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Board committee urges caution on rewriting consultation rules; cites reimbursement and workflow barriers
Summary
Committee report flagged barriers to pharmacists' duty‑to‑consult (CCR tit.16 §1707.2) — lack of reimbursement and workflow constraints were cited as reasons consultations are often missed; the board discussed moving from prescriptive rules to a standard‑of‑care model while preserving patient safety.
The board’s Enforcement & Compounding Committee presented a multi‑part report on the board’s outsourcing program and a focused discussion of pharmacists’ duty to consult (CCR tit.16 §1707.2). Deputy Executive Officer Julie Ansell and committee members reviewed consultation value, regulatory language, and practical barriers. Several members and public commenters said that without reimbursement dedicated to pharmacist consultation, pharmacies struggle to allocate time to meaningful interactions; one commenter said she is "almost never consulted on new medication" even when being a pharmacist herself.
Committee members suggested that regulation might be made less prescriptive to allow pharmacists to use professional judgment, but several members cautioned that less prescriptive language could lead to a diminished consultation standard unless paired with reimbursement and monitoring. Public commenters from health systems and associations urged clarity on which pharmacies and outpatient dispensers must report to the California Medication Error Reporting (CAMR) program (B&P Code §4113.1; CCR tit.16 §1710) and welcomed the committee’s plan to draft clarifying regulation for hospital pharmacies.
The committee will continue to refine recommended language and explore options such as targeted reimbursement, documentation requirements and FAQs to help operationalize any regulatory change. The board neither adopted immediate regulatory text nor initiated final rulemaking on the duty‑to‑consult item at this meeting; the committee recommended ongoing work and additional public outreach.
