Tennessee Expands Pharmacist Scope of Practice to Improve Healthcare Access

Tennessee has enacted one of the most comprehensive pharmacist scope-of-practice expansions to date, authorizing pharmacists to independently prescribe, test, and treat for select conditions to address healthcare access challenges. Effective May 1, 2024, Public Chapter 824 allows pharmacists to independently prescribe—without a collaborative practice agreement—for specific medication classes when statutory criteria are met, representing an evolution in pharmacy practice that reinforces the pharmacist's role as a frontline healthcare provider.

The legislation authorizes Tennessee pharmacists to independently prescribe antiviral agents for influenza and COVID-19 following a positive clinical laboratory improvement amendments (CLIA)-waived test, progesterone-only hormonal contraceptives, naloxone, epinephrine auto-injectors, HIV post-exposure prophylaxis (PEP), tuberculin purified protein derivative products, and topical fluoride products. This authority removes a significant administrative barrier that historically delayed care, particularly for acute and preventive services, allowing pharmacists to initiate therapy at the point of care and reducing reliance on urgent care centers and emergency departments for conditions that can be safely managed in the pharmacy setting.

Tennessee pharmacists may now administer all vaccines to adults aged 18 years and older as well as select immunizations to pediatric patients aged 3 to 17 years, including influenza and COVID-19 vaccines. Expanding immunization authority builds on pharmacists' demonstrated high vaccination capacity during the COVID-19 public health emergency and supports broader public health goals, including improved vaccination coverage in rural and medically underserved communities.

The legislation further authorizes pharmacists to perform and interpret CLIA-waived diagnostic tests for conditions such as streptococcal infections, influenza, and COVID-19, with pharmacists able to immediately initiate appropriate treatment following testing. These test-and-treat services represent a practical application of pharmacists' medication expertise and diagnostic training and can shorten time to treatment, reduce disease transmission, and improve patient satisfaction—particularly for patients facing long wait times for primary care appointments.

Although independent prescribing authority has broadened, Public Chapter 824 also enhances collaborative pharmacy practice agreements (CPPAs) by allowing greater flexibility in structure and scope. Pharmacists may now participate in diagnosis-driven or nondiagnosis-driven agreements, as well as patient-specific or population-based protocols, enabling pharmacies and health systems to design collaborative models tailored to local needs, including chronic disease management, preventive services, and transitions of care.

Tennessee recognized pharmacists as medical providers since 2017, enabling credentialing, referrals, and reimbursement through commercial insurers and Medicaid. Public Chapter 824 builds on this foundation by expanding the services pharmacists may independently deliver. The law was signed with the stated goal of reducing barriers to care, particularly in rural areas where provider shortages are most pronounced. Existing evidence from multiple states suggests that pharmacist-led prescribing and test-and-treat services are safe and effective when supported by clear regulatory frameworks and appropriate training.

Tennessee's approach highlights how states can leverage pharmacists to improve access to care without compromising quality or safety. For practicing pharmacists, the legislation underscores the importance of clinical readiness, documentation standards, and workflow integration to support expanded services. For policymakers and health system leaders, the Tennessee model offers a scalable strategy to address care gaps using an already accessible and trusted healthcare workforce.