CCPP Module 28, Section 5: Using CPA and CBA Templates for Real-World Implementation
MODULE 28: Advanced Collaborative Care Services and Revenue Integration

Section 28.5: Using CPA and CBA Templates for Real-World Implementation

A practical, hands-on guide to the legal frameworks of advanced practice. We will provide and deconstruct templated Collaborative Practice Agreements (CPAs) and Collaborative Business Agreements (CBAs), giving you the tools and confidence to formalize your partnerships.

SECTION 28.5

From Handshake to Blueprint: Formalizing Your Practice

A Hands-On Guide to Building Compliant, Scalable, and Legally Sound Clinical Partnerships.

28.5.1 The “Why”: The Professional Imperative for Formal Agreements

You have mastered the clinical skills. You have mastered the billing codes. You have built a strong, trust-based relationship with a physician partner. The temptation, at this stage, is to believe that this foundation of goodwill is sufficient—to operate on a handshake and a shared understanding of your goals. This would be a profound, and potentially catastrophic, mistake. Informal arrangements are the enemies of sustainability, scalability, and safety. Formal, written agreements are not about a lack of trust; they are the ultimate expression of professional respect and a shared commitment to building something that lasts.

The Collaborative Practice Agreement (CPA) and the Collaborative Business Agreement (CBA) are the twin pillars upon which your advanced practice is built. The CPA is your clinical charter, legally defining your scope of practice and the rules of engagement for patient care. The CBA is your financial constitution, defining the business relationship, the flow of money, and the allocation of risk and reward. One without the other is an incomplete structure, destined to wobble under pressure.

Why is this so critical?

  • Compliance and Risk Management: State pharmacy boards and federal regulators do not recognize handshakes. A well-drafted CPA is your primary evidence that you are practicing within the legal boundaries of your state’s pharmacy practice act. It is your shield in an audit and your defense against any accusation of practicing outside your scope.
  • Clarity and the Prevention of Misunderstanding: What happens if your supervising physician leaves the practice? What happens if the practice is sold? What happens if there is a dispute over payment? A verbal agreement is subject to memory and interpretation. A written contract provides an unambiguous source of truth that protects both you and your partners when circumstances change.
  • Scalability and Professionalism: To grow your services, add new pharmacists, or partner with larger health systems, you must have a professional, replicable framework. Formal agreements demonstrate that you are not just a clinician, but a serious professional who has built a durable, well-defined service line. They are the price of admission to the world of integrated healthcare.
This section will provide you with the tools to move from concept to contract. We will provide and meticulously deconstruct templates for both a CPA and a CBA. These are not intended to be a substitute for legal advice, but to serve as powerful educational tools and starting points for your discussion with your partners and your attorney. By the end of this masterclass, you will have the knowledge and confidence to build the legal and financial blueprint for your practice.

Pharmacist Analogy: The Architect’s Blueprint

Imagine you and a trusted builder decide to construct a state-of-the-art pharmacy. You share a vision, you trust each other’s skills, and you’re excited to start. You meet for coffee and sketch the layout on a napkin. You agree on the general size, the location of the counters, and the clean room. This napkin sketch is your handshake agreement. It’s full of potential and shared enthusiasm.

But you would never, ever begin construction based on that napkin. Why?

  • The Clinical Blueprint (The CPA): Before laying the foundation, you hire an architect to create a detailed set of blueprints. This blueprint specifies the exact dimensions of every room, the load-bearing walls, the electrical wiring diagrams, and the HVAC system. It ensures the building will be safe, functional, and, most importantly, compliant with all city building codes. You can’t get a building permit without it. This blueprint is your Collaborative Practice Agreement. It defines the “clinical architecture” of your service, ensuring it is safe, effective, and compliant with the “building codes” of your state’s Board of Pharmacy.
  • The Financial & Construction Contract (The CBA): Separately, you and the builder sign a detailed construction contract. This document has nothing to do with the blueprint’s clinical specifications. Instead, it details the project budget, the payment schedule (what gets paid when), who is responsible for which costs (materials vs. labor), the timeline for completion, and what happens if there are delays or disputes. This contract is your Collaborative Business Agreement. It defines the “financial architecture” of your partnership, ensuring everyone knows how and when they will be paid, and who is responsible for what.

Building a professional practice on a handshake is like building a pharmacy from a napkin sketch. It is unprofessional, unsafe, and doomed to fail when the first inspector (an auditor), the first storm (a legal dispute), or the first attempt to build an addition (scale your services) occurs. The CPA and CBA are your professional blueprints. They are the essential, non-negotiable tools for building a practice that is designed to last.

28.5.2 Masterclass: Deconstructing the Collaborative Practice Agreement (CPA)

The CPA is the legal instrument that defines your clinical relationship with a collaborating physician or practice. Its primary purpose is to grant you, the pharmacist, the authority to perform specific patient care functions, including initiating, modifying, and discontinuing medication therapy, under a defined protocol. This document is your license to practice at the top of your education.

Below is a comprehensive template for a CPA. We will break down each section, explaining its purpose, providing sample language, and highlighting key areas for consideration and customization. This template is a starting point; it must be adapted to fit your specific practice setting and the legal requirements of your state.

Legal Disclaimer: Templates are Not Legal Advice

The templates and sample language provided in this course are for educational purposes only. They are designed to help you understand the structure and components of these critical agreements. They are not a substitute for professional legal counsel. You must have any CPA or CBA reviewed by a qualified healthcare attorney in your state to ensure it is compliant with all applicable laws and protects your interests.

Collaborative Practice Agreement Template

A Section-by-Section Deconstruction

Section 1: Parties to the Agreement

Purpose: To clearly identify the collaborating pharmacist(s) and physician(s) who are bound by this agreement.

Sample Language: “This Collaborative Practice Agreement (‘Agreement’) is made and entered into as of [Date], by and between [Physician’s Full Name, MD/DO], hereinafter referred to as ‘Collaborating Physician,’ practicing at [Practice Name and Address], and [Pharmacist’s Full Name, PharmD, RPh], hereinafter referred to as ‘Collaborating Pharmacist,’ practicing at [Pharmacist’s Practice Site/Pharmacy Name and Address].”

Pro Tip: Group vs. Individual

If you are collaborating with a group practice, it is often wise to have the CPA be between you and the practice entity itself, with an appendix listing all the physicians in that practice who agree to participate. This prevents the need to create a new CPA every time a physician joins or leaves the group. Check your state law, as some may require a named physician to be the primary collaborator.

Section 2: Authority and Purpose

Purpose: To state the legal basis for the agreement. This section should explicitly reference the specific statute or regulation in your state’s Pharmacy Practice Act that authorizes CPAs.

Sample Language: “This Agreement is established pursuant to [Cite the specific State Law or Board of Pharmacy Regulation, e.g., ‘Florida Statutes § 465.1865’] to establish a formal collaborative practice for the purpose of providing enhanced patient care, optimizing medication therapy, and improving health outcomes for a mutually agreed-upon patient population.”

Tutorial: Finding Your State’s Law:

  1. Go to your state’s Board of Pharmacy website.
  2. Look for a section titled “Laws and Rules,” “Statutes,” or “Practice Act.”
  3. Use the search function (Ctrl+F) within the documents for keywords like “Collaborative Practice,” “Drug Therapy Management,” “Protocol,” or “Consult Agreement.”
  4. Once you find the relevant section, cite it directly in your CPA. This demonstrates to any auditor that you have done your due diligence.

Section 3: Patient Population

Purpose: To define which patients are covered by this agreement. This can be broad or narrow.

Sample Language (Broad): “This Agreement applies to all patients of the Collaborating Physician for whom the Physician has referred to the Collaborating Pharmacist for medication management services.”

Sample Language (Specific): “This Agreement applies to patients of the Collaborating Physician who have a diagnosis of one or more of the following conditions: Type 2 Diabetes Mellitus (E11), Hypertension (I10), or Hyperlipidemia (E78).”

Pro Tip: Start Specific, Then Broaden

When first starting, it’s often wise to be specific. Limit your initial CPA to 2-3 disease states you are most comfortable with. This creates a focused, manageable service. As the collaboration matures and trust is established, you can amend the CPA to include a broader patient population or additional disease states.

Section 4: Scope of Pharmacist’s Authorized Functions & Services

Purpose: This is the heart of the CPA. It must detail, with high specificity, what you are authorized to do. Vagueness here is your enemy.

Sample Language: “Under the terms of this Agreement and the attached protocols (Appendix A), the Collaborating Pharmacist is authorized to perform the following patient care activities:

  • Obtain patient histories and perform limited physical assessments (e.g., blood pressure, weight, point-of-care testing).
  • Order, interpret, and monitor patient-specific laboratory tests relevant to the management of the conditions specified in this Agreement.
  • Initiate, modify, and discontinue medication therapy. This includes adjusting dosages, changing formulations, or substituting alternative medications within the same therapeutic class, all in accordance with the disease-specific protocols in Appendix A.
  • Provide patient education and counseling on medications, devices, and lifestyle modifications.
  • Formulate and communicate medication-related care plans to the Collaborating Physician and other members of the healthcare team.
”
Section 5: Disease-Specific Protocols (Appendix A)

Purpose: This appendix is where you translate the “authority” from Section 4 into concrete, actionable clinical guidelines. The protocol acts as your “standing order.” It should be evidence-based and clear enough that any clinician could understand your decision-making process.

Protocols are Non-Negotiable

Many state laws mandate that the specific protocols be included as part of the CPA. Do not skip this step. A CPA that grants broad authority without specific protocols to guide clinical decisions may be deemed invalid by your state board.

Tutorial: Building a Hypertension Protocol

Protocol Component Sample Language / Content
Condition Essential Hypertension (I10)
Patient Inclusion Criteria Age > 18, diagnosis of hypertension, referred by Collaborating Physician.
Pharmacist Assessment Review medication history, assess adherence, take seated BP according to AHA guidelines, ask about side effects, order baseline and follow-up labs (BMP, K+).
Treatment Goals Target BP < 130/80 mmHg per ACC/AHA 2017 guidelines, unless otherwise specified by the Collaborating Physician for an individual patient.
Pharmacist-Managed Formulary Pharmacist may initiate and titrate medications from the following classes: ACE Inhibitors, ARBs, Thiazide Diuretics, Calcium Channel Blockers (DHP & non-DHP). Beta-blockers may be managed for compelling indications.
Titration Algorithm “If BP remains above goal and patient is tolerating therapy, pharmacist may increase dose of current agent every 2-4 weeks. If at max dose, pharmacist may add a second agent from an approved class. If BP is below 110/70 or patient is experiencing symptomatic hypotension, pharmacist may decrease dose or discontinue an agent.”
Referral Triggers Pharmacist will immediately consult with the Collaborating Physician for: BP > 180/110, significant adverse drug reaction, new concerning symptoms (e.g., chest pain), or failure to reach goal after 3 medication adjustments.
Section 6: Documentation and Communication

Purpose: To define how and where your interventions will be documented and how you will communicate with the physician.

Sample Language: “All patient care activities performed by the Collaborating Pharmacist under this Agreement shall be documented in the shared Electronic Health Record (EHR) within one (1) business day. All medication changes will be communicated to the Collaborating Physician via the EHR’s messaging system. The Pharmacist will provide a comprehensive progress note to the Physician after each patient encounter.”

Section 7: Quality Assurance and Review

Purpose: To create a mechanism for ongoing oversight and quality improvement. This shows regulators that you have a system of checks and balances.

Sample Language: “The Collaborating Physician and Pharmacist will meet on a [e.g., quarterly] basis to review the activities conducted under this Agreement. This review will include a random audit of at least [e.g., 10%] of patient charts managed by the Pharmacist to assess adherence to protocols, clinical outcomes, and quality of documentation. These meetings will be documented with meeting minutes.”

Section 8: Term, Amendment, and Termination

Purpose: To define the lifespan of the agreement and the process for changing or ending it.

Sample Language: “This Agreement shall be effective for a term of [e.g., two years] from the date of execution. It shall automatically renew for subsequent two-year terms unless terminated by either party. This Agreement may be terminated by either party, with or without cause, upon providing [e.g., 60 days] written notice to the other party. This Agreement may be amended only by written consent of both parties.”

28.5.3 Masterclass: Deconstructing the Collaborative Business Agreement (CBA)

If the CPA is the clinical blueprint, the CBA is the financial and operational contract. It has one primary purpose: to define the flow of work and money between two separate business entities (you, the pharmacist consultant, and the medical practice). It has nothing to do with clinical protocols and everything to do with invoices, liability, and reporting. It protects you from misunderstandings and ensures you get paid for your work.

Let’s deconstruct a template CBA, assuming you are operating as an independent contractor (the most common model for entrepreneurial pharmacists).

Collaborative Business Agreement Template

A Section-by-Section Deconstruction

Section 1: Parties and Relationship

Purpose: To identify the parties and explicitly define your relationship as an independent contractor, which has important tax and legal implications.

Sample Language: “This Agreement is made by and between [Practice Name, LLC/Inc.], (‘Practice’) and [Your Name or Your Business Name, LLC], (‘Consultant’). It is expressly understood that Consultant is an independent contractor and not an employee, agent, or partner of the Practice. Consultant is responsible for their own federal, state, and local taxes, and will not be eligible for any employee benefits.”

Section 2: Scope of Business Services

Purpose: To define the business services you are providing. This should reference the clinical work in the CPA but frame it in business terms.

Sample Language: “Consultant agrees to provide clinical support services to the Practice, including but not limited to the provision of Chronic Care Management (CCM), Transitional Care Management (TCM), and other cognitive services as defined in the separate Collaborative Practice Agreement executed between the parties. Consultant will be responsible for documenting all time and activities in the Practice’s EHR to support billing for these services.”

Section 3: Compensation

Purpose: The most critical section of the CBA. It must precisely detail how you will be paid. This is where you insert the specific financial model you negotiated (from Section 28.4).

Tutorial: Writing Compensation Clauses

ModelSample Clause Language
Per-Service Fee “The Practice agrees to pay Consultant a fee of Thirty-Five Dollars ($35.00) for each CPT code 99490 claim for which the Practice has received payment from a third-party payer or patient. Payment is contingent upon collection by the Practice.”
Revenue Share “The Practice agrees to pay Consultant Fifty Percent (50%) of the Net Revenue Collected for the services provided by the Consultant. ‘Net Revenue Collected’ is defined as the total payments received by the Practice from third-party payers and patients for the CPT codes listed in this Agreement, minus any payer-recouped funds or refunds.”
Hourly Rate “The Practice agrees to pay Consultant a flat rate of One Hundred Dollars ($100.00) per hour for all time spent performing the services defined in this Agreement. Consultant will submit a detailed invoice of hours worked on a monthly basis.”
Section 4: Invoicing and Reporting

Purpose: To define the mechanics of getting paid. How do you ask for your money, and how does the practice prove what you’re owed?

Sample Language (for Rev Share/Per-Service): “On or before the 15th of each month, the Practice shall provide the Consultant with a detailed report from its Practice Management system. This report will list, for the preceding month, each service provided by the Consultant, the CPT code billed, the date of payment, the amount collected, and the calculated compensation due to the Consultant. The Practice shall pay all undisputed amounts due to the Consultant within 30 days of providing the report.”

The Right to Audit

A crucial clause to include here is a “right to audit” clause. This gives you the right (e.g., once a year) to have an independent party review the practice’s billing records to verify the accuracy of the reports you are receiving. It’s a standard business practice that promotes transparency and trust.

Section 5: Professional Liability and Insurance

Purpose: To clarify who is responsible for insuring against malpractice.

Sample Language: “Consultant agrees to maintain, at their own expense, a professional liability (malpractice) insurance policy with coverage limits of not less than $1,000,000 per occurrence and $3,000,000 aggregate. Consultant shall provide the Practice with a certificate of insurance upon request.”

Section 6: Confidentiality and HIPAA

Purpose: To legally bind you to protect the practice’s and patients’ confidential information.

Sample Language: “Consultant agrees to hold all Confidential Information, including Protected Health Information (PHI) as defined by HIPAA, in strict confidence. Concurrent with this Agreement, the parties shall execute a separate Business Associate Agreement (BAA) to ensure full compliance with HIPAA regulations.”

28.5.4 Case Study: Putting the CPA and CBA into Practice

Let’s follow a fictional pharmacist, Dr. Chloe Davis, as she formalizes a partnership with a small primary care clinic, “Oakdell Family Health.”

  1. The Handshake: Dr. Davis has a great relationship with Dr. Miller at Oakdell. They agree that she can help manage their complex diabetes patients. They are excited to start.
  2. Due Diligence (CPA Prep): Dr. Davis goes to her state’s Board of Pharmacy website. She learns that her state allows pharmacists to initiate and modify therapy under a CPA for chronic diseases, provided there are specific protocols. She uses the CCPP template to draft a CPA.
    • Parties: Dr. Chloe Davis, PharmD and Oakdell Family Health, LLC.
    • Patient Population: “Patients of Oakdell Family Health with a diagnosis of Type 2 Diabetes Mellitus (E11).”
    • Protocols (Appendix A): She drafts a detailed protocol for diabetes management, including which labs she can order (A1c, BMP, Lipid Panel), her approved formulary (Metformin, SGLT2i, GLP-1 RA, DPP4i, Basal Insulin), and a clear algorithm for titration based on A1c and blood glucose readings.
  3. The Business Discussion (CBA Prep): Dr. Davis and Dr. Miller discuss financials. Dr. Miller is hesitant to take on the risk of a full-time salary. Dr. Davis is confident in the value she can bring and wants to share in the upside. They agree to a 60/40 revenue share (60% to the practice, 40% to Dr. Davis) of the net revenue collected for CCM and RPM services she provides. Dr. Davis drafts the CBA.
    • Compensation Clause: She uses the revenue share sample language from the CCPP template.
    • Reporting Clause: She includes the clause requiring a monthly report from Oakdell’s billing system and payment within 30 days.
    • Insurance: She contacts her malpractice insurance provider to ensure her policy covers these new activities and includes the $1M/$3M coverage clause in the CBA.
  4. The Legal Review: This is a critical step. Dr. Davis hires a healthcare attorney to review both documents. The attorney suggests a few minor language changes to strengthen the independent contractor status and adds a dispute resolution clause. Dr. Miller has the practice’s attorney review them as well.
  5. Execution: Once both parties and their legal counsel are satisfied, they sign the CPA, the CBA, and a HIPAA Business Associate Agreement.

Dr. Davis now has a rock-solid foundation. Her clinical scope is legally defined. Her financial arrangement is unambiguous. She can now begin providing patient care with the confidence that her practice is built on a professional, compliant, and sustainable framework.