Committee recommends updated community pharmacy self-assessment form, suggests formatting and clarity edits
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Summary
The committee reviewed a newly formatted community pharmacy/hospital outpatient self-assessment (per AB1503/BPC 4,040.6), praised linked statutory references and recommended edits including adding a table of acronyms up front, clearer version dates, and reconsidering requiring PIC initials on every page; the committee voted to refer the draft form to the full board.
The Enforcement & Compounding Committee reviewed and recommended referral of a redesigned community pharmacy and hospital outpatient pharmacy self-assessment form to the full board on Jan. 7.
Staff said the updated form is arranged by pharmacy law and regulation category, includes hyperlinks to cited statutes and regulations, and is intended to be a standardized format for all future self-assessments. The change responds to AB1503’s centralization of the self-assessment process in statute (BPC 4,040.6), staff said.
Members praised the new format and linked references. Licensee member Nicole Thiebaud called the hyperlinks "so much easier to follow" and suggested adding guidance at the front on how to mark "Not Applicable" versus "No." Licensing member Renee Barker recommended formatting tweaks including moving a note about retaining completed forms for three years to the first page, creating a table of contents, and switching column order so question number precedes reference. Members also discussed version control and whether PIC initials and dates should appear on each page; staff said the PIC initials are a carryover from previous regulation but that the legal requirement may no longer be necessary.
Public commenters raised concerns about (1) implied requirements that might not exist in underlying law and (2) the scope of stakeholder involvement in drafting forms. John Gray recommended clarifying question wording that could imply obligations not in statute, and Andre Peters urged broader stakeholder outreach beyond routine board meetings.
Renee Barker moved to recommend the updated form to the full board, Ricardo Sanchez seconded, and the motion passed by roll-call vote. Staff will incorporate editing suggestions, add an acronym/reference table up front or linked, and include version/date control before forwarding the form for board approval.
