(P118) EXAMINING THE LEGAL AUTHORITY FOR PHARMACIST-ADMINISTERED DOXYCYCLINE AS POST-EXPOSURE PROPHYLAXIS (DOXY PEP): A COMPARATIVE LEGAL ANALYSIS OF ANALOGOUS PUBLIC HEALTH PRACTICES

Background:
Pharmacist-administered doxycycline post-exposure prophylaxis (PADP) could improve STI prevention. Despite parallels with expedited partner therapy (EPT), naloxone, and pharmacist-initiated pre-exposure prophylaxis (PI-PrEP) and post-exposure prophylaxis (PI-PEP) for HIV, no state currently authorizes PADP. PADP could be authorized under pharmacist collaborative practice agreements (CPAs), which expand pharmacist scope of practice under physician collaboration/supervision. This study investigates legal frameworks for PADP-like interventions.

Methods:
We examined operational characteristics of EPT, PI-PrEP, PI-PEP, and naloxone, for physician involvement, diagnostic requirements, subject matter (sexual health, STI, or other), and feasibility of CPA policies authorizing PADP. We also assessed the existence of these PADP-analogous policies across states.

Results:
Only PADP and EPT are explicitly STI-focused, and only naloxone lacks a sexual health focus. Receipt of confirmatory diagnosis is not required prior to administration of PADP, PI-PEP, and naloxone, although testing recommended prior to PADP and PI-PEP could limit pharmacist practice. EPT and PADP address bacterial infections; apprehensions about antibiotic overuse and resistance may be specific to STI-related interventions where confirmatory diagnoses (as exist with EPT) clearly indicate exposure and necessity of treatment.  Physicians are involved with EPT, and generally provide oversight of PI-PrEP and PI-PEP, but not naloxone. CPAs could authorize PADP in an operational characteristic-neutral manner, although PADP is outside the scope of these policies in most jurisdictions. Across states, the prevalence of policies varies from universal (naloxone; available over-the-counter in all states), nearly universal (EPT; permissible in 46 states but 22 states include additional pharmacy-related barriers, e.g., prescription labeling), to less common (PI-PrEP and PI-PEP, authorized in 17 states).

Conclusion:
Operational alignment of, and legal authority for, analogous interventions may illustrate PADP acceptability within jurisdictions, informing policy development. EPT policies may be especially relevant due to their STI focus, although EPT and PADP may differ in important ways in terms of antibiotic stewardship.