Can Pharmacists Prescribe in Pennsylvania? 2026 Scope of Practice Guide

Status Check: Pennsylvania is a Green State. Current Authority Level: Test & Treat Authority (Act 34)

If you are a pharmacist in Pennsylvania, you are likely leaving revenue on the table—or practicing efficiently but dangerously.

The laws in Pennsylvania have changed significantly in recent years. Whether you are looking to launch a "Test and Treat" clinic or just want to legally dispense Paxlovid, you need to know exactly which protocol protects your license.

Here is the Breakdown of Pharmacist Prescribing Authority for Pennsylvania.

At-A-Glance: What Can You Prescribe?

Clinical Service	Authority Status	Protocol / Requirement	Billing Code
Flu/Strep/COVID	✅ YES	Protocol Required	CPT 99211
Hormonal Contraception	⚠️ NO	Standing Order Proposed	N/A
Paxlovid (COVID-19)	✅ YES	Federal Authority	CPT 99212
HIV PrEP/PEP	❌ NO	Not Authorized	N/A
Opioid Antagonist	✅ YES	Statewide Protocol	Product Only

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1. Test & Treat Authority (Flu / Strep / COVID)

The Law: Act 34

Pennsylvania's Act 34 grants pharmacists significant Test & Treat authority for respiratory infections including influenza, streptococcal pharyngitis, and COVID-19.

The Protocol: To legally prescribe, you must:

1. Follow established treatment protocols for each condition.
2. Perform CLIA-waived rapid diagnostic testing.
3. Document the clinical encounter and treatment decision.

⚠️ Key Point: Act 34 is one of the most comprehensive Test & Treat laws in the country, making Pennsylvania a leader in pharmacist clinical services.

The Workflow:

1. Test: Perform a CLIA-waived rapid test (Flu A/B, Strep, COVID).
2. Evaluate: Assess symptoms, patient history, and risk factors.
3. Treat: If positive, prescribe appropriate therapy per protocol.

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2. Hormonal Contraception Authority

The Status: Not Currently Authorized

In Pennsylvania, pharmacists cannot independently furnish hormonal contraception. Legislation to create a standing order has been proposed but is not yet in effect.

What This Means:

• Patients need a physician prescription for hormonal contraception.
• Pharmacists can advocate for expanding authority through professional associations.

Rx Agent Tip: Track pending legislation through Rx Agent to stay informed on when contraception authority may become available.

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3. Paxlovid (COVID-19 Treatment)

The Law: Federal Authority

Pennsylvania pharmacists can prescribe Paxlovid under federal emergency authorization, complementing the state's robust Test & Treat framework.

Requirements:

1. Perform renal function assessment.
2. Screen for drug-drug interactions (especially with common medications).
3. Document clinical decision-making and patient counseling.

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4. How to Bill for Services in Pennsylvania

It is not enough to do the work; you must get paid.

Medicaid Enrollment: To bill Pennsylvania Medicaid for CPT codes (like 99211, 99212), you must enroll as an Ordering/Referring Provider.

• Portal Link: Pennsylvania Medicaid Provider Enrollment

Commercial Payers: Most commercial plans in Pennsylvania are beginning to recognize pharmacists under Act 34. We recommend billing the patient a cash "Consult Fee" and providing a Superbill using the codes above.

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Compliance Checklist for Pennsylvania

Before you write your first prescription, ensure you have these documents on file:

• NPI Type 1: Do you have an individual NPI? (Type 2 is for the pharmacy).
• Act 34 Protocols: Do you have current treatment protocols on file?
• Liability Insurance: Does your policy cover "Prescribing" or just "Dispensing"?
• CLIA Waiver: Is your pharmacy registered as a laboratory?
• Documentation Templates: Are you using compliant encounter forms?

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Need the Official Protocols?

Stop searching through the Pennsylvania Board of Pharmacy website.

Rx Agent has the official, up-to-date Protocols and Standing Orders for Pennsylvania built right into the chat.

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"What conditions can I treat under Act 34 in Pennsylvania?"

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