SB250

Long-acting injectable medications—particularly those that are Schedule II or III controlled substances—are not routine injections. Administration of these medications should be done in a clinical setting and in the context of the physician-patient relationship where the provider has a full understanding of the patient's medical history, potential drug interactions, and the ability to assess and treat adverse effects. The pharmacy setting may not be equipped for clinical monitoring or emergency response in situations where there is an adverse reaction. The New Hampshire Medial Society values the critical role pharmacists play in medication management and public health and has concerns that administration of controlled long-acting injectables outside of the clinical setting and without direct patient oversight by a physician could compromise patient safety.

Dear Members of the House Health and Human Services Committee, My name is Dr. Maria Boylan, and I am a board-certified family medicine physician practicing in Bedford, NH. I am writing to respectfully express my strong opposition to SB250, which proposes to authorize pharmacists to administer long-acting injectable (LAI) medications. Long-acting injectable medications—particularly those that are Schedule II or III controlled substances—are not routine injections. These medications are often used to treat serious psychiatric conditions, substance use disorders, and chronic pain. Administering these treatments safely requires a full understanding of the patient's medical history, comorbid conditions, potential drug interactions, and the ability to assess for adverse effects, including emergent side effects that may not be immediately visible or verbalized by the patient. In a family practice setting, we ensure that these medications are administered as part of a comprehensive care plan. We monitor lab results, coordinate with specialists, assess mental status, and maintain long-term therapeutic relationships with our patients. Delegating this responsibility to pharmacists—who may not have access to the full clinical picture or the ability to follow up appropriately—risks fragmenting care and introducing safety gaps. Moreover, long-acting injectables often require specific handling, storage, and administration techniques. In some cases, the patient must be monitored for a period post-injection due to the risk of severe side effects like sedation, respiratory depression, or extrapyramidal symptoms. Pharmacists are highly trained professionals, but community pharmacy settings are not typically equipped for clinical monitoring or emergency response in these situations. I also worry that expanding this authority to pharmacists without clear limitations or protocols could inadvertently lead to overprescribing or inappropriate use, especially in communities where access to behavioral health services is already limited. This bill could open the door to treatment without adequate assessment, further distancing patients from comprehensive primary or psychiatric care. In conclusion, while I value the critical role pharmacists play in medication management and public health, the administration of controlled long-acting injectables should remain within the scope of practice of physicians and advanced practice providers with direct patient oversight. Our collective goal must be to ensure safe, coordinated, and high-quality care—this bill, as written, could undermine that goal. Thank you for your time and attention. I am happy to answer any questions. Respectfully, Dr. Maria Boylan