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C A L I F O R N I A S TAT E B OA R D O F P H A R M AC Y

THE SCRIPT
SEPTEMBER 2021

BE AWARE & TAKE CARE: Talk to your pharmacist!


Contents E-prescribing law takes
• News and FAQs about
e-prescribing law taking
efect 1/1/2022 ........................1 efect January 1, 2022
• President’s message.............2
• New regulations and
amendments............ ................8
• Top citations issued in
2020/21.......................................8
• FAQs about requirements
for automated drug delivery
systems (ADDS)..................... 11
• Monitor auto-refll
programs to avoid
medication errors................. 17
• Top inspection violations,
corrections ordered in
2020/21.................................... 18
• DUI, convictions outside
work can hurt professional
license ...................................... 19
• Board elects ofcers,
welcomes new members,
salutes retiring members .. 20
Pharmacists and other health care providers are preparing for major
• Report name, address
changes to Board within 30 changes in the way some prescriptions are issued, received, and
days........................................... 21 dispensed in California.
• Facilities with PHY license
Beginning January 1, 2022, Business and Professions Code (BPC)
can renew, pay online ........ 21
section 688 will require most prescriptions in California to be issued
• Law webinar updated for
2021 .......................................... 22 in the form of an electronic data transmission, or “e-prescription.”
• Board recognizes 40-year The law also requires prescribers to have the capability to send –
pharmacists............................ 22 and pharmacists to have the capability to receive – electronic data
• Board inspector volunteers transmission prescriptions by January 1, 2022.
with FEMA for COVID-19
vaccination duty................... 23 The law includes other provisions and contains exceptions to
• Disciplinary actions........... 25 e-prescription requirements in specifc situations, which are
• Board, committee meetings summarized here. In addition, the California State Board of Pharmacy
scheduled through 2022... 50 has prepared answers to frequently asked questions (FAQs) to help
educate licensees about BPC section 688.

See E-prescriptions, Page 3


PRESIDENT’S MESSAGE
posts online guidance to help January 1, 2022, that will require
pharmacists provide prescription most prescriptions in California
drugs to residents displaced to be issued and received
during declared disasters. electronically.
Also, a list of consumer tips for
preparing a go bag with a supply The FAQs are posted on
of prescription medications and the Board’s website under
other essential items in case “Important Information for
of emergency evacuation is Licensees.” We continuously
available on our website. look for ways to clarify laws and
regulations with FAQs. Please let
As always, licensees are us know if there are any other
reminded to check our website topics you feel would be helpful
and sign up to receive subscriber by developing FAQs.
By Seung Oh, President, alerts with updates about
Board of Pharmacy waivers related to COVID-19, The Board also has adopted
declared states of emergency, important regulations, including
The COVID-19 pandemic and other important information changes to waiver requirements
continues to evolve in from the Board. for of-site storage of records
unpredictable ways, as cases and requirements for automated
linked to the highly transmissible Meanwhile, the Board is prescription refll programs.
Delta variant grow even as more moving forward with important Summaries of new pharmacy
Americans receive vaccinations. initiatives. This includes revising laws and regulations are
On behalf of the California the Notice to Consumers with provided in this newsletter
State Board of Pharmacy, I hope a fresh look and important as well as in Board’s online
everyone is staying healthy and information intended to help pharmacy law webinar, which
safe. prevent medication errors has been updated for 2021.
and better inform consumers
As the newly elected president, about their medications by These policy and regulatory
I look forward to working with encouraging them to speak to actions refect the Board’s
Board members in support of their pharmacist. ongoing pursuit of its mission
our licensees’ eforts to care for “to protect and promote
patients in challenging times. In addition, the Board remains the health and safety of
The Board continues to review committed to informing Californians by pursuing the
Pharmacy Law waivers related to licensees about important highest quality of pharmacist
COVID-19, which are amended, regulatory matters and changes care and the appropriate use
extended, or allowed to expire as in the law. Recently, the Board of pharmaceuticals.” It is a
appropriate. approved frequently asked mission that I am humbled
questions (FAQs) to educate and privileged to lead as Board
In addition, the Board provides licensees about new regulations president, along with newly
important information for regarding automated drug elected Vice President Maria D.
licensees and consumers in areas delivery systems and about Serpa and Treasurer Jignesh “Jig”
threatened by recent wildfres. Business and Professions Code Patel.
The Board emails alerts and section 688, a new law efective
See President’s Message, Page 3

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2 The Script - September 2021
E-prescriptions President’s
Continued from page 1
Message
Continued from page 2
The FAQs are published here in The Script and posted on the Board’s
website. Additional questions about BPC section 688 may be
directed to the Board’s Ask an Inspector service. As I begin this new role, I
want to thank all the past
Key provisions of BPC section 688 include: Board presidents as well as
recent predecessors who set
• Beginning January 1, 2022, health care practitioners who are high standards for public
authorized to issue prescriptions shall have the capability to service while leading the
send electronic data transmission prescriptions. Board to national recognition
as a consumer protection
• Beginning January 1, 2022, pharmacies shall have
and regulatory agency. I am
the capability to receive electronic data transmission
especially grateful to the
prescriptions.
immediate past president,
• Beginning January 2, 2022, a prescription issued by a Greg Lippe, for his skills as
health care practitioner shall be issued as an electronic data a leader and 12 years of
transmission prescription subject to some exceptions. service to the Board as a
public member. I also want
The law does not apply to the following specifc situations: to acknowledge and thank
recent presidents Victor Law,
• Prescriptions issued pursuant to section 11159.2 of the Amy Gutierrez, and Stan
Health and Safety Code. Weisser for their professional
• An electronic data transmission prescription is not available dedication and enduring
due to a temporary technological or electrical failure – contributions to California
meaning failure of a computer system, application, or device; consumers.
the loss of electrical power to that system, application, I look forward to advancing
or device; or any other service interruption afecting the the Board’s mission in
certifed electronic data transmission prescription application conjunction with fellow Board
used to transmit the prescription. members and with active
• The prescribing health care practitioner is issuing a participation from consumers,
prescription to be dispensed by a pharmacy located outside licensees, stakeholders,
California. and other members of the
public. I encourage you
• A prescription issued in a hospital emergency department to stay informed about
or urgent care clinic when at least one of the following policy matters, meetings,
conditions is present: regulations, and other
important activities by
a. The patient resides outside California. subscribing to receive “News
and Information” alerts from
b. The patient resides outside the geographic area of the the Board. Also, I invite all
hospital. interested parties to attend as
c. The patient is homeless or indigent and does not have many meetings as possible to
a preferred pharmacy. share your voice.

d. The prescription is issued at a time when a patient’s


regular or preferred pharmacy is likely to be closed.

See E-prescriptions, Page 4

The Script - September 2021 3


E-prescriptions
Continued from page 3

Under any of conditions a, b, c, and d, a data transmission prescription failed,


prescription shall be electronically issued but does is incomplete, or is otherwise not
not require electronic transmission and may be appropriately received, the pharmacy shall
provided directly to the patient. immediately notify the prescribing health
care practitioner.
• The prescription is issued by a veterinarian.
• A pharmacist who receives a written, oral,
• The prescription is for eyeglasses or contact or faxed prescription shall not be required
lenses. to verify that the prescription properly falls
under one of the exceptions above and
• The prescribing health care practitioner and
may continue to dispense medications
the dispenser are the same entity.
from legally valid written, oral, or fax
• The prescribing health care practitioner prescriptions.
reasonably determines it would be Electronic Data Transmission Prescriptions
impractical for the patient to obtain the (E-Prescriptions) – Frequently Asked Questions
prescribed substances in a timely manner,
and the delay would adversely impact the 1. Does the pharmacy need to have the
patient’s medical condition. capability of receiving electronic data
transmission prescriptions from all prescribers?
• The prescription includes elements not
covered by the latest version of the Under California Business and Professions Code
National Council for Prescription Drug (BPC) section 688(b), a pharmacy must have
Programs’ SCRIPT standard. the capability to receive an electronic data
transmission prescription on behalf of a patient
Other key provisions of BPC section 688 from a health care practitioner authorized to issue
include: a prescription pursuant to BPC section 4040.
• A health care practitioner who issues a Reference: BPC 688(a), 688(b), 4040
prescription for a controlled substance but
does not transmit the prescription as an 2. Does BPC section 688(b) apply to both non-
electronic data transmission prescription controlled and controlled substances?
shall document the reason in the patient’s
medical record as soon as practicable BPC section 688(b) applies to both non-controlled
and within 72 hours of the end of the and controlled substances with regard to a
technological or electrical failure that pharmacy’s capability to receive electronic data
prevented the electronic data transmission transmission prescriptions. However, under BPC
of the prescription. section 688(c), a prescription for a controlled
substance, as defned by BPC 4021, the electronic
• A pharmacy that receives an electronic data transmission prescription must comply with
data transmission prescription but has not Parts 1300, 1304, 1306, and 1311 of Title 21 of the
dispensed the medication to the patient Code of Federal Regulations (CFR). Note: The Board
shall, at the request of the patient or other of Pharmacy recommends practitioners contact
authorized person, immediately transfer or their respective regulatory boards for guidance on
forward the electronic data transmission their requirements for issuing a prescription.
prescription to an alternative pharmacy.
Reference: BPC 688(a) 688(b), 688(c), 4021; CFR
• If a pharmacy or its staf is aware an 1300, 1304, 1306, 1311
attempted transmission of an electronic
See E-prescriptions, Page 5

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4 The Script - September 2021
E-prescriptions
Continued from page 4

3. On or after 01/01/2022, may a pharmacy designated by the requester.


dispense a prescription medication if it receives
a prescription that is not transmitted to the Reference: BPC 688(g)
pharmacy as an electronic data transmission
The Board of Pharmacy would strongly encourage
prescription?
licensees to contact their local DEA ofce for
BPC section 688(i) states that a pharmacist who confrmation of DEA’s policy and the federal
receives a written, oral, or faxed prescription is not requirements related to the forwarding of an
required to verify that the prescription properly unflled controlled substances prescription.
falls under one of the exceptions in subdivision
6. What are the record-keeping requirements
(e). Pharmacists may continue to dispense
for a pharmacy that transfers or forwards
medications from legally valid written, oral, or
electronic data transmission prescriptions?
faxed prescriptions pursuant to this division.
What are the record-keeping requirements for a
Reference: BPC 688(i) pharmacy that receives a transfer or forward of
electronic data transmission prescriptions?
4. Can an unflled non-controlled electronic
data transmission prescription received by Record-keeping must comply with California Code
a pharmacy be transferred or forwarded to of Regulations (CFR) section 1717(e) and CFR
another pharmacy? section 1306.25, if applicable

BPC section 688(g) states a pharmacy that receives 7. If a licensed non-resident pharmacy is located
an electronic data transmission prescription from outside of California and services a patient in
a prescribing health care practitioner who has California, is an electronic data transmission
issued the prescription but has not dispensed the prescription required?
medication to the patient must, at the request
BPC section 688(b) states a pharmacy, pharmacist,
of the patient or a person authorized to make
or other practitioner authorized under California
a request on behalf of the patient, immediately
law to dispense or furnish a prescription pursuant
transfer or forward the electronic data transmission
to section 4040 must have the capability to receive
prescription to an alternative pharmacy
an electronic data transmission prescription on
designated by the requester.
behalf of a patient. Depending on the scenario,
Reference: BPC 688(g) the pharmacy would not need to question a non-
electronic data transmission prescription under
5. Can an unflled Schedule II-V controlled BPC section 688(i).
substance electronic data transmission
prescription received by a pharmacy be Reference: BPC 688(b), 688(i)
transferred or forwarded to another pharmacy?
8. How does BPC section 688 apply to out-of-
BPC section 688(g) states a pharmacy that receives state telemedicine doctors or telephonic/faxed
an electronic data transmission prescription from prescriptions from out-of-state?
a prescribing health care practitioner who has
BPC section 688(a) states a health care practitioner
issued the prescription but has not dispensed the
authorized to issue a prescription pursuant
medication to the patient must, at the request
to section 4040 must have the capability to issue
of the patient or a person authorized to make
an electronic data transmission prescription, as
a request on behalf of the patient, immediately
defned under section 4040 on behalf of a patient
transfer or forward the electronic data transmission
and to transmit that electronic data transmission
prescription to an alternative pharmacy
See E-prescriptions, Page 6

The Script - September 2021 5


E-prescriptions
Continued from page 5

prescription to a pharmacy selected by the 11. Does the hospital retail pharmacy have
patient. Depending on the scenario, the pharmacy the option to only receive electronic data
would not need to question a non-electronic transmission prescription from its own hospital
data transmission prescription under BPC section health care practitioners, but not from any
688(i). Note: The Board of Pharmacy recommends other health care practitioner?
practitioners contact their respective regulatory
boards for guidance on their requirements for BPC section 688(a) is inclusive of all health care
issuing a prescription. practitioners authorized to issue a prescription
pursuant to BPC section 4040. As indicated
Reference: BPC 688(a), 688(i) in BPC section 688(b), a pharmacy must have
the capability to receive an electronic data
9. BPC section 688(e)(1) contains an exception
transmission prescription on behalf of a patient
to the law referencing California Health and
Safety Code (HSC) section 11159.2, which from all types of health care practitioners pursuant
discusses controlled substance prescriptions to BPC section 4040. BPC section 688(e)(7)
issued to terminally ill patients. Does HSC provides a potential exemption if the health care
11167.5 remain efective for those that practice practitioner and the dispenser are the same entity.
in the applicable hospice and long-term care
Reference: BPC 688(a), 688(b), 688(e)(7)
settings?
12. Is posting a prescription in a health care
HSC section 11167.5 will remain efective in the
provider’s system accessible by pharmacists in
applicable hospice and long-term care settings. their system considered transmission?
Reference: HSC 11167.5, 11159.2; BPC 688(e)(1) Under BPC section 688(e)(7), if the prescribing
10. Is there an instance when an electronic data health care practitioner and dispenser are the
transmission prescription must be printed? same entity, electronic transmission prescriptions
are not required. Based on the Board’s
Under certain circumstances as outlined in Health understanding of the scenario posed, “posting” of
and Safety Code (HSC) section 11167.5, there may the prescription in an electronic medical record
be instances where a long-term care or hospice for dispensing by a pharmacy of the same entity
care pharmacy may need to print the electronic meets the intent of California law. Controlled
transmission prescription. Additionally, BPC substance prescriptions must also comply with
section 688(e)(4)(A)(B) references instances when federal law.
a prescription must be electronically issued but
does not require electronic transmission and may Reference: BPC 688(a)(d)(e)(7)
be provided directly to the patient. Controlled 13. Under BPC 688(e)(7), what does “same
substance prescriptions provided directly to entity” mean? Same location or just same
the patient also must comply with federal law. health care system?
Depending on the scenario, the pharmacy would
not need to question a non-electronic data As described in BPC 688(e)(7), “same entity” refers
transmission prescription under BPC section 688(i). to the same health care system which may or may
not be the same physical location.
Reference: HSC 11167.5; BPC 688(e)(4)(A)(B), 688(i)
Reference: BPC 688(e)(7)

See E-Prescriptions, Page 7

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6 The Script - September 2021
E-prescriptions
Continued from page 6

14. For prescribers working under exempted 16. If after speaking with the prescriber/agent
medical practices described in BPC 688(e), do a modifcation is made, would the electronic
they still need to comply with BPC 688(a) and data transmission prescription be voided, and
have the capability of issuing and transmitting does the prescription need to be rewritten as a
an electronic data transmission prescription? telephone prescription?
BPC section 688(d) would not be applicable to a BPC section 688 does not address the modifcation
health care practitioner prescribing a prescription of an electronic data transmission prescription. For
pursuant to subdivision (e). However, the health a noncontrolled and Schedule III-V prescription,
care practitioner must have the capability to issue a pharmacy may reduce the oral prescription to
and transmit an electronic data transmission writing as described in BPC section 4070(a) and
prescription as defned under BPC section 4040 HSC section 11164(b). Note: DEA registrants also
and BPC section 688(a). Note: The California State must comply with federal law regarding controlled
Board of Pharmacy recommends practitioners substances.
contact their respective regulatory boards for
guidance on their requirements for issuing a Reference: BPC 688, 4070(a); HSC 11164(b)
prescription.
17. Does a pharmacist have a responsibility to
Reference: BPC 688(a), 688(d), 688(e), 4040 report prescribers who are not complying with
BPC section 688?
15. Does an e-mail qualify as “an electronic
data transmission prescription,” or does the The law does not require pharmacists to notify the
prescription need to come from an electronic respective regulatory agency of issues of non-
prescribing platform? compliance, but they may choose to do so.
BPC section 4040(c) describes an “electronic data Reference: BPC 688(j)
transmission prescription” as any prescription
order other than an electronic image prescription 18. Do health care practitioners, pharmacists,
that is electronically transmitted from a or pharmacies, when providing health care
licensed prescriber to a pharmacy. An email services to an inmate, individual on parole, or
could potentially qualify as an electronic data youth under the jurisdiction of the Department
transmission prescription for noncontrolled of Corrections and Rehabilitation, need to
substances; however, this does not appear to meet comply with BPC section 688?
the spirit of the law. However, under BPC section
688(c), a prescription for a controlled substance as BPC section 688(k) indicates this section must not
defned by BPC section 4021, the electronic data apply in the scenario described. However, if an
transmission prescription must comply with Parts
inmate, individual on parole, or youth is not under
1300, 1304, 1306, and 1311 of Title 21 of the Code
of Federal Regulations (CFR). Note: The Board of the jurisdiction of the Department of Corrections
Pharmacy recommends practitioners contact their and Rehabilitation, BPC section 688 would apply.
respective regulatory boards for guidance on their
requirements for issuing a prescription. Reference: BPC 688(k)

Reference: BPC 4040(c), 4021, 688(c); CFR 1300,


1304, 1306, 1311

The Script - September 2021 7


Top citations
in 2020/21
iEW i&ul!llois'
-- _,,
Business and Professions Code
(BPC) section 4314 authorizes
the California State Board of
- . ==
and Pharmacy to issue citations
for violations of Pharmacy
Law. Title 16, California Code
regulatory amendments of Regulations (CCR), sections
1775 to 1775.4 describe how the
The California State Board of Pharmacy has adopted important Board exercises this authority.
new regulations and regulatory amendments that take efect in Citations are administrative
2021 and 2022. Information and the Order of Adoption for each actions; they are considered
regulation is posted under “Approved Regulations” on the Board’s less serious than disciplinary
website, www.pharmacy.ca.gov. actions (which may result in
• Title 16, California Code of Regulations, section 1747 – This license probation, suspension,
regulation permanently establishes the required criteria or revocation). Each year, the
for training programs pharmacists must complete to Board’s Enforcement and
independently initiate and furnish HIV preexposure (PrEP) Compounding Committee
and postexposure (PEP) prophylaxis. Efective June 8, 2021. reports the most common
violations that result in citations
• Title 16, California Code of Regulations, section 1707 – in an efort to educate licensees
This change amends the waiver requirements for of-site and prevent violations.
storage of records to allow licensees previously cited for a
records violation to be eligible for a waiver to store records Most common citations in
of-site. Efective July 1, 2021. fscal year 2020/21

• Title 16, California Code of Regulations, sections 1711, Medication errors ranked as
1713, and 1715.1 – These amendments require submission the top reason for citations
of quality assurance records to the Board; update the issued to both pharmacies and
Board’s regulations regarding the use of automated pharmacists during the past
patient dispensing systems (APDS); and identify specifc fscal year.
requirements for the annual completion of the automated
drug delivery system (ADDS) self-assessment form.
Efective July 1, 2021. See Citations 2020/21, Page 9

• Title 16, California Code of Regulations, section 1717.5 –


This regulation establishes requirements for automatic
prescription refll programs. Efective July 1, 2022.
Complete information about pending and approved regulations
is posted on the Board’s website. In the “Quick Hits” column on
the homepage, go to Laws and Regulations and click on “Pending
Regulations” or “Approved Regulations.”

-
8 The Script - September 2021
Citations 2020/21
Continued from page 8

Pharmacies – Top 10 Citations, FY 2020/21*

Code Violation Description Number of Violations


CCR 1716 Medication Error 146
CCR 1761(a) Erroneous or Uncertain Prescription 41
CCR 1764 / CIV 56.10 Unauthorized Disclosure of Prescriptions and Medical 35
Information
CCR 1714(b) Safe and Secure Pharmacy – Maintain Facilities, etc. 35
BPC 4081(a) / CCR Records Kept Open for Inspection for Three Years and
1718 Current Inventory Defined 32
Notify Board within 30 Days of Change of Pharmacist-in-
BPC 4113 Charge 27
CCR 1707.2 Duty to Consult 27
CCR 1707.3 Duty to Review Drug Therapy 15
CCR 1711(d) Quality Assurance Program 9
HSC 11165(d) Report Controlled Substance Dispensing to CURES 6
* July 1, 2020 through June 18, 2021

Pharmacists – Top 10 Citations, FY 2020/21*

Code Violation Description Number of Violations


CCR 1716 Medication Error 147
CCR 1761 Erroneous or Uncertain Prescription 56
CCR 1707.2 Duty to Consult 37
BPC 4081 Records Kept Open for Inspection for Three Years 30
CCR 1764 / CIV 56.10 Unauthorized Disclosure of Prescriptions and Medical 28
Information
CCR 1714 Operational Standards and Security 28
BPC 4301(h) Unprofessional Conduct – Self-administer Drugs or 18
Alcohol
CCR 1707.3 Duty to Review Drug Therapy 16
BPC 4301(l) Unprofessional Conduct – Conviction of a Crime 14
Substantially Related to Pharmacy
CCR 1711(d) Quality Assurance Program 8
* July 1, 2020 through June 18, 2021
See Citations 2020/21, Page 10

The Script - September 2021 9


Citations 2020/21
Continued from page 9

Intern pharmacists and pharmacy technicians were cited most often for unprofessional conduct
stemming from self-use of dangerous drugs or alcohol in a manner dangerous or injurious to oneself or
others, and convictions of crimes substantially related to the practice of pharmacy.

Intern Pharmacists – Top Citations, FY 2020/21*

Code Violation Description Number of Violations


BPC 4301(h) Self-Use of Dangerous Drug/Alcohol 6
BPC 4301(l) Conviction of a Crime Substantially Related to Pharmacy 6
BPC 4301(o) Violating or Attempting to Violate Federal and State Laws or 1
Regulations Governing Pharmacy
* July 1, 2020 through June 18, 2021

Pharmacy Technicians – Top Citations, FY 2020/21*

Code Violation Description Number of Violations


BPC 4301(l) Conviction of a Crime Substantially Related to Pharmacy 58
BPC 4301(h) Self-Use of Dangerous Drug/Alcohol 54
BPC 4301(f) Commission of an Act Involving Moral Turpitude, Dishonesty, 14
Fraud, Deceit or Corruption
BPC 4301(k) Commission of More than One Misdemeanor or Felony 6
Involving Self-use
BPC 4115(e) Unlicensed Technician 6
BPC 4301(g) Knowingly Making or Signing Any Document that Falsely 2
Represents the Facts
* July 1, 2020 through June 18, 2021

This information and additional details about the Board’s citation and fne program can be found in
a slide presentation that is included in the July 15, 2021, Enforcement and Compounding Committee
meeting materials. An archived meeting webcast also is available for viewing on the Enforcement and
Compounding Committee meeting page.

www.pharmacy.ca.gov
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10 The Script - September 2021
Get answers to FAQs about new rules
for automated drug delivery systems
new permit or had a change in pharmacist-
in-charge, or if the pharmacy had a change
in address?

Yes. Per CCR section 1715(b), the pharmacist-


in-charge of the pharmacy shall complete a
self-assessment within 30 days whenever a new
pharmacy permit has been issued or there is a
change in PIC or a change in the licensed location
of the pharmacy to a new address.

Reference: BPC 4427.7; CCR 1715(b)

3. A medication error was made, and a quality


assurance review was completed related to
the licensed ADDS. Do I have to report to
the Board?

Yes. Per CCR section 1711(f ), any quality assurance


record related to the use of a licensed automated
drug delivery system must also be submitted
The California State Board of Pharmacy has drafted to the Board within 30 days of completion of
answers to frequently asked questions (FAQs) to the quality assurance review. A “medication
help licensees comply with new requirements for error” means any variation from a prescription or
automated drug delivery systems (ADDS). These drug order not authorized by the prescriber, as
requirements are in Title 16, California Code of described in CCR section 1716.
Regulations (CCR), sections 1711, 1713, and 1715.1.
Reference: CCR 1711(f ), 1716; BPC 4427.8
1. My pharmacy has multiple licensed ADDS.
Do I have to complete a self-assessment for 4. My pharmacy is in an acute care hospital
each licensed ADDS? and exempt from the licensing requirements
for an ADDS. Do I have to report all quality
Yes. Per BPC section 4427.2(c), a separate assurance records of medication errors
application and license is required for each ADDS. related to the use of the ADDS to the Board
Also, per BPC section 4427.7(a), a pharmacy at the time of renewal?
holding an ADDS license shall complete an annual
self-assessment. The pharmacy shall maintain Yes. Per CCR section 1711(f ), any facility with an
those records within the licensed pharmacy unlicensed automated drug delivery system must
holding the ADDS license and separate from other report the quality assurance review to the Board
pharmacy records. at the time of annual renewal. A “medication
error” means any variation from a prescription or
Reference: BPC 4427.7(a), 4427.2(c); CCR 1715 drug order not authorized by the prescriber, as
described in CCR section 1716.
2. Do I have to complete a new self-assessment
for each ADDS if my pharmacy received a See ADDS FAQs, Page 12

The Script - September 2021 11


ADDS FAQs
Continued from page 11

Reference: CCR 1711(f ), 1716, BPC 4427.8, Final Reference: CCR 1711(e), 1716; BPC 4427.8
Statement of Reasons for CCR sections 1711 and
1716 7. What personnel are authorized to
restock the ADDS (e.g., nurses and other
5. My pharmacy is located in an acute care personnel)?
hospital and exempt from the licensing
requirements for ADDS. Do I have to report This depends on the location of the ADDS. The
ALL quality assurance record related to the stocking and restocking of an ADDS shall be
use of the ADDS to the Board at the time of performed by a pharmacist, or by a pharmacy
renewal, including quality assurance records technician or intern pharmacist under the
related to near-misses or errors caught by supervision of a pharmacist, except for an ADDS
nursing staf? located in a health facility licensed pursuant to
section 1250 of the Health and Safety Code (HSC),
CCR section 1711(b) defnes “medication error” as where the stocking and restocking of the ADDS
any variation from a prescription or drug order not may be performed in compliance with section
authorized by the prescriber, as described in CCR 1261.6 of the Health and Safety Code.
section 1716. Section 1711(b), however, expressly
excludes from the defnition of a medication error Pursuant to HSC section 1261.6(g), if the ADDS
any variation that is corrected prior to furnishing utilizes removable pockets, cards, drawers, or
the drug to the patient or patient’s agent or any similar technology, or unit of use or single dose
variation allowed by law. NOTE: Only quality containers; and the facility, in conjunction with the
assurance records related to the use of the ADDS pharmacy, has developed policies and procedures
that caused the medication error, as defned by the to ensure the removable pockets, cards, drawers,
section, are required to be reported to the Board at or unit of use or single dose containers are
the time of renewal. properly placed into the ADDS, then the facility
and contracted personnel authorized by law to
Reference: CCR 1711(b), 1716; BPC 4427.8 administer drugs may also restock the ADDS.

6. What information is required to be reported Reference: June 2017 Script Newsletter; BPC
as part of the Quality Assurance Review? 4427.3, 4427.4, 4186, 4187.5, 4119.11; HSC 1261.6
(g)
CCR section 1711(e) states the record shall contain
at least the following: 8. Are drugs required to be restocked
immediately into the ADDS?
1. The date, location, and participants in the
quality assurance review; Per BPC section 4427.4(f ), if drugs are not
immediately transferred into an ADDS upon arrival
2. The pertinent data and other information at the ADDS location, the drugs may be stored for
relating to the medication error(s) reviewed no longer than 48 hours in a secured room within
and documentation of any patient contact the ADDS location. Upon retrieval of these drugs
required by subdivision (c); from secured storage, an inventory must be taken
3. The fndings and determinations generated to detect any losses or overages.
by the quality assurance review; and Reference: BPC 4427.4
4. Recommended changes to pharmacy
policy, procedure, systems, or processes, if See ADDS FAQs, Page 13
any.

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12 The Script - September 2021
ADDS FAQs
Continued from page 12

9. The pharmacy uses an ADDS device with (5) If the ADDS is an APDS, in a location as
an open-matrix design allowing the user provided in section 4427.6.
to access multiple drugs. What are the
requirements for the facility? There is currently pending legislation (Assembly
Bill 1533) that, if enacted, would expand the
Facilities using an automated drug delivery system permissible locations for ADDS.
with an open-matrix design shall contact the
California Department of Public Health for a clear Reference: BPC 4427.3
understanding of the requirements for use. 12. Is the pharmacy required to obtain a
Reference: HSC 1261.6 separate Drug Enforcement Administration
(DEA) registration for each licensed ADDS if
10. Does my pharmacy have to review the ADDS the device contains controlled substances?
on a monthly basis?
Pharmacies should consult federal regulations to
Yes. A review shall be conducted on a monthly ensure compliance with DEA requirements and
basis by a pharmacist and shall include a physical contact the DEA for any necessary clarifcations
inspection of the drugs in the automated drug regarding federal rules regarding controlled
delivery system, an inspection of the automated substances. Cited below are some authorities from
drug delivery system machine for cleanliness, and the DEA regarding ADDS.
a review of all transaction records in order to verify
the security and accountability of the system. Reference: Code of Federal Regulations (CFR)
1301.27; ADDS FAQ; Dispensing of Controlled
Reference: HSC1261.6(h); BPC 4186(d), 4119.11(h) Substances to Residents at Long Term Care
Facilities
11. Can an ADDS be licensed in other locations
such as psychiatric health facilities, jails, 13. Our pharmacy ofers an APDS to dispense
etc.? to patients. What is required for patient
consultation?
Answer: No, an ADDS may be placed only in
locations listed under BPC section 4427.3: The APDS shall only be used for patients who have
signed a written consent form demonstrating
(1) Adjacent to the secured pharmacy area of their informed consent to receive drugs from an
the pharmacy holding the ADDS license. APDS and if the APDS has a means to identify each
(2) A health facility licensed pursuant to patient and only releases the drugs to the patient
section 1250 of the Health and Safety Code or the patient’s agent.
that complies with section 1261.6 of the All prescribed drugs and devices dispensed from
Health and Safety Code. the APDS for the frst time must be accompanied
(3) A clinic licensed pursuant to section 1204 by a consultation conducted by a pharmacist
or 1204.1 of the Health and Safety Code, or licensed by the Board via a telecommunications
section 4180 or 4190 of the Business and link that has two-way audio and video.
Professions Code. Reference: BPC 4119.11(d)(6), 4427.6(f )
(4) A correctional clinic licensed pursuant to
section 4187.1.
See ADDS FAQs, Page 14

The Script - September 2021 13


ADDS FAQs
Continued from page 13

16. What drugs can be placed in the APDS?

The pharmacy should have policies and


procedures to determine which drugs and devices
are appropriate for placement in the automated
patient dispensing system.

Reference: BPC 4119.11(d)((1)(B), 4427.6(a)(2)

17. What shall a pharmacy do if a patient


cannot use the APDS due to the drug not
being in stock or the APDS is not in service?

The pharmacy must develop policies and


procedures orienting participating patients on the
use of the APDS, notifying patients when expected
prescription medications are not available in the
APDS, and ensuring that patient use of the APDS
does not interfere with delivery of drugs and
devices. The pharmacy shall ensure the delivery of
drugs and devices to patients expecting to receive
them from the APDS in the event the APDS is
disabled or malfunctions.
14. Can the pharmacist provide consultation
via telephone for new prescriptions prior to Reference: BPC 4427.6(a)
placing the medication in the APDS?
18. We are a hospital with fewer than 100
No. All prescribed drugs and devices dispensed beds and have a licensed drug room. When
from the APDS for the frst time shall be patients are discharged from the hospital,
accompanied by a consultation conducted the physician sometimes writes an order for
by a pharmacist licensed by the Board via a the patient to be discharged with a 72-hour
telecommunications link that has two-way audio supply, which is taken from the ADDS. The
and video. physician will remove the drugs from the
ADDS and dispense the drugs to the patient
Reference: BPC 4427.6(f )
that are properly labeled and meet the
15. Who can provide the consultation for patient-centered labeling requirements. Is
patients using the APDS? the drug room exempt from licensing the
ADDS located at the nursing station if the
A pharmacist licensed by the Board shall perform ADDS is primarily used to administer doses
all clinical services conducted as part of the to patients in the hospital but occasionally
dispensing process, including but not limited to used for dispensing no more than a 72-hour
drug utilization review and consultation. supply of discharge medications to the
patient?
Reference: BPC 4427.6(d)

See ADDS FAQs, Page 15

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14 The Script - September 2021
ADDS FAQs
Continued from page 14

No, the drug room is not exempt from licensing the hospital pharmacy required to license the
ADDS if the location is dispensing medications to ADDS in the emergency room if the ADDS
discharge patients. The drug room will be required is primarily used for the administration of
to license the ADDS location. The drug room is doses to patients in the emergency room
exempt only if the drugs in the ADDS are solely but occasionally used to dispense a 72-hour
used for administration to patients while in the supply of drugs to a patient discharged from
acute care hospital. When drugs from the ADDS are the emergency room for doses removed
used for dispensing, not solely for administration, from the ADDS by the physician?
the exemption no longer applies.
Yes, the ADDS will be required to be licensed. The
Should your hospital provide discharge medication hospital pharmacy is exempt from licensing the
from the drug stock contained within an ADDS, ADDS only when the acute care hospital pharmacy
the Board respectfully requests your facility secure solely uses the ADDS to administer drugs. When
licensure to be compliant with these requirements. an ADDS is used to dispense drugs to a patient,
the exemption no longer applies. While the
Reference: BPC 4427.2(i), BPC 4056
ADDS must be licensed, as long as the physician
19. Can a facility start using the ADDS device as removes the dangerous drug or device from the
soon as the ADDS application is submitted, ADDS to dispense to the patient, the ADDS is not
or do I need to wait until the Board issues considered to be an APDS and need not follow the
the ADDS permit? APDS requirements found in BPC section 4427.6.

The ADDS device cannot be used until the Board Should your hospital provide discharge medication
issues the ADDS permit. from the drug stock contained within an
ADDS when the pharmacy is closed, the Board
Reference: BPC 4427.1, 4427.2(a), 4119.11(a)(1) respectfully requests your facility secure licensure
for each ADDS used for such a function to be
20. We are a hospital with a 24-hour pharmacy. compliant with these requirements. Note: Under
Can we utilize an ADDS to dispense a 72- BPC section 4068, medications can be dispensed
hour supply of medication from our ER if from the emergency room only if the hospital
we request a license from the Board for the pharmacy is closed and there is no pharmacist
ADDS. available in the hospital.
No. A prescriber may dispense a prescription Reference: BPC 4017.3, 4068, 4427.2(i), 4427.6.
medication to an emergency room patient only if
the pharmacy is closed and there is no pharmacist This information is posted on the Board’s website
available. in addition to FAQs related to other topics. To see
all FAQs, go to www.pharmacy.ca.gov, scroll down
Reference: BPC 4068(a)(1) to “Important Information for Licensees,” and click
on the link to “Frequently Asked Questions.”
21. In the emergency room, when the pharmacy
is not open, the physician will remove from
the ADDS and dispense no more than a 72-
hour supply of drugs to a patient to ensure
a drug regimen is immediately commenced
and continued pursuant to Business and
Professions Code section 4068. Is the

The Script - September 2021 15


Auto-refll programs require vigilance
Auto-refll prescription programs can increase medication to a month supply of NorEE
compliance with drug therapy by reminding 0.18/0.215/0.25/0.03 with 12 additional reflls.
patients to pick up prescriptions before The prescription was processed and dispensed
they run out of their medication. However, on 10/9/2018 under Rx 1093646. Prescription
auto-refll programs can also lead to patient Rx 1093646 was reflled on 11/3/2018 and
confusion, medication errors and patient harm 11/28/2018, with 10 reflls remaining.
if implemented incorrectly or if policies and
procedures are not followed correctly. On 12/8/2018, Rx 1003737 for Femynor 0.25/0.035,
which was placed in the auto-refll program,
Complaints to the California State Board of was processed to be reflled. During the process
Pharmacy related to auto-reflls are often related to of flling prescription Rx1003737, a warning of
several types of errors: “duplicate therapy” was displayed. However, the
pharmacist ignored the warning and overrode the
• Failing to discontinue previous warning and allowed the prescription to be flled,
prescriptions when a new prescription for and the prescription was subsequently dispensed
the same drug class is prescribed. to the patient on 12/18/2018.
• Failing to perform a drug regimen review In this scenario, Rx1003737 for Femynor was
to detect duplicate therapy or a change in automatically processed for refll on 12/8/2018
therapy. because the prescription was still active since the
prescription was not discontinued on 10/9/2018
• Requesting renewal of a medications(s) the
when the medication was changed to NorEE
patient is no longer taking.
0.18/0.215/0.25/0.03, and the prescription was due
• Overriding drug-drug warning during the for refll since the prescription was last reflled on
data entry verifcation and or prescription 9/29/2018. On 12/8/2018, when Rx1003737 for
verifcation without reviewing the patient’s Femynor was processed, the pharmacist should
medication profle for duplicate therapy. have heeded the duplicate therapy warning.
Had the pharmacist reviewed the patient’s
• Reflling prescriptions the patient has not prescription profle, it would have shown that
requested to be added to the auto-refll a new medication, NorEE 0.18/0.215/0.25/0.03,
program. was prescribed and flled on 10/9/2018 and the
medication was subsequently reflled on 11/3/2018
Below are two case studies involving problems and 11/28/2018.
with an auto-refll program.
Case No. 2:
Case No. 1:
A patient was notifed by the pharmacy that her
The patient complained that the pharmacy prescription was ready for pick up. When the
dispensed the wrong birth control pills. The frst patient picked up her prescription for amitriptyline
prescription was prescribed on 1/18/2018 for a 50 mg, she questioned why she was picking up a
3-month supply of Femynor 0.25/0.035 with 3 prescription for amitriptyline 50 mg when she had
additional reflls. The prescription was processed just picked up amitriptyline 25mg two days prior.
under Rx 1003737 on 1/8/2018 but was not
flled until 4/19/2018, then the prescription was • The patient was originally prescribed
subsequently reflled on 7/10/2018 and 9/29/2018, Rx 659545 for amitriptyline 25 mg by
resulting in one refll remaining. her physician that was dispensed up to
11/15/2016. Rx 659545 had one refll
On 10/9/2018, the physician changed the remaining.
See Auto-refll, Page 17

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16 The Script - September 2021
Auto-refll
Continued from page 16

• On 12/7/2016, the dose of amitriptyline • Due to the pharmacy’s auto-refll and


was increased by the complainant’s new program and failure of the pharmacist to
physician to 50mg with 2 additional discontinue Rx 704461 for amitriptyline 50
reflls and an annotation stating, “replaces mg, prescription Rx 704461 for amitriptyline
previous prescription.” While processing the 50 mg was auto-reflled on 5/5/2017
prescription under Rx 695766, there was an instead of Rx 717534 for amitriptyline 25
alert stating, “duplicate therapy” because mg.
Rx 659545 for amitriptyline 25 mg was still
active and the pharmacist should have In this scenario, the pharmacist failed to
discontinued Rx659545. discontinue Rx704461 on 3/13/2017. The
pharmacist also failed to act on the duplicate
• Rx 695766 for amitriptyline 50 mg was therapy alerts. As a result, the auto-refll program
reflled on 1/3/2017 and 2/1/2017 with no continued to recognize prescription Rx 704461
reflls remaining. for amitriptyline 50 mg as an active and valid
prescription. Consequently, prescription Rx 704461
• On 1/17/2017, the pharmacy received a was reflled on 4/3/2017 and 4/30/2017 when in
new prescription for amitriptyline 50 mg fact the complainant’s physician had changed
with 2 additional reflls. The prescription the amitriptyline dose to 25 mg and discontinued
was processed under Rx 704461 but was amitriptyline 50 mg on 3/13/2017.
placed on hold and was not flled until
3/5/2017. In addition, the pharmacist failed to discontinue
prescription Rx 659545 for amitriptyline 25mg
• On 3/13/2017, the pharmacy received a on 12/7/2016 when the current physician
new prescription changing the dose of discontinued amitriptyline 25 mg on 12/7/2016
amitriptyline to 25 mg with instructions and change the medication to amitriptyline 50
to discontinue previous amitriptyline mg. Consequently, prescription Rx 659545 for
prescriptions. The prescription was amitriptyline prescribed by the complainant’s
processed under Rx 717534 and placed previous physician was inadvertently flled on
on hold. The pharmacist who completed 5/5/2017.
the data entry verifcation should have
discontinued Rx704461. As a result of failing to discontinue the previous
prescriptions as directed by the prescriber and
• Due to the pharmacy’s auto-refll program placing the new prescriptions on hold, the auto-
and the pharmacist’s failure to discontinue refll program processed the incorrect dose of
Rx 704461, prescription Rx 704461 for amitriptyline. This prompted the complainant to
amitriptyline 50 mg was reflled on question the strength of amitriptyline she should
4/3/2017 instead of the new prescription Rx take and placed the complainant in potential
717534 for amitriptyline 25 mg. harm.
• Due to the pharmacy’s auto-refll program Auto-reflls can help decrease workload and
and the failure of the pharmacist to improve a pharmacy’s efciencies. However,
discontinue Rx 659545 on 12/7/2016, Rx a poorly designed auto-refll program can be
659545 for amitriptyline 25 was reflled a potential source of confusion and harm to
on 4/30/2017 instead of Rx 717534 for consumers when the program does not include:
amitriptyline 25 mg prescribed by the active patient and pharmacist engagement to
complainant’s current physician. correctly identify which medications should be
auto-reflled; continuous review of a patient’s
See Auto-refll, Page 21

The Script - September 2021


-
17
Top inspection violations, corrections in 2020/21
Inspecting all pharmacies at least once every four years is an important goal of the California State Board
of Pharmacy. Inspections are performed for a variety of reasons – including consumer complaints, as a
condition of license issuance or renewal, to monitor probation activities, and as a routine visit to verify
compliance with state and federal laws and regulations.
While inspections provide Board staf an opportunity to observe and evaluate for compliance, they also
provide an opportunity to educate licensees. During an inspection, an inspector may order a correction
for a minor violation of Pharmacy Law or issue a written notice for a more substantial violation.
Each year, the Board’s Enforcement and Compounding Committee reports on the most common
corrections ordered and violation notices issued during inspections in an efort to educate licensees and
prevent future violations.

Top 10 Corrections Ordered during Routine Pharmacy Inspections, FY 2020/21*

Code Violation Description


CCR 1714(c) Pharmacy Clean and Orderly
CCR 1707.5(a)(1) Prescription Label Requirements – Patient-Centered Labeling, 12pt Font
CCR 1715.65(a) Inventory Reconciliation Report of Controlled Substances
CCR 1714(b) Safe and Secure Pharmacy – Maintain Facilities
BPC 4058 License Display
CCR 1715(a) Self-Assessment
CCR 1707.5(d) Policies and Procedures – Provide Interpretive Services
CCR 1707.2(b)(1) Written Notice of Right to Consultation When Patient or Agent is Not Present
(including drugs shipped by mail)
BPC 4076.6(a) Provide Translated Directions for Use if Requested by Patient
CCR 1707.6(c) Notice to Consumer – Requirements
*July 1, 2020 through June 18, 2021

Top Violation Notices Issued during Routine Inspections, FY 2020/21*

Code Violation Description


CCR 1714(d) Security of Prescription Department
CCR 1714(b) Safe and Secure Pharmacy – Maintain Facilities
CCR 1735.3(a)(2) Recordkeeping for Compounded Drugs – Log Requirements
CCR 1776 Prescription Drug Take Back – Authorization
CCR 1716 Variation from Prescription
*July 1, 2020 through June 18, 2021

See Inspections 2020/21, Page 19

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18 The Script - September 2021
DUI, other criminal convictions outside workplace
can have consequences for professional license
Driving under the states a Board license
infuence (DUI) is a shall be suspended “if the
criminal ofense. But Board determines that
did you know a DUI the felony conviction ...
conviction also can result is substantially related
in serious consequences to the qualifcations,
for your California State functions, or duties of the
Board of Pharmacy licensee.”
license?
Licensees should
Under Business and remember that criminal
Professions Code (BPC) behaviors outside the
section 4301, the Board workplace – including
shall take disciplinary action against any licensee DUI – can result in denial, suspension, or
who is guilty of “unprofessional conduct.” The revocation of a license issued by the Board of
provisions of BPC section 4301 defne specifc Pharmacy. Don’t drink or take dangerous drugs
types of acts that constitute “unprofessional and drive.
conduct,” including:
This information is posted on the Board’s website,
• Subsection (k): “The conviction of more www.pharmacy.ca.gov. In the “Quick Hits” column
than one misdemeanor or any felony on the homepage, click on Enforcement Actions >
involving the use, consumption, or self- Warning Regarding DUI Convictions.
administration of any dangerous drug
or alcohol, or any combination of those
substances.” Inspections 2020/21
Continued from page 18
• Subsection (l): “The conviction of a crime
substantially related to the qualifcations, This information and additional details
functions, and duties of a licensee under about the Board’s inspection program can
this chapter.” be found in a slide presentation that is
included the July 15, 2021, Enforcement
What does “substantially related” mean? California and Compounding Committee meeting
Code of Regulation, title 16, section 1770 materials. An archived meeting webcast also
states that for the purpose of a license denial, is available for viewing on the Enforcement
suspension, or revocation, and Compounding Committee meeting
“(A) crime or act shall be considered page.
substantially related to the qualifcations, Licensees also may visit the Board’s website
functions, or duties of a licensee or registrant if to watch an informational video about
to a substantial degree it evidences present or how to prepare for a pharmacy inspection
potential unftness of a licensee or registrant to and download a brochure about pharmacy
perform the functions authorized by his license inspections. Click on the “Licensees” tab at
or registration in a manner consistent with the the top of the homepage and follow the
public health, safety, or welfare.” links to Important Information for Licensees
In addition, BPC section 4311 authorizes license > Board Inspections.
suspension for conviction of a felony. BPC 4311(c)

The Script - September 2021 19


Board elects ofcers, changes members
The California State Board of Pharmacy has Ms. Thibeau has been director of pharmacy
elected ofcers for terms beginning June 1, 2021. services at the Los Angeles LGBT Center since 2013.
In addition, two members have joined the Board She was pharmacist in charge at Target Pharmacy
following the departure of two veteran members. from 2012 to 2013 and pharmacist in charge at CVS
Pharmacy from 2009 to 2012.
Ofcers
Retired members
The Board elected Dr. Seung
Oh of San Diego as president. The Board said thank you and
Dr. Oh, who joined the goodbye to Greg Lippe and
Board in 2020, has worked Albert Wong, who served
as a pharmacist, pharmacist- California consumers and
in-charge, and director of the pharmacy profession as
operations at retail pharmacies longtime members of the Board.
Seung Oh
since 2014. Mr. Lippe served 12 years as Greg Lippe
Members also elected Dr. a public member. He was frst
Maria Serpa of Elk Grove as appointed in 2009 and reappointed in 2012 and
vice president and Jignesh “Jig” 2016 by Governor Edmund G. Brown Jr. He chaired
Patel of Roseville as treasurer. Board committees and was elected vice president
Dr. Serpa, a system support in 2018. He flled a vacancy as acting president and
pharmacist at was elected president in 2019 and in 2020.
Sutter Medical Mr. Lippe was widely respected by stakeholders
Center, for his knowledge and active engagement in
Maria Serpa Sacramento, policy matters. In addition to serving on the Board,
joined he built a successful career as a certifed public
the Board in 2018. Mr. Patel, accountant and company president in Southern
a division pharmacy manager for California.
Safeway since 2006, joined the
Board in 2020. Jig Patel Mr. Wong was frst appointed
as a licensee member in 2012
New members and reappointed in 2016 by
Jose De La Paz of Southgate was Governor Edmund G. Brown
appointed as a public member Jr. He co-owns a pharmacy in
by the Speaker of the Assembly Oakland and earned a doctor
in July 2021. His term expires in of pharmacy degree from
2024. University of California, San
Albert Wong Francisco.
In addition,
Nicole D. Jose De La Paz Mr. Wong’s experience as a pharmacist and
Thibeau of Los a business owner infuenced the Board’s
Angeles was consideration of many important policies. He
appointed as a licensee member advocated for licensee education and supported
by Governor Gavin Newsom in training programs, publications, and other
July 2021. Her term expires in resources to assist professional development of
Nicole Thibeau 2024. pharmacists.

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20 The Script - September 2021
Report name, address changes on time
Licensed individuals who the Board. Although licensee
change their name or address addresses are not available
are required to notify the on the License Search on the
California State Board of Board’s website, the information
Pharmacy within 30 days, is public and will be released
pursuant to Business and upon request to the Board.
Professions Code section 4100
and Title 16, California Code of For complete information about
Regulations, section 1704. changing name or address
records with the Board, go
A change of name must be online to www.pharmacy.ca.gov.
supported with any of the Click on the “Applicants” tab, and
following documents: go to “Address/Name Change.”
The Board will not automatically
• Copy of marriage
issue a new license. To obtain an
certifcate.
updated license with a changed
• Copy of court document name, submit an Application
authorizing a legal name for Reissue of License with the Auto-refll
change. appropriate fee. Continued from page 17

• Copy of driver’s license A change of address can be drug therapy; making notes
and Social Security card submitted online or by mailing for the next pharmacist
with new name. a change of address form to dispensing the next refll;
addressing computer
alerts; and communicating
with the consumer and
prescribers when needed.

Facilities with PHY license The Board has recently


adopted a regulation –

can renew, pay online


Title 16, California Code of
Regulations, section 1717.5
– establishing requirements
Pharmacy facility licenses issued practice pharmacists, pharmacy for automated prescription
by the California State Board of technicians, and designated refll programs. The new
Pharmacy with a PHY prefx can representatives also can be regulation takes efect
now be renewed online with a renewed online with a credit July 1, 2022. Complete
credit card.  card. information about the
regulation is posted on
Online payments may be made Information about license the Board’s website; in the
no earlier than 60 days before renewals and links to renew “Quick Hits” column on the
the license expiration date. and pay online can be found homepage, go to “Laws
Please allow two business days on the Board’s website under and Regulations,” click on
for processing. the “Licensees” tab. Click on “Approved Regulations,” and
“Personal License Information/ scroll to the “Automatic Refll
In addition to facility PHY Renewal” or “Facility License Programs” section.
licenses, personal licenses Information/Renewal.”
issued to pharmacists, advanced

The Script - September 2021 21


2021 law webinar Board recognizes
available online pharmacists
The California Pharmacy Law Update 2021 Edition,
a free continuing education (CE) webinar from with 40 years
of active service
the California State Board of Pharmacy, is now
available for viewing online.

to California
The webinar covers important pharmacy laws
enacted by the Legislature that took efect this
year. In addition, the presentation includes new
regulations adopted by the Board; an overview
of the Board’s structure and activities; and tips on consumers
how to fnd additional information about laws and
regulations on the Board’s website. The California State Board
of Pharmacy proudly
California Code of Regulations, title 16, section celebrates licensed
1732.5(b) requires at least two of the 30 hours of pharmacists who have
CE required for renewal of a pharmacist license dedicated 40 years
be completed by participating in law and ethics of service or more to
courses provided by the Board of Pharmacy. In California consumers!
addition to the law webinar, a CE webinar on ethics Your decades of
is available for viewing on the Board’s website. contributions to patient care
Each webinar meets one of the two hours required and the pharmacy profession
for law and ethics CE courses provided by the are widely acknowledged and
Board. deeply appreciated.

The video player for each webinar asks In honor of their service, pharmacists who
pharmacists to enter their name, email address, have been on active status with the Board
and license number. Upon completion, the Board for at least 40 years will receive certifcates of
automatically receives electronic notifcation appreciation. Because of the high volume of
of licensees who view the webinar. However, eligible candidates, there may be a delay in
licensees must download a completion certifcate issuing certifcates.
at the end of each video and save it for four years
in case evidence of completing the CE requirement The names of 40-year pharmacists also are
is requested. posted on the Board’s website. To see the
names of these dedicated professionals, go
To fnd the law and ethics webinars on the Board’s the www.pharmacy.ca.gov, scroll down to
website, click on the “Applicants” tab at the top of “Important Information for Licensees,” and
the homepage; go to “Important Information for click on Congratulations to California’s 40-Year
Licensees”; and click on Law and Ethics Webinars. Pharmacists!

Besides law and ethics courses, the Board has


online webinars that provide important training
for licensees on corresponding responsibility,
furnishing naloxone, and preparing for a Board
inspection. Visit “Important Information for
Licensees” on the Board’s website for additional
information.

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22 The Script - September 2021
Inspector volunteers for COVID-19 duty
By Christopher Woo

my time at the FEMA site in Norfolk from May 2


to May 9, I served with a team of pharmacists and
Navy corpsmen who administered 8,951 COVID-19
vaccines.
Volunteers also joined outreach efforts at churches
in Norfolk, Chesapeake, and Newport News, VA.
I served as pharmacy lead at three events at First
Baptist Church in Chesapeake from May 17 to May
22. Amid pots and pans in the church kitchen,
pharmacists and pharmacy technicians prepared
vaccines while pharmacists and Army medics in
another room screened patients and administered
COVID-19 vaccines. A total of 559 vaccinations
were administered at these events with assistance
from volunteers nationwide, including California
Christopher Woo, second from left, with other FEMA
pharmacists Peter Chen and Irwin Chow and
pharmacy volunteers in Chesapeake, Va.
pharmacy technicians Dana Clancy and Yamileth
Simmons.
In early 2021, national pharmacy groups solicited
volunteers to administer COVID-19 vaccines at sites Immunization events also were held at high schools
organized by the Federal Emergency Management in Portsmouth and Virginia Beach. Although not
Agency (FEMA). California pharmacist Christopher all students were attending classes on site, many
Woo took personal leave from his position as an arrived just to receive a COVID-19 immunization.
inspector for the California State Board of Pharmacy During one event, I met a Washington pharmacist
to sign up and serve patients this spring in Virginia who had served with a FEMA vaccination mission
and currently in New Mexico. Here is his experience in in Pueblo, Colo., where volunteers visited homes to
Virginia: administer vaccines to housebound and mobility-
challenged patients.
In May 2021, I had the honor of volunteering for a
FEMA COVID-19 vaccination mission in Norfolk, Va. Everywhere we served, volunteers were heartened
While I am not licensed as a pharmacist in Virginia, by the patience and gratitude of people who waited
the federal Public Readiness and Emergency in long lines to receive COVID-19 vaccines. It felt
Preparedness Act was amended to allow health good helping people during the pandemic, and I was
care professionals to administer vaccines in states proud to play a part in this effort.
where they are not licensed as part of a COVID-19
immunization effort by a federal, state, local, tribal, I am grateful for the efforts of all health care
or territorial authority. professionals to protect the health and safety of
the public. I encourage pharmacists, pharmacy
I joined volunteer pharmacists in Norfolk from technicians, and intern pharmacists to consider
California, Maryland, Michigan, Texas, Washington volunteering for COVID-19 vaccination missions
state, Illinois, Massachusetts, Virginia, North sponsored by FEMA. (Find out about volunteering or
Carolina, and Idaho. The goal of the mission donating through FEMA at https://www.fema.gov/
was to broaden access to COVID-19 vaccines in disaster/volunteer-donate). Pharmacy is a valuable
underserved communities. People signed up for health care profession, and volunteering in this way
appointments or walked in and received either demonstrates the benefits of pharmacy for public
the Pfizer or Janssen COVID-19 vaccine. During health and welfare.

The Script - September 2021 23


Disciplinary terms explained
Accusation – An accusation is the document Voluntary Surrender – The licensee has agreed
containing the charges and allegations of to surrender his or her license, and the right
violations of the law that is fled when an agency is to practice or operate a Board-licensed entity
seeking to discipline a licensee. is ended. The Board may agree to accept the
surrender of a license through a “stipulation” or
Efective Date of Action – The date the agreement.
disciplinary action goes into operation.
Suspension – The licensee is prohibited from
Revocation or Revoked – The license is taken practicing or from operating a Board-licensed
back by the Board as a result of disciplinary action, entity for a specifc period of time.
and the licensee’s right to practice or operate a
Board-licensed entity is ended. Suspension/Probation – The right to practice or
operate is contingent on compliance with specifc
Revoked, Stayed – The license is revoked, but the terms and conditions during the probationary
revocation is not efective as long as the licensee period, including a term of suspension.
complies with specifc probationary conditions,
which may include a temporary suspension of the PC 23 Order Issued – The licensee is restricted
licensee’s right to practice. from practicing or operating by the terms of a
court order issued under the provisions of Penal
Stipulated Settlement – The Board and a licensee Code section 23.
mutually agree to settle a disciplinary case brought
by the board by way of a settlement agreement. Public Reprimand – Resulting from a disciplinary
action, the licensee is issued a letter of public
Stayed – The revocation or suspension action is reprimand.
not immediately efective, and the operation or
practice may continue so long as the licensee fully Reinstatement of License – A previously revoked
complies with any specifed terms and conditions. or suspended license is reinstated with or without
specifed terms and conditions.
Probation – The licensee may continue to practice
or operate a board-licensed entity under specifc Statement of Issues – A legal document that
terms and conditions for a specifc period of time. details the factual or legal basis for which a license
was denied.

Disciplinary actions: January through June 2021


Click on a licensee name/number furnishing of controlled accountability of controlled
to read the details of each case. substances; compounding substances; failing to notify the
or dispensing prescriptions Board of the loss of controlled
January 1 – March 31, 2021 that contained signifcant substances.
Personal Licenses error, omission, irregularity,
uncertainty, ambiguity or Action: The license is revoked,
Abergel, Joel (aka Joelle alteration; failing to contact the revocation stayed, and the
Abergel), RPH 41192, AC 5321 prescribers to obtain information license is placed on probation for
Santa Clarita, CA to validate the prescription; fve years. Efective 3/5/2021.
Cause for discipline: Failing flling prescriptions for habitual
to exercise corresponding doctor shoppers and erroneous/
responsibility by clearly excessive uncertain prescriptions. Also
failing to keep complete See Disciplinary actions, Page 25

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24 The Script - September 2021
Disciplinary actions Ambriz, Noel A., TCH 141614, AC Bischof, Renee Sue, TCH 1061,
Continued from page 24 7017 AC 6945
Stockton, CA Bakersfeld, CA
Agustin, Christopher M., TCH Cause for discipline: Conviction Cause for discipline: Conviction
57650, AC 6956 of a crime substantially related of two felony counts of
Torrance, CA to qualifcations, functions, and conspiracy to ship with intent to
Cause for discipline: Conviction duties as a pharmacy technician, distribute at least 80,000 tablets
of crimes substantially related to i.e., DUI; giving misleading of tramadol 50 mg without
the qualifcations, functions, and information to ofcer during a prescription; furnishing a
duties of a pharmacy technician; DUI arrest; use of alcohol to dangerous drug without a
repeatedly stealing dangerous dangerous or injurious extent; prescription; furnishing a
drugs; possession of controlled conviction of more than one controlled substance without a
substance without a prescription. misdemeanor involving use of prescription.
Action: The license is revoked. alcohol.
Action: The license is revoked. Action: The license is revoked.
Efective 2/11/2021. Efective 3/5/2021.
Efective 3/26/2021.
Al Roubae, Rousl N., RPH 72775, Blanks, John C., RPH 46087, AC
AC 6777 Ando, Christopher Kenji, RPH
51762, AC 6896 6803
Bonita, CA Palm Springs, CA
Cause for discipline: Failing Redwood City, CA
Cause for discipline: Diverting Cause for discipline: Failing
to exercise corresponding to maintain current inventory
responsibility, repeatedly bottle of morphine from
pharmacy where employed; and account for promethazine
furnishing prescriptions for with codeine and alprazolam
controlled despite obvious and possessing controlled substance
without a prescription; self- missing from pharmacy; failing
systemic “red fags”; dispensing to maintain drug security;
prescriptions for controlled furnishing a controlled
substance without a unprofessional conduct.
substances that contained
signifcant errors, omissions, prescription; using a controlled Action: The license is revoked,
irregularities, uncertainties, substance in dangerous manner; the revocation stayed, and the
ambiguities, or alterations; acts involving moral turpitude; license is placed on probation for
failing to exercise professional unprofessional conduct. three years. Efective 2/04/2021.
judgment in dispensing Action: The license is voluntarily
controlled substances despite surrendered. Efective 2/11/2021. Centeno, Aleili Bantegui, RPH
“red fags’; dispensing controlled 48641, AC 6692
Andrade, Gabriel Eliseo, TCH Culver City, CA
substances from noncompliant 149977, AC 7069
prescription forms; failing to Cause for discipline: Failing to
Santa Rosa, CA maintain accurate records of
compile inventory reconciliation Cause for discipline: Conviction
reports of Schedule II controlled acquisition and disposition;
of a crime substantially related maintaining misbranded drugs
substances; unprofessional to qualifcations, functions, and
conduct. in pharmacy stock; labeling
duties as a pharmacy technician, bubble card expiration dates
Action: The license is revoked, i.e., DUI; dangerous use of
the revocation stayed, and the with incorrect expiration dates
alcohol; having more than one for the medication; failing to
license is placed on probation for alcohol-related convictions.
three years subject to the terms register with DEA and using
and conditions in the decision. Action: The license is revoked. improper receptacle for drug
Efective 2/04/2021. Efective 3/19/2021. take-back service; failure of
pharmacy technician to have
name tag.
See Disciplinary actions, Page 26

The Script - September 2021 25


Disciplinary actions or experience as a pharmacist two years. Efective 3/5/2021.
Continued from page 25 in practice or operation of a
pharmacy; failing to exercise Gotlinsky, Dimitry, RPH 60239,
Action: The license is revoked, professional judgment in AC 6238
the revocation stayed, and the dispensing dangerous drugs. Encino, CA
license is placed on probation for Cause for discipline:
four years. Efective 2/11/2021. Action: The license is revoked, Convicted of submitting false
the revocation stayed, and the prescription claims for Medicare
Chang, Jill, RPH 66782, AC 6647 license is placed on probation reimbursement; committing
Anaheim, CA for eighteen months. Efective acts warranting license denial;
Cause for discipline: Failing 3/19/2021. having outdated medications
to comply with required among medications ready
sterile compounding policies Dang, Danh H., RPH 45368, AC to be dispensed to patients;
and procedures; failing to 6468 having overfll bottles among
comply with facility and Claremont, CA medications ready to be
equipment standards for sterile Cause for discipline: Denying dispensed; conviction of a
compounding; delivering Board inspectors access to crime substantially related to
adulterated medications to facility; failing to complete qualifcations, functions, or
patients; failing to exercise self-assessment; allowing non- duties of a pharmacist.
education, training, or pharmacist to sign for drug
experience as a pharmacist deliveries. Action: The license is voluntarily
in practice or operation of a surrendered. Efective 2/04/2021.
pharmacy; failing to exercise Action: The license is publicly
professional judgment in reproved. Efective 3/5/2021. Hasan, Afm N., RPH 36127, AC
dispensing dangerous drugs. 6803
Dang, Michael, TCH 63245, AC Hemet, CA
Action: The license is publicly 6468 Cause for discipline: Failing
reproved. Efective 3/19/2021. Claremont, CA to maintain current inventory
Cause for discipline: Denying and account for promethazine
Cheung, Ainslie Hoi Li, RPH Board inspectors access to with codeine and alprazolam
64668, AC 6647 facility; removing prescription missing from pharmacy; failing
Poway, CA records from pharmacy without to maintain drug security;
Cause for discipline: Failing authorization. repeatedly failing to report
to comply with required controlled substance dispensing
sterile compounding policies Action: The license is publicly
reproved. Efective 3/5/2021. to CURES; unprofessional
and procedures; failing to conduct.
comply with facility and Dangtran, Helen Munirah, RPH
equipment standards for sterile 55589, AC 6490 Action: The license is revoked,
compounding; delivering Fairfeld, CA the revocation stayed, and the
adulterated medications to Cause for discipline: Failing to license is placed on probation for
patients; failing to comply with maintain facility in a secure four years. Efective 2/04/2021.
compounding quality assurance manner, resulting in large
requirements; failure to include Hazama, Wayne G., TCH 20638,
amount of promethazine with AC 7013
compounding date on product codeine syrup missing from
labels; failing to justify the North Hills, CA
inventory. Cause for discipline: Taking
maximum allowable beyond-
use date for preparations in Action: The license is revoked, metoprolol tablets from
the master formula; failing to the revocation stayed, and the pharmacy where employed
exercise education, training, license is placed on probation for
See Disciplinary actions, Page 27

-
26 The Script - September 2021
Disciplinary actions with ingredient not authorized South San Francisco, CA
Continued from page 26 by prescriber; dispensing Cause for discipline: Responsible
compounded prescription for deviation from Coumadin
without prescription for self-use; containing controlled substances prescription for patient who
dishonest act. pursuant to preprinted, multiple- instead received warfarin and for
Action: The license is voluntarily checkof, prescription blanks. failure to review patient records;
surrendered. Efective 3/5/2021. responsible for beyond-use
Action: The license is revoked. dates assigned to compounded
Henderson, Brandalyn Marie, Efective 2/04/2021. preparations that exceeded
TCH 141434, AC 6841 Huizar, David, TCH 150247, AC ingredient expiration dates.
Bay Point, CA 7021
Cause for discipline: Act Action: The license is publicly
Bakersfeld, CA reproved. Efective 3/19/2021.
involving moral turpitude, Cause for discipline: Conviction
dishonesty, fraud, and deceit, of a crime substantially related Kidwell, Patricia Nichol, TCH
i.e., selecting store merchandise to the qualifcations, functions, 146167, AC 6704
matching a found receipt and and duties of a pharmacy Napa, CA
returning those items in order to technician, i.e., DUI and hit-and- Cause for discipline:
gain store credit, resulting in job run; dangerous use of alcohol; Unprofessional conduct,
termination. act involving moral turpitude, i.e., child endangerment,
Action: The license is revoked. dishonesty, fraud, or deceit, i.e., maintaining place for trafcking
Efective 3/5/2021. hit-and-run. of controlled substances, child
neglect; acts involving moral
Hernandez, David G., TCH Action: The license is revoked. turpitude; dangerous use of
168976, AC 6939 Efective 1/20/2021. drugs and alcohol.
Santa Ana, CA Ignatyeva, Natalya, INT 39269, AC
Cause for discipline: Colliding Action: The license is revoked.
6947 Efective 2/11/2021.
vehicle with a police vehicle San Diego, CA
while driving under the Cause for discipline: Stealing Kiefer, Dwight Lee, RPH 70160,
infuence, causing bodily injury tramadol from pharmacy AC 6702
to another person; dangerous where employed; committing Los Angeles, CA
use of alcohol; multiple act involving moral turpitude, Cause for discipline: DUI
convictions involving alcohol; dishonesty, fraud, deceit, or conviction; criminal conviction
conviction of crimes substantially corruption; self-administering substantially related to the
related to the qualifcations, a controlled substance in a qualifcations, functions, and
functions, and duties of a dangerous manner; possessing duties of a pharmacist.
pharmacy technician. a controlled substance without
a prescription; furnishing a Action: The license is revoked,
Action: The license is revoked. the revocation stayed, and the
Efective 2/04/2021. dangerous drug without a valid
prescription. license is placed on probation for
Herrera, Vivian Jao, RPH 44484, four years. Efective 2/11/2021.
AC 6839 Action: The license is revoked,
the revocation stayed, and the Kolta, Noha Wasf Benyam, RPH
Anaheim, CA 59346, AC 6864
Cause for discipline: Shipping license is placed on probation for
fve years. Efective 2/11/2021. Rancho Cucamonga, CA
dangerous drugs outside Cause for discipline: Allowing
California without a license; Jajeh, Raymond Paul, RPH 47418, pharmacist technician to
incorrectly labeling compounded AC 6819 perform intern pharmacist duties
pain cream; compounding drug
See Disciplinary actions, Page 28

The Script - September 2021 27


Disciplinary actions or duties of a licensee, i.e., for more tablets than actually
Continued from page 27 possession of child pornography; dispensed to patient; failing to
conviction of a crime warranting return to stock prescriptions that
without a valid intern pharmacist denial of a license. were not delivered to patients;
license. holding misbranded drugs.
Action: The license is revoked.
Action: The license is publicly Efective 2/04/2021. Action: The license is publicly
reproved. Efective 1/20/2021. reproved. Efective 2/04/2021.
Markos, Roufes R., RPH 74602, AC
Leano, Rosalinda S., TCH 10968, 6171 Newman, Nathan R., TCH 121454,
AC 6351 Beaumont, CA AC 6933
West Covina, CA Cause for discipline: Violating Foresthill, CA
Cause for discipline: Improperly pharmacist-to-pharmacist Cause for discipline: Unlawfully
possessing pharmacy key and technician ratio; violating obtaining and possessing
accessing pharmacy with key. pharmacist technician trainee controlled substances, including
Action: The license is voluntarily ratio; violating requirement for morphine, fentanyl, and heroin;
surrendered. Efective 1/20/2021. pharmacist technician trainees to self-administering morphine,
wear identifcation. fentanyl, and heroin; fraud.
Low-Blunt, Christine, RPH 47198,
AC 6988 Action: The license is publicly Action: The license is voluntarily
Vacaville, CA reproved. Efective 1/20/2021. surrendered. Efective 1/20/2021.
Cause for discipline: Theft of Namikas, Joanne Leslie, RPH Nguyen, Chi L., RPH 46977, AC
phentermine tablets from 30259, AC 6760 6877
pharmacy where employed; Ojai, CA Sacramento, CA
acts involving moral turpitude, Cause for discipline: Diverting Cause for discipline: Billing
dishonesty, fraud, or deceit; controlled substances; unlawful for prescriptions not picked
unlawful possession of a use or possession of controlled up within 14 days; failing to
controlled substance; obtaining substances; unlawful furnishing maintain accurate inventory
a controlled substance by of dangerous drugs; conviction records; entering incorrect
fraud, deceit, or subterfuge; of a crime substantially related information on prescription
administering a controlled to the qualifcations, functions, label; failing to have a required
substance without a valid or duties of a licensee, i.e., sink with hot and cold running
prescription; self-administering embezzlement under $950. water.
a controlled substance without
a valid prescription; violating Action: The license is revoked. Action: The license is revoked,
statutes regulating controlled Efective 1/20/2021. the revocation stayed, and the
substances. license is placed on probation for
Nasrah, Iyad I., RPH 40241, AC two years. Efective 2/11/2021.
Action: The license is revoked, 6213
the revocation stayed, and the San Francisco, CA Nover, Thomas R., TCH 8273, AC
license is placed on probation for Cause for discipline: Failing to 6821
fve years. Efective 3/26/2021. retain readily retrievable sale Santa Clarita, CA
and disposition records for three Cause for discipline: Diverting
Macavinta, Ryan, TCH 145542, AC years; improperly furnishing 1,500 Norco tablets; furnishing
6920 dangerous drugs to another a dangerous drug to himself,
Gardena, CA pharmacy; failing to reverse furnishing a controlled substance
Cause for discipline: Conviction billing claims for returned to himself, and possessing a
of a crime substantially related substances; billing Medi-Cal controlled substance without a
to the qualifcations, functions,
See Disciplinary actions, Page 29

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28 The Script - September 2021
Disciplinary actions Ouellette, Randy K., RPH 84113, compounding drugs; holding
Continued from page 28 AC 6853 adulterated drugs; assigning
Corona, CA beyond-use dates that exceeded
valid prescription; engaging in Cause for discipline: Unlawful ingredient expiration date;
conduct involving dishonesty, possession of controlled selling adulterated drugs.
fraud, or deceit. substances MDMA and cocaine.
Action: The license is publicly
Action: The license is revoked. Action: The license is revoked, reproved. Efective 1/20/2021.
Efective 3/19/2021. the revocation stayed, and the
license is placed on probation for Paredes, Andres, TCH 133857, AC
Olson, Mark E., RPH 46825, AC 6884
6861 fve years. Efective 3/5/2021.
San Diego, CA
Forestville, CA Ouellette, Randy K., TCH 135321, Cause for discipline: Arrest and
Cause for discipline: Failing to AC 6853 felony conviction for unlawfully
properly maintain pharmacy Corona, CA importing more than 5 kilograms
records, resulting in overages Cause for discipline: Unlawful of cocaine, a controlled
and shortages of controlled possession of controlled substance; unprofessional
substances; failing to exercise substances MDMA and cocaine. conduct.
corresponding responsibility
in dispensing controlled Action: The license is voluntarily Action: The license is voluntarily
substance prescriptions with surrendered. Efective 3/5/2021. surrendered. Efective 3/26/2021.
irregularities and “red fags”;
failing to perform inventory Pai, James Sungjin, RPH 54731, Park, Hee-Joo, RPH 58102, AC
reconciliation for Schedule II AC 6313 6673
controlled substances; failing to Anaheim, CA Auburn, CA
report dispensing of controlled Cause for discipline: Acting as Cause for discipline: Shipping
substances to CURES; failing to a wholesaler without a license; nonsterile-to-sterile batched
maintain physical security of attempting to buy, trade, sell, preparations into California
controlled substance stock; gross or transfer adulterated drugs; before confrming sterility;
negligence; clearly excessive holding adulterated drugs; assigning incorrect beyond-
furnishing of controlled attempting to buy, trade, sell, use dates; extending beyond-
substances. or transfer misbranded drugs; use dates without required
holding misbranded drugs; testing; master formulas
Action: The license is revoked, failing to maintain facilities, lacking storage and handling
the revocation stayed, and the space, fxtures, and equipment instructions; compounding
license is placed on probation for so that drugs are safely and adulterated injectable using
four years. Efective 3/26/2021. properly prepared, maintained, non-pharmaceutical grade
secured, and distributed. ingredient; selling adulterated
Ouellette, Randy K., INT 40873, drug.
AC 6853 Action: The license is revoked,
Corona, CA the revocation stayed, and the Action: The license is publicly
Cause for discipline: Unlawful license is placed on probation for reproved. Efective 3/26/2021.
possession of controlled fve years. Efective 2/04/2021.
substances MDMA and cocaine. Patel, Rikesh A., RPH 76644, AC
Pajouhi, Annamariam, RPH 6811
Action: The license is revoked, 56332, AC 6521 Los Angeles, CA
the revocation stayed, and the El Dorado Hills, CA Cause for discipline: Dispensing
license is placed on probation for Cause for discipline: Failing to unapproved drugs from an
fve years. Efective 3/5/2021. supervise pharmacy technician unlicensed facility as generic
See Disciplinary actions, Page 30

The Script - September 2021 29


Disciplinary actions Action: The license is revoked. license is placed on probation for
Continued from page 29 Efective 3/19/2021. fve years. Efective 1/20/2021.

drugs; dispensing drug that Perez, Jacquelene Zentyatce, Perryman, Ragina D., TCH 13941,
varied from prescription; Applicant, SI 6968 AC 6827
dispensing controlled substance San Pablo, CA Merced, CA
prescriptions lacking required Cause for discipline: Conviction Cause for discipline: Using
security features; committing of a crime substantially related to alcohol in a dangerous manner
dishonest, fraudulent, corrupt the qualifcations, functions, or by driving and reporting to work
acts; purchasing misbranded duties of a pharmacy technician, with blood-alcohol content of
drugs from unlicensed entity; i.e., three alcohol-related driving 0.225 percent.
purchasing, trading, selling, or ofenses; having more than one
transferring misbranded drugs; misdemeanor alcohol-related Action: The license is revoked,
failing to comply with labeling conviction; dangerous use of and the right to practice or
requirements; dispensing alcohol; unprofessional conduct. operate has ended. Efective
controlled substances pursuant 2/04/2021.
to preprinted multiple checkof Action: The application for
pharmacy technician is denied. Porchia, Jr., Lawrence Kirk, TCH
prescription blank; dispensing 156391, AC 6815
ambiguous prescription; Efective 1/20/2021.
Citrus Heights, CA
allowing unauthorized employee Perez, Ramiro M., RPH 55547 AC Cause for discipline: Conviction
and pharmacist intern to have 6521 of a crime substantially related
keys to pharmacy. Folsom, CA to the qualifcations, functions,
Action: The license is publicly Cause for discipline: Failing duties of a pharmacy technician,
reproved. Efective 3/26/2021. to make interpretive services i.e., possession of assault
available to consumers; failing weapon; act involving moral
Patton, Nicole L., Applicant, SI to post Notice to Consumers; turpitude; possessing controlled
6892 storing controlled substances substance without a valid
Valley Center, CA in unsecured bin; failing to prescription.
Cause for discipline: Conviction supervise pharmacy technician;
of crimes substantially related to intermingling expired drugs in Action: The license is revoked,
the qualifcations, functions, or active drug stock and preparing the revocation stayed, and the
duties of a pharmacy technician, prescriptions with expired drugs; license is placed on probation for
i.e., DUI, possession of drug assigning beyond-use dates that three years. Efective 1/20/2021.
paraphernalia, possession of exceeded ingredient expiration Randhawa, Karandeep S., TCH
methamphetamine; using date; selling adulterated drugs 140331, AC 7039
alcohol in a manner dangerous and drugs after beyond-use Elk Grove, CA
to self or others; violating date; failing to follow procedures Cause for discipline: Diverting
controlled substance laws. to guard against using expired codeine/acetaminophen
products for compounding and tablets; unlawful possession of
Action: The application for failing to have current, dated
pharmacy technician is denied. controlled substances; furnishing
procedures; failing to comply of controlled substances without
Efective 2/04/2021. with training requirements for valid prescription; violating
Perez, Claudia J., TCH 120924, AC compounding personnel; failing pharmacy laws.
6973 to complete self-assessment;
Arleta, CA gross negligence. Action: The license is revoked.
Cause for discipline: Unlawful Efective 3/19/2021.
Action: The license is revoked,
use of methamphetamine. the revocation stayed, and the
See Disciplinary actions, Page 31

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30 The Script - September 2021
Disciplinary actions Action: The license is voluntarily pharmacies without
Continued from page 30 surrendered. Efective 3/26/2021. documentation; dispensing
prescriptions with incorrect
Ramirez, Sarina M., TCH 74107, Reese, Clark A., TCH 156186, AC labels; failing to report required
AC 6810 6930 information to CURES.
Stockton, CA Citrus Heights, CA
Cause for discipline: Failing to Cause for discipline: Conviction Action: The license is revoked,
comply with terms of probation of DUI and grand theft; act the revocation stayed, and the
for previous discipline, case no. involving moral turpitude; license is placed on probation for
6113. dangerous use of alcohol. four years Efective 3/26/2021.

Action: The license is revoked. Action: The license is voluntarily Sioson, Augusto B., RPH 50095,
Efective 1/20/2021. surrendered. Efective 1/20/2021. AC 6915
Chula Vista, CA
Rashidi, Masoud, RPH 56324, AC Sakla, Silvana A., RPH 58281, AC Cause for discipline: Acts of
6683 6500 moral turpitude related to
Folsom, CA Newport Beach, CA violent outbursts; unauthorized
Cause for discipline: Maintaining Cause for discipline: Attempting disclosure of patients’
inaccurate dispense records; to subvert investigation by prescriptions; unprofessional
compounding a commercially making false statements to conduct.
available preparation without Board inspectors; failing to safely
documentation of shortage or quarantine expired medications Action: The license is voluntarily
medical need; failing to maintain from active pharmacy stock; surrendered. Efective 1/20/2021.
disposition records; failing failing to complete self-
to obey pharmacy laws and assessment; failing to keep Sun, Seung Pil, RPH 72473, AC
regulations while on probation. written policies and procedures 6826
on pharmacy operations during Los Angeles, CA
Action: The license is revoked, pharmacist absence; failing Cause for discipline: Failing
the revocation stayed, and to have written policies and to exercise corresponding
the terms in case no. 5663 procedures on assistance to responsibility in dispensing
shall remain in efect. Efective patients with limited English controlled substances despite
3/5/2021. profciency; failing to properly presence of “red fags”;
exercise education, training, or flling controlled substance
Razo, Erin Renee, TCH 59517, AC prescriptions that did not
6984 experience as a pharmacist by
not safely quarantining expired comply with form requirements
Bakersfeld, CA or contained signifcant
Cause for discipline: Improperly medications.
error, omission, irregularity,
accessing an inmate’s protected Action: The license is revoked, uncertainty, ambiguity, or
health information. the revocation stayed, and the alteration.
Action: The license is publicly license is placed on probation for
fve years. Efective 3/5/2021. Action: The license is publicly
reproved. Efective 3/26/2021. reproved. Efective 1/20/2021.
Read, Bruce Caddle, RPH 35955, Saliba, Shukri F., RPH 45530, AC
6843 Tatevossian, Armen G., RPH
AC 6941 47251, AC 6870
Goleta, CA Paramount, CA
Cause for discipline: Improperly Glendale, CA
Cause for discipline: DUI Cause for discipline: Reflling
conviction; dangerous use of billing for returned-to-stock
prescriptions; transferring prescriptions that were not
alcohol. authorized; failing to keep
prescriptions between
See Disciplinary actions, Page 32

The Script - September 2021 31


Disciplinary actions to complete compounding syrup, a controlled substance;
Continued from page 31 self-assessment; responsible for unlawful possession of a
pharmacy failing to comply with controlled substance.
complete accountability for immediate-use compounding
dangerous drugs. requirements; responsible for Action: The license is revoked.
pharmacy failing to comply with Efective 3/26/2021.
Action: The license is publicly
reproved. Efective 3/5/2021. written policies and procedures; Yasavolian, Martha Elisabeth,
failing to exercise education, RPH 41591, AC 6774
Tavakkoli Isfahani, Seid Amir F., training, or experience as a Los Altos, CA
RPH 72910, AC 6907 pharmacist when pharmacy Cause for discipline: Failing
Irvine, CA dispensed at least 150 medium- to meet criteria to compound
Cause for discipline: Dispensing risk level CSPs as “immediate- immediate-use sterile drug
controlled substance use”; failing to exercise preparations; assigning incorrect
prescriptions that contained professional judgment when beyond-use dates; failing to
signifcant errors, omissions, pharmacy dispensed at least document quality reviews and
irregularities, uncertainties; 150 medium-risk level CSPs as post-compounding process and
dispensing controlled substance “immediate-use.” procedures; failing to document
prescriptions written on compounding date in logs;
unauthorized forms; failing to Action: The license is revoked,
the revocation stayed, and the failing to document beyond-
exercise judgment in dispensing use date and time of fnal
controlled substances license is placed on probation for
two years. Efective 3/19/2021. compounded drug preparations
on noncompliant forms; in logs.
unprofessional conduct. Wagner, Christina Lynn,
Applicant, SI 6970 Action: The license is revoked,
Action: The license is revoked, the revocation stayed, and the
the revocation stayed, and the Clearlake Oaks, CA
Cause for discipline: Conviction license is placed on probation for
license is placed on probation two years. Efective 1/20/2021.
for eighteen months. Efective of driving with blood-alcohol
1/20/2021. content of 0.8 percent or greater; Zartoshti, Shahriar, RPH 66143,
dangerous use of alcohol; lying AC 6532
Valenzuela, Fidel H., RPH 39708, about conviction on application; Encino, CA
AC 6728 unprofessional conduct. Cause for discipline: Unlawful
Corona, CA possession of controlled
Cause for discipline: Conviction Action: The application for
registration as a pharmacy substances heroin and
of interstate transportation amphetamine; possessing
in aid of a racketeering technician is granted. Upon
satisfaction of all statutory and paraphernalia to unlawfully
enterprise; conviction of a crime use controlled substances;
substantially related to the regulatory requirements, the
pharmacy technician license is possessing controlled substances
qualifcations, functions, duties without a prescription.
of a licensee. issued, immediately revoked,
the revocation stayed, and the Action: The license is revoked.
Action: The license is revoked. license is placed on probation for Efective 2/04/2021.
Efective 2/6/2021. fve years. Efective 3/19/2021.

Vo, Jacqueline H., RPH 45816, AC Williams, Jezimine D., TCH


6647 137559, AC 6759
Los Angeles, CA Sacramento, CA
Cause for discipline: Failing to Cause for discipline: Diversion
complete self-assessment; failing of a promethazine with codeine See Disciplinary actions, Page 33

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32 The Script - September 2021
Disciplinary actions required protective apparel; drugs and controlled substances.
Continued from page 32 failing to ensure to adequate
space for orderly placement Action: The license is publicly
 Facility Licenses of equipment and materials; reproved. Efective 2/18/2021.

Anchor Drugs III, PHY 48787, AC failing to appropriately test each CVS Pharmacy #9708, PHY
6819 drug component for purity, 47872, AC 6759
San Francisco, CA strength, and quality; failing Pomona, CA
Cause for discipline: Deviating to have written procedures Cause for discipline: Failing to
from Coumadin prescription for production and process properly secure drugs from
for patient who instead control; failing to establish employee diversion; failing to
received warfarin and failing and follow procedures to maintain proper records and
to review patient records; describe the in-process controls produce records for missing
assigning beyond-use dates to and tests to be conducted controlled substances and
compounded preparations that on appropriate samples of dangerous drugs.
exceeded ingredient expiration in-process materials of each
dates. batch; failing to determine Action: The license is publicly
expiration dates by appropriate reproved. Efective 3/26/2021.
Deviating from prescription stability testing; failed to
requirements; assigning beyond- ensure laboratory control CVS Pharmacy #9858, PHY
use dates that exceeded the mechanisms were documented 49676, AC 6919
ingredient expiration dates. and followed, and deviations Santa Clarita, CA
were recorded and justifed; Cause for discipline: Failing to
Action: The license is publicly failing to conduct appropriate provide oral consultation to
reproved. Efective 3/19/2021. laboratory testing for each batch patients.
of controlled-release dosage
Apha Drugstore, PHY 51665, AC Action: The license is publicly
to determine conformance to
6468 reproved. Efective 3/26/2021.
the specifcations for the rate
Claremont, CA
of release of each ingredient; Daniels Pharmacy, PHY 36740,
Cause for discipline: Denying
failing to properly assure AC 6213
physical access to Board
uniformity from batch to batch. San Francisco, CA
inspectors; renewing license
Also misbranding progesterone Cause for discipline: Failing
but not engaging in practice of
and tadalafl capsules; selling to retain records of sale and
pharmacy; failing to perform
misbranded products; falsely disposition in readily retrievable
self-assessment; allowing
advertising products; failing to form for three years; improperly
purchased drugs to be left
notify the Board within 24 hours furnishing drugs to another
at door or signed for by non-
of a recall. pharmacy; failing to reverse bill
pharmacist.
claims for returned prescriptions;
Action: The licenses are
Action: The license is publicly billing Medi-Cal for more
voluntarily surrendered. Efective
reproved. Efective 3/5/2021. medication than actually
2/11/2021.
dispensed to patient; holding
Cari Boyd’s Prescription Shop, or ofering for sale misbranded
CVS Pharmacy #3944, PHY
NSF 109, NSF 126, AC 6694 drugs.
49620, AC 6740
Hurst, TX
Oakdale, CA
Cause for discipline: Failing Action: The license is publicly
Cause for discipline: Failing to
to have appropriate standard reproved. Efective 2/04/2021.
secure drug stock from diversion
operating procedures and
by employee; failing to maintain
protocols for quality control unit;
accurate inventory of dangerous See Disciplinary actions, Page 34
failing to ensure personnel wore

The Script - September 2021 33


Disciplinary actions corresponding responsibility Folsom, CA
Continued from page 33 in dispensing controlled Cause for discipline: Maintaining
substance prescriptions with inaccurate dispense
Del’s Pharmacy I, PHY 50935, AC irregularities and “red fags”; records; compounding a
6864 failing to perform inventory drug preparation that was
Rancho Cucamonga, CA reconciliation for Schedule II commercially available without
Cause for discipline: Employing controlled substances; failing to documentation of a shortage or
an intern pharmacist with report dispensing information a specifc medical need; failing
expired license. to CURES; failing to properly to keep disposition records for
Action: The license is publicly store controlled substances a compounded preparation;
reproved. Efective 1/20/2021. to prevent loss or theft; gross violating pharmacy laws and
negligence; excessive furnishing regulations.
Folsom Medical Pharmacy, PHY of controlled substances.
48577, AC 6521 Action: The licenses are revoked,
Folsom, CA Action: The license is revoked, the revocation stayed, and
Cause for discipline: Failing the revocation stayed, and the the terms in case no. 5663
to make interpretive services license is placed on probation for shall remain in efect. Efective
available to consumers; failing four years. Efective 3/26/2021. 3/5/2021.
to post Notice to Consumers; Grove Harbor Medical Center Key Compounding Pharmacy,
storing Schedule II controlled Pharmacy, PHY 55281, AC 6907 NRP 1396, NSC 100631, AC 6673
substances in unsecured bin in Garden Grove, CA Federal Way, CA
main drug stock area; failing to Cause for discipline: Dispensing Cause for discipline:
supervise pharmacy technician controlled substance Shipping nonsterile-to-sterile
compounding drugs; mingling prescriptions with signifcant preparations into California
expired drugs with active stock errors, omissions, irregularities, before confrming sterility;
and preparing products with uncertainties, ambiguities, or assigning beyond-use dates
adulterated drugs; assigning alterations; dispensing controlled without frst confrming sterility;
beyond-use dates exceeding substance prescriptions extending beyond-use dates
ingredient expiration date; sale written on unauthorized forms; without required tests; having
of adulterated drugs; failing unprofessional conduct. incomplete master formula;
to comply with compounding compounding an injectable
training; failing to complete self- Action: The license is publicly with non-pharmaceutical grade
assessment; gross negligence. reproved. Efective 1/20/2021. ingredient; selling adulterated
Action: The license is revoked, Highland Hospital Pharmacy, dangerous product; discipline by
the revocation stayed, and the HPE 14210, AC 6755 out-of-state pharmacy board.
license is placed on probation for Oakland, CA Action: The licenses are publicly
fve years. Efective 1/20/2021. Cause for discipline: Approving reproved. Efective 3/26/2021.
a prescription that contained an
Forestville Pharmacy, PHY 50031, uncertainty, resulting in patient Key Drug Company, PHY 51127,
AC 6861 death. AC 6313
Forestville, CA Los Angeles, CA
Cause for discipline: Failing to Action: The license is publicly Cause for discipline: Acting as
keep adequate inventory and reproved. Efective 1/20/2021. wholesaler without a license;
having overages and shortages attempting to purchase, trade,
of controlled substances with Innovative Compounding
Pharmacy, LSC 99600, PHY sell, or transfer adulterated
no records to account for the drugs; holding adulterated
diference; failing to exercise 48417, AC 6683
See Disciplinary actions, Page 35

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34 The Script - September 2021
Disciplinary actions acquisition and disposition Action: The license is voluntarily
Continued from page 34 to account for drug overages surrendered. The efective date
and shortages; maintaining shall be stayed until July 3, 2021,
drugs; purchase, attempting misbranded drugs in pharmacy at which time the pharmacy
to trade, sell, or transfer stock; labeling bubble cards with shall be sold or closed. Efective
misbranded drugs; holding incorrect medication expiration 3/5/2021.
misbranded drugs; failing to dates; failing to register with
maintain operational standards DEA and have proper receptacle Raley’s Pharmacy #332, PHY
and security. for drug take-back service; 53516, AC 6490
pharmacy technician lacking Fairfeld, CA
Action: The license is revoked, Cause for discipline: Failing to
the revocation stayed, and the name tag.
maintain operational standards
license is placed on probation for Action: The license is voluntarily and security, resulting in large
fve years. Efective 2/04/2021. surrendered. The efective shortage of promethazine with
Kim Pharmacy #3, PHY 51051, AC date shall be stayed until April codeine cough syrup.
6877 30, 2021, at which time the
pharmacy shall be sold or Action: The license is publicly
Sacramento, CA reproved. Efective 3/5/2021.
Cause for discipline: Billing closed. Efective 2/11/2021.
for prescriptions not picked Pacifc Side Pharmacy, PHY Royal Care Pharmacy, PHY 44271,
up within 14 days; failing to 47284, AC 6478 AC 6238
maintain accurate inventory Huntington Beach, CA Los Angeles, CA
records to account for drug Cause for discipline: Reflling Cause for discipline: Submitting
overages and shortages; prescriptions without prescriber false Medicare claims for
entering incorrect information authorization; furnishing reimbursement; committing
on prescription label; lacking dangerous drugs without violations of law that would
sink with hot and cold running a prescription; furnishing warrant license denial;
water. controlled substances without keeping overfll bottles among
a prescription; labeling medications ready to be
Action: The license is publicly dispensed to patients.
reproved. Efective 2/11/2021. compounded product with
improper beyond-use date; Action: The license is revoked.
Market Pharmacy LTC, PHY failing to ensure the security, Efective 2/04/2021.
51030, AC 6870 integrity, authority, and
Northridge, CA confdentiality of electronically Seton Medical Center, HSP
Cause for discipline: Filling received prescriptions; 45703, AC 6774
prescriptions that were not failing to maintain complete Daly City, CA
authorized; failing to keep accountability of dangerous Cause for discipline: Failing
complete records of dangerous drugs; failing to report to CURES; to meet criteria to compound
drugs to account for inventory failing to retain prescriptions; immediate-use sterile drug
variances. failing to maintain patient preparations; incorrectly
medication profles; failing to assigning beyond-use dates
Action: The license is publicly maintain compounding log; greater than 12 hours to
reproved. Efective 3/5/2021. failing to exercise corresponding preparations compounded in
responsibility corresponding a segregated area; failing to
Montebello Pharmacy, PHY
responsibility to ensure document quality reviews and
41430, AC 6692
that a controlled substance post-compounding process and
Montebello, CA
prescription is for a legitimate procedures in compounding
Cause for discipline: Failing
medical purpose.
to keep accurate records of
See Disciplinary actions, Page 36

The Script - September 2021 35


Disciplinary actions Southern California Hospital at uncertainty, ambiguity or
Continued from page 35 Culver City, HSP 51172, AC 6647 alteration; failing to contact
Culver City, CA prescribers to obtain information
logs; failing to document Cause for discipline: Failing to to validate the prescription;
the compounding date in maintain written policies and flling prescriptions for habitual
compounding logs; failing to procedures addressing actions doctor shoppers and erroneous/
document beyond-use date and for CFUs detected during viable uncertain prescriptions. Also
time of fnal compounded drug surface and air sampling; failing failing to keep complete
preparation in compounding to comply with policy requiring accountability of controlled
logs. immediate investigation when substances; failing to notify the
Action: The license is voluntarily environmental monitoring Board of the loss of controlled
surrendered. The efective action levels were exceeded substances.
date shall be stayed until May on viable testing; delivering
adulterated dangerous drugs Action: The license is revoked,
20, 2021, at which time the the revocation stayed, and the
pharmacy shall be sold or to patients; negligence in
addressing repetitive microbial license is placed on probation for
closed. Efective 1/20/2021. fve years. Efective 3/5/2021.
air contamination of the ISO 5
Seton Medical Center, LSC CAI; failing to conduct potency The Medicine Shoppe, PHY
100405, AC 6774 testing annually; failing to 55851, AC 6777
Daly City, CA include compounding date San Diego, CA
Cause for discipline: Failing on labeling; failing to justify Cause for discipline: Failing
to meet criteria to compound maximum allowable beyond- to exercise corresponding
immediate-use sterile drug use dates in master formula; responsibility, repeatedly
preparations; incorrectly failing to complete self- furnishing prescriptions for
assigning beyond-use dates assessment; failing to complete controlled despite obvious and
greater than 12 hours to compounding self-assessment; systemic “red fags”; dispensing
preparations compounded in violating written policies prescriptions for controlled
a segregated area; failing to and procedures prohibiting substances that contained
document quality reviews and compounding medium- and signifcant errors, omissions,
post-compounding process and high-risk products as immediate- irregularities, uncertainties,
procedures in compounding use. ambiguities, or alterations;
logs; failing to document dispensing controlled substance
the compounding date in Action: The license is revoked,
the revocation stayed, and the prescriptions written on
compounding logs; failing to
document beyond-use date and license is placed on probation for unauthorized forms; failing to
two years. Efective 3/19/2021. compile inventory reconciliation
time of fnal compounded drug reports of Schedule II controlled
preparation in compounding The Druggist, Inc., PHY 50146, AC substances; unprofessional
logs. 5321 conduct.
Action: The license is voluntarily Valencia, CA Action: The license is voluntarily
surrendered. The efective Cause for discipline: Failing surrendered. The efective date
date shall be stayed until May to exercise corresponding shall be stayed until June 4, 2021,
20, 2021, at which time the responsibility by clearly excessive at which time the pharmacy
pharmacy shall be sold or furnishing of controlled shall be sold or closed. Efective
closed. Efective 1/20/2021. substances; compounding 2/04/2021.
or dispensing prescriptions
that contained signifcant
error, omission, irregularity, See Disciplinary actions, Page 37

-
36 The Script - September 2021
Disciplinary actions pharmacy license to obtain retail license is placed on probation for
Continued from page 36 license, drugs, and equipment fve years. Efective 3/5/2021.
without paying for them;
United Family Pharmacy, PHY misrepresenting its ownership Vibrant Care Pharmacy Inc, PHY
55735, AC 6803 to the Board; failing to notify 51969, AC 6482
San Jacinto, CA the Board before transferring Oakland, CA
Cause for discipline: Failing to drugs to another pharmacy; Cause for discipline: Failing
maintain current inventory of failing to respond to letters from to reduce oral or electronic
promethazine with codeine and the Board; failing to assign a prescriptions to writing;
alprazolam; failing to maintain pharmacist-in-charge; allowing flling or reflling a Schedule
security of promethazine unsupervised possession and III or IV controlled substance
with codeine and alprazolam; transport of drugs to another prescription more than six
failing to report controlled pharmacy; failing to maintain months after the issue date or
substance dispensing to CURES; security of drugs during more than fve times in total;
unprofessional conduct. transport; subverting eforts of failing to maintain complete
the PIC; failing to disclose true accountability of inventory by
Action: The license is voluntarily storing an overage of dangerous
surrendered. The efective date pharmacy ownership to Board;
failing to furnish owner’s name drugs; failing to maintain
shall be stayed until June 4, 2021, accurate records of billed
at which time the pharmacy to Board inspector; obstructing
patients from picking up and dispensed medication;
shall be sold or closed. Efective obstructing a patient from
2/04/2021. medications by closing without
notice. receiving a legally prescribed
United Pharmacy LLC, NRP 1278, drug.
NSC 99795, AC 6969 Action: The license is voluntarily
surrendered. Efective 3/5/2021. Action: The license is publicly
West Palm Beach, FL reproved. Efective 3/5/2021.
Cause for discipline: Extending Vernbro Medical Pharmacy Inc.,
beyond-use dates for PHY 50188, AC 6500 April 1 – June 30, 2021
compounded products without Los Angeles, CA
required studies; improper Personal Licenses
Cause for discipline: Attempting
stability testing of products; to subvert Board investigation Bertrand, Brianna C., EXC 23938,
compounding a manufacturer with false statements to TCH 146875, AC 6601
drug without proof of medical inspectors; failing to quarantine Oxnard, CA
necessity; failing to report expired medications from active Cause for discipline: Failing
dispensing of Schedule III inventory shelves; failing to to complete self-assessment;
controlled substances to CURES. complete self-assessment; failing failing to maintain records of
Action: The licenses are publicly to have written policies and disposition of dangerous drugs
reproved. Efective 3/26/2021. procedures regarding pharmacy or dangerous devices; failing to
operations during temporary maintain records of receiving
Verdugo Plaza Pharmacy & absence of the pharmacist; dangerous drugs and devices;
Compounding, PHY 51780, AC failing to have written policies failing to secure dangerous drugs
6500 and procedures to help patients in lockable area and limit entry
Glendale, CA with limited or no English to authorized personnel; actions
Cause for discipline: Ceasing profciency understand label related to procuring license
pharmacy operations but information. by fraud or misrepresentation;
maintaining permit without actions related to reformulating
fling Discontinuance of Business Action: The license is revoked, commercially available products
or notifying patients; using the revocation stayed, and the
See Disciplinary actions, Page 38

The Script - September 2021 37


Disciplinary actions Action: The license is revoked, not prescriber’s patient; self-
Continued from page 37 the revocation stayed, and the furnishing controlled substances
license is placed on probation for without a prescription; failing
under a proprietary name for four years. Efective 4/28/2021. to maintain compounding log
sale and suspicious billing identifying manufacturer or
practices. Cortez, Gerardo, TCH 50799, AC supplier of ingredients; failing
7030 to exercise corresponding
Action: The licenses are Santa Ana, CA
voluntarily surrendered. Efective responsibility to ensure
Cause for discipline: Acts of controlled substance prescribed
4/14/2021. moral turpitude, dishonesty, and for legitimate medical purpose.
Bibona, Donald Enslen, TCH deceit related to taking retail
116132, AC 7051 merchandise without paying on Action: The license is revoked,
Ladera Ranch, CA several occasions. the revocation stayed, and the
Cause for discipline: Conviction license is placed on probation for
Action: The license is revoked. fve years. Efective 4/28/2021.
of a crime substantially related to Efective 5/26/2021.
the qualifcations, functions, and Ellis, Latrisa E., TCH 57206, AC
duties of a pharmacy technician, Desai, Dhansukhlal B., RPH 7059
i.e., arson of an inhabited 32783, AC 6697 Mentone, CA
property and possession of Long Beach, CA Cause for discipline: Conviction
fammable material with the Cause for discipline: Failing of a crime substantially related to
intent to set fre to and burn to exercise corresponding the qualifcations, functions, and
a structure; unprofessional responsibility in flling duties of a pharmacy technician,
conduct. prescriptions despite factors i.e., assault with a frearm on
suggesting they were not a person; committing an act
Action: The license is revoked. written for legitimate purposes;
Efective 4/28/2021. involving moral turpitude, deceit,
flling controlled substance or corruption.
Billena-Serna, Malissa M., TCH prescriptions on noncompliant
46225, AC 7006 forms; failing to report controlled Action: The license is revoked.
Murrieta, CA substance prescriptions Efective 4/28/2021.
Cause for discipline: Acts of to CURES; deviating from
prescriptions by dispensing England, David E., RPH 36116, AC
dishonesty and unprofessional 6882
conduct in accessing, multiple prescriptions under the
incorrect prescriber. Las Vegas, NV
printing, copying, and sharing Cause for discipline: Failing to
patient information without Action: The license is voluntarily comply with various federal
authorization. surrendered. Efective 6/9/2021. and state regulations related
Action: The license is revoked. to compounding; failing to
Doan, Linh KH, RPH 43569, AC ensure pharmacy compliance
Efective 5/12/2021. 6478 with compounding regulations;
Concepcion, Anne Rose L., RPH Nipomo, CA compounding controlled
61050, AC 6887 Cause for discipline: Reflling substances without DEA
Buena Park, CA prescriptions after prescriber registration; failing to ensure
Cause for discipline: Failing denied request; furnishing pharmacy compliance with DEA
to maintain current inventory dangerous drugs without registration requirements.
of drugs; falsifying pharmacy prescriptions; furnishing
records; making or signing false controlled substances without Action: The license is publicly
documents; unprofessional prescriptions; falsely reporting reproved. Efective 5/12/2021.
conduct. prescriber approval of
prescription for person who was See Disciplinary actions, Page 39

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38 The Script - September 2021
Disciplinary actions to be missing from sterile Gak, Eun J., RPH 54146, AC 6514
Continued from page 38 compounding labels; allowing Granada Hills, CA
dispensing of controlled Cause for discipline: Selling
Farmer, Leanne E., TCH 61787, AC substance with preprinted, dangerous drugs without
6912 check-box prescription forms; prescriptions; transacting
Merced, CA allowed pharmacy to fail to dangerous drugs at wholesale
Cause for discipline: Selling or submit controlled substance with an entity that is not licensed
dispensing drugs while under information to CURES; allowing with the Board as a wholesaler
the infuence of dangerous violations of requirements or pharmacy; transacting
drugs. for dispensing compounded misbranded drugs; holding
Action: The license is revoked. preparations for prescriber use. misbranded drugs; providing
Efective 6/16/2021. drug take-back service in
Action: The license is publicly violation of regulations and DEA
Forde, Esan N., RPH 57162, AC reproved. Efective 6/9/2021. requirements; failing to exercise
6724 Figueroa, Alejandra N., TCH corresponding responsibility in
Hollywood, CA 159381, AC 7030 dispensing excessive controlled
Cause for discipline: Allowing Santa Ana, CA substance prescriptions with
products to have potency Cause for discipline: Acts of irregularities and red fags and
over time for an extended moral turpitude, dishonesty, and not ensure the prescriptions
beyond-use date; allowing staf deceit related to taking retail were issued for legitimate
violations of attire requirements merchandise without paying on medical need; unprofessional
for sterile compounding; several occasions. conduct.
allowing violations of facility
and equipment standards for Action: The license is revoked. Action: The license is revoked,
sterile compounding; allowing Efective 5/26/2021. the revocation stayed, and the
dusty and dirty fat surfaces in license is placed on probation for
ISO 8 formulation area; allowing Foth, Darrel W., RPH 52592, AC fve years. Efective 5/12/2021.
violations in compounding 6889
Sacramento, CA Harbert, Krystal S., TCH 63567, AC
area for parenteral solutions; 7045
allowing violation of sterility Cause for discipline: Stealing
controlled substances from Riverdale, CA
testing requirements; allowing Cause for discipline: Conviction
compounding of commercially pharmacy were employed;
self-administering oxycodone of crimes substantially related to
available product without a the qualifcations, functions, or
shortage and specifc medical and amphetamine-
dextroamphetamine to a duties of a pharmacy technician,
need; allowing missing elements i.e., DUI; dangerous use of
from master formulas; allowing dangerous extent; acts involving
moral turpitude, dishonesty, alcohol; conviction of more than
labels for compounded products one misdemeanor involving use
without full ingredient names fraud, deceit, or corruption;
endangering public by taking of alcoholic beverages.
and strengths; improperly
allowing sterile water for controlled substances at work; Action: The license is revoked.
irrigation to be left open with no failing to maintain security Efective 4/14/2021.
date of opening or expiration; of controlled substances;
allowing compounded products unprofessional conduct. Haverstock, Cara L., TCH 166451,
with no potency testing; allowed AC 7016
Action: The license is revoked, Davis, CA
no hand washing during the revocation stayed, and the
compounding of sterile product; Cause for discipline: DUI
license is placed on probation for conviction; using alcohol
allowing required information four years. Efective 4/28/2021.
See Disciplinary actions, Page 40

The Script - September 2021 39


Disciplinary actions hydrocodone by fraudulent substances; failing to timely
Continued from page 39 means; unlawful possession of report drug loss to Board in
controlled substance; obtaining writing; failing to countersign
to dangerous extent or in a controlled substances or reconciliation reports; deviating
dangerous manner; conviction of procuring a prescription for from prescriptions without
a crime involving alcohol. controlled substances by fraud, prescriber consent; failing to
Action: The license is revoked, deceit, misrepresentation, or properly identify dispensing
the revocation stayed, and the subterfuge. pharmacist on prescription
license is placed on probation for documents or in electronic
Action: The license is revoked. dispensing data; failing to
three years. Efective 5/26/2021. Efective 4/14/2021. keep controlled substance
Horne, Gary Lynn, RPH 42499, AC Jalali Farahani, Korush, RPH inventory on fle and available
6756 70445, AC 6715 for inspection upon request
Carson City, NV West Hills, CA for three years; failing to
Cause for discipline: Assigning Cause for discipline: Failing report controlled substance
incorrect beyond-use dates to exercise corresponding loss to Board; acts involving
for sterile compounded responsibility to ensure moral turpitude, dishonesty,
preparations; failing to keep controlled substances were fraud, deceit, or corruption;
complete compounding dispensed for a legitimate unprofessional conduct.
records; failing to document medical purpose; dispensing
annual review of policies and Action: The license is revoked.
controlled substances despite Effective 5/12/2021.
procedures; failing to document “red fags” and irregularities
staf training related to garbing; suggesting they were not for
violating federal regulations legitimate medical purpose;
regarding comingling and dispensing controlled substance
biennial inventory of controlled prescriptions issued on
substances; using hard-to-clean noncompliant forms; dispensing
foor mats in compounding prescriptions with incorrect
area; failing to follow written prescriber on label and in
policies and procedures electronic pharmacy record;
in assigning beyond-use unprofessional conduct; violated
dates; failing to maintain requirements for completing
complete compounding logs; biennial inventory of controlled
compounding hazardous drugs substances; failing to maintain
in an environment failing to facilities, space, fxtures,
meet pressure, venting, and air and equipment, resulting in
change requirements. signifcant
Action: The license is publicly shortage of controlled
reproved. Efective 6/23/2021. substances; failing to maintain
Hummel-Ceballos, Sierra A., TCH complete accountability of
26047, AC 6818 all dangerous drugs; failing
Fontana, CA to complete and have self-
Cause for discipline: Acts of assessment on fle; failing to
moral turpitude, dishonesty, compile quarterly inventory
fraud, and/or deceit, i.e., reconciliation report for
obtaining prescription for all Schedule II controlled See Disciplinary actions, Page 41

-
40 The Script - September 2021
Disciplinary actions Khlghatyan, Margarita, RPH smoking marijuana during meal
Continued from page 40 64079, AC 5513 break; unlawful possession
Burbank, CA of controlled substance; sale,
Joaquin, Zenaida B., RPH 46432, Cause for discipline: Failing dispensing or compounding
AC 6847 to have pharmacist on duty; while under the infuence of
Pasadena, CA allowing unlicensed staf to drugs.
Cause for discipline: Failing to receive and sign for delivery
complete controlled substance of dangerous drugs; failing to Action: The license is revoked.
inventories; failing to perform comply with compounding Efective 4/28/2021.
inventory reconciliation quality assurance by allowing
for Schedule II controlled Lee, Michael Myung Y., RPH
unlicensed staf to receive and 44619, AC 6847
substances; billing insurance sign for delivery of dangerous
companies and Medi-Cal for Montebello, CA
drugs; allowing unlicensed Cause for discipline: Failing
dispensing more drugs than individual to act as a pharmacist
actually purchased; failing to exercise corresponding
in transferring prescriptions responsibility in dispensing
to perform corresponding over the phone to a pharmacy;
responsibility in dispensing controlled substance
failing to maintain acquisition prescriptions despite “red fags”
controlled substance and disposition records for
prescriptions with irregularities of illegitimacy; clearly excessive
dangerous drugs; allowing staf furnishing of controlled
and “red flags”; inappropriately to order Schedule II controlled
exercising training, education, substances.
substances without a power
and experience in dispensing of attorney; acting as a reverse Action: The license is revoked,
over 35,000 tablets of Schedule distributor without a wholesaler the revocation is stayed, and the
II-IV controlled substances license; maintaining dispensed license is placed on probation for
despite objective signs of bottles with patient labels fve years. Efective 5/12/2021.
irregularity and without on shelves in active stock;
ensuring they were issued for a involvement in Medi-Cal billing Levin, Steven A., RPH 46443, AC
legitimate medical purpose and scheme. 6927
failing to reference patient and Woodland Hills, CA
prescription records to identify Action: The license is revoked, Cause for discipline:
trends and patterns of the revocation stayed, and the Purchasing, trading, selling,
illegitimacy. license is placed on probation for or transferring a misbranded
fve years. Efective 6/9/2021. dangerous drug, ammonium
Action: The license is revoked. tetrathiomolybdate (ATTM),
Effective 4/14/2021. Kopooshian, Michael, TCH which is not FDA approved and
154835, AC 7095 is intended only for research
Glendale, CA and development use; gross
Cause for discipline: Conviction negligence; dispensing 280
of felony vandalism; acts prescriptions containing ATTM,
involving moral turpitude. which was obtained from entity
Action: The license is revoked. not registered by the FDA nor
Efective 6/9/2021. licensed by Board.

Lasso De La Vega, Cristian, TCH Action: The license is revoked,


146504, AC 6948 the revocation stayed, and the
Pacoima, CA license is placed on probation for
Cause for discipline: an additional two years. Efective
Unprofessional conduct, i.e., 6/23/2021.
See Disciplinary actions, Page 42

The Script - September 2021 41


Disciplinary actions Mendoza, Daniel Casey, TCH of ownership during ownership
Continued from page 41 159524, AC 7044 transfer; conviction of conspiracy
Sunnyvale, CA to engage in the unlawful
Lo, Jenny Tzuning, RPH 70581, AC Cause for discipline: Conviction wholesale distribution of drug,
6747 of possession of child a crime substantially related
Diamond Bar, CA pornography and contact with a to the qualifcations, duties,
Cause for discipline: Allowing minor with the intent to commit and functions of a pharmacy
unlicensed employees to a sex crime; acts involving moral technician.
prepackage medications, a task turpitude.
for which a pharmacy technician Action: The licenses are
license is required. Action: The license is revoked. voluntarily surrendered. Efective
Efective 4/28/2021. 4/28/2021.
Action: The license is publicly
reproved. Efective 4/14/2021. Mumphrey, Tenishia Patrice, TCH Phair, Stephen Allen, TCH 4066,
85431, AC 7037 AC 6880
Love, David Jordan, TCH 145541, Highland, CA Watsonville, CA
AC 6938 Cause for discipline: Diverting Cause for discipline: Conviction
Ben Lomond, CA tramadol tablets from pharmacy of crime substantially related
Cause for discipline: Conviction where employed; violation to the qualifcations, duties,
of crime substantially related to of laws regulating controlled and functions of a pharmacy
the qualifcations, functions, and substances. technician, i.e., assault with great
duties of a pharmacy technician, bodily injury and sexual battery.
i.e., DUI; dangerous use of Action: The license is revoked.
alcohol. Efective 5/26/2021. Action: The license is revoked.
Efective 4/28/2021.
Action: The license is revoked, Palmer, Jamie L., TCH 23577, AC
the revocation stayed, and the 6928 Pham, Dong N., RPH 47062, AC
license is placed on probation for Thousand Oaks, CA 6478
fve years. Efective 6/9/2021. Cause for discipline: Failing Huntington Beach, CA
to comply with terms and Cause for discipline: Labeling
Matias, Jennifer Cunanan, TCH conditions of probation. compounded product with
73435, AC 7096 beyond-use date past ingredient
Suisun City, CA Action: The license is revoked. expiration date; failing to ensure
Cause for discipline: Conviction Efective 4/28/2021. the security, integrity, authority,
of an ofense substantially and confdentiality of erroneous
related to the qualifcations, Perez, Nichole Alanna, TCH
84811, AC 6448 or uncertain electronic
functions, and duties of a prescriptions; failing to maintain
pharmacy technician, i.e., San Jose, CA
Cause for discipline: Mental current inventory, resulting
embezzlement and grand theft; in drug losses and shortages;
acts involving moral turpitude, illness afecting competency.
failing to report dispensing
dishonesty, fraud, deceit, or Action: The license is revoked. controlled substance to CURES;
corruption, diverting and selling Efective 6/4/2021. failing to retain prescriptions;
large quantities of opioid and failing to maintain proper patient
narcotic pain medications from Petoyan, Suren, EXC 20715, TCH medication profles; failing to
employer; self-administering 43450, AC 5514 maintain compounding log
controlled substance in North Hollywood, CA identifying manufacturer or
dangerous manner. Cause for discipline: Involvement supplier of ingredients; failing
in Medi-Cal billing scheme; to exercise corresponding
Action: The license is revoked. failing to complete application
Efective 6/16/2021. See Disciplinary actions, Page 43

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42 The Script - September 2021
Disciplinary actions the revocation stayed, and the activity; inappropriate exercise
Continued from page 42 license is placed on probation for of education, training, or
two years. Efective 5/12/2021. experience by allowing
responsibility to ensure unlicensed outsourcing activity;
controlled substance prescribed Quinn, Robert Denis, RPH 32154, failing to exercise or implement
for legitimate medical purpose. AC 6922 best professional judgment by
San Luis Obispo, CA allowing unlicensed activity;
Action: The license is publicly Cause for discipline: Failing
reproved. Efective 4/28/2021. to maintain records of the Action: The license is publicly
Phan, Chau Thanh, RPH 62912, manufacture, acquisition, reproved. Efective 5/12/2021.
AC 6905 receipt, sale and disposition of
compounded cannabidiol (CBD) Raleigh, Frederick Ronan, RPH
Hayward, CA 27362, AC 6226
Cause for discipline: products; manufacture and sale
of adulterated and misbranded Templeton, CA
Compounding and selling Cause for discipline: Failing to
diazepam suppositories drugs; unlicensed manufacturing
of drugs; making false or complete compounding self-
containing silica gel; selling assessment; failing to end test
dangerous drugs after misleading statements to Board
inspectors about compounding compounded products for
beyond-use date; failing sterility or potency; allowing
to justify product use after activiteis; attempting to
subvert Board investigation; pharmacists to compound
beyond-use date; failing to without frst demonstrating
document quality reviews of inappropriate exercise of
education, training, or expertise knowledge; failing to annually
compounding products in review compounding policies
the master formula; failing to as a pharmacist in compounding
CBD products. and procedures; failing to
complete compounding log; have procedure for notifying
failing to document quality Action: The license is revoked. compounding staf of
reviews of compounding Efective 5/12/2021. any changes in policies or
products in the compounding procedures; using converted
record or log; failing to include Quitoriano, Allyn Marie K., TCH patient room as compounding
instructions for storage 154206, AC 6940 room; failing to clean
on labels of compounded Whittier, CA compounding room; assigning
preparations; failing to list Cause for discipline: Conviction inappropriate beyond-use dates.
date of compounding on of a crime substantially related to
preparation labels; failing to the qualifcations, functions, or Action: The license is publicly
follow written policies and duties of a licensee, i.e., infiction reproved. Efective 5/26/2021.
procedures; failing to annual of corporal injury on spouse/
review policies and procedures; cohabitant; conduct warranting Rayos, Denise E., TCH 83569, AC
failing to provide documentation denial of a license. 6910
of compounding skills and Bellfower, CA
training; failing to document Action: The license is revoked, Cause for discipline: Failing
demonstration knowledge the revocation stayed, and the to disclose DUI conviction on
before compounding; failing license is placed on probation for license renewal application.
to provide documentation three years. Efective 4/28/2021.
Action: Through a disciplinary
demonstrating quality Rahbaran, Rebecca, RPH 66477, action of the Board, the license is
assurance; inappropriately AC 6758 publicly reproved and subject to
exercising education, training, or Woodland Hills, CA the terms and conditions in the
experience as a pharmacist. Cause for discipline: Aiding and decision.
Action: The license is revoked, abetting unlicensed outsourcing Efective 6/9/2021.
See Disciplinary actions, Page 44

The Script - September 2021 43


Disciplinary actions or not received by the patient; Facility Licenses
Continued from page 43 pharmacy stored compounded
drug products in containers not Allied Health Pharmacy, PHY
Seleh, Moshe, RPH 58075, AC labeled with expiration dates; 52501, AC 6715
6754 allowing pharmacy technician Van Nuys, CA
Los Angeles, CA to be present in pharmacy with Cause for discipline: Failing
Cause for discipline: Dispensing no pharmacist present and in to exercise corresponding
controlled substances possession of pharmacy key; responsibility to ensure
prescriptions on forms missing pharmacy had compounded controlled substances were
required security features; drug products in containers dispensed for a legitimate
excessively furnishing controlled not labeled with expiration medical purpose; dispensing
substances despite multiple cues dates; pharmacy issued false controlled substances despite
of uncertainty and irregularity prescriptions; responsibility as “red fags” and irregularities
and failing to comply with PIC. suggesting they were not for
corresponding responsibility to legitimate medical purpose;
ensure they are dispensed for Action: The license is revoked, dispensing controlled
a legitimate medical purpose; the revocation stayed, and the substance prescriptions issued
holding misbranded drugs. license is placed on probation for on noncompliant forms;
three years. Efective 6/9/2021. dispensing prescriptions with
Action: The license is revoked, incorrect prescriber on label
the revocation stayed, and the Shird, Ashiley Shiann, TCH and in electronic pharmacy
license is placed on probation for 169947, AC 7012 record; unprofessional conduct;
fve years. Efective 5/26/2021. Camarillo, CA violated requirements for
Cause for discipline: Possession completing biennial inventory
Semones, Jacob Alexander, TCH of controlled substances;
172575, AC 7052 of controlled substances;
unlawfully taking hydrocodone/ failing to maintain facilities,
Culver City, CA acetaminophen and vyvanse
Cause for discipline: Gross space, fxtures, and equipment,
pills from pharmacy where resulting in signifcant shortage
negligence in arriving at work employed; committing acts
under infuence of alcohol; of controlled substances;
involving dishonesty, fraud, or failing to maintain complete
acts involving moral turpitude, deceit.
dishonesty, fraud, deceit, or accountability of all dangerous
corruption; dangerous use of Action: The license is revoked. drugs; failing to complete and
alcohol. Efective 4/14/2021. have self-assessment on fle;
failing to compile quarterly
Action: The license is voluntarily Xiong, Chor Neng, EXC 23029, AC inventory reconciliation report
surrendered. Efective 4/28/2021. 7043 for all Schedule II controlled
Sacramento, CA substances; failing to timely
Shemtoub, Rozita, RPH 49785, Cause for discipline: Conviction report drug loss to Board in
AC 6510 of vehicular manslaughter while writing; failing to countersign
Los Angeles, CA intoxicated; dangerous use of reconciliation reports; deviating
Cause for discipline: Issuing key alcohol; conviction of a crime from prescriptions without
allowing pharmacy technician involving alcohol. prescriber consent; failing to
full access to pharmacy and properly identify dispensing
dangerous drugs with no Action: The license is voluntarily pharmacist on prescription
pharmacist present; pharmacy surrendered. Efective 5/26/2021. documents or in electronic
created and processed dispensing data; failing to
prescriptions not prescribed or keep controlled substance
authorized by the prescriber
See Disciplinary actions, Page 45

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44 The Script - September 2021
Disciplinary actions three states without obtaining commercially available products
Continued from page 44 nonresident pharmacy licenses under a proprietary name for
from those states. sale; failing to have of-site
inventory on fle and available storage waiver for records.
for inspection upon request Action: The license is publicly
for three years; failing to reproved. Efective 4/28/2021. Action: The license is voluntarily
report controlled substance surrendered. Efective 4/14/2021.
loss to Board; acts involving Balboa Pharmacy, PHY 51136, AC
moral turpitude, dishonesty, 6514 California Pharmaceuticals LLC,
fraud, deceit, or corruption; Granada Hills, CA WLS 7179, AC 6601
unprofessional conduct. Cause for discipline: Selling Camarillo, CA
dangerous drugs without Cause for discipline: Failing
Action: The license is revoked. prescriptions; transacting to complete self-assessment;
Efective 5/12/2021. dangerous drugs at wholesale failing to secure dangerous
with an entity that is not licensed drugs in lockable area and limit
Alpha Medical Pharmacy II, PHY with the Board as a wholesaler entry to authorized personnel;
54632, AC 6747 or pharmacy; transacting failing to maintain records of
Monterey Park, CA misbranded drugs; holding acquisition of dangerous drugs
Cause for discipline: Allowing misbranded drugs; providing and devices; failing to maintain
unlicensed employees to drug take-back service in records of receiving dangerous
prepackage medications, a task violation of regulations and DEA drugs and devices; submitting
for which a pharmacy technician requirements; failing to exercise false or misleading information
license is required. corresponding responsibility in for wholesaler permit; actions
Action: The license is publicly dispensing excessive controlled related to reformulating
reproved. Efective 4/14/2021. substance prescriptions with commercially available products
irregularities and red fags and under a proprietary name for
Apothecary Options, PHY 45637, not ensure the prescriptions sale; failing to have of-site
AC 6862 were issued for legitimate storage waiver for records.
Chico, CA medical need; unprofessional
Cause for discipline: Incorrectly conduct. Action: The license is voluntarily
dispensing prescription to surrendered. Efective 4/14/2021.
wrong patient; disclosing Action: The license is revoked,
the revocation stayed, and the Complete Pharmacy and Medical
protected health information Solutions LLC, NRP 1371, AC
without authorization; failing license is placed on probation for
fve years. Efective 5/12/2021. 6724
to document quality assurance Miami Lakes, FL
report for medication error; California Pharmaceuticals LLC, Cause for discipline:
maintaining as inventory WLS 7048, AC 6601 Compounding products having
outdated compounding Camarillo, CA potency over time for an
ingredients and compounding Cause for discipline: Failing extended beyond-use date; staf
solutions; continuing to to complete self-assessment; violations of attire requirements
store misbranded drugs after failing to maintain records of for sterile compounding;
advised by Board inspectors disposition of dangerous drugs allowing violations for facility
to dispose of them; failing to and devices; failing to maintain and equipment standards
verify authenticity of controlled records of receiving dangerous for sterile compounding;
substance prescriptions sent drugs and devices; submitting violations of facility and
electronically by facsimile; false or misleading information equipment standards for sterile
dispensing compounded for wholesaler permit; actions compounding; dusty and dirty
medications to residents of related to reformulating
See Disciplinary actions, Page 46

The Script - September 2021 45


Disciplinary actions falsely representing the location procedures; using converted
Continued from page 45 of pharmacy records; subverting patient room as compounding
Board investigation by failing to room; failing to clean
fat surfaces in ISO 8 formulation provide location of records. compounding room; assigning
area; violations in compounding inappropriate beyond-use dates.
area for parenteral solutions; Action: The license is revoked.
violation of sterility testing Efective 4/28/2021. Action: The license is voluntarily
requirements; compounding surrendered. Efective 5/26/2021.
commercially available product George L. Mee Memorial
without a shortage and specifc Hospital, HSP 43395, AC 6226 Guaranteed Returns, OSD 4256,
medical need; missing elements King City, CA AC 6252
from master formulas; labeling Cause for discipline: Failing to Holbrook, NY
compounded products without complete compounding self- Cause for discipline: Conviction
full ingredient names and assessment; failing to end test of crime substantially related
strengths; leaving sterile water compounded products for to practice of pharmacy, i.e.,
for irrigation open with no sterility or potency; allowing multiple counts of fraud,
date of opening or expiration; pharmacists to compound conspiracy, obstruction of
compounding with no potency without frst demonstrating justice, and other counts
testing; staf not washing knowledge; failing to annually related to schemes defrauding
hands during compounding review compounding policies pharmacies of reimbursements
of sterile product; required and procedures; failing to for returned drugs; acts involving
information missing from have procedure for notifying moral turpitude, dishonesty,
sterile compounding labels; compounding staf of fraud, deceit, or corruption.
dispensing controlled substance any changes in policies or
procedures; using converted Action: The license is revoked,
with preprinted, check-box the revocation stayed, and the
prescription forms; failing to patient room as compounding
room; failing to clean license is placed on probation for
submit controlled substance fve years. Efective 5/12/2021.
information to CURES. compounding room; assigning
inappropriate beyond-use dates. GVHC PMQ FS Pharmacy, PHY
Action: The license is publicly 57228, AC 6912
reproved. Efective 6/9/2021 Action: The license is publicly
reproved. Efective 5/26/2021. Modesto, CA
First Choice Pharmacy, PHY Cause for discipline: Failing to
51130, AC 6866 George L. Mee Memorial maintain facilities, space, fxtures,
North Hollywood, CA Hospital, LSC 100083, AC 6226 and equipment such that
Cause for discipline: Allowing King City, CA drugs were safely and properly
pharmacy technician to possess Cause for discipline: Failing to prepared, maintained, secured,
pharmacy key with access to complete compounding self- and distributed, resulting in
controlled substances and assessment; failing to end test tramadol shortage.
dangerous drugs; willful failure compounded products for
sterility or potency; allowing Action: The license is publicly
to keep or permit inspection reproved. Efective 6/16/2021.
of records of prescriptions and pharmacists to compound
other records; making false without frst demonstrating GVHC PMQ West Modesto, PHY
statements on Discontinuance of knowledge; failing to annually 57229, AC 6912
Business application regarding review compounding policies Modesto, CA
prescription inventory and and procedures; failing to Cause for discipline: Failing to
all records of acquisition and have procedure for notifying maintain facilities, space, fxtures,
disposition; signing document compounding staf of and equipment such that
any changes in policies or
See Disciplinary actions, Page 47

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46 The Script - September 2021
Disciplinary actions instructions for storage prescriptions.
Continued from page 46 on labels of compounded
preparations; failing to list date Action: The license is revoked.
drugs were safely and properly of compounding on preparation Efective 5/26/2021.
prepared, maintained, secured, labels; failing to follow written
and distributed, resulting in San Mateo Medical Center
policies and procedures; failing Outpatient, HPE 19576, LSE
shortages of acetaminophen/ to annual review policies and
codeine, lorazepam, and 100358, AC 6756
procedures; failing to provide San Mateo, CA
tramadol. documentation of compounding Cause for discipline: Assigning
Action: The license is publicly skills and training; failing to incorrect beyond-use dates
reproved. Efective 6/16/2021. document demonstration for sterile compounded
knowledge before preparations; failing to keep
Kohana Pharmacy and Center compounding; failing to provide complete compounding
for Regenerative Medicine, PHY documentation demonstrating records; failing to document
50264, AC 6922 quality assurance. annual review of policies and
San Luis Obispo, CA procedures; failing to document
Cause for discipline: Failing Action: The license is revoked,
the revocation stayed, and the staf training related to garbing;
to maintain records of the violating federal regulations
manufacture, acquisition, license is placed on probation for
two years. Efective 5/12/2021. regarding comingling and
receipt, sale and disposition of biennial inventory of controlled
compounded cannabidiol (CBD) Robert Burns Beverly Hills substances; using hard-to-clean
products; manufacture and sale Medical Tower Pharmacy, PHY foor mats in compounding
of adulterated and misbranded 39451, AC 6464 area; failing to follow written
drugs; unlicensed manufacturing Los Angeles, CA policies and procedures
of drugs. Cause for discipline: Failing to in assigning beyond-use
Action: The license is revoked. complete self-assessment; failing dates; failing to maintain
Efective 5/12/2021. to complete compounding self- complete compounding logs;
assessment; failing to maintain compounding hazardous drugs
Pleasant Care Pharmacy, PHY quality assurance policy; failing in an environment failing to
51503, AC 6905 to exercise best professional meet pressure, venting, and air
Hayward, CA judgment; dispensing change requirements.
Cause for discipline: prescriptions without prescriber
Compounding and selling authorization; failing to retain Action: The license is revoked,
diazepam suppositories records of prescriptions and the revocation stayed, and the
containing silica gel; selling patient medication histories; license is placed on probation for
dangerous drugs after failing to report Schedule two years. Efective 6/23/2021.
beyond-use date; failing II-IV controlled substance Specialty Med Services, PHY
to justify product use after prescriptions to CURES and late 51985, AC 7081
beyond-use date; failing to reporting other prescriptions to Inglewood, CA
document quality reviews of CURES; dispensing controlled Cause for discipline: Convictions
compounding products in substance prescriptions lacking of substantially related
the master formula; failing to lot number and watermark; crimes, i.e., conspiracy, fraud
complete compounding log; failing to exercise corresponding conspiracy, and health care
failing to document quality responsibility in dispensing fraud; committing acts of
reviews of compounding prescriptions with signifcant dishonesty, fraud, or deceit to
products in the compounding factors of irregularity; furnishing defraud health care beneft
record or log; failing to include dangerous drugs without
See Disciplinary actions, Page 48

The Script - September 2021 47


Disciplinary actions Superior Pharmacy II, PHY 49215, labeled with expiration dates;
Continued from page 47 AC 5513 issuing false prescriptions.
North Hollywood, CA 
programs in scheme involving Cause for discipline: Allowing Action: The license is voluntarily
misleading advertisements for unlicensed pharmacy staf to surrendered. Efective 6/9/2021.
nutritional shakes for bariatric receive and sign for delivery
surgical patients; making and Tropicana Drugs, PHY 17122, AC
of dangerous drugs; failing to 6469
signing documents with false comply with compounding
statements. San Jose, CA
quality assurance by allowing Cause for discipline: Failing
Action: The license is revoked. unlicensed staf receive and to maintain pharmacy, i.e.,
Efective 6/23/2021. sign for controlled substance unsecured will-call area,
deliveries; failing to maintain signifcant dust on pharmacy
Superior Pharmacy, PHY 48287, records of acquisition and fxtures, disorderly conditions;
AC 5513 disposition for Abilify and failing to maintain pharmacy in
North Hollywood, CA  Seroquel products; holding in clean and orderly conditions;
Cause for discipline: Failing to active stock prescription drugs failing to have policy and
have a pharmacist on duty in dispensed by another pharmacy; procedure for repacking
the pharmacy for more than 30 having medications with patient of drugs; failing to keep
minutes; allowing unlicensed labels dispensed by another records regarding acquisition
pharmacy staf to receive and facility on the active stock and disposition of patient
sign for delivery of dangerous shelves. medications to be repackaged;
drugs; failing to comply with misbranding drugs by labeling
compounding quality assurance Action: The license is voluntarily
surrendered. The efective date in a false or misleading manner;
by allowing unlicensed staf stocking unadulterated drugs;
receive and sign for controlled shall be stayed 180 days from
date settlement signed, at which submitting documents with
substance deliveries; allowing inconsistent and contradictory
unlicensed individual to act time the pharmacy shall be sold
or closed. Efective 4/28/2021. statements of ownership; billing
as pharmacist in transferring Medi-Cal for purchases not
prescriptions over the phone Tenth Street Medical Pharmacy, supported by invoices.
for patient; failing to maintain PHY 48956, AC 6510
records of acquisition and Santa Monica, CA Action: The license is voluntarily
disposition for Abilify and Cause for discipline: Issuing key surrendered. Efective 5/26/2021.
Seroquel products; allowing to pharmacy technician allowing
unlicensed individual to order 18 University Care Pharmacy, PHY
full access to the pharmacy 51603, AC 6840
Schedule II controlled substances and dangerous drugs with no
on behalf of pharmacy without Los Angeles, CA
pharmacist present; creating Cause for discipline: Operating
power of attorney; acting as and processing prescriptions not
reverse distributor without pharmacy without a valid permit;
prescribed or authorized by the failing to notify Board and follow
wholesaler license. prescriber or not received by the instructions for discontinuance
Action: The license is voluntarily patient; storing compounded of business; forging signatures.
surrendered. The efective date drug products in containers
shall be stayed 180 days from labeled with no expiration dates; Action: The license is revoked.
date settlement signed, at which pharmacy technician in the Efective 4/14/2021.
time the pharmacy shall be sold pharmacy with no pharmacist
or closed. Efective 4/28/2021. present and in possession of a
pharmacy key; compounded
drug products in containers not See Disciplinary actions, Page 49

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48 The Script - September 2021
Disciplinary actions Village Road Pharmacy, PHY
Continued from page 48 36027, AC 6697
Long Beach, CA
Van Nuys Pharmacy, PHY 52545, Cause for discipline: Failing
AC 6709 to exercise corresponding
Van Nuys, CACause for discipline: responsibility in flling
Failing to maintain and produce prescriptions despite factors
pharmacy records for Board suggesting they were not
audits; failing to provide written for legitimate purposes;
requested records to Board; flling controlled substance
engaging in conduct subverting prescriptions on noncompliant
a Board investigation. forms; failing to report controlled
Action: The license is revoked. substance prescriptions
Efective 4/28/2021. to CURES; deviating from
prescriptions by dispensing
Verdugo Care Pharmacy, PHY multiple prescriptions under the
54451, AC 6964 incorrect prescriber.
Sun Valley, CA
Cause for discipline: Failing to Action: The license is publicly
maintain acquisition records reproved. Efective 6/9/2021.
related to dozens of syringe
kits and thousands of Abilify
tablets; selling or transferring
drug inventory to another
pharmacy upon discontinuance
of business before notifying
the Board; signing documents
with false representations
regarding transfer of drug
inventory and the maintenance
of acquisition and disposition
records upon discontinuation
of business; failing to comply
with multiple Board requests for
drug acquisition and disposition
Contact
records; subverting a Board
investigation; subverting PIC’s
The Script
eforts to comply with pharmacy
laws; allowing non-pharmacist Do you have any questions
to act as pharmacy supervisor or comments about The
or manager; unprofessional Script? Are there topics
conduct. you would like to see in the
newsletter?
Action: The license is voluntarily
surrendered. Efective 5/12/2021. Let us know! Send a note to
editor Bob Dávila at
Bob.Davila@dca.ca.gov.

The Script - September 2021 49


This newsletter is published by the

California State Board of Pharmacy


Department of Consumer Afairs
2720 Gateway Oaks Drive, Suite 100
Make plans to attend 2021/22
Sacramento, CA 95833
(916) 518-3100
Board, committee meetings
Fax: (916) 574-8618 Get involved with the 2021
www.pharmacy.ca.gov California State Board of
Pharmacy! Consumers, • October 20: Licensing,
licensees, stakeholders, and Enforcement/
BOARD MEMBERS Compounding.
other members of the public
are encouraged to attend • October 27:
Seung Oh, Pharm.D. and participate at Board and Communication/Public
President committee meetings. Education.
Maria D. Serpa, Pharm.D. Visit Board and Committee • October 27-28: Board of
Vice President Meetings on the Board’s website Pharmacy.
for comprehensive information,
Jignesh Patel, R.Ph. including dates, agendas and • December 2: Board of
Treasurer materials, live and recorded Pharmacy.
webcasts, and minutes. Notices 2022
Lavanza Butler, Pharm.D. are emailed when agendas and
Jose De La Paz, Public Member materials for posted online; to • January 18:
Shirley B. Kim, Public Member receive notices, visit the email Enforcement/
Ricardo Sanchez, Public Member registration page and follow Compounding,
Nicole Thibeau, Pharm.D. the instructions to subscribe to Legislation/Regulation.
Deborah Veale, R.Ph. “News and Information” alerts.
• January 19: Licensing,
Jason Weisz, Public Member
Pursuant to Executive Order Communication/Public
N-08-21, signed June 11, 2021, Education.
STAFF by Governor Gavin Newsom, • February 1-2: Board of
meetings are expected to return Pharmacy.
Anne Sodergren from teleconference to in-
Executive Ofcer person events October 1, 2021, • March 16: Board of
unless Executive Order N-08-21 Pharmacy.
Bob Dávila is extended before October 1,
Editor 2021. However, conditions and • April 19: Licensing.
meeting dates are subject to • April 20: Enforcement/
Victor Perez
change during the COVID-19 Compounding
Layout/Design
pandemic. Check the meetings
page on the Board’s website for • April 26:
current information. Communication/Public
Education, Legislation/
Mark your calendar for Board and Regulation.
committee meetings scheduled
for 2021 and early 2022. • April 26-27: Board of
Pharmacy.
California State
Board of Pharmacy

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