Pharmacy Support Persons (PSP)

Unless exempt in 657 IAC 5.5, any individual employed by a pharmacy who has direct access to prescription drugs or confidential patient information must be registered as a pharmacy support person.

Effective May 12, 2021, 657 IAC 5 went into effect which now requires pharmacy employees which are solely employed for delivery functions to be registered with the Board of Pharmacy as a pharmacy support person.

Using the pharmacy’s established policies and procedures and the supervising pharmacist’s professional judgment, a supervising pharmacist may delegate nontechnical functions in the operation of the pharmacy (except those prohibited by 657 IAC 5.17, to an appropriately trained and registered pharmacy support person).

The pharmacist must be on site and available to supervise the pharmacy support person when delegated functions are performed, except as provided in 657 IAC Chapter 6.7 or Chapter 7.6.

The ultimate responsibility for the actions of a pharmacy support person shall remain with the supervising pharmacist. A pharmacy license holder shall not infringe on the authority of a supervising pharmacist to delegate or decline to delegate specific nontechnical functions to a pharmacy support person based on the supervising pharmacist’s professional judgment regarding the knowledge and training of the pharmacy support person.

A PSP is not authorized to perform any of the following functions:

1. Provide the final verification for the accuracy, validity, completeness, or appropriateness of a filled prescription or medication order.
2. Conduct prospective drug use review or evaluate a patient’s medication record for purposes identified in rule 657—8.21(155A).
3. Provide patient counseling, consultation, or patient-specific drug information; make an offer of patient counseling on behalf of the pharmacist; or accept a refusal of patient counseling from a patient or patient’s agent.
4. Make decisions that require a pharmacist’s professional judgment, such as interpreting or applying information.
5. Accept by oral communication any new or refill prescription authorizations communicated to a pharmacy by a prescriber or by the prescriber’s office or contact a prescriber to obtain prescription refill authorizations.
6. Provide a prescription or drug to a patient without a pharmacist’s verification as to the accuracy of the dispensed medication and without the physical presence of a pharmacist.
7. Package, pour, or place in a container for dispensing, sale, distribution, transfer, vending, or barter any drug which, under federal or state laws, may be sold or dispensed only pursuant to the prescription of a practitioner authorized to prescribe drugs. This prohibited task includes the addition of water or other liquid for reconstitution of oral antibiotic liquids. A pharmacy support person may place a prescription container into a bag or sack for delivery to the patient as part of the sales transaction after the accuracy of the prescription has been verified by the pharmacist.
8. Affix required prescription labels upon any container of drugs sold or dispensed pursuant to the prescription of an authorized prescriber.
9. Process or enter, including entry into the pharmacy computer system, pertinent clinical patient or prescription information, including allergies and disease state information.
10. Prepackage or label multidose and single-dose packages of drugs, including dose picks for unit dose cart fills for hospital or long-term care facility patients.
11. Check or inspect drug supplies provided and controlled by an Iowa-licensed pharmacy but located or maintained outside the pharmacy department, including but not limited to drug supplies maintained in an ambulance or other emergency medical service vehicle, a long-term care facility, a hospital nursing unit, or a hospice facility.
12. Reconstitute prefabricated noninjectable medication, prepare parenteral products, or compound sterile or nonsterile drug products.
13. Communicate, transmit, or receive patient or prescription information to or from the pharmacy for the purpose of transferring a patient’s prescription between pharmacies.
14. Assist with or witness the destruction or wastage of controlled substances pursuant to 657—subrule 10.22(2).
15. Perform any technical functions pursuant to 657—Chapter 3 that may be delegated to a pharmacy technician.

Iowa rule requires that a registration be issued prior to commencing work in a secured pharmacy department. 

Employment means that you have been hired by a pharmacy to perform the duties of a PSP, not necessarily that you have actually started working in the secured pharmacy area. On the application, please identify the pharmacy that has hired you and the anticipated start date to begin working in the secured pharmacy area. If you have already started working in the secured pharmacy area, you must indicate the exact date that you started working in that capacity. As a reminder, you should not begin work in the secured pharmacy area until registered with the Board. Please be advised that applications can take 5-7 business days upon receipt of application to process and should be taken into consideration at the time of hire. If you continue employment as a PSP without a current registration, you (as well as the pharmacy and pharmacist in charge) may be subject to public discipline.

If you have been working for the company in another capacity, or working in the secured pharmacy area in another pharmacy position, but are just now to begin the duties of a PSP, indicate the anticipated start date you will begin or the actual start date you began to perform the duties of a PSP, not the initial date you were hired to work elsewhere with the company or to work in the pharmacy in another position.

You must indicate the licensed Iowa pharmacy where you have been hired, even if you have not started employment.

As part of the application process, you will be asked questions about prior criminal history and disciplinary actions.

If you have any questions concerning these requirements, please notify the Board office.  If any of these situations pertain to you, there may be delays in processing your application.  Please contact the Board office for information as to what documentation may be necessary for registration.  Contacting the Board office about any of these situations may avoid unnecessary delays issuing your registration.

Initial Applicants: You must disclose all convictions, regardless of where or how long ago they occurred.  Failure to disclose a criminal conviction could result in delays in processing or denial of your application.

Renewals: You are required to disclose only convictions from the time of your last application.

The following information is required to be submitted for any criminal conviction:

• Complete criminal record – At a minimum a copy of the criminal complaint and final court Order will be required.
  • Records can be obtained by contacting the Clerk of Courts in the county where the charges were filed.
• Personal statement explaining the criminal conviction and whether the conviction directly relates to the practice of pharmacy. A conviction is directly related to the duties and responsibilities of the profession if either (1) the actions taken in furtherance of an offense are actions customarily performed within the scope of the practice of pharmacy, or (2) the circumstances under which an offense was committed are circumstances customary to the practice of pharmacy.
• All evidence of rehabilitation that you wish to be considered.
  • This could include a description of the circumstances relative to the offense, including any aggravating and mitigating circumstances or social conditions surrounding commission of the offense, any treatment undertaken, any letters of reference, or anything else pertaining to the present fitness of the applicant.

Submitting print outs from Iowa Courts Online is not sufficient information.

You are strongly encouraged to perform a background check on yourself through Iowa Courts Online or to have your employer perform one prior to submitting your application. If any convictions that were not dismissed can be found on Iowa Courts, it is required that they are disclosed when applying.  Keep in mind that the Iowa Courts Online database only shows Iowa state court convictions. 

The list of the Board’s disqualifying convictions can be found in the Applications and Forms section below.

Please review 657 IAC Chapter 31 for more information.

An individual who has not yet submitted a completed a registration application may petition the Board for a determination of whether one or more of the individual’s convictions are disqualifying offenses that would render the individual ineligible for registration.

An individual with a conviction is not required to petition the Board for an eligibility determination prior to applying for a registration.

To petition the Board for an eligibility determination of whether one or more of the petitioner’s convictions are disqualifying offenses, a petitioner must submit all of the following:

• A completed petition for eligibility determination form;
• The complete criminal record for each of the petitioner’s convictions;
• A personal statement regarding whether each conviction directly relates to the duties and responsibilities of the practice of pharmacy and why the Board should find the petitioner rehabilitated;
• All evidence of rehabilitation that the petitioner wishes to be considered by the Board; and
• A nonrefundable fee of $25.

The cutoff for inclusion on the Board's agenda is two weeks prior to a scheduled Board meeting. Requests received after the cutoff will be held for the following Board meeting (i.e. deadline for March 12 meeting is February 27; a request received on February 28 would not go before the Board until the next meeting).

For more information, please see 657 IAC 31.

Initial Applicants: You must disclose all disciplinary action, regardless of where or how long ago it occurred.  Failure to disclose a disciplinary action could result in delays in processing your application or in your application being denied.

Renewals: You are required to disclose only disciplinary action from the time of your last application.

The application requires the disclosure of the following:

• Any disciplinary or enforcement action imposed by any licensing agency or regulatory authority on any license or registration held by the individual.
• Knowledge of any charges, complaints or investigations, pending before any licensing authority.
• Any license or registration denials by any licensing authority.

The following information is required to be submitted for any disclosures:

• A written description of the event(s).
• All unredacted documents related to any disciplinary or enforcement action imposed by any licensing agency or regulatory authority.

Beginning July 1, 2021, any person not currently registered with the Board as PSP is required to obtain registration prior to commencement of employment in an Iowa pharmacy as a PSP.

Applications are only valid for 45 days from the date of receipt. You will be notified by email if additional information is required. If the application has not been completed within 45 days, a new application and fee will have to be submitted if you wish to obtain an Iowa PSP registration.

Failure to answer all questions completely or accurately, and/or omission or falsification of material facts may be cause for denial of your application, or disciplinary action if you are subsequently registered by the Board. If you are in doubt, answer “yes” and provide an explanation.

Submit the completed application with any required documentation and a check or money order payable to the Iowa Board of Pharmacy.

• Do not send cash.
• Cash and debit/credit cards payments are not accepted by mail or when dropping off an application at the office.  

An individual who fails to register as a PSP may be subject to public discipline.

See the Applications/Forms and Online Services section below.

As a courtesy, the Board office sends a registration renewal notice to each registrant at least 60 days prior to registration expiration; however, the option to renew will not be available more than 60 days prior to your renewal date. The renewal notice is sent via email to the registrant’s last known email address. Failure of the registrant to receive the notice does not relieve the registrant of responsibility for renewing that registration prior to its expiration. A registration can be renewed online or by paper application.

A registered pharmacy support person who ceases practice as a pharmacy support person and does not intend to renew the registration prior to its expiration may request that the board cancel the registration. If the pharmacy support person later seeks registration as a pharmacy support person, the individual shall not be assessed a late penalty fee or reactivation fee for renewal of the registration.

See the Applications/Forms and Online Services section below.

Individuals are required to report to the Board, within ten days, a change of name, address, or pharmacy employment.

Changes to your address, email address, phone number, and employment may be made through your online profile.

A registered pharmacy support person who ceases practice as a pharmacy support person and does not intend to renew the registration prior to its expiration may request that the board cancel the registration. If the pharmacy support person later seeks registration as a pharmacy support person, the individual shall not be assessed a late penalty fee or reactivation fee for renewal of the registration.

Name changes can be made using the Individual Licensee/Registrant Online Notification of Name Change form. To change your name, you must attach a copy of the legal name change document (name change petition, marriage certificate, divorce decree, etc.)

A registered pharmacy support person is required to provide to the Board written notice of and unredacted documents related to any disciplinary or enforcement action imposed by any licensing agency or regulatory authority on any license or registration held by the registered PSP no later than 30 days after the final action. Discipline may include, but is not limited to, fine or civil penalty, citation or reprimand, probationary period, suspension, revocation, and voluntary surrender.

A registered pharmacy support person is required to provide written notice to the Board of any criminal conviction that is related to the practice of pharmacy or controlled substances no later than 30 days after the conviction. The term “criminal conviction” includes instances when the judgment of conviction or sentence is deferred.

All application fees are nonrefundable and nontransferrable. Once an application is submitted and the fee is paid, the withdrawal of an application, determination of ineligibility based on prior criminal convictions, or discovery of the submission of an incorrect application type does not merit return or refund of the application fee. Do not submit an application if you are unsure of which application type to submit.

Do not send cash.

Online Applications

• Online Profile Portal (For online renewals, address and employment changes, and to print certificates) A valid credit or debit card (Visa, Mastercard, or Discover) is required for online renewal. There will be a $2.00 convenience fee charged for online renewal and payment. The renewal certificate will be mailed within a few days of the online renewal.
• Initial Pharmacy Support Person Registration Application  (Application for applicants that have never been registered as a PSP in Iowa)

Paper Applications

• Initial and Renewal Registration Application

Forms

• Individual Licensee/Registrant Notification of Name Change
• Licensee/Registrant Discipline Reporting Form
• Military Service Application Form
• Quarterly Report of Compliance
• Verification of Medical Condition
• Low-Income Initial Fee Waiver Application
• Criminal History Petition for Determination of Eligibility
  • List of Disqualifying Offenses