In response to Governor Gavin Newsom’s emergency declaration in San Bernardino County, a waiver has been issued for pharmacies in impacted areas, allowing remote processing under Business and Professions Code (BPC) 4071.1(a). This waiver enables California-licensed pharmacists to process medication orders, including Schedule II-V controlled substances, from remote locations.
Pharmacies must have policies to guide remote processing and be ready to provide them to the Board. The waiver is effective from September 13, 2024, and expires on October 12, 2024, or when the emergency is lifted.
Pharmacy and Pharmacist Remote Processing Waiver Conditions
Pharmacists are permitted to conduct remote processing as permitted by this waiver if in compliance with the following:
- The pharmacist must be a California-licensed pharmacist who either processes medication orders or prescriptions from a remote site located in California or on the premises of a California licensed-pharmacy.
- A California-licensed pharmacy may allow staff pharmacists to engage in remote processing provided the pharmacy has policies and procedures that outline the authorized functions to be performed. Policies and procedures must include methods for protecting the confidentiality and integrity of patient information and must expressly prohibit the printing or storage of protected health information on a device that is outside of the licensed pharmacy. Such policies must be readily retrievable and provided to the Board upon request (i.e. be able to be produced within three business days of request).
- A pharmacy utilizing remote processing shall ensure that all pharmacists providing such services have been trained on the pharmacy's policies and procedures relating to medication order, prescription processing, and remote supervision via technology that, at a minimum, ensures a pharmacist is (1) readily available to answer questions of a pharmacy intern or pharmacy technician; and (2) verify the work performed by the pharmacy intern or pharmacy technician.
- A pharmacy must ensure that any pharmacist performing remote processing shall have secure electronic access to the pharmacy's patient information system and to other electronic systems that an on-site pharmacist has access to when the pharmacy is open.
- Each remote entry record must comply with all record keeping requirements for pharmacies, including capturing the positive identification of the pharmacist involved in the remote review and verification of a medication order or prescription.
- A pharmacy utilizing remote processing is responsible for maintaining records of all medication orders and prescriptions entered into the pharmacy’s information system.
Pharmacy Intern and Pharmacy Technician Remote Processing Waiver Conditions
Pharmacy interns and pharmacy technicians are permitted to conduct nondiscretionary tasks related to remote processing as permitted by the waiver if in compliance with the following:
- The pharmacy intern or pharmacy technician who either enters medication orders or prescriptions from a remote site located in California or on the premises of a California-licensed pharmacy must be licensed by the Board.
- A pharmacy utilizing remote processing shall ensure that all pharmacy interns and pharmacy technicians providing such services have been trained on the pharmacy's policies and procedures relating to medication order or prescription processing and remote supervision via technology that, at a minimum, ensures a pharmacist is (1) readily available to answer questions of a pharmacy intern or pharmacy technician; and (2) verify the work performed by the pharmacy intern or pharmacy technician.
- A pharmacy shall ensure that any pharmacy intern or pharmacy technician performing remote processing shall have secure electronic access to the pharmacy's patient information system and to other electronic systems to which an on-site pharmacy intern or pharmacy technician has access when the pharmacy is open.
- Each remote entry record must comply with all record keeping requirements for pharmacies.
- A pharmacy utilizing remote processing is responsible for maintaining records of all medication orders and prescriptions entered into the pharmacy’s information system, including capturing the positive identification of the pharmacy intern and pharmacy technician.
Full document can be read here.
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