Pharmacy Practice

Frequently Asked Questions

Under the legislature's new compounding law (SHB 1445), should I continue to follow USP requirements when diluting a reconstituted sterile medication, such as Remicade, according to federal food and drug administration-approved labeling?

Yes, the new compounding law exempts non-sterile and sterile products that only require reconstitution and mixing according to FDA-approved labeling. Further manipulation of a reconstituted product, such as dilution, should be an indicator that compounding is occurring and USP should be followed, per RCW 18.64.270(2). Additionally, under the new pharmacy standard of care rules, the commission expects pharmacists to utilize their professional judgment in the best interest of the patient.

Please note: This law became effective July 25, 2021.

May a pharmacist fill patient pill boxes/medication planners for a patient?

A pharmacist, like a family member, may fill a patient's medication planner/pill box.

Keep in mind a patient may not bring a prescription bottle filled by Pharmacy A into Pharmacy B and ask for the pills to be repackaged into something else (such as a bubble pack) as Pharmacy B did not fill the prescription. This is considered repackaging.

Do I need to adhere to the Washington State Department of Labor and Industries' (L&I) General Occupational Health Standards rules on Hazardous Drugs (i.e., WAC 296-62-500 et al) when handling hazardous drug preparations?

Yes, licensees should be familiar with WACs 296-62-500 through 296-62-50055 when handling hazardous drug preparations.  Contact L&I with any questions on WACs 296-62-500 through 296-62-50055.

Can a pharmacist partially fill a schedule II drug if requested by the patient or the prescriber?

RCW 18.64.265 states a pharmacist may partially fill a prescription for a Schedule II controlled substance if the partial fill is requested by the patient or the prescribing practitioner and the total quantity dispensed in all partial fillings doesn't exceed the quantity prescribed.

May a pharmacist dispense a 12-month supply of a contraceptive drug?

Yes, a pharmacist may dispense a 12-month supply of a contraceptive drug if the prescription is written for an initial supply of 12 months, e.g. 364 tablets of a contraceptive pill. (RCW 48.43.195)

A pharmacist may not dispense a 12-month supply of a contraceptive drug if the prescription is written for a limited initial supply with refills, e.g. an initial 30-day supply with 11 refills. In this situation, a pharmacist is limited to dispensing a 90-day supply of that prescription. (RCW 18.64.520)

If a pharmacist receives an oral, faxed, or written prescription, is that pharmacist required to first verify that the prescriber has been granted an exemption to the e-prescribing requirement, before filling the prescription?

No. RCW 69.50.312(4) states, “A pharmacist who receives a written, oral, or faxed prescription is not required to verify that the prescription properly meets any exemptions under this section. Pharmacists may continue to dispense and deliver medications from otherwise valid written, oral, or faxed prescriptions.” Pharmacists should not refuse to fill valid prescriptions simply because they have not been transmitted to the pharmacy electronically.

May a pharmacist engage in sterile/nonsterile compounding outside a licensed pharmacy?

Yes, a pharmacist may engage in compounding outside of a licensed pharmacy. 

RCW 18.64.270(2) requires pharmacists and pharmacy personnel with commission credentials to meet USP standards no matter the facility where compounding is taking place.

May a pharmacist administer flu vaccinations when operating under a CDTA at a patient's home?

A pharmacist would be able to administer patient-specific vaccines at a patient's home. The pharmacist would still be responsible for the proper packaging and storage of the vaccines while in transit.

Can pharmacy technicians engage in remote medication order processing or perform order entry from a remote location?

Yes, but pharmacists should ensure ancillary personnel or interns are supervised in a manner that meets the commission definition of “immediate supervision”. Immediate supervision is defined in WAC 246-945-001(44). This includes the ability of pharmacists to employ technological means for the supervision of ancillary personnel or interns remotely. Pharmacists are encouraged to review WAC 246-945-001(44) in its entirety when remotely supervising ancillary personnel or interns. 

Does the Uniform Controlled Substances Act (RCW 69.50) restrict the quantity of controlled substances that may be prescribed?

The Uniform Controlled Substances Act (UCSA), chapter 69.50 RCW, does not limit the quantity of controlled substances (including those drugs listed in Schedule II) that may be prescribed. However, prescribers and pharmacists should be aware of specific prescribing laws that may apply to their profession. For example, a number of prescribing boards and commissions have specific laws and rules applicable to prescriptions for opioids. The USCA does prohibit refills for a drug listed in Schedule II (see RCW 69.50.308(d)). The USCA also prohibits filling of a prescription for a drug listed in Schedule II more than six months after the date the prescription was issued (see RCW 69.50.308(d)). The USCA prohibits more than five refills of a prescription for a drug listed in Schedule III, IV, or V (see RCW 69.50.308(g)). In addition, the USCA prohibits filling or refilling of a prescription for a drug listed in Schedule III, IV, or V, more than six months after the date issued by the prescriber (see RCW 69.50.308(g)).

  Can a prescription for a substance included in Schedule II be dispensed upon the oral prescription of a practitioner?

A substance included in Schedule II may be dispensed upon the oral prescription of a prescriber in an emergency (RCW 69.50.308(c)). Further guidance can be found in WAC 246-945-010(6).

Can a pharmacy supply naloxone to an entity that is not licensed by DOH or to an individual not credentialed by the DOH?

Yes, under the “Standing Order to Dispense Naloxone” pharmacists are authorized to dispense naloxone to any “eligible person or entity.” The commission will not take enforcement action against a pharmacist or pharmacy for supplying naloxone in good faith and with reasonable care to a non-credentialed entity or non-credentialed provider in accordance with RCW 69.41.095 and the statewide naloxone standing order (PDF).

An example may include a pharmacy providing naloxone to a behavioral health clinic or provider not credentialed by DOH for the purpose of treating substance use disorder in accordance with RCW 70.41.480 and RCW 71.24.594.

Another example may include a hospital pharmacy and its staff providing naloxone to a patient upon discharge from inpatient care.  
 
Note: An eligible person or entity is any person at risk of experiencing an opioid-related overdose or any person or entity in a position to assist a person at risk of experiencing an opioid-related overdose. These could include a natural person, such as an individual at risk of an opioid-related overdose or a family member, friend or acquaintance of that individual; or a legal person, such as an ambulance service, police department, or school or other educational institution that could be in a position to assist a person at risk of experiencing an opioid-related overdose.

Does an individual's (or businesses') acquisition of more than 50% of the shares in a pharmacy corporation trigger the commission's “change of ownership” process?

Yes, according to statute and rule, pharmacies should immediately notify the commission and comply with the commission's “change of ownership” process if an individual or business acquires more than 50% of the shares in a pharmacy corporation (such as through a stock sale (see RCW 18.64.043(3), WAC 246-945-230(3)(c) and WAC 246-907-040(2)). If there are other change of ownership questions, contact us.

Do I need to include a separate AUP with my pharmacy technician training program application?

Yes. Both the technician training program's AUP and the pharmacy’s general AUP require two separate approvals by the commission. These are two independent processes. These AUPs may be identical or different depending on the duties and responsibilities   specified in the technician training program.  

Is a pharmacist working under a collaborative drug therapy agreement (CDTA) allowed to prescribe controlled substances?

A pharmacist working under a collaborative drug therapy agreement (CDTA) may prescribe controlled substance (CS) prescriptions under the following conditions:

• The scope of the CDTA must permit this activity; and
• The pharmacist must have a Drug Enforcement Administration (DEA) registration (unless exempted from obtaining a DEA registration, for example see the FAQ on use of the hospital DEA with a suffix).

Pharmacists acting with prescriptive authority to prescribe CS must have their own unique DEA registration issued by DEA. (From PQAC Newsletter No. 1283 Practitioner DEA Registrations, April 2018 (PDF) Note: DEA regulations are within the authority of the DEA, so final determination on the need for DEA registration lies with the DEA and not the commission.

For additional information on CDTAs see the commission's Guidance on Collaborative Drug Therapy (PDF).

Is a hospital pharmacist with prescriptive authority under a collaborative drug therapy agreement (CDTA) or other licensed prescribers (such as medical residents) allowed to use their hospital's DEA number on a controlled substances prescription?

Yes, if in compliance with applicable DEA regulations.

The DEA allows any prescriber (as determined by state law) to use the hospital's DEA registration as long as two conditions are met: (i) the prescription or order is entered for drugs to be dispensed and/or administered within the hospital, and (ii) the hospital assigns a specific suffix to the end of the hospital's DEA registration that is unique to the prescriber. The specific suffix will be maintained internally by the hospital.

This might be done with medical residents or other licensed prescribers working within an institutional setting.

For example: Hospital DEA: AB1234567 – 012 (emphasis indicates internal code unique identifier added as a suffix 012)

You can read more about general DEA registrations at Practitioner's Manual - SECTION III. For more information on this specific topic, scroll down the web page to the section titled “Use of a Hospital's DEA Registration Number.”

Note: DEA regulations are within the authority of the DEA, so final determination on the need for DEA registration lies with the DEA and not the commission.

(From PQAC Newsletter No. 1283 Practitioner DEA Registrations, April 2018) (PDF))

Can a pharmacy use transportation network companies (TNCs) such as Uber, Lyft, or Postmates to deliver a patient’s prescription medication?

Possibly: Under Washington law, a TNC could transport a patient’s prescription medication if they are a “common carrier” or “contract carrier” (see RCW 69.41.030(1)). If a TNC is a “common carrier” or “contract carrier” the TNC would have to obtain a permit from the Washington State Utilities and Transportation Commission (UTC) unless they are exempt. Pharmacies should contact the UTC to verify the status of a “common carrier” or “contract carrier”. Pharmacies should consider other applicable laws and other regulators (e.g., United States Drug Enforcement Administration) before using TNCs to deliver a patient’s prescription medications. For example, the DEA has stated registrants are responsible for selecting common or contract carriers that will provide adequate security against in-transit losses or thefts.

Where can I find printable signage indicating “contraceptives prescribed/dispensed here?"

Pharmacies seeking to locate and display printable signage indicating “Contraceptives Prescribed & Dispensed Here” may see the following information on the Washington State Department of Health website's Pharmacy Contraceptive Sign (wa.gov)(PDF). RCW 18.64.008.

May a pharmacy sell and distribute sterile hypodermic syringes and needles without a prescription?

Pharmacies are not prohibited from selling and distributing sterile hypodermic syringes without a prescription (RCW 69.50.4121(3)). Further, individuals over the age of 18 may possess sterile hypodermic syringes and needles for the purpose of reducing blood-borne diseases (RCW 69.50.412(5)).

If “hypodermic syringes, hypodermic needles, or any device adapted for the use of drugs by injection” is sold at retail by a pharmacy, then the pharmacist “shall satisfy himself or herself that the device will be used for the legal use intended” (RCW 70.115.050). The Commission has previously determined that “legal use” includes the distribution of sterile hypodermic syringes and needles for the purpose of reducing the transmission of blood-borne diseases.