowledge, skills, and behaviors to provide the full range of professional services within

their regulated scope of practice. Furthermore, with the move to the PharmD degree, the experiential

component of pharmacists’ education has been greatly expanded. This experiential component now

includes required learning experiences throughout the curriculum and advanced pharmacy practice

experiences with diverse patient populations in the final year of training. Completely ignored in the

document is the fact that many medical and pharmacy school curricula are being revised to facilitate

the education and training of medical students and student pharmacists together, using collaborative

team-based models of care.

Patients today have important and increasing concerns about the safety and appropriate use of their

medications. Practically every week, the lay press examines incidents in which patients have either

been harmed by the therapy they receive or have failed to achieve the desired therapeutic results. The

AMA could better serve the public and its members by issuing resource guides on how physicians

and pharmacists can collaborate to better assure that the medication therapy provided in both the

hospital and in the community results in optimal medication therapy outcomes. The tone of the AMA

document suggests a concern by the authors that pharmacists are expanding their practice to usurp

roles traditionally served by physicians. On the contrary, pharmacists are filling roles today that

were largely unmet and that support the health care team in a patient centered model.

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