Policy Statements and Briefs

These policy statements represent AAPP’s position on professional and practice issues. They are intended to aid members in describing their roles and will serve as the basis for AAPP’s policy positions and requests. They also aid in advancing AAPP’s positions to target audiences. These policy statements are approved by the Board of Directors and cover a wide range of pharmacy and practice issues. They have been derived from existing legislative and regulatory positions and AAPP papers.

Access to Care

BuprenorphineAAPP supports exempting buprenorphine products from the Suspicious Orders Report System to increase access to treatment for opioid use disorder. Additionally, AAPP recommends community pharmacies stock a minimum of 1 buprenorphine product.
Gender affirming careAAPP supports access to Gender Affirming Care (GAC) for all transgender and gender-diverse individuals. GAC, for many, is lifesaving. Access to routine health care, including GAC, improves mental health, self-esteem, and social/physical development among transgender and gender-diverse youth. A safe and affirming health care environment is critical to improve mental health among children and adolescents and includes medical, mental health, and non-medical (e.g., affirming language) services.
ImmunizationsAAPP supports access to immunizations, up-to-date educational resources for youth and adults, and evidence-based and current immunization schedules for vaccine administration (e.g., American Academy of Pediatrics). Pharmacists, including psychiatric pharmacists, receive training on the benefits, risks, and pediatric- and adult-specific schedules for vaccine administration. All pharmacists are equipped to help caregivers separate fact from fiction where vaccine safety is concerned. It is a priority to vaccinate individuals with a mental health condition, given increased risk for physical health complications of communicable diseases.

Guiding Principles for State Policy on Pharmacy Personnel-Administered Vaccines

Immunizations and autismAAPP supports the strong evidence that vaccines do not cause autism. AAPP additionally supports following routine vaccination schedules for individuals with autism. Although the myth that the measles, mumps, and rubella (MMR) vaccine is linked to autism has been debunked, it continues to fuel stigma and fear among parents making vaccination decisions for their children and those living with autism.
Low threshold modelsAAPP supports expanded funding for low-threshold models and other strategies to reduce barriers for providing mental health and harm reduction services to underserved populations.
Medicaid access for incarcerated personsAAPP supports allowing states to restore access to health care, including substance use and mental health treatment, through Medicaid for incarcerated individuals up to 30 days before their release. Change to: AAPP supports allowing states to restore Medicaid for incarcerated individuals up to 30 days before their release in order to access health care, inclusive of substance use and mental health treatment.
MethadoneAAPP supports increasing access to methadone and reducing barriers to treatment for opioid use disorders, including take-home doses for stable patients and allowing pharmacies to dispense methadone for the treatment of opioid use disorders.

Fact Sheet The Modernizing Opioid Treatment Access Act

Pharmacies and medication accessAAPP supports access to medication via legitimate and clinically appropriate prescription regardless of origin, including telehealth prescriptions. Placing additional administrative burdens on pharmacists, such as tracking the number of controlled prescriptions from telehealth providers, diverts focus from patient care and risks delaying needed treatment.
Prior authorization and fail-first protocolsAAPP supports streamlining the use of step therapy and prior authorizations, so that formulary decisions are timely, evidence-based, clinician-driven, and do not delay care or access to necessary treatment.
Substance use disorders-Access to treatmentAAPP supports the use of medication as part of a personalized treatment plan for individuals with substance use disorders, along with psychotherapy. Additionally, if non-pharmacotherapy is not accessible, pharmacotherapy for substance use disorders alone is recommended.

Fact Sheet

Telehealth-In-person requirement removalAAPP supports removal of the in-person requirements under Medicare for mental health services, including SUD services, provided via telehealth.  In-person requirements unnecessarily restrict access to mental health services for those living in rural and/or underserved communities, without improving quality of care.

Fact Sheet

Telehealth-Medicare flexibilitiesAAPP supports telehealth services as an important tool for addressing the shortage of psychiatric providers in less densely populated areas, where resources are limited or there is difficulty attracting clinicians. These telehealth flexibilities include removing geographic requirements and expanding originating sites for telehealth services as well as extending telehealth services for FQHCs and rural health clinics.

Fact Sheet

Telehealth-MOUD accessAAPP supports the continued use of telehealth to deliver care for persons receiving medications as part of treatment for opioid use disorder.

Fact Sheet

The Evidence Base

Addressing Misinformation Regarding Antidepressants and ViolenceAAPP's most recent policy statement and brief seeks to dispel misinformation misinformation about the association between antidepressants and violence, emphasizing the safety and benefits of antidepressants for treating various mental health disorders in youth and adults. Please join AAPP in using this brief in your own advocacy as we work together to lead with the evidence.

Policy Brief Answering FAQs on Antidepressants-NAMI

Gender Affirming CareAAPP supports access to health care that is inclusive, gender-affirming, evidence-based, and developmentally appropriate for all transgender youth. Access to integrated, multidisciplinary gender-affirming care is associated with improved physical and mental health outcomes. Alternatively, “conversion” or “reparative” treatment models that are used to prevent youth from identifying as transgender or to dissuade them from exhibiting gender-diverse expressions are ineffective, deceptive, and lack evidence.

 

Gold Standard Treatments

Antidepressants for youth with depressionAAPP supports access to antidepressants for youth with moderate to severe symptoms of a depressive, anxiety, or obsessive-compulsive-based disorder. Landmark studies demonstrate a reduction in suicide among youth treated with an antidepressant. The 2004 boxed warning for emergence of new-onset suicidal thoughts/behaviors should be reevaluated, given its many unintended consequences and role in accelerating stigma.

Policy Brief

Antipsychotics for schizophrenia and other psychotic disordersAAPP supports the use of antipsychotics as the first line treatment for acute and maintenance treatment of schizophrenia, with individual agent and route of administration selected based on patient-specific factors.

Policy Brief

Antipsychotic monitoring and prescribing in youthAAPP supports access to evidence-based monitoring for youth prescribed antipsychotics, including routine metabolic (i.e., blood glucose, lipid panel) and muscle (i.e., abnormal involuntary movement scale) side effect monitoring. AAPP supports updates to child and adolescent psychotropic prescribing regulations to support safe and effective use of antipsychotics in this patient population.

Policy Ask

Autism Spectrum Disorder TreatmentAAPP supports evidence-based treatment of autism spectrum disorder that is based on an accurate assessment of the available data.

Policy Brief

Mood stabilizers for bipolar disorderAAPP supports access to mood stabilizers, including lithium, for the treatment of bipolar disorder. Landmark studies have identified lithium as a “gold standard” mood stabilizer for the prevention and treatment of depressive and manic episodes. Additionally, lithium decreases the risk of suicide among individuals with bipolar disorder.

Policy Brief

Psychotropic DeprescribingAAPP ssupports an evidence-based and personalized approach to psychotropic deprescribing among youth and adults. Indications for deprescribing may include a changing benefit-to-risk ratio, unclear rationale for use, lack of evidence to support medication use, completion of a typical treatment course, and/or inappropriate polypharmacy. Additional research is needed to determine medication-specific tapering protocols. It is important to recognize, however, that many individuals will still benefit from long-term psychotropic medication treatment.

Policy Brief

Selective serotonin reuptake inhibitors (SSRIs) and pregnancyAAPP supports the continued availability of SSRIs as an option for treatment of moderate to severe symptoms of perinatal depression and anxiety. Any concerns regarding risks of antidepressant use in this population must be weighed against the risks associated with suboptimal management of psychiatric symptoms.

Policy Brief

Shared Decision MakingAAPP supports the use of shared decision making (SDM) by all healthcare providers as an essential element of the patient care process for all individuals living with a mental health condition, including a substance use disorder. SDM not only reduces stigma, but is associated with patient autonomy and improved quality of life and mental health symptoms.

Policy Brief

Stimulants for Attention Deficit Hyperactivity Disorder (ADHD)AAPP supports access to behavioral interventions, including parent training in behavior management, and stimulant treatment for youth with functionally impairing symptoms of attention-deficit/hyperactivity disorder (ADHD). Landmark studies and updated treatment guidelines indicate that stimulants are the most effective treatment for ADHD given their associated improvement in academic, social, and developmental functioning. Additionally, timely and adequate treatment with a stimulant is associated with reductions in mortality, engagement in risky behavior, and severity of co-occurring psychiatric conditions.

Policy Brief

Substance use disorder medication treatmentAAPP supports defining opioid use disorder as a treatable medical condition with a biological basis that is often associated with a history of trauma. Furthermore, it is considered a disability and thus, according to the Americans with Disabilities Act, a correctional facility cannot deny access to medications for opioid use disorder, or any other medication, solely based on the medication class.

Policy Brief

Policy Asks

ACA Marketplace Plans ProtectionsAAPP supports the continuation of the Affordable Care Act Enhanced Premium Tax Credits (EPTCS) to ensure that eligible people on ACA Marketplace plans with psychiatric disorders, including substance use disorders, have access to affordable health insurance that provides standard of care treatments for their conditions.
Cannabis Research and ReschedulingAAPP supports rescheduling cannabis from Schedule I to Schedule III to reduce barriers to rigorous clinical research and strengthen the evidence base on both benefit and harm. Recent randomized-trial syntheses suggest limited efficacy across most psychiatric indications and highlight a need for more high-quality studies to guide safe, effective, evidence-based care.
Center for Medicare and Medicaid Innovation (CMMI) study of the impact of medication optimization via CMMAAPP supports The Center for Medicare and Medicaid Innovation (CMMI) studying the impact of pharmacist-provided comprehensive medication management (CMM) on patient outcomes as part of a comprehensive strategy to improve access to evidence-based care. CMM has been shown to improve outcomes in small trials, but a large-scale trial that includes pharmacist-provided CMM as part of a comprehensive team-based strategy to address the quintuple aim is warranted.
Collaborative Care Model (CoCM)-Inclusion of pharmacists as the psychiatric expertAAPP supports the role of psychiatric pharmacists as the psychiatric expert in the CoCM as another means of expanding access to mental health and substance use disorder care. There has been limited uptake in the CoCM for a variety of reasons, including in part a lack of access to psychiatric providers. BCPPs are highly trained in the medication management of psychiatric disorders as part of a team approach to care. BCPPs can recommend dosage adjustments and/or medication changes to address inadequate response to treatment while monitoring patients in a CoCM practice setting. They collaborate with primary care providers, care managers, psychiatric providers, and behavioral health providers to ensure access to a comprehensive treatment plan.

Fact Sheet

Comprehensive Medication Management (CMM)AAPP supports payment for comprehensive medication management (CMM) performed by psychiatric pharmacists. CMM is the gold-standard, evidence-based process in which psychiatric pharmacists ensure appropriate, safe, and effective use of psychotropic medications among individuals with mental health conditions, including substance use disorders.

Fact Sheet

Federal funding for mental health (MH) and substance use disorder (SUD) careAAPP supports protecting federal funding as essential for ensuring access to treatment for people living with psychiatric and substance use disorders. 
Federal funding through Medicare, Medicaid, Department of Veterans Affairs, the Substance Abuse and Mental Health Services Administration (SAMHSA), and the National Institute of Mental Health supports clinical research and training while the United States Department of Agriculture provides funding for rural mental health services. 
AAPP supports SAMHSA’s role in the care for people with psychiatric disorders as it provides dedicated subject matter experts on Severe Mental Illness (SMI) and substance use disorders (SUD) to ensure access to state of the art, evidence-based research, information, and care.
All of these agencies are essential in ensuring patient access to MH and SUD services.

Concerning Layoffs at SAMHSA and Other Federal Agencies

Federal funding for training and student loan repayment programs for pharmacistsAAPP supports inclusion of psychiatric pharmacists as professionals eligible for HRSA training and National Health Service Corp student loan repayment programs. Inclusion is essential to increase the psychiatric pharmacy workforce, particularly in rural and/or underserved communities.
Federal Medical Assistance Percentage (FMAP) match for mental health and substance use servicesAAPP supports policies to incentivize states to expand coverage of mental health and substance use services by providing a corresponding increase in the Federal Medical Assistance Percentage (FMAP) matching rate for these services. Medicaid is the single largest payor of mental health and substance use services for adults and children. Unfortunately, many Medicaid beneficiaries face long delays for behavioral health services, including crisis services, due to the nationwide provider shortage. By improving coverage for Medicaid beneficiaries and helping ensure providers are paid adequately, it would provide a meaningful incentive for providers to offer mental health and substance use services, reduce wait times for patients, while encouraging states to fully cover mental health and substance use services.
Foster CareAAPP supports access to trauma-informed care for all youth in foster care and access to psychotropics for those with co-occurring mental health conditions. AAPP supports updates to foster care psychotropic prescribing regulations to support safe and effective use of psychotropics in this patient population.

Policy Ask

Gambling Disorder/Problem GamblingAAPP supports increased research into and access to treatment of gambling disorder and problem gambling. There has been significant increase in access to gambling but limited research on screening and treatment of gambling disorder/problem gambling. With no currently FDA-approved medications for treatment of gambling disorder, high quality research and reimbursement for treatment of gam[GU1.1]bling disorder would improve access to care.
Gas Station Drugs and Unregulated Wellness ProductsAAPP supports limiting access to unregulated “wellness products” such as Kratom/7-OH, Tianeptine, Sildenafil, and Phenibut that are sold at gas stations, convenience stores, and online markets. While these products are commonly marketed as “wellness products” or “dietary supplements”, there is a lack of transparency regarding safety and efficacy. Additionally, these products may contain prescription drug like properties (e.g., opioid) without the same manufacturing standards, efficacy testing, and regulatory and medical oversight. Although limited restrictions are in place, such as age for purchasing, FDA regulation would limit access and promote safety.

Clinical Toolkit: Phenibut Clinical Toolkit: Tianeptine

Harm reduction servicesAAPP supports funding, access, and delivery of harm reduction services to prevent substance-use-related injury, disease, overdose, and misuse. Harm reduction is an evidence-based paradigm that focuses on health promotion and risk reduction through practical public health interventions that address infectious disease transmission, increase access to physical and mental health treatment, provide lifesaving tools (e.g., naloxone, drug test strips), and reduce stigma associated with substance use.

Policy Ask AAPP Paper

Involuntary commitmentAAPP opposes the expansion of involuntary psychiatric commitment and instead advocates for increased investment in community mental health services and supportive housing, which promote recovery, autonomy, and long-term stability. While involuntary hospitalization may be necessary to protect individuals during acute crises, it does not consistently improve long-term treatment engagement and can reinforce mistrust in the mental health system. AAPP supports greater investment in person-centered recovery approaches and maintains that involuntary hospitalization should only be used when individuals lack decision-making capacity—not as a punitive measure.

ASAM Policy Rounds: Involuntary Civil Commitment of People with Substance Use Disorders
NAMI Statement on Executive Order Targeting Homelessness and Criminalizing Mental Illness

Medicaid protectionsAAPP supports the continuation of comprehensive Medicaid coverage to ensure that Medicaid eligible people with psychiatric disorders, including substance use disorders, have access to standard of care treatments for their conditions.
Mental Health Parity and Addiction Equity Act of 2008 enforcementAAPP supports ongoing enforcement of the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008. The MHPAEA prohibits restrictive copays and treatment limitations for mental health or substance use disorder benefits, ensuring equitable access to treatment.
Nicotine and YouthAAPP stands with pediatricians in supporting policies that reduce access to nicotine-containing products among teens and adolescents including flavored vaping products that increase youth appeal.
Psychedelic Research and Rescheduling AAPP supports ongoing research of psychedelics for the treatment of mental health conditions, including substance use disorders, through randomized controlled clinical trials to evaluate safety and efficacy. Additionally, rescheduling psychedelics would increase the ability to produce quality research. FDA-approved medications should remain first-line treatment options given their established safety and efficacy.
Psychiatric pharmacist recognition as qualified health providersAAPP supports:
  1. Medicare recognition of BCPPs as qualified health providers and comprehensive medication management (CMM) as a covered service. BCPPs increase access to care and the quality of care for people living with psychiatric disorders but require payment for services to be a sustainable part of a healthcare team.
  2. Medicaid payment for services provided by BCPPs when providing services that would be covered if the service was provided by another type of health care practitioner and if the service is provided in compliance with state laws and administrative regulations, within the state scope of practice.
  3. Private Health Plans payment for services provided by BCPPs when providing services that would be covered if the service was provided by another type of health care practitioner and if the service is provided in compliance with state laws and administrative regulations, within the state scope of practice.

Fact Sheet

Psychiatric pharmacy residency financial supportAAPP supports federal funding for psychiatric pharmacy residency programs. Most BCPPs complete a PGY-2 prior to entering the workforce. These training programs, along with the BCPP credential, are the gold standard for psychiatric pharmacy.

Fact Sheet

Psychotropic stewardship programs (PSPs) expansion and adoption by The Joint Commission (TJC)AAPP supports the expansion of psychotropic stewardship programs to promote the safe and appropriate use of psychotropic medications accomplished by ensuring every patient with a psychiatric diagnosis having their medication treatment plan reviewed, optimized, and managed by a psychotropic stewardship team with a psychiatric pharmacist as a co-leader. The standards established by antimicrobrial stewardship programs (ASPs) and recognized by regulatory agencies provide psychiatric pharmacists with an appropriate model to develop psychotropic stewardship teams in a variety of patient care settings. We support The Joint Commission (TJC) adopting guidelines, similar to those developed for ASPs to require PSPs in all settings treating psychiatric disorders, including substance use disorders (SUDs).

AAPP Paper Psychotropic Stewardship in Youth Psychotropic Stewardship in Practice

Public notice-and-comment rulemaking for federal agenciesAAPP believes public comment periods, per the Administrative Procedures Act, are a vital part of the federal rulemaking process. The use of notice-and-comment rulemaking allows health care providers, industry stakeholders, and patient advocacy groups to offer feedback on proposed regulations, helping to refine rules, prevent unintended consequences, and ensure effective policymaking. Bypassing stakeholder input may negatively impact Medicaid, Medicare, reimbursement models, patient safety, and provider operations.
REMS SimplificationAAPP supports efforts to simplify FDA Risk Evaluation and Mitigation Strategies (REMS) when their complexity creates barriers to treatment access. While AAPP strongly advocates for the safe and appropriate use of high-risk medications, it recognizes that overly burdensome safeguards may hinder patient access and limit prescribers in utilizing potentially beneficial therapies.
Telehealth payment parityAAPP supports the continued utilization of telehealth services as an alternative to traditional face-to-face appointments. However, this will not be feasible if there is disparity in reimbursement based on appointment format. Reimbursement rates for telehealth services should equal those of in-person encounters.

Fact Sheet

Tobacco cessation fundingAAPP supports the funding of federal programs directed toward tobacco cessation among individuals living with mental health and/or substance use disorders.

Policy Ask

340B drug discount programAAPP supports maintaining the 340B Drug Pricing Program (340B) as essential in providing low-income patients access to medically necessary medications. This includes the ability of 340B covered entities to use contract pharmacies to dispense covered medications to patients. The Health Resource and Services Administration, that administers the program, has developed guidelines to allow covered entities to contract with one or more outside pharmacies to act as a dispensing agent. Under these guidelines, the covered entity is required to purchase the drugs, and the contract pharmacy provides some or all the pharmacy services.

Fact Sheet

Value-based payment modelsAAPP supports the inclusion of Board-Certified Psychiatric Pharmacists (BCPPs) as essential team members for value-based payment models. BCPPs are educated and skilled in optimizing all of a patient’s medications to ensure appropriate, safe, and effective outcomes for their conditions. BCPPs add a unique medication focused perspective, complementing the skills of other members of the treatment team.