Pharmacy Scope of Practice
Recognizing the distinct expertise of each profession.
What is Pharmacist’s Test & Treat and how does it affect us?
Pharmacist Test & Treat: Protecting Comprehensive Patient Care
The proposed Pharmacist Test & Treat legislation would significantly expand pharmacists’ authority to test, diagnose, and prescribe treatment for an expanded list of conditions. For New Hampshire physicians, this raises important questions about patient safety, continuity of care, and the appropriate role of each member of the healthcare team.
Pharmacists are highly trained medication experts and play an important role in patient care. However, diagnosing and treating patients requires more than expertise in medications. Physicians are trained to evaluate the patient as a whole—including medical history, comorbidities, medications, physical findings, differential diagnoses, and the possibility that seemingly routine symptoms may signal a more serious underlying condition.
For physicians practicing in New Hampshire, the concern is not about limiting pharmacists’ valuable contributions to the care team. It is about ensuring that testing and treatment decisions are made within a comprehensive clinical context and with appropriate physician involvement when diagnosis or medical complexity requires it.
New Hampshire patients deserve a healthcare system in which every member of the care team practices to the full extent of their training, while recognizing the distinct expertise and responsibilities of each profession.

Important information to know:
Pharmacists are not prepared to practice medicine.
- Pharmacists are well-trained as medication experts within an interprofessional team; however, their training in patient care is limited.
- The majority of the Doctor of Pharmacy (PharmD) curriculum across the country consists of instruction in applied sciences and therapeutics. Residency is not required and very uncommon.
- Students do engage in some “practice experiences” during their education, but the training is not focused on providing medical care to patients and do not include performing a physical examination, making a diagnosis, triaging severity, or prescribing.
Pharmacists are already significantly overburdened.
- Perhaps even more concerning is the fact that pharmacists in the community setting are already significantly overburdened by their current workload.
- 71% of all pharmacists and 91% of pharmacists working in community pharmacies rated their workload as high or excessively high.
- Moreover, pharmacists reported that the “three most common ‘highly stressful’ job aspects were ‘having so much work to do that everything cannot be done well’ (43% reporting ‘highly stressful’), ‘working at current staffing levels’ (37% reporting ‘highly stressful’), and ‘fearing that a patient will be harmed by a medication error’ (35% reporting ‘highly stressful’).”
- Scope expansions like the one proposed in this bill only add further responsibilities to an overburdened pharmacist workforce and threaten patient safety due to their insufficient training in these activities.
Do More—But Do It Carefully
As we consider expanding pharmacists’ role in testing, diagnosing, and prescribing, we should look beyond the immediate question of access and consider the unseen and unspoken consequences for healthcare delivery, cost, and the long-term sustainability of New Hampshire’s healthcare system.
There is an important reason physicians and nurse practitioners have traditionally served as independent prescribing providers: they are separated from the financial interests of the pharmaceutical distribution chain. Prescribers make decisions about medications without a financial stake in the drugs they prescribe. That separation was intentional. It is a safeguard designed to ensure that prescribing decisions are driven by the patient’s clinical needs—not by financial incentives.
Any expansion of prescribing authority should therefore be considered in the context of the increasingly complex financial pressures and consolidation within the drug-delivery marketplace. We need to ask not only whether a proposed expansion increases access, but also what incentives it creates, who benefits financially, and what those changes could mean for patients and the healthcare system over time.
There may be very good reasons to expand pharmacists’ role in targeted, carefully designed ways, particularly in rural New Hampshire. Rural physicians, FQHCs, critical access hospitals, and pharmacists have been collaborating for years to address access challenges, and their experience should be central to developing solutions. Supporting those existing relationships and integrating pharmacy more effectively into rural care delivery could be a meaningful—and potentially lifesaving—step forward.
But a broad, statewide expansion of independent prescribing is a very different proposition. It could create a new dynamic in the healthcare marketplace that is difficult to anticipate, measure, or unwind—and potentially create costs and consequences that we do not yet understand.
We should do more where it makes sense, but we should do it thoughtfully. New Hampshire has an opportunity to develop targeted solutions that bring physicians, pharmacists, nurses, rural providers, FQHCs, critical access hospitals, and patients to the table. If we get it right, expanded pharmacy services in areas of genuine need could improve access and save lives while strengthening—not fragmenting—our healthcare system.
But if we move too broadly and too quickly, we risk creating a problem that will be extraordinarily difficult and expensive to fix.
New Hampshire should not rush to be first. We owe our pharmacists, our rural healthcare providers, and, most importantly, our patients a better and more carefully considered plan.