Pharmacy Commission

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

1. The scope of the CDTA must permit this activity; and
2. 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 Pharmacy Commission.

For additional information on CDTAs see the Commission’s CDTA – Interim Guidance on Collaborative Drug Therapy (PDF).

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 II. For more information on this specific topic, scroll down the web page to the section titled “Practitioner’s 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 Pharmacy Commission.

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

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)

Yes, a pharmacist may engage in compounding outside of a licensed pharmacy. If yes, is USP still applicable to the pharmacist? 

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

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

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 (chapter 314, Laws of 2019 – section 7, SSB5380).

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

The most appropriate way to enforce USP standards in these scenarios would be complaint-based and not preemptive inspections. Keep in mind the drugs the pharmacist used would need to be purchased, stored, etc. by a health care practitioner licensed to possess those drugs.

No. Compounding is explicitly called out in the definition of the "practice of pharmacy." Other pharmacy-credentialed personnel would still require supervision in accordance with state and federal law. The pharmacist would still need to ensure the compounding operation was compliant with applicable chapters of USP and the compounding facility obtained any necessary licenses.

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.

RCW 18.64A.030(1) states a "'pharmacy technician[]' may assist in performing, under the supervision of a licensed pharmacist, manipulative, nondiscretionary functions associated with the practice of pharmacy and other such duties subject to such restrictions as the commission may by rule adopt.

WAC 246-901-020(1) also requires pharmacy technicians to be under the immediate supervision of a licensed pharmacist when performing nondiscretionary and specialized functions consistent with their training. Based on the laws quoted above, a pharmacy technician is required to be supervised by a pharmacist. Therefore, if pharmacist technicians are acting within their scope at a clinic or non-pharmacy facility, they still must be supervised by a pharmacist.

Relevant factors include, but are not limited to:

• Does the job advertise as a "pharmacy technician" position?
• Does the person have the job title of "pharmacy technician" or "technician?"
• Does the job require the person to have an active national certification or pharmacy technician credential?

Licensed personnel are able to work in different settings based on their scope of practice. If pharmacy technicians are advertising their services based on their credential, they would have to meet the regulatory requirements and standards for that credential. If pharmacy technicians are not performing the functions of a pharmacy technician and are not advertising those services, they must be credentialed appropriately for the functions/actions they are taking.