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PQAC offers the following reminders regarding the transfer of controlled substance (CIII-CV) prescriptions:
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WAC 246-945-345 states that the transfer of controlled substance prescription information must conform to the requirements of 21 C.F.R. Sec. 1306.25.
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21 C.F.R. Sec. 1306.25 contains detailed information related to the transfer between pharmacies of prescription information for Schedules III, IV, and V controlled substances for refill purposes.
- Pharmacies that electronically share a real-time, online database may transfer up to the maximum refills permitted by law and the prescriber’s authorization.
- Pharmacies that do not share a real-time, online database may only transfer the original prescription information for a controlled substance (CIII-CV) for the purpose of refill dispensing on a one-time basis.
- The transfer of prescription information must be communicated directly between two licensed pharmacists.
The commission has filed a rulemaking inquiry (CR-101) under [WSR 23-01-113] on December 19, 2022, to consider amending sections in chapter 246-945 WAC related to continuing education (CE) requirements to establish minimum standards for health equity CE training programs.
The Washington State legislature passed Engrossed Substitute Senate Bill (ESSB) 5229 in 2021, requiring rulemaking authorities to establish health equity CE requirements. Per requirements established in ESSB 5229, the Department of Health completed model rulemaking in 2022, tasking the commission with either adopting minimum requirements or establishing its own rulemaking pertaining to health equity training as an element of existing CE requirements.
The purpose of health equity CE training is to develop skills among licensed health care personnel to "address structural factors, such as bias, racism, and poverty that manifest as health inequities" per RCW 43.70.613(3)(c). Establishing training requirements for pharmacists and pharmacy technicians will help identify and address ongoing health inequities in Washington State and promote overall patient safety.
The commission has filed a rulemaking inquiry (CR-101) under [WSR 23-01-111] on December 19, 2022, to consider amending WAC 246-945-455 to codify the guidance the commission has provided on access to drugs outside the pharmacy by unlicensed staff of a healthcare facility.
Previously, WAC 246-873-070(3) permitted the director of pharmacy at a hospital to "designate in writing, by title and/or position those individuals who shall be authorized access to particular areas within the pharmacy, including authorization of access to keys and/or combinations." This provision was removed in the chapter rewrite process and replaced by WAC 246-945-455(1)(c).
Under WAC 246-945-455(1)(c), unlicensed staff responsible for supporting supply chain management as a part of their scope of employment are not able to access certain drugs without obtaining a credential from PQAC. This provision caused unintended disruptions in health care facilities and the commission determined at its December 3, 2020 business meeting that they would not find licensees deficient or take enforcement actions against licensees for violations of WAC 246-945-455(1)(c) if the conditions outlined in the associated guidance document are met.
The Washington State Department of Health’s Office of Infectious Disease wants to make sure that you receive information about their new PrEP Pharmacy Toolkit. It includes information and resources to support pharmacies with offering PrEP and addressing STIs onsite. Many were shared and practiced during the PrEP-Based Pharmacy Program Webinar Series offered earlier this year.
Here are links to the toolkit and their bulletin.
Business meetings (9 a.m. via Zoom; venue TBD).
- January 12-13
- March 2-3
- May 4-5
- June 15-16
- August 24-25
- October 19-20
- December 14-15
PQAC Weekly Legislative Calls (Fridays, during Legislative Session 2023)
- January 12 or 13, time TBD
- January 20, 12-1 p.m.
- January 27, 12-1 p.m.
Pharmacy Practice Subcommittee
*Meetings subject to change.
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