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Committee refers updated self‑assessment forms for wholesalers, surgical clinics and hospital pharmacies to full board
Summary
The committee recommended the full board review revised self‑assessment forms for wholesalers/3PLs, surgical clinics and hospital pharmacies (updated format and hyperlinks to law). Members urged targeted stakeholder outreach, clearer 'if applicable' labeling and legal review of some statutory references.
The Enforcement and Compounding Committee on April 16 unanimously indicated it would refer updated self‑assessment forms for wholesalers/third‑party logistics providers (3PLs), surgical clinics and hospital pharmacies to the full California State Board of Pharmacy.
Staff said the updated forms were reorganized by law and regulation category, include hyperlinks to relevant code sections, and implement statutory changes from the board’s sunset legislation (AB1503). The format is intended to standardize annual self‑assessment and make legal citations easier to find.
Dr. O urged staff to issue a subscriber alert or targeted outreach to designated representatives and responsible managers so stakeholders could review the drafts and submit written comments before the full board meeting. "I'd love for us to send like a subscriber alert to all the designated representatives... so they can provide written comments before the board meeting," Dr. O said.
Members suggested several editorial and usability edits: separating some combined fields (for example, discharge versus emergency room prescriptions), restoring a disappearing footnote explaining optional sections, and standardizing license‑type labels (for example, shortening long labels to familiar abbreviations such as "LSC number"). Julie from staff explained some wording choices and agreed to clean up phrasing for clarity.
Public comments included a request that consultant pharmacists in surgery centers be recognized with PIC‑like standing in practice settings where they effectively act as the pharmacist in charge. On the hospital form, commenter Stephen Gray flagged the inclusion of Health and Safety Code §11167.5, warning that DEA interpretation and past enforcement actions make that citation potentially problematic; the committee said staff and counsel would review the reference.
The committee agreed to send the revised forms to the full board for consideration and possible action; staff will incorporate editorial changes and consult counsel as needed before the board meeting.
