Oregon
The West Coast Health Alliance, comprised of California, Hawaii, Oregon and Washington, jointly announced Consensus 2025-26 Respiratory Virus Immunization Recommendations for COVID-19, influenza and respiratory syncytial virus (RSV) vaccines. The recommendations state that immunization is safe and effective, and it offers the best protection available against respiratory viruses. The recommendations also endorse broad access to the COVID-19 vaccine for anyone who chooses protection.
Also in Oregon, at the Board of Pharmacy Special Meeting on September 17, the board adopted the following Temporary Rules and Vaccination Protocols:
September 17 Temporary Rule Noticed
- REPEALED – Standard Vaccination Protocol for Persons 3 through 6 Years of Age & Assessment and Treatment Care Pathway
- REPEALED – Standard Vaccination Protocol for Persons 6 Months through 2 Years of Age & Assessment and Treatment Care Pathway
- Div 102 – Board Delegated Limited Authority for Vaccine Protocol rules *Effective September 17
Email all rulemaking related inquiries to pharmacy.rulemaking@bop.oregon.gov.
Also in Oregon, the Division of Financial Regulation issued Bulletin No. DFR 2025-6 regarding coverage of the COVID-19 vaccination. This bulletin clarifies the division's expectations around the coverage of COVID-19 vaccination by health benefit plans in the state in accordance with Bulletin No. DFR 2021-1. For more information, please visit the FAQs about COVID-19 vaccine insurance coverage requirements related to the West Coast Health Alliance.
Finally in Oregon, the Board of Pharmacy posted its agenda and meeting materials for the October 8-10 meeting. Please note on October 8 the board will meet in Executive Session for most of the day and anticipates resuming Open Session around 4:30 pm and on October 9 the board anticipates meeting in Executive Session after roll call and resuming Open Session at 1:00 pm. The board anticipates meeting in Open Session on October 10 and will break for lunch between 12:00 noon-1:00 pm. Please be advised that additional meeting materials may be added to the agenda prior to the board meeting. Visit the board website for current meeting materials.
For more information, contact NACDS’ Sandra Guckian at 703-774-4801.
South Carolina
The Board of Medical Examiners has approved revisions to the SC Protocol for Administration of Vaccines by Pharmacists effective September 17. These changes follow recommendations from the Joint Pharmacist Administered Vaccines Committee on September 15.
Key Update:
Pharmacists, pharmacy interns, and eligible pharmacy technicians are now authorized to administer FDA-approved COVID-19 vaccines without a licensed practitioner's order, provided administration follows recommendations from one of the following:
- ACIP (Advisory Committee on Immunization Practices)
- AAP (American Academy of Pediatrics)
- AAFP (American Academy of Family Physicians) or
- ACOG (American College of Obstetricians and Gynecologists)
Important Reminders:
- Age restrictions still apply. As outlined in Appendix J, pharmacists may only administer FDA-approved or EUA COVID-19 vaccines to individuals 16 years of age and older, in accordance with guidelines from the groups above.
- All pharmacies must have a printed copy of the most current protocol in the area where vaccines are administered.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
Tennessee
Certification of low-volume status must be submitted to each PBM you work with by December 1 annually to ensure you receive the low-volume dispensing fee. The Department of Commerce & Insurance (TDCI) rules 0780-01-95-.01(1) outlines requirements for submitting such certifications, including submitting proof of the pharmacy’s actual prescription volume from July 1, 2024 to June 30, 2025.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
Texas
Gov. Greg Abbott (R) signed into law HB 25, legislation allowing pharmacists to dispense ivermectin without requiring a prescription order from a licensed healthcare practitioner effective December 4.
The second 30-day special legislative session ended early on September 4.
Also in Texas, the Health and Human Services Commission (HHSC) sent CMS a state plan amendment regarding substitutions when there are drug shortages. Considering CMS is encouraging states to do this, Texas is expecting quick approval.
Also in Texas, the Board of Pharmacy posted the agenda for the September 25 Prescription Monitoring Program (PMP) Advisory Committee meeting.
Also in Texas, the Health and Human Services Commission (HHSC) Vendor Drug Program (VDP) is currently accepting stakeholder comments on requiring a prescription for the COVID-19 At-Home Test Kit. Currently, at-home COVID-19 test kits are available without a prescription. The policy change includes requiring a prescription for test kits filled and dispensed for members in Medicaid and CHIP. HHSC does not propose changing the quantity limit of a maximum of four test kits per month.
Also in Texas, the Department of State Health Services (DSHS) issued a Texas COVID-19 Vaccine Information Statement, outlining the benefits, risks, development process, long-term studies, legal protections and adverse event reporting related to the COVID-19 vaccine. Pharmacies are required to provide patients with this document and obtain written informed consent from the patient as a result of HB 4535, which took effect on September 1.
Finally in Texas, NACDS submitted the state survey on the Rural Health Transformation Program funds.
For more information, contact NACDS’ Mary Staples at 817-442-1155.
Vermont
The Board of Pharmacy met in a special meeting on September 17 to approve a revision of the State Pharmacist Prescribing Protocol for COVID 19 and Influenza Vaccines Ages 5 and Up.
- The Purpose of updating this protocol is to remove requirements that COVID vaccines are only administered based on ACIP recommendation. Essentially removing the tie to ACIP.
- Technicians will still be able to administer vaccines
For more information, please contact NACDS’ Mike Sargent at 207-272-6435.
Washington
The Department of Health (DOH) issued a COVID-19 Vaccine Standing Order authorizing health care providers to administer the most updated versions of the COMIRNATY, MNEXSPIKE, SPIKEVAX and NUVAXOVID COVID-19 vaccines to all persons aged 6 months and older, including pregnant individuals.
Also in Washington, the Health Care Authority is continuing to solicit Rural Health Transformation Program (RHTP) input through September 26 at 5:00 pm Pacific time. Written comments are limited to 10 pages or less. Slides or other formats are welcome. Specifically, they want to meet the needs of Washington's rural communities:
- Projects with an implementation plan that are ready to launch soon
- Input about community needs and regional trends
- Recommendations for leveraging RHTP funds
- Initiatives to transform rural health care delivery
- Opportunities to support workforce, infrastructure and technology
Finally in Washington, Gov. Bob Ferguson (D) joined the Oregon, Hawaii and California governors known as the West Coast Health Alliance (WCHA), announced coordinated winter virus vaccination recommendations to include the 2025–26 COVID-19 vaccine, influenza and RSV.
For more information, contact NACDS’ Mary Staples at 817-442-1155.
Wyoming
The Department of Health is conducting a series of public meetings to gather input on rural healthcare challenges, strengths and opportunities. Please note, later this fall, the Department of Health will release a statewide survey to collect additional input and help refine Wyoming's priorities for the application. These engagement opportunities will be posted to the Department of Health site for this project.
Also in Wyoming, the Department of Health announced, effective September 2, Jesse Springer has been appointed the state's Interim State Medicaid Agent and Senior Administrator for the Division of Health Care Financing. This division oversees Medicaid and the Children's Health Insurance Program (CHIP).
For more information, contact NACDS’ Sandra Guckian at 703-774-4801.
California
The Department of Health Care Services posted the following:
- August 2025 Pharmacy Medi-Cal Update Bulletin
- August 2025 Durable Medical Equipment and Medical Services Medi-Cal Update Bulletin
For more information, contact NACDS’ Sandra Guckian at 703-774-4801.
Florida
The proposal to roll back certain school vaccine requirements will not take effect for at least 90 days, according to the state health department. The initial changes would apply only to chickenpox and a few other illnesses, while any expansion to include diseases, such as polio and measles would require legislative action.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
Kentucky
MedImpact, the state’s single PBM, announced that beginning September 28 they will cover and reimburse certain new COVID vaccines and issued an updated protocol.
For more information, contact NACDS’ Jill McCormack at 717-592-8977.
New York
Effective September 1, 2025, NYRx, the state's Medicaid Pharmacy program, announced coverage for the 2025-2026 formulations of the COVID-19 vaccine. Effective September 5, 2025, in accordance with the Executive Order #52 and the guidance issued by the Commissioner of Health, pharmacists are authorized to order patient-specific orders for COVID-19 vaccination for patients aged 3 years and older for off-label usage of COVID-19 vaccine. See Advisory Immunization Notification titled 2025-20206 COVID-19 Guidance for Pharmacists located at https://commerce.health.ny.gov. Enrolled pharmacy providers will be reimbursed for vaccine cost and administration when administered to eligible members. Pharmacies will bill NYRx using the National Council on Prescription Drug Programs (NCPDP) D.0 format.
The Department has since then issued an update on non-patient specific standing order for the administration of the Pfizer-BioNTech updated COVID-19 vaccine (2024-2025 Formula) for persons 5 years of age and older by pharmacists.
For more information, please contact NACDS’ Mike Sargent at 207-272-6435.
Minnesota
Gov. Tim Walz (D) issued an executive order (EO) to address the state’s intention to ensure that vaccine access is preserved and expanded. The EO directs various government agencies to investigate ways to expand access to payment for vaccines. NACDS intends to work with members and state partners to advocate for strengthening pharmacy vaccine reimbursement.
For more information, contact NACDS’ Jill McCormack at 717-592-8977.
Pennsylvania
In the wake of the massive pharmacy closures across the Commonwealth, the Senate Pharmacy Caucus held a briefing this week to discuss the crisis and examine models to reform Medicaid Managed Care pharmacy reimbursement that received widespread press coverage. NACDS and PACDS were heavily involved in preparation for the briefing, including drafting questions, providing supporting materials and meeting directly with the Senators and senior staff. Following the Department of Human Services' (DHS') testimony, the Senators, led by Caucus Chairs Judy Ward (R), Lisa Boscola (D) and Tina Tartaglione (D), aggressively grilled Secretary Val Arkoosh. They expressed strong exception to the Secretary's testimony that downplayed the role of Medicaid rates on pharmacy closures; their lack of awareness that chains operating in the greater Philadelphia metro area are receiving a $1.00 professional dispensing fee after the health plan raised it to $3.00 for independents; the fact that they are approving rates that don't comply with their MCO contract terms that require both the ingredient cost and professional dispensing fee to reflect pharmacies' actual costs. NACDS participated in the Pennsylvania Pharmacy Coalition panel that testified next, dismissing DHS' points and emphasizing that immediate pharmacy reimbursement is critical to protect patients' access to medications and healthcare services. Senators Ward and Boscola will soon introduce legislation backed by the Pennsylvania Pharmacy Caucus and drafted by NACDS, to require cost-based reimbursement under a non-conflicted, transparent single PBM model.
Also in Pennsylvania, a group of House Democratic health professionals announced that they introduced legislation that would protect Pennsylvanians' access to recommended vaccines. HB 1828 would require private insurers to cover vaccines that have been recommended by the Pennsylvania Department of Health, based on the vaccine guidelines of professional medical societies, including the American Academy of Pediatrics, the American College of Obstetricians and Gynecologists, the American College of Physicians, the American Academy of Family Physicians, the Infectious Diseases Society of America and the Society for Maternal-Fetal Medicine.
For more information, contact NACDS’ Jill McCormack at 717-592-8977.
South Carolina
Gov. Henry McMaster (R) has issued an executive order prohibiting the use of SNAP (Supplemental Nutrition Assistance Program) benefits to purchase candy, energy drinks, soft drinks and other sweetened beverages. The order directs the Department of Social Services to submit a waiver request to the USDA Food and Nutrition Service to implement the policy.
The executive order also provides specific definitions for candy, energy drinks, soft drinks and sweetened beverages, while outlining certain exceptions.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
Tennessee
Effective October 1, TennCare will cover OTC medications and supplements at a GPI (generic product identifier) level rather than by specific NDCs. Please review this document for additional information and instructions on how to dispense such products.
Also in Tennessee, TennCare distributed an updated Preferred Drug List (PDL) that was effective on September 1. Additional TennCare updates are available online. Subscribe to the TennCare Pharmacy Updates newsletter to receive updates directly from TennCare.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
Virginia
On September 10, the Department of Health issued a standing order authorizing the dispensing and administration of COVID vaccines to adults.
For more information, contact NACDS’ Jill McCormack at 717-592-8977.
Colorado
The Department of Public Health Environment issued a Public Health Order and Standing Order today to address COVID-19 vaccine administration. These orders enable all vaccine providers to administer these vaccines in accordance with the Standing Order, eliminating the need for additional prescriptions. In addition to the Public Health Order and Standing Order, the Colorado State Board of Pharmacy will engage in emergency rulemaking on Friday, September 5, to adopt changes to Rule 3 and 19 to allow for continuity of vaccinations, especially COVID, thus ensuring that pharmacists, pharmacy interns, and pharmacy technicians may continue to prescribe, dispense and administer vaccinations in accordance with applicable Colorado Revised Statutes.
For more information, contact NACDS’ Mary Staples at 817-442-1155.
Florida
Under Constitutional Amendment No. 2, approved by voters in 2020, Florida's minimum wage will rise again this fall. Beginning September 30, 2025, the state minimum wage will increase from $13.00 to $14.00 per hour.
The amendment requires annual increases until the rate reaches $15.00 per hour by September 30, 2026. This applies to all employers in Florida—public and private—regardless of size.
Employers must also update required workplace postings to reflect the new wage. Updated posters will be made available for download once released.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
Illinois
Gov. J.B. Pritzker (D) has signed HB3637, authorizing health care professionals to prescribe any drug approved by the FDA before 2025 that continues to carry World Health Organization approval. The law is designed to safeguard access to abortion medication in the event of future FDA restrictions.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
Indiana
The Family and Social Services Administration (FSSA) Medicaid announced that based on the results of a recent cost of dispensing survey, they plan to reduce the dispensing fee by 8%, lowering it from $10.48 to $9.63, effective March 1, 2026. NACDS will submit comments by September 19, 2025, the deadline, and encourages members to do so too.
For more information, contact NACDS’ Mary Staples at 817-442-1155.
Massachusetts
The Department of Public Health has recently issued a standing order allowing for all qualified pharmacy personnel at Massachusetts pharmacies to dispense and administer COVID-19 vaccine in Massachusetts to all eligible persons.
For more information, please contact NACDS’ Mike Sargent at 207-272-6435.
Mississippi
Effective October 1, 2025, House Bill 1463 requires all sellers of pseudoephedrine products in the state to participate in the NPLEx electronic tracking system. Products from manufacturers that do not participate will no longer be processed through NPLEx after that date.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
North Carolina
Effective Sept. 28, 2025, NCTracks is implementing a new attestation process for Individual and Atypical Individual providers as part of initial enrollment, re-enrollment and reverification applications submitted through the secured provider portal of NCTracks. This change aligns with the National Committee for Quality Assurance (NCQA) standards.
Also in North Carolina, NCTracks will capture an Individual provider's race, ethnicity, and languages spoken during Individual provider enrollment, re-enrollment, manage change requests, and reverification applications.
Responses will not be shared outside of the North Carolina Department of Health and Human Services and will be used only for internal purposes.
For questions, please contact the NCTracks Contact Center at 1-800-688-6696.
Also in North Carolina, the Board of Pharmacy has published its list of seven pages of rules and determined that every one of these rules are necessary except for some rules dealing with administrative or operational conduct of the Board of Pharmacy. These rules are not being amended but are being readopted, as necessary. The comment period ends for these rules on Thursday, September 11, 2025. Here is a link to all of the rules under review .
Any person wishing to submit public comments must do so by September 11, 2025. Submit written comments by mail to Jay Campbell, Executive Director, North Carolina Board of Pharmacy, 6015 Farrington Road, Suite 201, Chapel Hill, NC 27517; by fax (919) 246-1056; or by e-mail ncboprulemaking@ncbop.org.
For more information, contact NACDS’ Leigh Knotts at 803-243-7207.
Texas
The second 30-day special legislative session convened on August 26, 2025.
Also in Texas, HB 25, legislation allowing pharmacists to dispense ivermectin without a prescription, was signed into law by Gov. Greg Abbott (R). The bill requires the Board of Pharmacy (TSBP) to adopt standardized procedures and protocols for pharmacists to follow.
Also in Texas, HB 7, legislation that strengthens existing law on abortion-inducing drugs, will allow private citizens to sue anyone who manufactures, distributes, mails or provides abortion medication to or from Texas, passed the House and is awaiting final approval in the Senate before heading to Gov. Greg Abbott's (R) desk.
Finally in Texas, HB 4535, which passed during the regular session and went into effect on September 1, 2025, is aimed at ensuring that Texans are equipped with the information they need to make informed medical decisions by requiring written informed consent prior to any COVID-19 vaccination. The Department of State Health Service (DSHS) created a COVID-19 Vaccine Information Statement to be used as a handout at the pharmacy to comply with the law.
For more information, contact NACDS’ Mary Staples at 817-442-1155.
California
The Board of Pharmacy provided the following August 26, 2025, Update. It is being shared here in its entirety.
California Medication Error Reporting (CAMER)
Pursuant to Business and Professions Code section 4113.1
Business and Professions Code (BPC) section 4113.1 establishes requirements for a community pharmacy to report medication errors to an entity approved by the Board. The Board refers to this as the California Medication Error Reporting (CAMER) system. The statute requiring reporting to CAMER can be viewed at BPC section 4113.1.
In September 2024, the Board approved the Institute for Safe Medication Practices (ISMP), an ECRI Company, as the entity to receive and review medication error reports under BPC section 4113.1. Consistent with its commitment to keep licensees apprised of implementation activities, in April 2025, the Board announced the availability of information about how community pharmacies can register with ISMP to report medication errors to the California Medication Error Reporting (CAMER) system. To continue its communication with licensees, the Board advises licensees that medication errors that occur on or after September 1, 2025, must be reported to the CAMER system consistent with legal requirements established.
The API to allow for direct, electronic submission of medication errors to the California Medication Error Reporting (CAMER) systems will be available beginning Friday, August 29. 2025. If you are interested in implementing the API in your internal reporting system, please email the Institute for Safe Medication Practices at: clientservices@ecri.org.
For individual pharmacies that want to implement the API, please include the following information in your communication:
- Pharmacy name (as listed on the pharmacy license)
- Pharmacy license number
- Please confirm that this is for an individual pharmacy and the pharmacy is not part of a parent organization who will be reporting on behalf of the pharmacy
For organizations and Patient Safety Organizations (PSO) that will implement the API to report on behalf of multiple pharmacies, we will need to understand the hierarchy or relationships between individual pharmacies and the parent organization and/or PSO. Please include the following information in your communication:
- Name of the parent organization and/or PSO
- A list of the pharmacies on whose behalf you will be reporting
- Please provide both the pharmacy names (as listed on the pharmacy license) and license numbers
- Please provide details as to the relationship between the individual pharmacies, any multi-pharmacy organizations, and your organization
Once we confirm the above information and the correct relationships, if any, between individual pharmacies and parent organizations is established, an API key to use for testing purposes during the organization’s internal development process will be issued via encrypted email.
When the organization has completed their internal development and testing, they can contact ISMP for a new API key to use for submission of medication error reports. The API used during development and testing will be discontinued.
The API technical documentation to use for development will be posted by Friday, August 28, 2025 in the Frequently Asked Questions section at: https://mederrors.ismp.org/products/ca-board-of-pharmacy-error-reporting.
For more information, contact NACDS’ Sandra Guckian at 703-774-4801.
