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Committee refers updated self‑assessment forms for wholesalers, surgical clinics and hospital pharmacies to full board
Summary
The committee reviewed revised self‑assessment forms (wholesaler/3PL, surgical clinics, hospital pharmacies), recommended targeted stakeholder outreach and wording edits (clarify 'if applicable' fields and some regulatory references) and agreed to forward the forms to the full board for consideration.
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The Enforcement & Compounding Committee on April 16 reviewed updated self‑assessment forms the board staff prepared for wholesalers/third‑party logistics providers (3PLs), surgical clinics, and hospital pharmacies.
Staff explained the new format organizes each form by pharmacy law and regulation category and embeds hyperlinks to relevant code sections. Members complimented the readability and linked references, and recommended additional stakeholder input for the wholesaler/3PL form (for example, sending a subscriber alert to designated representatives and responsible managers) before full‑board consideration.
On the surgical clinic form, members asked that fields for ADDS/ADS license numbers be placed consistently and that sterile vs. non‑sterile patient‑specific compounding fields be marked “if applicable.” Board counsel noted some service‑type fields are required for initial licensure and staff agreed to refine labeling and restore a missing explanatory footnote that indicates optional sections.
On the hospital pharmacy form, members flagged a set of succinct bullets in Section 8 that should be clarified into actionable statements (for example, explicitly saying confidentiality of medical information "is maintained" rather than listing the topic alone). A public commenter, Stephen Gray, urged removing or re‑reviewing a reference to Health & Safety Code section 11167.5 because DEA guidance and past enforcement actions have raised conflicts when facilities relied on that provision for oral prescription workflows. Staff agreed to consult with legal counsel and adjust references as appropriate before the full board meeting.
The committee signaled consensus to forward the revised self‑assessment forms to the full board for consideration and possible action; staff will make wording and format edits and solicit targeted stakeholder feedback where recommended.
Votes and formal actions: earlier in the meeting, the committee approved the Jan. 7, 2026 minutes by roll call vote (unanimous yes from present members). Several self‑assessment referrals were forwarded by consensus (no committee roll‑call votes required).

