Patient Care Concerns with SB 504

Stakeholders and lawmakers need additional time to fully understand and address outstanding safety and patient care concerns created by SB 504, a bill that expands scope of practice for pharmacists. Rushing to pass a bill that significantly expands pharmacist prescribing authority threatens to create a pathway of healthcare that is disconnected and without important safeguards. The New Hampshire Medical Society encourages lawmakers to pause on pharmacist prescribing until there is a more cohesive path forward for both patients and prescribers.

SB 504 effectively dismantles a patient’s continuity of care. Patients are best served when the care team is connected and there is shared access to the patient’s health care records. This bill establishes a system that lacks longitudinal care – many pharmacists are not integrated into hospitals and healthcare teams and do not have access to important health records – prescription history, effective dosing, allergies, or chronic health information. Fragmented prescribing with poor communication can result in missed diagnoses, unnecessary treatment & testing, failed treatment attempts, and dangerous drug interactions.

Communication within the health care team is a larger problem than is being communicated. Safe prescribing requires knowing the patient's labs, imaging, allergies, prior adverse reactions, and medications from other providers. Most retail pharmacists have no training in reading imaging and have no integrated view of the patient’s health records. A prescribing decision made with a partial understanding of the patient is, at best unsafe and at worst, can cause life-threatening complications.

Finally, patients in rural areas need quality care, not just closer care. Substituting a pharmacist-prescriber for a physician is a real solution only if the care quality is comparable and if there’s reliable communication within the healthcare team. Important drugs may stay out of reach for pharmacist prescribers, even if state authority is extended. The FDA's risk-management programs restrict prescribing access for drugs like isotretinoin, clozapine, and the buprenorphine products used for opioid use disorder — tie authority to provider credentials that FDA has no obligation to extend to pharmacists. The same is true of DEA registration for controlled substances. A rural pharmacist-prescriber may have the state license to prescribe and no federal authority to prescribe the medications patients most often need.

For these reasons, we respectfully urge the House Executive Departments and Administration Committee to recommend an interim study of this bill. Doing so will allow stakeholders the necessary time to fully address outstanding safety and patient care concerns and to develop a more cohesive path forward.