9/2/2020

The Practice of Pharmacy in Florida

Laws & Rules

GO AR ALVAR E Z, P H AR M .D.,C .P H .,FAS C P

AS S IS TAN T D E AN
N S U C O L L E GE O F P H AR M AC Y
F M R P R E S ID E N T – F LO R IDA P H AR M AC Y AS S O C .
F M R M E M B E R – F LO R IDA B O AR D O F P H AR M AC Y

Objectives (parts 1&2)

1. Discuss the drug distribution process
2. List required elements on a prescription drug order
3. Describe the process for drug transfers
4. State information required on prescriptions and IV labels
5. Assess a prescription for generic drug substitution and biosimilar replacement
6. Survey a prescription for eligible drug refills and compliance with regulations
7. Review recordkeeping requirements in pharmacy practice
8. Justify the role of compounded prescriptions in patient and professional realms
9. State the composition and function of the Board of Pharmacy

Objectives (parts 1&2)

9. Discuss the opening and closing requirements and procedures of a pharmacy
10. Analyze the operational requirements for a pharmacy
11. Resolve a disciplinary case involving pharmacies and pharmacists
12. Develop and evaluate a pharmacy CQI program
13. Evaluate the role of a pharmacy inspection
14. Categorize the types of pharmacy systems within a permit type (e.g. Central Fill, Common
Database, Clinic, Home Therapy, etc.)
15. List elements of advanced practice agreements in Florida such as collaborative practice
agreements, test and treat of minor ailments, and administration of long acting
antipsychotics and dispensing of naloxone
16. Identify immunization types and requirements administered by pharmacists and
technicians

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JOHN SMITH, M.D

INTERNAL MEDICINE
19999 UNIVERSITY DR, SUIT 100
FORT LAUDERDALE, FL 33317
(954) 123 -4561 TEL DEA# AS1234563

NPI# ME29634561

DATE: 08/08/2020

N A M E : JA N E D O E DOB 8/06/1952
A D D R E S S : 1 0 0 0 H A P P Y D R , D AV I E , F L 3 2 5 1 4

RX
AMBI E N 10MG # 90 ( NI NE TY)
SI G : TAKE 1 TABL E T P O TI D

REFILL: 2

JOHN SMITH_________________________________________
SIGNATURE

“…………the practice of pharmacy is a

learned profession……….”
465.002 Legislative findings; intent

Board of Pharmacy Makeup

9 members appointed by the Governor and confirmed by the Senate
• 7 pharmacists (at least 2 community, 2 institutional)
• 2 consumers
• 1 member at least 60 years of age

Despite expiration of their term, board members may continue to serve at “the
pleasure of the Governor” until they are replaced.

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Licensing
• You need a license to practice pharmacy
◦ The type of license depends on what you are going to do

• You need to maintain competency

◦ CPE requirements

• You need (added) special training / certification to do certain things (ex: immunize)

License Types – Pharmacy Profession

• Pharmacist
• Consultant Pharmacist
• Nuclear Pharmacist
• Pharmacy Intern
• Pharmacy Technician

465.007-465.014

Pharmacy Intern Licensure Requirements

• Be enrolled in an accredited school of pharmacy intern program or a graduate but not
yet licensed

• Must register with the BOP

• There are no CPE requirements for Interns

• Intern fee is waived

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Pharmacy Intern scope of practice

• May do anything* a pharmacist does under direct and immediate supervision
◦ Dispense, compound, counsel patients, copies and transfers of Rxs, may vaccinate (1:1 ratio
supervised by immunizing pharmacist – intern must take 20 hr initial immunization course &
CPR).

• There is NO pharmacist to intern ratio (except for immunizing) (1:1)

• Interns MAY NOT prescribe*

Pharmacy Technician Scope of Practice

• Non-Delegable Tasks
◦ New Verbal Orders or Changes
◦ Assess Prescriptions for Therapeutic Appropriateness
◦ Final Verification
◦ Prospective Drug Review
◦ Override Clinical Alerts
◦ Transfer Prescriptions
◦ Prepare Copy of Prescriptions
◦ Patient Counseling
◦ Exercise Pharmacist Professional Judgment

Pharmacy Technician Scope of Practice

• Tasks performed pursuant to a pharmacist’s direct and immediate supervision
• Without the exercise of the pharmacy technician’s own judgment and
discretion
◦ Data entry, labeling, counting, weighing, measuring, pouring, initiating communication for and
accepting refill authorizations

64B16-27.420 Technicians: Non-Delegable Tasks

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Discussion of
Community Pharmacy Practice
Scenarios
(prescription transfers)

Discussion

Discussion

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Transferring prescriptions
• Legend drugs
• Controlled substances:
• C2
• C3 – C5
• Other jurisdiction
• Common database

Pharmacy Technician Ratios

• Tech ratios (5/8/18)
◦ 1:1 default
◦ 1:3 sterile compounding
◦ 1:6 pharmacy (community or institutional)
◦ 1:8
◦ Location where drugs are not stored / dispensed (i.e. fulfillment center – claims adj., refills processing, call
center)
◦ Dispensing pharmacy with a “physically separate area” separated by a permanent wall

• Must sign written job description / policies & procedures within 90 days of hire
enumerating non-delegable tasks

Tech Supervision
https://www.youtube.com/watch?v=IGQmdoK_ZfY

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Responsibility
• Tech: 0% (?)
• Pharmacist: 100%

Standards of Practice
(pharmacist Scope of practice)
• 465.0155 – Standards of Practice
◦ The Board shall adopt rules relating to the practice of pharmacy

• 64B16-27.1001
◦ Practice of Pharmacy reserved to pharmacist or intern under direct and immediate supervision of
a licensed pharmacist

Standards of Practice
(pharmacist Scope of practice)
Pharmacist Must:
• Supervise & be responsible for controlled substances inventory

• Receive verbal Rxs & transfer Rxs

• Interpret & identify Rx contents

• Consult with prescriber regarding interpretation of Rx

• Engage in professional communication with health professionals

• Advise and consult patient

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Standards of Practice
(pharmacist Scope of practice)
• Pharmacist Must:
◦ For compounding: interpret & identify all orders, mix or be physically present, physically
examine & certify the finished product (assuming full responsibility), create records in a
manner that pharmacist responsibility can be easily traced

◦ Make final check for accuracy

◦ Be available to the patient for consultation

◦ Shall be actively licensed as a pharmacist

◦ May take 30 minute meal break

◦ Sign displayed, pharmacist on the premises, pharmacy considered “open”, tech considered
under direct and immediate supervision of pharmacist (responsibility rests with pharmacist),
pharmacist retains personal & professional responsibility of acts performed by interns and
technicians

Standards of Practice
(pharmacist Scope of practice)
• Order labs by Pharm.D. or Consultant pharmacist in nursing home or home health agency (64B16-
27.120)
◦ Authorized by medical director (nursing home) or practitioner in home health
◦ May order (prescribe) and dispense medications (64B16-27.210)
◦ No injectables
◦ Not to pregnant / nursing patients
◦ Not to exceed 34 day supply
◦ Pursuant to Rule 64B16-27.220 – Medicinal Drugs Which may be Ordered by Pharmacists
• May enter in Collaborative Practice Agreements (64B16-27.830)
◦ A) Order and interpret labs, B) execute drug therapy
• May enter in Collaborative Practice Agreements (465.1865) effective 7/2020
• Initiate, modify and d/c drug therapy for chronic health conditions
◦ Order and interpret clinical labs and / or perform CLIA waived tests
◦ Must report certain conditions of public health concern to DOH
• Test and treat minor health conditions as defined in 465.1865 or by Board rule (effective 7/2020)

CQI
Continuous Quality Improvement (CQI)
• Identification & evaluation of quality related events (QREs) & improve patient care
• QRE means
◦ Inappropriate dispensing, compounding or administration
◦ Variation from prescribers’ order (ex: wrong drug, wrong patient, wrong strength,
etc.)
◦ Failure to identify and manage pharmacotherapy (ex: interactions, contraindications,
over/under utilization, clinical abuse/misuse, therapeutic duplications, etc.)

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CQI – Pharmacy Shall

• Form CQI committee (chaired by PDM or CPh of record) – attended by members of pharmacy staff

• Policies and procedures describing functions of committee

• Must meet at least quarterly

• Assess and improve quality – QRE identification & resolution via “root-cause analysis”

• Records of minutes (summarizations) maintained 4 years

◦ No names
◦ Protected under FS 766.101

Case
https://www.youtube.com/watch?v=_V_vAxoI6U8

What are your thoughts on this?

Pharmacist Med Error Case

Admin Complaint
Respondent – a pharmacist, dispensed Levothyroxine 50mcg – Rx for Levocetirizine 5mg
Respondent verified Rx
Background:
Rx was dispensed on “06/12/2015” and re-dispensed the next day due to insurance issue
Respondent was pharmacist on duty when Rx was picked up
Rx was originally dispensed by another pharmacist (not respondent) and re-labeled by
respondent due to insurance issues – pt stated he would pay cash as he was getting frustrated
Patient states picked up Rx at drive through and tech did not ask if he had any questions
STOP

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Pharmacist Responsibilities
• Must be licensed to practice (see licensing criteria)

• Must maintain professional competence (CE requirements)

• Must practice with “reasonable skill and safety”

◦ Mental impairment, under the influence, poor judgement, poor clinical skills

• Dispense, compound, and administer vaccinations and other medications authorized by law or
rule: (465.003(6)) – interpret and assess Rx for medication related problems & using professional
judgement shall certify and counsel as appropriate

Pharmacist Responsibilities
• Patient Safety: Check each patient’s medication record every time he or she gets a new or refill a
prescription to prevent potential medication related problems

• Patient Consultation: share advice on the use of prescription, non-prescription medications,

supplements, herbals, lifestyle (exercising and maintain healthy diet) and wellness

• Prescriber Consultation: confirm dosage, formulation, brand/generic specification any time a

prescription order is unclear or potentially harmful for patients (therapeutic appropriateness)

• Certify that Rx is ready to deliver to patient (final check)

Pharmacist Responsibilities
• Documentation: Document care, interventions, prescriber consultations, patient consultations, etc.
• Perform Administrative Tasks: keep patient files up to date, conduct inventory management, make sure
needed products are stocked
• Staff Management: oversee the work of pharmacy technicians, student interns, and residents; enforce
workplace policies.
◦ Ratios and identification of staff
◦ Supervision (direct = on premises) and not more than YOU can personally supervise
◦ Non-delegable tasks

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Patient Counseling

Omnibus Budget Reconciliation Act of

1990 (OBRA ‘90)
• Enacted on November 5,1990
◦ Pharmacists responsible for the following:
◦ Prospective Drug Use Review (ProDUR)
◦ Patient Counseling (and / or “offer to counsel”)
◦ Maintaining Proper Patient Records

• Requires pharmacists to review patient’s entire drug profile before filling

prescription(s)

Elements of Patient Counseling

Using professional judgement
◦ (a) The name and description of the drug
◦ (b) The dosage form, dose, route of administration, and duration of drug therapy
◦ (c) Intended use of the drug and expected action (if indicated by the prescribing health care practitioner)
◦ (d) Special directions and precautions
◦ (e) Common severe side effects or interactions and therapeutic contraindications that may be encountered,
including their avoidance, and the action required if they occur
◦ (f) Techniques for self-monitoring drug therapy
◦ (g) Proper storage
◦ (h) Refill information
◦ (i) Action to be taken in the event of a missed dose
◦ (j) Pharmacist comments relevant to the individual’s drug therapy

Not required if patient refuses such consultation

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Pharmacist Responsibilities
OBRA 90: Including prospective drug utilization (pro-DUR), offer to counsel
◦ Perform Pro-DUR (check patient profile) for therapeutic appropriateness
◦ (a) Over-utilization or under-utilization
◦ (b) Therapeutic duplication
◦ (c) Drug-disease contraindications
◦ (d) Drug-drug interactions
◦ (e) Incorrect drug dosage or duration of drug treatment
◦ (f) Drug-allergy interactions
◦ (g) Clinical abuse/misuse

Discussion

Discussion

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Discussion

Discussion

Display of Licensure
People need to know that you are licensed
◦ Posting of licenses or immediately available
◦ Identification of personnel (badge/monogram)
◦ Tech – identify self (verbally in person, phone and correspondence)

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Prescription Department Manager (PDM)

• Responsible to pharmacy’s compliance with statutes and rules governing community
(out-patient) pharmacy practice
◦ Maintenance of drug records
◦ Establishing drug handling procedures for the safe handling and storage of medications
◦ Security of medications
◦ File required reports and notices to the Board
• ALL Community Pharmacy permits MUST designate a PDM
• A change in PDM requires notification to the BOP within 10 days
• Fingerprint submission
• Limit 1 community pharmacy unless approved by BOP

Pharmacy Inspection Requirements

Community Pharmacy
• http://www.floridahealth.gov/licensing-and-regulation/enforcement/inspection-
program/_documents/community-requirements.pdf

Institutional Pharmacy
• http://www.floridahealth.gov/licensing-and-regulation/enforcement/inspection-
program/_documents/classii-institutional-rx.pdf

Pharmacy requirements
(64B16-27, 28 and sections of FS465)
• Rx dept is clean and safe, sink with running water, refrigerator, temp logs (if vaccines)
• Expired meds removed
• Certified (signed) daily Rx log
• Maintain copy of current laws/rules, other references
• Techs and interns properly identified and supervised (ID and ratios)
• Tech Policy (non-delegable and # of positions – 90 days of hire)
• Tech training documentation on duties enumerated in JD
• Pharmacist on duty at all times that pharmacy is OPEN
◦ Padlock if pharmacist is not present
• Policy of preventing dispensing of fraudulent Rxs
◦ Reporting to law enforcement within 24 hrs
• CQI policy and meeting summarizations (min qtrly)

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New pharmacist practitioner case PDM

Admin Complaint
• On routine inspection BUD dates w/o sterility testing
• No ante room
• Compounding log not appropriately maintained
• Failure to have persons compounding high risk sterile
compounds demonstrate competency
• No P&P
• Background STOP
• Respondent upon completion of rotation at a pharmacy was offered position as PDM
• Pharmacy is a sterile compounding pharmacy

Controlled Substances Requirements

(FS893)
• Controlled substances Rx contain required info
◦ Prescriber name, address, signature, DEA # and date prescribed
◦ Patient name and address
◦ If an animal – species
◦ Drug name, strength, qty (alpha & numeric), sig
◦ Rx #
◦ Pharmacist initials and date dispensed
• Written Rxs for controlled substances on counterfeit-proof pad approved by DOH
• Inventory biennially (C2 separate from C3-5)
• DEA 222 forms properly completed
• Record of theft / significant loss reported to DEA and law enforcement within 24 hrs of
discovery
• Dispensing reported to PDMP daily

Misc. Requirements
• Offer to counsel
• Duty to warn
• Pedigree
• Central Fill
◦ Contract with Central Fill Pharmacy (if not under common ownership)
◦ Originating and central fill pharmacies identified on label
◦ If controlled substance “central fill” to appear on face of original Rx
◦ Originating pharmacy maintains record of date of receipt and date of delivery
◦ Toll free number provided to patient for consultation purposes

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Prescribing Authority
• Medical/Osteopathic physicians
• Optometrists
◦ Topical eye medications – FL (NOW expanded)
• Podiatrists
• Veterinarians
• Dentists

*Scope of practice

Prescribing Authority
Florida HB 423 – ARNP/PA Controlled Substance Prescribing

• Prescriptions for Schedule II controlled substances are limited to a 7-day supply, except for
psychiatric medications prescribed by a psychiatric nurse.
◦ Up to 30 days

• Psychiatric medications for patients younger than 18 years old may only be prescribed by a
psychiatric nurse.

• An ARNP must have a master’s degree or doctorate to prescribe controlled substances.

Prescribing Authority
• Nurse practitioners and physician assistants
◦ Dependent
• Chiropractors
◦ NO PRESCRIBING RIGHTS
• Pharmacists
◦ Independent
◦ Limited formulary in state of Florida
◦ Under CPA
◦ Under Test and Treat protocol (effective 7/2020)

64B16-27.220

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JOHN SMITH, DPM

19999 UNIVERSITY DR, SUIT 100
F T. L A U D E R D A L E , F L 3 3 3 2 8
(954) 123-4561 TEL DEA# AS1234563
NPI# ME29634561
DATE: 08/08/2020
N A M E : L I L LY TO B I A S DOB 8/06/1972
A D D R E S S : 1 2 3 4 O A K D R I V E , D AV I E , F L 3 3 3 2 5

RX
PHENTERMINE 30MG #30 (THIRTY)
SIG: TAKE 1 CAPSULE PO QD

REFILL: 3

JOHN SMITH________________________________________________
S I G N AT U R E

JOHN SMITH, DDS

19999 UNIVERSITY DR, SUIT 100
F T. L AU D E R D A L E , F L 3 3 3 2 8
(954) 123-4561 TEL
NPI# ME29634561
DATE: 08/08/2020
NAME: JOHN SMITH DOB 8/06/1972
A D D R E S S : 1 2 3 4 O A K D R I V E , D AV I E , F L 3 3 3 2 5

RX
ALBUTEROL INHALER
SIG: ONE INHALATION EVERY 6 HOURS IF NEEDED FOR SOB

REFILL: PRN

JOHN SMITH DDS________________________________________________

S I G N AT U R E

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Methods of communicating Rx
information
• From prescriber to dispenser by any means of communication
• Written Rxs
◦ Written by prescriber or agent of prescriber and must bear all requirements of valid Rx (ex: prescriber name,
address, patient name, drug name, etc.)
◦ Must be dated and signed by prescriber
◦ If CS (tamper proof Rx pad)
• Verbal / Oral Rxs
◦ From prescriber or agent of prescriber to pharmacist or intern (under supervision of pharmacist)
◦ Promptly reduced to writing by pharmacist/intern
◦ No CII
◦ Except in emergency (as defined in regs) – max. 72 hr supply
◦ Pharmacist must receive original Rx within 7 days or report to DEA (attach emergency oral Rx to
original Rx)
• No initial weight control Rx

Methods of communicating Rx
information
Faxed Rxs
• From individual (patient) to pharmacist
◦ Pharmacist must possess original Rx prior to dispensing
• From prescribers’ office to pharmacy
◦ Legend and CIII-CV
◦ CII only in following cases:
◦ In emergency – (max 72 hr supply) Pharmacist must notify DEA if does not receive original Rx from prescriber within 7 days
◦ Home infusion / IV pain therapy
◦ Patients in LTC
◦ Hospice

E-Prescriptions
• All medications including CS (CII-CV)
◦ Now required unless practitioner has a waiver from DOH - 2021

Rx Requirements
• Patient name • Directions (SIG)
• Date Rx issued • Amount
• Route
• Prescriber name and address
• Frequency
• Medication prescribed • Route of administration
◦ Name • Clear and concise
◦ Strength
◦ Dosage form • Prescriber signature
◦ Quantity • Stamped signature
• Written signature
• Refills • Electronic signature (e-scripts)
• Non-controlled Rx • (Hard-copy of e-script must be
• C II: not allowed signed)
• C III-V: maximum of 5 refills within 6 months from
date of issue

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Rx Requirements
• Controlled Substance
◦ Patient’s address
◦ Date prescribed (alpha)
◦ Qty (alpha and numeric)
◦ Prescriber’s DEA #
◦ Pharmacist initials
◦ Date dispensed
◦ ALL OF THE ABOVE ON THE “FACE OF THE RX”
◦ If C II – written Rx with some exceptions

Prescription Label (Outpatient)

• Name and address of pharmacy • Discard after expiration date
• Pt’s name • Quantity
• Prescriber’s name • Refills
• Directions for use
• Date dispensed
• Rx ID number
• Name/Strength of drug
• Manufacturer name (if generic)

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64B16-28.118 Unit Dose and Customized Patient Medication

Package Returns by In-patients

Auxiliary Labels

Prescription Refills
• No refills in excess of 1 year from date Rx written (legend Rx)

• No refills on CII

• CIII-CV – no more than 5 times within 6 months of Rx written

64B16-27.211

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Emergency Prescription Refills

• One time emergency 72 hour supply
• One time emergency refill of vial of insulin, 1 box of insulin pens
• Governor’s emergency order

◦ 30 day supply in areas affected by emergency order

◦ Meds for chronic conditions & those pharmacist deems necessary (professional
judgement)

◦ Pharmacist creates written order (with elements required in FS499 & FS893) &
signs order
◦ Advises physician of emergency dispensing within reasonable time

◦ Not for CII

465.0275

64B16-27.831 Standards of Practice for the Filling of Controlled Substance

Prescriptions
• Sound professional judgement
• No one may interfere with that professional judgment
• Corresponding responsibility
• Validating a controlled substance Rx
• Valid practitioner-patient relationship for a legitimate medical purpose
• 1) Patient consultation/communication 2) Prescriber consultation communication 3) Review of PDMP
• Duty to report – if pharmacist believes the prescriber is involved in diversion
• CII-CV may be electronically prescribed
• Must query PDMP (effective 7/18)
• Mandatory 2 hr CE

JOHN SMITH, M.D

INTERNAL MEDICINE
19999 UNIVERSITY DR, SUIT 100
AUSTIN, TX 33317
(354) 123 -4561 TEL DEA# AS1234563

NPI# ME29634561
DATE: 08/08/2020

NAME: JOHN Q. RICHARDS DOB 8/06/1962

A D D R E S S : 1 2 3 4 O A K D R I V E , B O S TO N , M A 3 2 5 1 4

RX
PE RCOCE T 5/325MG #60 ( SIXTY )
SIG: TA KE 1 TA BL E T PO Q 6 HOU RS PRN PA IN

REFILL: 0 CHRONIC PAIN EXCEPTION

JOHN SMITH________________________________________________
SIGNATURE

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Substitution of Drugs
• Pharmacist shall substitute for less expensive generic drug
◦ Unless “medically necessary” indicated on face of Rx or verbally to pharmacist
◦ Biosimilars considered in same manner as “brand-generic”
◦ Shall notify patient of substitution
◦ Patient may request brand
• Sign posted:
◦ “consult your pharmacist concerning the availability of a less expensive generically equivalent
drug and the requirements of Florida law”

465.025

Negative Drug Formulary

• Demonstrate clinically significant biological or therapeutic inequivalence
• Shall not be substituted
◦ (1) Digitoxin
◦ (2) Conjugated Estrogen
◦ (3) Dicumarol
◦ (4) Chlorpromazine (Solid Oral Dosage Forms)
◦ (5) Theophylline (Controlled Release)
◦ (6) Pancrelipase (Oral Dosage Forms)

DAW 7

Sample Medicinal Drugs

• Pharmacies may not possess sample drugs EXCEPT:
◦ For meds that can be ordered by pharmacist (64B16-27.220)
◦ Institutional pharmacies upon written request of prescriber
◦ For meds that can be ordered by pharmacist pursuant to 465.1865 - TBD

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Pharmacy Records
1. Vendor invoices 9. Prescriptions
2. Pedigree 10. Policies and Procedures
3. MSDS 11. Compounding records
4. Pharmacy permits 12. Control substance inventory (biennial)
5. CQI summarization records 13. Immunizations
6. Patient profiles 14. HIPAA
7. Patient charts 15. Others depending on license type (i.e.
wholesaler, institutional pharmacies, etc.)
8. Agreements (third party, collaborative
practice, protocols, standing orders)

Recordkeeping

Dispensing Record
• Prescription #

• Date dispensed

• Name and strength of drug

• Quantity dispensed

• ID of dispensing pharmacist
◦ If controlled substance (pharmacist initials and date dispensed on face of Rx)

• Dispensing and Compounding Records must be maintained for a minimum of 4 years

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Compounding
Log Elements

Compounding Record
• Name and quantity of all ingredients • Calculations/quantities of ingredients made
at all steps
• Source of all ingredients
• Total amount made
◦ Manufacturer
• Specific procedure description (formula)
◦ Lot # • Beyond use date
◦ Expiration date ◦ Literature or formulated product data

• Strengths/concentrations • Name of preparer and verifier

• Capsule size and color • Compounding records must be maintained a
minimum of 4 years

Patient Records (profiles)

• Maintained minimum of 4 yrs
◦ Demographic info (name, address, phone, age, gender, etc.)
◦ List of prescriptions dispensed (with drug name, date dispensed, prescriber, etc)
◦ Pharmacist comments relevant to the individual’s drug therapy
◦ allergies, drug reactions, chronic conditions, over-the-counter drugs, herbs and supplements,
devices being used

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HB 389- Practice of Pharmacy

• Creates collaborative pharmacy practice agreement between pharmacist & physician

• Requires agreements to be appropriate to training & scope of practice of pharmacist & physician
• Requires maintenance of records & specified pharmacists to report certain diseases of public health
significance to DOH
• Authorizes pharmacists to test for & treat influenza & streptococcus
• Provides requirements for written protocol between pharmacist & supervising physician

HB-599 – Consultant Pharmacists

• Requires pharmacist to complete additional training for consultant pharmacist licensure

• Authorizes consultant pharmacist to perform specified services

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