ALL QUESTIONS AND ANSWERS SURE A+
✔✔Can the store be open but the pharmacy
department closed? Under what requirements? - ✔✔Pharmacy security
Drop off box or mail slot for Rx's
Distinct telephone number
Recording of phone calls if answered in main store when RPh not present
Oral Rx's may be recorded if hours are announced by answering machine
Operating hours displayed at entrance; if in larger store, at entrance to larger store and
near the pharmacy
Advertising must list operating hours
✔✔Do pharmacist licenses have to be on display? The
original or official copy? Is a photocopy ok? Can
you obscure your address on the copy displayed to
the public? - ✔✔A photocopy of the license is permitted
There is no specific rule regarding obscuring the address, however, the Board is not
allowed to reveal the address and phone number of a licensee to the public, (RCW
42.56.230), so it seems reasonable that the licensee can obscure the address.
✔✔Are there any required notices that must be
displayed to the public? - ✔✔Notice to Public regarding generic drugs: Every pharmacy
shall post a sign in a location at the prescription counter that is readily visible to patrons
,stating, "Under Washington law, a less expensive interchangeable biological product or
equivalent drug may in some cases be substituted for the drug prescribed by your
doctor. Such substitution, however, may only be made with the consent of your doctor.
Please consult your pharmacist or physician for more information."
✔✔Is a separate patient counseling area required? - ✔✔No separate counseling area
required per se, though patient confidentiality must be considered
✔✔Is OBRA counseling required for Medicaid only or
all patients? - ✔✔No "offer to counsel" -- must counsel
Shall "directly counsel" patient
If delivered, must offer in writing to provide direct counseling and information about the
drug, including how to contact the pharmacist
✔✔How must the offer to counsel be made? - ✔✔For prescriptions delivered outside of
the pharmacy, the pharmacist shall offer in writing, to provide direct counseling and
information about the drug, including information on how to contact the pharmacist.
✔✔Does the offer to counsel need to be documented?
Does the refusal of the offer need to be
documented? How? - ✔✔Washington does not require documentation of counseling
Washington does not require documentation when counseling is refused
It is highly recommended that the pharmacist document refusal to be counseled to
protect the pharmacist/pharmacy in case of lawsuit
✔✔Is counseling required on new prescriptions, refills,
or both? - ✔✔This rule applies to all prescriptions except where a medication is to be
administered by a licensed health professional authorized to administer medications.
✔✔Can printed materials satisfy the counseling
requirement? Under what circumstances? - ✔✔For prescriptions delivered outside of
the pharmacy, the pharmacist shall offer in writing, to provide direct counseling and
information about the drug, including information on how to contact the pharmacist.
The pharmacist shall directly counsel the patient or patient's agent on the use of drugs
of devices, based on the pharmacist's review of the patient's profile. This is for
prescriptions delivered outside of the pharmacy.
✔✔What about prescriptions that are delivered or
mailed to the patient? - ✔✔The pharmacist shall directly counsel the patient or patient's
agent on the use of drugs of devices, based on the pharmacist's review of the patient's
profile. This is for prescriptions delivered outside of the pharmacy.
✔✔Are there any special requirements for mail order
pharmacies? - ✔✔Sell or ship drugs to patients in WA
,Must register with WA Pharmacy Commission
Registered & regulated by home state
Must put 800-number on label for patients to receive consultation
Must maintain patient profiles
Must provide patient information
May be disciplined or fined by WA if home state doesn't investigate a complaint within
45 days.
✔✔Under what circumstances may a pharmacist fill
prescriptions written in another state? - ✔✔Out of state prescriptions are acceptable.
WA allows the following prescribers who are licensed in any state or US territory, or in
British Columbia, to issue prescriptions for legend drugs that are valid
in WA. (Note: Canadian prescribers cannot issue prescriptions for controlled substances
unless they are also licensed in the US and registered with the DEA.)
Physicians (MD, DO)
Podiatrists (PodD, DPM)
Dentists (DDS, DMD)
Veterinarians (DVM)
Nurse Practitioners (ARNP)
Physician Assistants (PA-C)
When licensed in any state, territory, or British Columbia (legend drugs only from BC)
✔✔Is there any provision for dispensing an emergency
refill supply of legend drugs when there are no
refills left and the prescriber cannot be contacted?
What is allowed/required? - ✔✔Non-CSA drugs: an emergency supply for up to 72-
hours may be given (see WAC 246-869-100(f))
Emergency refills—If the prescriber is not available and in the professional judgment of
the pharmacist an emergency need for the medication has been demonstrated, the
pharmacist may dispense enough medication to last until a prescriber can be contacted
- but not to exceed 72 hours' supply. The prescriber shall be promptly notified of the
emergency refill.
✔✔Are patient profiles required for all patients? - ✔✔Establishment of a patient
medication record system is intended to insure that the information it contains will be
reviewed by the pharmacist in a manner consistent
with sound professional practice when each prescription is filled.
✔✔What information is required on the profile? - ✔✔This system will consist of certain
patient and prescription information, and shall provide the pharmacist within the
pharmacy means to retrieve all new prescription and refill prescription information
relevant to patients of the pharmacy
✔✔What use of the profile is required? Review prior to
dispensing new Rx's? Review prior to refills? - ✔✔Prospective - before the fact
, Screen prescriptions against history prior to dispensing
Therapeutic duplication
Drug-disease contraindications
Drug-drug interactions (including OTCs)
Incorrect dosage or duration of treatment
Drug allergies
Clinical abuse or misuse
May be manual and/or computer-assisted
May be "on-line"
Washington Law Requires examination of the medication record for each dispensing
✔✔What is expected to be looked for during profile
review? - ✔✔Examine the patients medication record upon receipt of a prescription or
drug order to determine the possibility of
A clinically significant drug interaction;
A clinically significant drug reaction;
A clinically significant therapeutic duplication; or
Improper utilization of the drug
✔✔Can a patient refuse to give certain information for
the profile? If so, must the refusal be documented,
and how? - ✔✔Elements under required by OBRA-90 may be withheld (age/DOB,
gender, phone); no documentation needed, though RPh cannot be held responsible for
errors d/t the withheld patient info
✔✔What are the requirements for use of computers to
process prescriptions? - ✔✔Must meet standards for security and integrity
Must be approved by Commission - approved systems listed on web site
Staff must sign and adhere to security and integrity policy and procedures
Must allow for communicating preferences for substitution
Pharmacist responsible to for accuracy, validity, and authenticity of the order
Faxes no longer considered a form of electronic prescribing, but considered an image of
a written prescription
✔✔What must be done if the computer system goes
down? - ✔✔If an automated data processing system is used to maintain a patient's
medication record, an auxiliary recordkeeping procedure must be available for use
when the automated data system is temporarily inoperative due to scheduled or
unscheduled system interruption. The auxiliary recordkeeping procedure shall provide
for the maintenance of all patient recordkeeping information as required by this chapter.
Upon restoration of operation of the automated system the information placed in the
auxiliary recordkeeping procedure shall be entered in each patient's records within two
working days, after which the auxiliary records may be destroyed. This section does not
require that a permanent dual recordkeeping system be maintained.