Original Post: May 3rd @ 3:20pm
Dear Florida Pharmacists and Pharmacies:
Today following Governor Scott’s Executive Order declaring the opioid epidemic a state of emergency in Florida, Dr. Philip, State Surgeon General, declared a public health emergency and issued a naloxone standing order for emergency responders. http://ww10.doh.state.fl.us/pub/bop/Executive%20Order%2017146.pdf
The order authorizes pharmacists who maintain a current active license practicing in a pharmacy located in Florida that maintains a current active pharmacy permit to dispense naloxone to emergency responders for administration to persons exhibiting signs of opioid overdose. Emergency responders include law enforcement officers, firefighters, paramedics and emergency medical technicians.
The pharmacy must maintain a copy of the Naloxone Standing Order if dispensing naloxone pursuant to the order.
Incorporated in the Naloxone Standing Order is the expectation that the SAMHSA Opioid Overdose Prevention Toolkit Five Essential Steps for First Responders be followed.
If you have any questions, please contact Board of Pharmacy staff at (850) 245-4292.
Erica White, MBA, JD
FREQUENTLY ASKED QUESTIONS
GOVERNOR’S EXECUTIVE ORDER 17-146 AND DEPARTMENT OF HEALTH’S STATEWIDE STANDING ORDER FOR NALOXONE
EXECUTIVE ORDER FAQs
- How long will the Executive Order be in effect?
Response: Executive Order shall expire sixty days from May 3, 2017, unless extended.
- Who will be providing reimbursements for the Naloxone?
Response: The process for reimbursement is still being established. The Executive Order directs that sufficient funds be made available, as needed, by transferring and expending moneys appropriated for other purposes, moneys from unappropriated surplus funds, or from the Budget Stabilization Fund.
STANDING ORDER FAQs
- How long will the Standing Order be in effect?
Response: The Standing Order shall expire sixty days from May 3, 2017, unless extended.
- What is the Emergency Treatment and Recovery Act?
Response: The Emergency Treatment and Recovery Act is found in Section 381.887, Florida Statutes. The Act provides for the prescription of an emergency opioid antagonist to patients and caregivers, and encourages the prescription of emergency opioid antagonists by authorized health care practitioners.
- What is an emergency opioid antagonist?
Response: “Emergency opioid antagonist” is naloxone hydrochloride or any similarly acting drug that blocks the effects of opioids administered from outside the body, and that is approved by the United States Food and Drug Administration for the treatment of an opioid overdose.
- Who is authorized to prescribe and dispense an emergency opioid antagonist under the Act?
Response: An authorized health care practitioner may prescribe and dispense an emergency opioid antagonist to a patient or caregiver, and pharmacists may dispense an emergency opioid antagonist pursuant to such a prescription or pursuant to a non-patient-specific standing order for an auto injection delivery system or intranasal application delivery system.
- Who can administer an emergency opioid antagonist under the Act?
A patient or caregiver is authorized to store and possess approved emergency opioid antagonists and, in an emergency situation when a physician is not immediately available, may administer the emergency opioid antagonist to a person believed in good faith to be experiencing an opioid overdose, regardless of whether that person has a prescription for an emergency opioid antagonist.
STANDING ORDER FAQs (FOR PHARMACISTS)
- Does the Standing Order only apply to pharmacies that are licensed in Florida?
- What should pharmacists document when they dispense Naloxone under the Standing Order?
Response: Rule 64B16-27.800, Florida Administrative Code, provides that a patient record system shall be maintained by all pharmacies for patients to whom new or refill prescriptions are dispensed. Due to the uniqueness of the implementation of the Standing Order, it is recommended that pharmacists show the “patient” as the emergency responder obtaining the Naloxone formulation, and the “prescriber” as Dr. Celeste Philip, for the purposes of entering the necessary information into their individual patient record system.
- What are the approved options for dispensing Naloxone under the Standing Order?
Response: Under the Standing Order, approved options for dispensing Naloxone formulations are Intranasal or Auto-Injector administration.
- Are there any legal ramifications for pharmacists who dispense Naloxone under the Standing Order?
Response: Immunity from civil liability is provided under Section 768.13, Florida Statutes, the Good Samaritan Act, to any person, including health care practitioners and emergency responders, who possess, administer, or store an approved opioid antagonist in accordance with the Emergency Treatment and Recovery Act. In addition, a health care practitioner acting in good faith and exercising reasonable care is not subject to discipline under the applicable professional licensure statute, and is also immune from civil or criminal liability for prescribing or dispensing an opioid antagonist in accordance with the Act.
- Should pharmacists require that those requesting Naloxone under the Standing Order show that they are an emergency responder? How does the pharmacist prevent fraud?
Response: No. Under the Standing Order a Naloxone formulation would only be dispensed to emergency responders for administration to persons exhibiting signs of an opioid overdose. The definition of emergency responder is broad and need not be proven under the terms of the Standing Order.
STANDING ORDER FAQs (FOR FIRST RESPONDERS)
- Who is considered an Emergency Responder under the Standing Order?
Response: Emergency responders include, but are not limited to, law enforcement officers, firefighters, paramedics, and emergency medical technicians.
- Does a person have to show proof as an Emergency Responder in order to receive the Naloxone under the Standing Order?
Response: No; however, a pharmacist may request that a person show proof that they qualify as an emergency responder, for the purposes of documenting this information in their patient record system.
- Do those requesting Naloxone under the Standing Order need a prescription?
Response: No. The Standing Order serves as the “prescription” for purposes of dispensing Naloxone in the formulations found in the Standing Order. A pharmacy must only maintain a copy of the Standing Order in order to dispense Naloxone formulations.
- What is the SAMHSA Opioid Overdose Prevention Toolkit Five Essential Steps for First Responders?
Response: The Substance Abuse and Mental Health Services Administration (SAMHSA) Opioid Overdose Prevention Toolkit may be found by clicking on the following link:
The Five Essential Steps for First Responders are:
Step 1: Call for Help (Dial 911)
Step 2: Check for Signs of Opioid Overdose
Step 3: Support the Person’s Breathing
Step 4: Administer Naloxone
Step 5: Monitor the Person’s Response