Committee plans listening sessions to gather public input on the duty-to-consult regulation

The Enforcement and Compounding Committee discussed plans to hold public listening sessions to collect feedback on the board's duty-to-consult regulation (Title 16, California Code of Regulations section 1707.2). Staff framed the sessions as information-gathering aimed at improving patient understanding of medications, reducing medication errors, and identifying practical barriers pharmacists and pharmacy staff face when providing consultations.

Committee members recommended specific topics and question refinements for the listening sessions. Nicole Thiebaud suggested adding questions about whether pharmacy software can distinguish a genuine new prescription from a reissued prescription that should not trigger a consult, calling such repeated flags "annoying" for patients (SEG 246-256, 266-275). Ricardo Sanchez and other members emphasized balancing the value of repeated consultations for some patients (for example, elderly or complex-medication patients) against the administrative burden and potential "devaluing" of consults for patients on stable regimens (SEG 305-313, 322-333).

Sung Oh supported combining listening sessions with surveys to gather broader, more analyzable feedback and recommended the sessions remain practical in length and scope (SEG 372-379). Members also discussed distinguishing between large mail-order pharmacies and small independent pharmacies when asking about requirements for written notice and availability for consultation (SEG 671-706). Several members recommended including questions about language access and physical or sensory barriers to ensure consultations reach populations with limited English proficiency or other communication challenges (SEG 846-859).

Legal staff advised the committee that a formal motion is not required for staff to schedule listening sessions, but the committee may authorize staff to proceed. Committee members ultimately decided to report the committee discussion and proposed questions to the full board and allow the full board to weigh in on question wording and the number of sessions. Staff will return to the board with a proposed outreach plan and finalized question set.

Representative comments:
"It would be an excellent path to ask a question ... about issues with consultation on continuing prescriptions that have a new prescription number," Nicole Thiebaud said. "Is there a way that software can designate or distinguish this?" (paraphrased from SEG 266-273)