RSV Update
Pursuant to Md. Code Ann., Health Occ. § 12-508(a)(3) and COMAR 10.34.32.03B-2, a licensed pharmacist registered with the Board may administer a vaccination listed on the Center for Disease Control and Prevention’s (“CDC”) Recommended Immunization Schedule to an adult without a prescription, subject to certain requirements. On September 22, 2023, the CDC released an addendum to the Schedule adding the RSV vaccine for pregnant people during weeks 32 to 36 of gestation and adults 60 years of age and older, as recommended by ACIP and adopted by the CDC. As such, a licensed pharmacist’s vaccination administration authority for adults currently includes the RSV vaccine administered to a pregnant person during weeks 32 to 36 of gestation or to an adult 60 years of age or older.
The Next Public Board Meeting will be held on December 20th, 2023 at 9:30 AM.
The meeting will be in person with a virtual option (see below)
Masks will NOT be required.
The Maryland Board of Pharmacy is currently live streaming board monthly public meetings
Please Note:
You will NOT get CE credits for attending virtually
Your video, audio, and chat will be disabled and
you will not be able to adjust these features
To join us, use this link:
Join before 9:30 am to ensure you are connected, attempts to connect after 9:30 will be accommodated when possible
Comments, questions or suggestions can be emailed to
All email will be read, but a response is not guaranteed
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Prescribing Practitioner Enrollment in Medicaid
At The Maryland Board of Pharmacy board meeting held on November 15,,2023 the Maryland Department of Health Office of Medicaid Provider Services and the Office of Pharmacy Services presented an important update on Medicaid provider enrollment policy.
Beginning January 3, 2024 In order for states to comply with the federal Affordable Care Act requirements, Medicaid programs must deny any pharmacy claim in which the prescriber is not actively enrolled in Medicaid.
Current policy implementation applies to Fee-For-Service (FFS) claims only.
Phase 1 Denials: (January 2024) Medicaid will
deny pharmacy claims for non-behavioral health
drug classes if the prescriber is not enrolled.
“AS OF JANUARY 3, 2024, CLAIMS WILL DENY FOR UNENROLLED
PRESCRIBERS. PRESCRIBER MUST ENROLL WITH MEDICAID.”
● Phase 2 Denials: (July 2024) Medicaid will deny
ALL pharmacy claims regardless of drug class if
the prescriber is not enrolled
Prescriber Enrollment Options
An individual practitioner may enroll as either:
1) A fully participating (billing or rendering) provider;
or
2) An ORP-only Provider - Does not bill for services
or sign a full Provider Agreement.
Provider Resources
DEA Update
The DEA recently published a final rule, effective July 24, 2023, which amends the regulations regarding DEA Form 106, used by registrants to formally report thefts or significant losses of controlled substances. The final rule requires that all DEA Form 106s be submitted electronically. DEA will allow registrants 45 days from discovery of the theft or significant loss to submit the form, up from the agency’s original proposal of 15 days. (In comments to the proposed rule back in September 2020, NCPA requested a 60-day timeframe, and alternately supported the proposed 15-day timeframe if that was implemented after the COVID-19 PHE ended.) Notably, the final rule does not change the requirement that registrants preliminarily notify their area DEA Field Division Office of the theft or significant loss of any controlled substances in writing within one business day of discovering such loss or theft. Paper copies of DEA Form 106 will no longer be accepted once the final rule becomes effective.
Electronic Prescribing of Controlled Substances
Effective January 1, 2022, Senate Bill 0166 (CH0299)/House Bill 0512 (CH0230) (2020) Drugs and Devices – Electronic Prescriptions – Controlled Dangerous Substances requires licensed health care providers to electronically prescribe prescriptions for controlled dangerous substances. The Health General Article, 21-220(C) provides exceptions to this requirement, and the requirement to request a waiver. A health care practitioner who is unable to electronically transmit prescriptions for controlled dangerous substance drugs may request a waiver from the electronic prescribing requirement under certain circumstances. A waiver, if granted, may not exceed one year.
Pharmacists:
A pharmacist may continue to accept handwritten prescriptions. This bill allowed for a waiver and multiple exceptions. Many of the exceptions would be difficult for a pharmacist to verify. Therefore, the bill stated that a pharmacy is not required to verify the ability of a provider to issue non-electronic prescriptions. While a pharmacist does not need to verify that the prescription is an authorized exception to the electronic prescription requirement, the pharmacist must still follow due diligence requirements to ensure the prescription is written for a legitimate medical purpose.
Providers:
If you are a provider that is unable to issue controlled substance prescriptions electronically, please visit the OCSA website. On the left panel, select the “Electronic Prescribing Waiver Request". Please read the page completely to verify the need for a waiver. If you meet the criteria for one of the listed exceptions, you do not need to apply for a waiver or issue controlled substance prescriptions electronically. If you are required to apply for a waiver, click the link at the bottom of the page to submit an application for a waiver.
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Maryland Implicit Bias Training Requirement: Definition and Resources
Pursuant to MD. Code Ann., Health Occ. § 1-225, all health practitioners must attest to completing an implicit bias training program approved by the Cultural and Linguistic Health Care Professional Competency Program on their first license renewal after April 1, 2022.
Amended Governor's Orders
2023.01.18.01 - MDH Order - Amended Various Health Care Matters Order
2023.01.18.02 - MDH Order - Amended Nursing Home Matters Order
