12/20/2024

The purpose of this Special General Memorandum (SGM) is to reinforce the recognition of Indian Health Service (IHS) pharmacists as health care providers with prescriptive privileges.  The IHS provides comprehensive health care to American Indian and Alaska Native beneficiaries by utilizing providers, including non-physician licensed practitioners such as pharmacists, who are integral members of the health care team delivering direct patient care and comprehensive medication management services.

The medical staff of each IHS facility determines the clinical services and prescriptive privileges for individual pharmacists.  State governments generally may not regulate the activities of the Federal Government, and furthermore, Federal employees, when acting within the scope of their Federal employment, are not generally subject to state laws.  In instances where a pharmacist's licensure defines specific restrictions on prescribing, the pharmacy may identify another pharmacist or provider within the facility with appropriate privileges to prescribe.

The IHS recognizes the valuable contribution of pharmacists in increasing access to care, acting as safety net providers, and operating at the highest level of clinical practice, especially in times of physician shortages.  These valuable components combine to improve program and agency sustainability, as pharmacy direct care services are reimbursable through third-party payers, and pharmacists are recognized billable providers in a multitude of government and private systems. 

As health care continues to evolve, the IHS will continue to support the expansion of pharmacist-delivered health care services for its beneficiaries.

Effective Date

This SGM becomes effective on the date signed.

Supersedure

This SGM supersedes all previous emails on the IHS Prescriptive Authority of Pharmacists Policy Statement.

/Roselyn Tso/
Roselyn Tso
Director
Indian Health Service