NOTICE IS HEREBY GIVEN that the Board of Pharmacy proposed adding Title 16 CCR § 1717.11, related to Remote Processing.   

• Notice of Proposed Action 

• Initial Statement of Reasons 

• Proposed Text 

Any person who wishes to comment on the proposed text may do so by submitting written comments beginning January 9 and ending on February 24 to the following: 

Contact Person: Debbie Damoth
Agency Name: California State Board of Pharmacy
Address: 2720 Gateway Oaks Drive, Ste 100 Sacramento, CA 95833
Email: PharmacyRulemaking@dca.ca.gov
Fax: (916) 574-8618 

 Any responses to comments directly concerning the proposed addition of the text of the regulation will be considered and responded to in the Final Statement of Reasons. 

Please send your comments on the proposed text to Sandra Guckian by close of business on February 9.  

Also in California, as part of the Board's actions during the January 26-27 Board meeting, the Board approved a policy statement related to Pharmacy Intern Hours Earned Outside of Formal Experiential Training. The Pharmacy wishes to provide licensees with information on its policy related to this transition.  

Also in California, the Board of Pharmacy issued the following information regarding "Corresponding Responsibility Considerations for Dispensing Buprenorphine". 

State and Federal law establish that pharmacists share a corresponding responsibility with prescribers to ensure controlled substances are dispensed solely for a legitimate medical purpose and within the bounds of professional practice. Because buprenorphine is most often prescribed for the treatment of opioid use disorder (OUD), its therapeutic intent should be a key part of the pharmacist's evaluation. Pharmacists are legally required to verify the legitimacy of the prescriber and the appropriateness of the prescription. This assessment should reflect buprenorphine's established role in preventing withdrawal, reducing cravings, supporting long-term recovery and lowering rates of overdose, emergency department visits, hospitalizations and death.

Research consistently shows that access to buprenorphine is protective. Given the clinically significant distinctions in buprenorphine's use, pharmacists are obligated to balance vigilance for potential concerns with an understanding that delaying or denying buprenorphine can expose patients with OUD to serious harm. 

Pharmacists should also be aware that commonly cited indicators of potentially fraudulent controlled substance prescriptions do not always translate well to buprenorphine used for OUD treatment. Long travel distances, telehealth prescribing, cash payment, early refills or use of multiple pharmacies often reflect limited availability of prescribers or pharmacies, particularly in rural or underserved areas, rather than misuse or diversion. Because interruptions in buprenorphine therapy can increase the risk of relapse and overdose, pharmacists are encouraged to take these access challenges into account, communicate with prescribers when questions arise and support continuity of care when prescriptions are determined to be legitimate. 

Additional resources are available to assist pharmacists in identifying practice considerations, including "The Pharmacy Access to Resources and Medication
for Opioid Use Disorder (PhARM-OUD) Guideline, A Joint Consensus Practice Guideline from the National Association of Boards of Pharmacy and the National Community Pharmacists Association." 

Finally in California, the Department of Health Care Service posted the following on the Medi-Cal Rx Web Portal:  

• Upcoming Pharmacy Professional Dispensing Fee Provider Self-Attestation 

• Medi-Cal Rx Monthly Bulletin for February 

• User Administration Console (UAC) Registration – Next Steps 

For more information, contact NACDS’ Sandra Guckian at 703-774-4801.