What Is SB 2188?
Senate Bill 2188 was signed into Tennessee law in April 2022. The bill amended Tennessee Code Annotated § 63-10-217 and related statutes to allow licensed pharmacists to dispense ivermectin under a Collaborative Pharmacy Practice Agreement (CPPA) without a patient-specific physician prescription.
The bill was introduced in the context of national debate about ivermectin access during the COVID-19 pandemic, but the law itself is not limited to any specific indication. It applies to the dispensing of ivermectin generally — for any use that the pharmacist, operating within the CPPA agreement, determines is appropriate.
What Is a CPPA (Collaborative Pharmacy Practice Agreement)?
A Collaborative Pharmacy Practice Agreement is a formal written agreement between a licensed physician (or physician group) and one or more licensed pharmacists. The agreement authorizes the pharmacist to perform specific clinical functions — in this case, dispensing ivermectin — within defined protocols, without requiring a patient-specific prescription for each dispensing event.
The CPPA is not a loophole. It is a structured clinical collaboration with defined scope, protocols, documentation requirements, and pharmacist oversight obligations. Participating pharmacists must:
- Operate under a valid CPPA with a licensed Tennessee physician
- Screen patients for contraindications before dispensing
- Maintain records of dispensing activity
- Refer patients to a physician when the clinical situation exceeds CPPA scope
- Document the patient consultation and pharmacist authorization
What the Law Permits
- ✓Pharmacist dispensing of human-formulated ivermectin under CPPA without a patient-specific prescription
- ✓Dispensing of FDA-approved ivermectin tablets (3mg, 6mg) or compounded ivermectin capsules
- ✓Patient consultation by the pharmacist to screen for contraindications
- ✓Dispensing for FDA-approved uses (strongyloidiasis, onchocerciasis) without a prescription
- ✓Off-label use discussion as part of pharmacist-guided care (pharmacist may decline to dispense)
What the Law Does NOT Permit
- ✗OTC (over-the-counter) dispensing without pharmacist consultation
- ✗Dispensing of veterinary formulations (horse paste, injectable veterinary ivermectin) for human use
- ✗Pharmacist diagnosis of any medical condition
- ✗Dispensing without an active CPPA agreement in place
- ✗Dispensing to patients with known serious contraindications without physician referral
Why Tennessee Is Unique
Most states require a physician prescription for any dispensing of prescription ivermectin. Tennessee's CPPA mechanism — while not unique to ivermectin (CPPAs exist for other medications in many states) — creates a legally clear pathway for patients who want access to human-formulated ivermectin without going through a full physician appointment.
This is why Tennessee pharmacies participating in the SB 2188 framework have seen increased demand from both in-state residents and patients from bordering states (Georgia, Alabama, Mississippi, Kentucky) who do not have similar access pathways.
Disclaimer: This article is for educational purposes only and does not constitute legal or medical advice. The legal landscape around ivermectin dispensing may change. Verify current CPPA requirements with a licensed Tennessee pharmacist or attorney before taking action.