As the 2019 novel coronavirus (COVID-19) is expected to reach its apex in several states over the next two weeks, the Department of Health & Human Services (HHS) has issued new guidance authorizing licensed pharmacists to order and administer COVID-19 tests approved by the Food and Drug Administration (FDA). Notably, pharmacists will now qualify as “covered persons” under the Public Readiness and Emergency Preparedness Act (PREP Act), affording them immunity with respect to all claims for losses caused by, arising out of, relating to or resulting from the administration or use of the FDA-approved COVID-19 tests. Public health experts believe that widespread testing for COVID-19 is important because it would help determine who is infected and needs to be isolated, rather than ordering the entire population to remain home.
While physicians and hospital staff have been on the frontlines battling COVID-19, pharmacists and pharmacy staff, who may interact with patients exhibiting COVID-19 symptoms or fill prescriptions for infected COVID-19 patients, have served a key role as well. The role of pharmacists and pharmacy staff in combating the pandemic is expected to grow even more as HHS has cleared the way for licensed pharmacists to administer COVID-19 tests.
In light of the expanding role of pharmacy staff during the COVID-19 pandemic and the increased potential for exposure to patients infected with COVID-19, the Centers for Disease Control and Prevention (CDC) issued new guidance for pharmacies. The guidance builds upon CDC’s previously issued guidance to pharmacies and advises that pharmacy staff can minimize their risk of exposure to COVID-19 and reduce the risk for customers by using the principles of infection prevention and control, and social distancing. Specifically, the CDC recommends that pharmacies take the following actions:
- Advise pharmacy staff who have a fever or respiratory symptoms to remain home and away from the workplace until they have recovered.
- Provide hand sanitizer on counters for use by customers and have sufficient and easy access to soap and water or hand sanitizer for staff.
- Encourage prescribers to submit prescription orders via telephone or electronically and avoid the handling of paper prescriptions, in accordance with applicable state laws.
- Place packaged medication on the counter for the customer to retrieve instead of handing it directly to the customer.
- Avoid the handling of insurance cards. Instead, ask the customer to take a picture of the insurance card for processing or read aloud the information that is needed (in a private location so other customers cannot hear).
- Avoid touching objects that have been handled by customers. If the transfer of items must occur between a customer and a pharmacy staff member, the pharmacy staff member should wash their hands afterwards with soap and water for at least 20 seconds or use an alcohol-based hand sanitizer.
The CDC also recommends that pharmacies implement additional strategies to minimize close contact between staff and customers and between and among customers. For instance, the CDC recommends that pharmacies implement certain engineering and administrative controls, such as:
- Use signage/barriers and floor markers to instruct waiting customers to remain six feet back from the counter, other customer interfaces, and from other customers and pharmacy staff.
- Install a section of clear plastic at the customer contact area to provide barrier protection (e.g., Plexiglas-type material or clear plastic sheet), with a pass-through opening at the bottom of the barrier for people to speak through or share items, if necessary.
- Frequently clean and disinfect all customer service counters, customer contact areas, and frequently touched objects and surfaces such as workstations, keyboards, telephones and doorknobs.
- Discontinue the use of magazines and other shared items in pharmacy waiting areas and ensure that the waiting area is cleaned regularly.
- For pharmacies with a co-located retail clinic, use signs to ask customers who have respiratory symptoms to wait for their appointment in a specific part of the store.
- Promote the use of self-serve checkout registers and clean them frequently.
- Divert as many customers as possible to drive-through windows, curbside pick-up or home delivery, where feasible.
- Limit the number of customers in the pharmacy at any given time.
- Pharmacists who are providing patients with chronic disease management services, medication management services and other services that do not require face-to-face encounters should make every effort to use telephone, telehealth or telepharmacy strategies.
- Close self-serve blood pressure units.
Pharmacies that are interested in offering COVID-19 testing should communicate with their local and state public health officials to determine which customers meet the criteria for testing. State and local health departments can inform pharmacies regarding the appropriate procedures to collect, store and ship specimens. Further, pharmacy staff conducting COVID-19 testing and other close-contact patient care procedures that will likely elicit coughs or sneezes (e.g., influenza and strep testing) should be provided with appropriate personal protective equipment (PPE) by the pharmacy. The pharmacy should also make sure that pharmacy staff are trained in the appropriate donning and doffing of PPE.
Additionally, pharmacies interested in offering COVID-19 testing should consider sharing the recent guidance document published by the American Pharmacists Association (APhA) with their pharmacy staff. APhA’s guidance document addresses over a dozen frequently asked questions about COVID-19 testing on a broad array of topics, including the type of specimens that are collected, who can collect the specimen, how the testing assays work, the current testing kits that are available and authorized by the FDA, and whether a pharmacy may need additional licenses to perform the COVID-19 testing.
As the number of cases around the world grows, Faegre Drinker’s Coronavirus Resource Center is available to help you understand and assess the legal, regulatory and commercial implications of COVID-19.