A pharmacy support person (PSP) is an individual who assists in the nontechnical functions of the practice of pharmacy, enabling the pharmacist to provide pharmaceutical care to the patient. The supervising pharmacist is responsible for the actions of a pharmacy support person or other supportive personnel.
Other health care providers who assist in the non technical functions of the practice of pharmacy and who are actively licensed or registered in their profession are also required to register as a pharmacy support person. Registered pharmacist-interns are exempt from PSP registration.
All application fees are nonrefundable and nontransferable. Once an application is submitted and the fee is paid, the withdrawal of an application, determination of ineligibility based on prior criminal convictions, or discovery of the submission of an incorrect application type does not merit return or refund of the application fee. Do not submit an application if you are unsure of which application type to submit.
Unless exempt in Iowa Administrative Code 657 Chapter 5.5, any individual employed by a pharmacy who has direct access to prescription drugs or confidential patient information must be registered as a pharmacy support person.
Duties and Functions
Effective May 12, 2021, 657 IAC 5 went into effect which now requires pharmacy employees which are solely employed for delivery functions to be registered with the Board of Pharmacy as a pharmacy support person.
Using the pharmacy’s established policies and procedures and the supervising pharmacist’s professional judgment, a supervising pharmacist may delegate nontechnical functions in the operation of the pharmacy (except those prohibited by 657 IAC 5.17, to an appropriately trained and registered pharmacy support person).
The pharmacist must be on site and available to supervise the pharmacy support person when delegated functions are performed, except as provided in 657 IAC Chapter 6.7 or Chapter 7.6.
The ultimate responsibility for the actions of a pharmacy support person shall remain with the supervising pharmacist. A pharmacy license holder shall not infringe on the authority of a supervising pharmacist to delegate or decline to delegate specific nontechnical functions to a pharmacy support person based on the supervising pharmacist’s professional judgment regarding the knowledge and training of the pharmacy support person.
Prohibited Duties and Functions
A PSP is not authorized to perform any of the following functions:
Provide the final verification for the accuracy, validity, completeness, or appropriateness of a filled prescription or medication order.
Conduct prospective drug use review or evaluate a patient’s medication record for purposes identified in rule 657—8.21(155A).
Provide patient counseling, consultation, or patient-specific drug information; make an offer of patient counseling on behalf of the pharmacist; or accept a refusal of patient counseling from a patient or patient’s agent.
Make decisions that require a pharmacist’s professional judgment, such as interpreting or applying information.
Accept by oral communication any new or refill prescription authorizations communicated to a pharmacy by a prescriber or by the prescriber’s office or contact a prescriber to obtain prescription refill authorizations.
Provide a prescription or drug to a patient without a pharmacist’s verification as to the accuracy of the dispensed medication and without the physical presence of a pharmacist.
Package, pour, or place in a container for dispensing, sale, distribution, transfer, vending, or barter any drug which, under federal or state laws, may be sold or dispensed only pursuant to the prescription of a practitioner authorized to prescribe drugs. This prohibited task includes the addition of water or other liquid for reconstitution of oral antibiotic liquids. A pharmacy support person may place a prescription container into a bag or sack for delivery to the patient as part of the sales transaction after the accuracy of the prescription has been verified by the pharmacist.
Affix required prescription labels upon any container of drugs sold or dispensed pursuant to the prescription of an authorized prescriber.
Process or enter, including entry into the pharmacy computer system, pertinent clinical patient or prescription information, including allergies and disease state information.
Prepackage or label multidose and single-dose packages of drugs, including dose picks for unit dose cart fills for hospital or long-term care facility patients.
Check or inspect drug supplies provided and controlled by an Iowa-licensed pharmacy but located or maintained outside the pharmacy department, including but not limited to drug supplies maintained in an ambulance or other emergency medical service vehicle, a long-term care facility, a hospital nursing unit, or a hospice facility.
Reconstitute prefabricated noninjectable medication, prepare parenteral products, or compound sterile or nonsterile drug products.
Communicate, transmit, or receive patient or prescription information to or from the pharmacy for the purpose of transferring a patient’s prescription between pharmacies.
Assist with or witness the destruction or wastage of controlled substances pursuant to 657—subrule 10.22(2).
Perform any technical functions pursuant to 657—Chapter 3 that may be delegated to a pharmacy technician.
Employment
Iowa rule requires that a registration be issued prior to commencing work in a secured pharmacy department.
Employment means that you have been hired by a pharmacy to perform the duties of a PSP, not necessarily that you have actually started working in the secured pharmacy area. On the application, please identify the pharmacy that has hired you and the anticipated start date to begin working in the secured pharmacy area. If you have already started working in the secured pharmacy area, you must indicate the exact date that you started working in that capacity. As a reminder, you should not begin work in the secured pharmacy area until registered with the Board. Please be advised that applications can take 5-7 business days upon receipt of application to process and should be taken into consideration at the time of hire. If you continue employment as a PSP without a current registration, you (as well as the pharmacy and pharmacist in charge) may be subject to public discipline.
If you have been working for the company in another capacity, or working in the secured pharmacy area in another pharmacy position, but are just now to begin the duties of a PSP, indicate the anticipated start date you will begin or the actual start date you began to perform the duties of a PSP, not the initial date you were hired to work elsewhere with the company or to work in the pharmacy in another position.
You must indicate the licensed Iowa pharmacy where you have been hired, even if you have not started employment.
Disclosure of Criminal History and Disciplinary Action
The initial and renewal applications ask about any medical conditions the applicant has that might impair the applicant’s ability to perform delegated functions.
The Board also considers any prior criminal history and disciplinary actions when issuing licenses and registrations. As part of the application process, you will be asked questions about prior criminal history and disciplinary actions.
If you have any questions concerning these requirements, please notify the Board office. If any of these situations pertain to you, there may be delays in processing your application. Please contact the Board office for information as to what documentation may be necessary for registration. Contacting the Board office about any of these situations may avoid unnecessary delays issuing your registration.
Be advised that the application asks about any medical conditions you have that might impair your ability to perform delegated functions.
Definitions
“Ability to perform required tasks with reasonable skill and safety” means ALL of the following:
The cognitive capacity to use pharmacy systems to obtain necessary patient and prescription related information to process prescriptions
The ability to effectively communicate information to pharmacists, providers, technicians, pharmacy support persons, and patients
The ability to perform required tasks such as filling prescriptions, stocking medications, replenishing pharmacy supplies, and other tasks as determined by the pharmacist on duty
“Medical condition” means any physiological, mental, or psychological condition, impairment, or disorder, including drug addiction and alcoholism.
“Chemical substances” means alcohol, legal and illegal drugs, or medications, including those taken pursuant to a valid prescription for legitimate medical purposes and in accordance with the prescriber’s direction, as well as those used illegally.
“Currently” does not mean on the day of, or even in weeks or months preceding the completion of this application. Rather, it means recently enough so that the use of chemical substances or medical conditions may have an ongoing impact on the ability to function and perform the duties required of a technician, or has adversely affected the ability to function and perform the duties required of a technician within the past two years.
“Improper use of drugs or other chemical substances” means ANY of the following:
The use of any controlled drug, legend drug, or other chemical substances for any purpose other than as directed by a licensed health care practitioner; and
The use of any substance, including but not limited to, petroleum products, adhesive products, nitrous oxide, and other chemical substances for mood enhancement.
“Illegal use of drugs or other chemical substances” means the manufacture, possession, distribution, or use of any drug or chemical substance prohibited by law.
If you answer yes to any of the medical condition questions, you will be required to provide a signed and dated explanation and submit the “Verification of Medical Condition” form which is to be completed by your treating physician(s).
Initial Applicants: You must disclose all convictions, regardless of where or how long ago they occurred. Failure to disclose a criminal conviction could result in delays in processing or denial of your application.
Renewals: You are required to disclose only convictions from the time of your last application.
The following information is required to be submitted for any criminal conviction:
Complete criminal record – At a minimum a copy of the criminal complaint and final court order will be required.
Records can be obtained by contacting the Clerk of Courts in the county where the charges were filed.
Personal statement explaining the criminal conviction and whether the conviction directly relates to the practice of pharmacy. A conviction is directly related to the duties and responsibilities of the profession if either (1) the actions taken in furtherance of an offense are actions customarily performed within the scope of the practice of pharmacy, or (2) the circumstances under which an offense was committed are circumstances customary to the practice of pharmacy.
All evidence of rehabilitation that you wish to be considered.
This could include a description of the circumstances relative to the offense, including any aggravating and mitigating circumstances or social conditions surrounding commission of the offense, any treatment undertaken, any letters of reference, or anything else pertaining to the present fitness of the applicant.
Submitting print outs from Iowa Courts Online is not sufficient information.
You are strongly encouraged to perform a background check on yourself through Iowa Courts Online or to have your employer perform one prior to submitting your application. If any convictions that were not dismissed can be found on Iowa Courts, it is required that they are disclosed when applying. Keep in mind that the Iowa Courts Online database only shows Iowa state court convictions.
An individual who has not yet submitted a completed a registration application may petition the Board for a determination of whether one or more of the individual’s convictions are disqualifying offenses that would render the individual ineligible for registration.
An individual with a conviction is not required to petition the Board for an eligibility determination prior to applying for a registration.
To petition the Board for an eligibility determination of whether one or more of the petitioner’s convictions are disqualifying offenses, a petitioner must submit all of the following:
A completed petition for eligibility determination form;
The complete criminal record for each of the petitioner’s convictions;
A personal statement regarding whether each conviction directly relates to the duties and responsibilities of the practice of pharmacy and why the Board should find the petitioner rehabilitated;
All evidence of rehabilitation that the petitioner wishes to be considered by the Board; and
A nonrefundable fee of $25.
The cutoff for inclusion on the Board's agenda is two weeks prior to a scheduled Board meeting. Requests received after the cutoff will be held for the following Board meeting (i.e. deadline for March 12 meeting is Feb. 27; a request received on Feb. 28 would not go before the Board until the next meeting).
Initial Applicants: You must disclose all disciplinary action, regardless of where or how long ago it occurred. Failure to disclose a disciplinary action could result in delays in processing your application or in your application being denied.
Renewals: You are required to disclose only disciplinary action from the time of your last application.
The application requires the disclosure of the following:
Any disciplinary or enforcement action imposed by any licensing agency or regulatory authority on any license or registration held by the individual.
Knowledge of any charges, complaints or investigations, pending before any licensing authority.
Any license or registration denials by any licensing authority.
The following information is required to be submitted for any disclosures:
A written description of the event(s).
All unredacted documents related to any disciplinary or enforcement action imposed by any licensing agency or regulatory authority.
Notifications to the Board
Individuals are required to report to the Board, within ten days, a change of name, address, or email.
Changes to your address, email address, phone number, or employment may be made through your online profile.
You are required to provide to the Board written notice of and unredacted documents related to any disciplinary or enforcement action imposed by any licensing agency or regulatory authority on any license or registration you hold no later than 30 days after the final action. Discipline may include, but is not limited to, fine or civil penalty, citation or reprimand, probationary period, suspension, revocation, and voluntary surrender.
You are required to provide written notice to the Board of any criminal conviction, other than a minor traffic offense, no later than 30 days after the conviction. The term “criminal conviction” includes instances when the judgment of conviction or sentence is deferred.
