What a CPA actually is
A Collaborative Practice Agreement is a written agreement between a pharmacist and a physician (or a group of physicians) that authorizes the pharmacist to perform specific clinical activities under the physician's general or direct supervision. The activities are negotiated between the two parties. The agreement is signed by both. And once it is in place, the pharmacist has legal authority to do things that would otherwise require physician intervention for every decision.
The most common activities covered by a CPA include prior authorization delegation, medication therapy management, chronic disease state monitoring, immunizations in some states, medication adjustment within defined parameters, and patient education programs. Some states allow more. Some allow less. The scope is defined by your state's pharmacy practice act.
The reason this matters for your business is simple. Prior auth delegation alone can generate meaningful recurring revenue if you are doing it for multiple physicians. MTM services can unlock per-encounter billing through Medicare Part D plans and some commercial insurers. And the relationship you build with a physician who signs a CPA with you is worth more than any single script because it establishes you as a clinical partner, not a vendor.
Most independent pharmacy owners I talk to have never set up a CPA because they think it requires lawyers, Board of Pharmacy approval, and some kind of formal certification. None of that is true in most states. A CPA is a simple written agreement between two professionals. You can draft it yourself, review it with legal counsel for a few hundred dollars if you want, and have it signed in under a month. The barrier is not complexity. It is that nobody told you this was an option.
The two revenue opportunities that matter most
1. Prior authorization delegation
Prior authorizations are one of the most hated parts of medical practice. Physicians and their office staff spend hours every week filling out PA forms for medications they have already prescribed, waiting for approval, and fighting denials. Most primary care offices would happily pay to make this problem go away or at least to push the work to someone else.
Through a CPA that includes PA delegation as a prescriber delegate, your pharmacist can complete PAs on behalf of the physician using tools like the Surescripts Provider Portal. You are not prescribing the medication. You are handling the administrative work required to get it approved. That is billable work in most arrangements, and even when it is not directly billable, it is a relationship-building service that makes you irreplaceable to the physician.
There are two ways to structure the billing side. Some pharmacies bill the physician practice directly on a per-PA or monthly retainer basis. Others treat the PA work as a value-add service that supports higher dispensing volume from the physician in exchange. Both models work. The first is more scalable. The second is easier to start with because it requires no money to change hands.
2. Medication Therapy Management
MTM is a formal clinical service where a pharmacist reviews a patient's entire medication regimen, identifies problems, recommends changes, and documents the intervention. Medicare Part D plans are required to offer MTM to certain patients and they pay pharmacies to provide the service. The rates vary by plan and encounter type but most MTM encounters pay between $10 and $75 per patient depending on the complexity and the plan.
The math on MTM is interesting. A pharmacist who spends 20 minutes on an MTM encounter at a $50 reimbursement is making $150/hour for that time. That is dramatically better than the dispensing margin on most prescriptions. A pharmacy that runs a disciplined MTM program with 40 to 60 encounters per month is generating $2,000 to $3,000 in additional monthly revenue from work that improves patient outcomes at the same time.
The CPA is what formalizes the relationship between the pharmacy and a local physician's patients for MTM purposes. The physician refers patients to the pharmacist. The pharmacist conducts the review. Documentation goes back to the physician and into the medical record. Everyone wins.
The legal framework (and why it varies by state)
CPAs are authorized under state pharmacy practice acts. Every state allows some version of them but the specifics vary widely. In some states CPAs can authorize pharmacists to adjust dosing, discontinue medications, order lab tests, and manage chronic disease states. In other states the scope is much narrower and limited to specific activities. A handful of states require the CPA to be filed with the state Board of Pharmacy. Most do not.
Before you draft or sign any CPA, you need to know what your state allows. The easiest way to find out is to look up your state's pharmacy practice act and search for "collaborative practice" or "collaborative pharmacy practice." Most state boards have a dedicated page or FAQ on the topic. If your state is restrictive, that does not mean CPAs are impossible, just that the scope has to be adjusted to fit.
This guide and the template included below are educational resources, not legal advice. Collaborative practice agreements are legal documents governed by state-specific laws and regulations. Before implementing a CPA at your pharmacy, you should verify the requirements of your state pharmacy practice act, consult with a healthcare attorney if the scope of practice involves significant clinical activities, and confirm any documentation or filing requirements with your state Board of Pharmacy.
The template provided is a generic sample based on commonly used structures. It may not be appropriate for your specific situation, jurisdiction, or intended scope of practice. Do not use it as a finished legal document without review and customization.
The core components of a CPA
Every CPA needs to cover the same basic elements regardless of scope. If any of these are missing, the agreement will not serve its purpose legally or practically. Here is what has to be in every CPA you draft.
How to approach a physician about a CPA
This is where most pharmacy owners freeze up. The idea of walking into a physician's office and asking them to sign a legal document feels presumptuous. It should not. What you are actually offering is a service that saves the physician time and improves their patient outcomes. The ask is on their side, not yours.
Here is the approach that works in practice. Do not lead with the CPA itself. Lead with the problem you solve.
Step 1: Start with the prior auth pain
Call or visit the office of a physician who sends you regular business. Ask to speak with the office manager or the physician directly. Here is the line that works:
Almost every office will be interested in continuing the conversation because PA burden is universal. The conversation from there goes in one of two directions. Either they want to know more immediately, or they want to talk to the physician first and get back to you. Both are good outcomes.
Step 2: Explain what a CPA does
Once you have their attention, explain that the way you handle PAs legally is through a Collaborative Practice Agreement. This is a standard document used in pharmacy clinical services that authorizes you to act as a prescriber delegate for specific administrative tasks. Make it sound routine, because it is.
If they ask whether this is complicated or requires legal review on their end, be honest. Most CPAs are reviewed by the physician personally, not by their attorney, because the scope of activities is limited and the risk to the physician is low. Some larger practices or hospital-affiliated offices will route it through legal, which can add a few weeks. Plan for both scenarios.
Step 3: Bring the template
Show up to the second meeting with a draft CPA that you have already filled out as much as possible. The physician name, the pharmacy name, the addresses, the scope of practice checked off. Leave the signature lines blank and let them review it. Having a complete draft demonstrates that you know what you are doing and turns the conversation from a hypothetical into a decision.
Step 4: Offer to pilot with MTM if PAs are not enough
Some physicians will want more than PA delegation. They will want to know if you can also do MTM or help with chronic disease monitoring. This is a good conversation to have. Medicare Part D MTM is reimbursable work that helps their patients. Offering to pilot MTM with their 10 highest risk patients is a low-commitment way to get started and proves the value before anyone commits to a broader program.
The sample template
Below is a sample CPA template based on commonly used language for pharmacist-led clinical services. It covers PA delegation and MTM as the core authorized activities. You can copy it directly, adapt it for your practice, and use it as your starting draft.
Remember the legal disclaimer at the top of this guide. This is a starting point. Review it with legal counsel if you are uncertain and verify the scope against your state pharmacy practice act before you ask anyone to sign.
Collaborative Practice Agreement for Pharmacist-Led Clinical Services
Date of Implementation:
Parties
PharmacyName:
Address:
Phone: Fax:
Name:
License Number:
Name:
License Number:
Name:
Practice Name:
Address:
NPI:
Purpose and Background
The Pharmacy Practice Act allows pharmacists to practice under direct or general supervision of a physician through a Collaborative Practice Agreement. This agreement authorizes the named clinical pharmacist(s) to perform the clinical activities selected below on behalf of patients of the named physician(s), for the purpose of enhancing collaborative patient care and improving medication-related outcomes.
Under this agreement, the named pharmacy will provide the selected services as defined. This agreement does not include payments between parties unless specifically addressed in a separate written addendum.
Authorized Clinical Activities
The physician authorizes the clinical pharmacist(s) named above to perform the following activities (check all that apply):
Prior Authorization Completion as Prescriber Delegate — using the Surescripts Provider Portal or equivalent electronic system
Medication Therapy Management (MTM) — including comprehensive medication reviews, targeted medication reviews, and documentation of interventions
Medication Adherence Support — including follow-up with non-adherent patients and communication of findings to the physician
Chronic Disease State Monitoring — limited to disease states and parameters agreed to in writing between the parties
Other:
Scope of Practice
Clinical activities provided by the clinical pharmacist under general or direct supervision of the physician will include:
- Reviewing the patient's medical profile from the EHR/EMR, if made available, for the purpose of providing patient care activities as defined by this agreement
- Obtaining medication histories to identify changes in medication regimens, recognize drug-related problems, and identify drug interactions, adverse reactions, and adherence issues
- Providing Medication Therapy Management as directed by the physician and in accordance with Medicare Part D and other applicable payer requirements
- Completing prior authorization requests on behalf of the physician as a prescriber delegate
- Documenting all clinical activities in the appropriate system and communicating findings to the physician as agreed
Referral Process
The physician may refer any patient they feel would benefit from pharmacy clinical services. Referrals may be made by any of the following methods: direct verbal referral, written referral form, or documentation in the shared EMR with a flag for pharmacy review. The pharmacist will acknowledge receipt of each referral within one business day.
Documentation Requirements
The clinical pharmacist will document all activities performed under this agreement in the appropriate system. Prior authorization activities will be documented in the Surescripts Provider Portal. Medication Therapy Management interventions will be documented in the pharmacy's clinical documentation system and summarized in a report sent to the physician at least monthly, or upon request.
Supervision and Quality Review
Clinical activities performed under this agreement will be reviewed at least quarterly by the physician and the clinical pharmacist. The parties will meet or communicate in writing to discuss any issues, review sample documentation, and adjust the scope of practice as needed.
The physician will be available for consultation on any patient matter that falls outside the scope of this agreement or that the clinical pharmacist feels requires physician attention.
Modification and Termination
This agreement may be modified at any time by mutual written consent of the clinical pharmacist(s) and the physician. Either party may terminate this agreement with thirty (30) days written notice to the other party. Upon termination, the clinical pharmacist will cease performing activities under this agreement immediately.
Term of Agreement
This agreement will remain in effect from the date of implementation indicated above until terminated or modified by mutual consent. It will be reviewed annually for relevance and appropriateness.
By signing below, the parties agree to the terms of this Collaborative Practice Agreement.
Pharmacy RepresentativeName:
Title (Owner/Manager):
Name:
Practice Name:
What to actually do with this template
Do not just fill it out and hand it to the first physician who walks by. Here is the sequence I recommend.
- Customize the template for your pharmacy. Put your pharmacy name, address, pharmacist names, and license numbers in the appropriate fields. Save this as your master template.
- Verify the scope against your state pharmacy practice act. Make sure every activity checked in the agreement is legally allowed in your state. If your state does not permit a specific activity, remove it from the template before using.
- Optional: have a healthcare attorney review it. If you are planning to implement MTM or chronic disease monitoring at significant scale, a short consult with a healthcare attorney is worth the money. For pharmacies starting with just PA delegation, the risk is low enough that legal review is nice to have but not essential.
- Identify three to five physician targets. Start with physicians who already send you regular business. They trust you already and the conversation is easier.
- Schedule meetings. Call or visit their offices. Have the draft template filled in as much as possible before you arrive.
- Close one CPA before pursuing the others. Your first CPA is the hardest because you are learning the process. Once you have one physician signed and the workflow running, the second and third are dramatically easier.
Common mistakes I see
- Making the scope too broad. Owners get excited and check every box on the agreement. Then they have authorized a scope of practice they are not actually equipped to deliver. Start narrow. Expand later.
- Not involving the pharmacist. The pharmacist whose name is on the agreement needs to be involved in designing the scope and comfortable with every activity. If the pharmacist is not bought in, the program will fail no matter how good the agreement looks on paper.
- Skipping the supervision and review language. Some owners try to write the agreement so tightly that the physician has no ongoing responsibility. Physicians will not sign those agreements. The supervision language is what makes the physician comfortable that they are not signing away their license.
- Forgetting to document the workflow. Having a CPA does not automatically mean you are prepared to do the work. You need SOPs for how PA requests will flow from the physician to the pharmacy, how MTM encounters will be scheduled, how documentation will be shared back. Build the workflow before you sign the agreement, not after.
- Not billing for the work. Some pharmacies set up CPAs, do the work, and never figure out how to get paid for it. Decide up front whether you are billing the practice directly, billing through Medicare Part D for MTM, or treating the service as relationship building. Whatever the answer is, make it intentional.
- Signing without reviewing annually. The CPA is supposed to be reviewed at least annually. Most pharmacies sign one and never look at it again. Put a calendar reminder for the annual review and actually do it. Scope changes. Physician practice changes. Your team changes. The agreement has to evolve.
The bigger picture
Setting up CPAs with local physicians is one of the highest leverage moves an independent pharmacy can make in 2026. It is the difference between being a dispensing operation that anyone can replace and being a clinical partner that is woven into the fabric of local healthcare. The pharmacies that are thriving right now are the ones that figured out how to be more than just a place where prescriptions get filled. The CPA is a tool that lets you become that.
And the best part is that once you have one CPA signed, you have social proof for the next one. You can walk into the next physician office and say "I am already working with Dr. X across town on prior auth delegation, and she was happy to sign a simple agreement to set it up." That is a completely different conversation than the first one. The first CPA is the hard one. Everything after that is momentum.
Pull the template. Customize it for your pharmacy this week. Identify one physician to approach next week. Have the conversation. That is the entire roadmap.