The California State Board of Pharmacy's Enforcement & Compounding Committee discussed whether current consultation regulations (Cal. Code Regs., tit. 16, §17.07.2 and related statutes) remain fit for purpose and whether the board should move toward a standard-of-care approach rather than a prescriptive checklist.

Committee staff presented barriers to effective pharmacist consultation — high workflow demands during immunization periods, lack of reimbursement for consultation services, and operational differences across community, mail-order and closed-door pharmacies. Committee members and public commenters emphasized that without payer reimbursement and better access to accurate patient information, pharmacies struggle to prioritize or staff consistent oral consultations.

Key points from the meeting:
- Reimbursement: Multiple commenters and board members said consultation is difficult to prioritize without dedicated payment. CPHA urged engagement with Medi-Cal and commercial payers to enable clinical reimbursement models tied to AB 1503's standard-of-care framework.
- Mail-order and closed-door pharmacies: Committee members noted that some pharmacies dispatch medications to providers or mail to patients; in some models, in-person consultation is impractical and staff recommended exploring tech-enabled or documented alternatives for patient counseling.
- Regulatory approach: Members discussed making regulations less prescriptive and more flexible to let pharmacists determine clinically necessary consultation content, but emphasized preserving a clear duty to consult and associated documentation expectations.

Public commentary included practicing pharmacists and pharmacists who described operational examples where consultation obligations were hard to meet during high-volume immunization periods and urged the board to consider reimbursement and technological documentation (bidirectional health IT) as part of any policy change.

Next steps: The committee will continue its work and may propose regulatory changes or policy guidance based on further stakeholder input; staff suggested additional investigation into how pharmacies document and provide consultation in mail-order, infusion, and closed-door settings.

Source: Enforcement & Compounding committee report, meeting transcript.