Memorandum of Understanding
The following agreement is entered into by the Pennsylvania Pharmacists Association (PPA) and
the Pennsylvania Coalition of Nurse Practitioners, (PCNP) on behalf of their members.
Whereas the PPA represents pharmacists and the PCNP represents nurse practitioners practicing
in the Commonwealth of Pennsylvania and both organizations are comprised of healthcare
professionals concerned with meeting the needs of the patients they serve; both groups enter into
the following agreement in a spirit of cooperation in an effort to foster better communication and
for the benefit of our patients.
Pharmacists understand that nurse practitioners must have education in advanced pharmacology
to become CRNPs and respect nurse practitioners for this professional commitment and their
interest in providing safe and effective medications for their patients.
Nurse practitioners understand that pharmacists are highly-educated in the aspects of medication
use and are also concerned with their patients receiving the medications they need.
In these litigious times, each professional must appreciate the responsibility of the other to
comply fully with all federal and state regulations relative to their respective practices.
An appreciation for further compliance with each separate private or government provided
prescription plan policies is also necessary.
Pharmacy reimbursement, for both the drug product and the professional service, is subject to
audits by the insurers which check for compliance in full detail with the insurers’ contract
requirements and can take back money from the pharmacy if all aspects do not comply
Time constraints, patient expectations and demands, and managed care restraints only further add
to the pressures both nurse practitioners and pharmacists face on a daily basis.
There is an understanding that all requests made for additional information are not done to be
challenging or disrespectful but rather part of an effort to comply with all these requirements and
still meet the needs of the patient.
Pharmacists must be familiar with the differences in the prescriptive authority of physician
assistants and how they differ from nurse practitioners.
It is recognized that all prescribing nurse practitioners must have a collaborative agreement
which outlines their scope of prescribing practice in collaboration with a physician (either MD or
DO). Pharmacists can only fill lawfully prescribed prescriptions.
Regulations state that the collaborative agreement must “be made available for inspection to
anyone seeking to confirm the scope of practice of the CRNP” and “be kept at the primary
practice location of the CRNP”.
Therefore, in the spirit of cooperation, nurse practitioners will have their collaborative agreement
readily available at their practice site so that it may be faxed to a pharmacy when requested.
Pharmacists will make such a request with as much notice as possible and only when they feel it
is essential, (e.g. first time they have a prescription from a CRNP, etc.)
It is recognized that DEA numbers are only to be used and required on prescriptions for
controlled substances. Unfortunately, numerous private payers require the inclusion of a DEA
number on the electronic claim submitted by the pharmacist. Without it the claim will not go
through and the patient must pay for the prescription medication as a cash transaction.
PPA and other groups such as the American Medical Association and nurse practitioners have
tried to contest this requirement unsuccessfully. NPI numbers may solve this issue in the future.
Therefore, in the spirit of cooperation, pharmacists will only request DEA numbers from nurse
practitioners when they are absolutely needed and nurse practitioners will provide their DEA
number when such a request is made even if it is not for a controlled substance, so the drug claim
may be submitted saving the patient from paying the cash price. If a CRNP does not have a DEA
number and the insurance claim requires one, the collaborating physician’s name will be used to
fill the prescription.
The M.A. Program FFS delivery system will recognize prescriptions written by CRNPs in
accordance with their prescriptive authority. CRNPs enrolled in the M A. Program do not need to
provide any further enrollment information. For prescriptions written by CRNPs, pharmacies
may now use the license number of the CRNP prescribing the medication when submitting
claims through the Electronic Claims Management (ECM) on-line pharmacy billing system.
ECM has been programmed to accept CRNPs license numbers in the prescriber identification
number field (NCPDP field 411). (MA Bulletin 99-03-06)
A nurse practitioner is a valid prescriber within the law and according to their collaborative
agreement with their physician. The prescription label on a dispensed drug is to include the
nurse practitioner’s name when they are the prescriber.
According to the CRNP regulations, “a prescription blank shall bear the name, title, and
certification number of the CRNP, and the CRNP’s National Provider Identifier (NPI) number,
and a space for the entry of the DEA registration number, if appropriate. The collaborating
physician shall also be identified as required in § 16.91” (“the name and license number of the
physician shall be printed or preprinted on a written prescription for drugs and on a written order
for services or equipment to be provided to a patient by another provider unless the patient is
receiving those drugs or other services or equipment as part of inpatient services”).
Therefore, in the spirit of cooperation, pharmacists will include the name of the nurse
practitioner as the prescriber on the prescription medication label and nurse practitioners will
ensure the information concerning their collaborating physician is included, even on phoned in
Nurse practitioners may prescribe a maximum of 30 day supply of a schedule II drug, 90 days for
schedule III and IV drugs, and the collaborating physician must authorize refills. Pharmacists
should recognize this scope of practice for CRNPs.
Therefore, in the spirit of cooperation, scheduled prescription medications prescribed within the
CRNP’s scope of practice should be dispensed.
If at any time, a pharmacist or nurse practitioner does not seem to be following the spirit of
professional cooperation noted in this memorandum of understanding, provision of a copy of this
document is encouraged.
This agreement becomes effective upon the approval and signature noting such approval of both
groups. It may be similarly modified upon the approval of both groups.
Pennsylvania Pharmacists Association Pennsylvania Coalition of Nurse Practitioners
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Date: ________________________ Date: ______________________________