Pharmacist Cheat Sheet for Maryland

Requirements for Supervising Physician agreements in Maryland, plus a free agreement builder tailored to Maryland law.

Provider supervision requirements in Maryland

Updated 2026-09-03

Provided for educational and research purposes only — this is not legal advice. Laws and regulations change frequently, and this content may contain errors or omissions. Always confirm current requirements with a licensed attorney before relying on this for compliance decisions.

Maryland's APRN categories are not uniform: CRNPs and CNMs gained full practice authority in 2015 (after an 18-month new-graduate mentorship), CRNAs remain fully supervised with no prescriptive authority at all (Maryland is one of about 11 states granting CRNAs none), and only the psychiatric-mental-health population focus of CNS practice is independent. Maryland does not recognize PLLCs; professional entities use physician-only professional corporations, so multi-disciplinary ownership questions remain open.

Pharmacist

Supervision required

Represents Maryland's optional prescriber-pharmacist Drug Therapy Management (DTM) agreement tier under COMAR 10.34.29, not ordinary pharmacist licensure — base dispensing needs no agreement. Requires a PharmD (or documented equivalent training) plus 1,000 hours of relevant clinical experience (or 320 hours in an approved structured program) and disease-state-specific credentialing; no independence pathway once entered.


Proximity

Not codified — left to the practice agreement

Chart review

Not codified — left to the practice agreement

Prescriptive authority

Covered by practice agreement · no controlled-substance authority

Under a prescriber-pharmacist agreement the pharmacist may modify, continue or discontinue drug therapy and order labs under a written, disease-state-specific protocol (COMAR 10.34.29.02). This is delegated drug-therapy management, not independent DEA-registered controlled-substance prescribing, so controlled substances are shown as not allowed. Only a licensed physician-pharmacist protocol may additionally authorize initiating drug therapy; whether that extends to controlled substances is not settled.

Practice ownership (CPOM)

Non-licensee ownership permitted — No pharmacist-ownership requirement identified for Maryland pharmacy permits

Materially more permissive than the physician-only Professional Corporation regime governing PA/APRN entities above, if confirmed.

Supervision ratio

Not codified — left to the practice agreement

Meeting cadence

As needed

COMAR 10.34.29.05 requires the pharmacist to notify the authorized prescriber within 48 hours (unless the agreement states otherwise) whenever the pharmacist modifies a dose/agent, detects an abnormal assessment result, or initiates drug therapy under a physician-pharmacist written protocol — an event-driven notification duty rather than a fixed recurring meeting.

Written agreement

Required

Only required if the pharmacist and an authorized prescriber (physician, podiatrist, or certified APRN with prescriptive authority) elect to engage in drug therapy management under a written protocol and prescriber-pharmacist agreement (COMAR 10.34.29) — a pharmacist's base license and general dispensing authority need no such agreement.

Legal sources

Md. Health Occupations Code §§ 12-6A-01 – 12-6A-10 — Drug Therapy Management (statutory authority for COMAR 10.34.29)

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