Policy & Billing

This page outlines the policy framework and payment pathways that support pharmacy-based PrEP and PEP services in California. It is intended to help pharmacies and referring clinicians understand the legal, operational, and financial context for participating in PrideScript.

California law authorizes pharmacists to provide preventive and clinical services, including initiating PrEP and PEP, ordering tests, and receiving reimbursement. The laws below form the foundation for pharmacy-based HIV prevention programs such as PrideScript.

A. Practice Authority

Collaborative Practice Agreements (CPAs) are formal agreements between pharmacists and prescribers that allow pharmacists to provide expanded clinical services under shared protocols. In HIV, hepatitis C, STI, and substance use care, CPAs can support lab ordering and monitoring, ongoing therapy management, and follow-up coordination beyond initial service delivery. While California law already authorizes pharmacists to initiate services such as PrEP, PEP, HIV testing, and naloxone, CPAs help extend care, clarify clinical roles, and support continuity and reimbursement. PrideScript can assist pharmacies with CPA templates and implementation guidance.

CLIA-waived testing allows pharmacies to perform simple point-of-care tests on-site. These tests support same-day PrEP and PEP initiation and improve access to timely HIV prevention services. To offer CLIA-waived testing, a pharmacy must obtain a CLIA Certificate of Waiver from CMS, register as a clinical laboratory with the California Department of Public Health, pay modest federal and state fees, and comply with required testing, documentation, and public health reporting procedures. Pharmacies that meet these requirements may receive payment for CLIA-waived HIV testing in certain situations, including Medi-Cal fee-for-service when properly enrolled. Coverage varies across Medi-Cal managed care and commercial plans, and testing costs may be bundled with clinical services or funded through public health sources. PrideScript supports pharmacies with CLIA applications, workflow setup, and staff training.

B. Financial Sustainability

California policy supports pharmacy-based PrEP and PEP as financially viable services. Medication coverage, reimbursable clinical services, and robust patient assistance programs reduce the risk of uncompensated care. Pharmacy-based PrEP programs report high same-day initiation rates, with most patients who complete screening starting PrEP immediately. This supports efficient use of staff time and smooth integration into routine workflows. Demonstration projects in California and other states show that pharmacy-led PrEP services can be delivered sustainably while expanding access to prevention and clinical care.

Next Steps

The PrideScript team can help pharmacies and clinicians understand policy requirements, billing pathways, and setup considerations.