CLEARINGHOUSE DATA SHARING - OFFERS NUMEROUS BENEFITS, PROTECTS PUBLIC HEALTH - NABP
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August 2021 | Volume 50 | Number 7
CLEARINGHOUSE
OFFERS NUMEROUS
DATA SHARING BENEFITS, PROTECTS
PUBLIC HEALTH
CONTENTS
06 09 01 Letter From the Chairperson
02 Policy Perspectives
The Future of Telehealth and the
Ryan Haight Act Post-Pandemic
04 I nterview With a Board Inspector
Krystal Brashears Stefanyk, CISCI
05 Association News
05 NABP Educates Consumers
on Dangers of Rogue
Online Pharmacies
08 Association Seeks Item Writers
for NABP Examinations
15 Interview With a Board Member
Julie Lanza, CPhT, CSPT
16 State Board News
alifornia Board Develops Sample
C
Collaborative Practice Agreement
for Providing MAT
17 Professional Affairs Update
FDA Warns of Biological Products
Being Offered to Patients Outside
the Scope of an Approved BLA
Feature News Association News
Disciplinary Data Sharing Through NABP Inspectors Identify
NABP Clearinghouse Offers Dangerous Scheme Involving
Numerous Board Benefits, Over-the-Counter Insulin Products
Protects Public Health
NABP Executive Committee
(ISSN 2472-6850 — print; ISSN 2472-6958 — Amy Sanchez Timothy D. Fensky Fred M. Weaver
online) is published 10 times a year by the National Publications and Editorial Manager Chairperson Member, District 4
Association of Boards of Pharmacy® (NABP®)
©2021 National Association of Boards of Pharmacy. Caroline D. Juran Shane R. Wendel
to educate, to inform, and to communicate the
All rights reserved. No part of this publication may President Member, District 5
objectives and programs of the Association and its
be reproduced in any manner without the written
65 member boards of pharmacy. Reginald B. “Reggie” Deborah C. Mack
permission of the executive director/secretary of the
Dilliard Member, District 6
The opinions and views expressed in this National Association of Boards of Pharmacy.
President-elect
publication do not necessarily reflect the official Nicole L. Chopski
NABP Mission Statement
views, opinions, or policies of NABP or any board Lenora S. Newsome Member, District 7
NABP is the independent, international, and
unless expressly so stated. The subscription rate is Treasurer
impartial association that assists its member boards Kamlesh “Kam”
$70 per year. Bradley S. Hamilton Gandhi
and jurisdictions for the purpose of protecting the
National Association of Boards of Pharmacy public health. Member, District 1 Member, District 8
1600 Feehanville Drive, Mount Prospect, IL 60056 Tejal J. Patel
847/391-4406 | www.nabp.pharmacy Member, District 2 NABP Executive
help@nabp.pharmacy Committee elections
Jeffrey J. Mesaros are held each year
Lemrey “Al” Carter Member, District 3 at the Association’s
Executive Director/Secretary Annual Meeting.
2 | APRIL 2020
LETTER FROM THE CHAIRPERSON
Fellow Members,
We pharmacy regulators know all too well safety at risk. We strongly encourage boards to
that if there’s a will, criminals can find a way. keep up with timely reporting of disciplinary
Rapid advances in technology, social media actions to the NABP Clearinghouse as a
sites, and the long-standing effects of the means to further combat these risks. With
COVID-19 pandemic have made it easier many licensees holding licenses in multiple
for bad actors to take advantage of vulnerable states, keeping the Clearinghouse updated in a
consumers and threaten public health. In this timely manner is vital to determining whether
issue, we delve into some of these continued a current or prospective licensee is eligible to
threats, including a recent scheme involving safely practice pharmacy or operate a licensed
diverted nonprescription insulin products that facility. I wish to personally thank those board
was encountered by NABP surveyors during a of pharmacy staff members who dedicated
routine visit to a pharmacy. their time to sharing their experiences using
The online pharmacy landscape also the Clearinghouse and the benefits it has
continues to threaten patient safety, with rogue offered them. For more information on their
websites and social media accounts marketing experiences, see page 6.
Timothy D. Fensky, fake, substandard, and counterfeit prescription Please know that NABP is aware of the
RPh, DPh, FACA medications. As such, NABP educates patients many resource challenges our member
NABP Chairperson about the risks of buying medication online boards face in their day-to-day business. Feel
and, through its accreditation and verification free to reach out to NABP staff with any
programs, provides patients with tools to help challenges you may be facing in reporting to
them easily identify safe online pharmacies and the Clearinghouse as we likely have solutions
pharmacy-related businesses. that can help.
As part of this initiative, we are pleased to The NABP Interactive Forums are another
announce the launch of the newest consumer great resource for connecting with fellow
campaign, which focuses on the dangers of members and NABP staff about challenges
buying medication from unlicensed internet you may be experiencing in your pursuit of
pharmacies and social media sites. This year, public health protection. Make sure to save
the campaign places a family’s devastating the dates for the three upcoming forums
loss at the forefront with the story of Ed and taking place in person this fall/winter in
Mary Ternan, who lost their son Charlie to Northbrook, IL. Dates for these events are
a fake prescription pill purchased through available in the Meetings section of the NABP
social media in 2020. We are honored and website. Invitations for the forums will be
grateful to have partnered with Ed and Mary, sent to the executive officers soon. I’m looking
who are founders of the nonprofit charity forward to these in-person discussions and
Song for Charlie. Throughout the campaign, working on solutions with all of you.
we encourage all boards to actively
participate in connecting with consumers Sincerely,
about these dangers. There are social media
posts, images, video links, and more available
in a social media kit that you can all access.
More information about the campaign is
available on page 5.
This issue also focuses on one of the largest Timothy D. Fensky, RPh, DPh, FACA
responsibilities that boards of pharmacy have NABP Chairperson
in public health protection – licensure. It is up
to us, the boards of pharmacy, to screen for
licensees who have failed to uphold state and
federal rules and regulations and put patients’
AUGUST 2021 | 1
POLICY PERSPECTIVES
The Future of Telehealth and the of telemedicine over the last decade –
especially in the last year – the “practice
Ryan Haight Act Post-Pandemic of telemedicine” as implemented by DEA
under the Ryan Haight Act is narrow
and outdated, requiring the patient to be
A year into the pandemic, the coronavirus Office of National Drug Control Policy, have physically located in a state-licensed hospital
disease 2019 (COVID-19) has radically also been contemplating updates to the law or clinic, or in the presence of another DEA-
changed our health care system – from the that enables providers to remotely prescribe licensed practitioner, to be prescribed CS.
pace at which new drugs come to market controlled substances (CS) using telehealth. An additional exemption available to
to the way patients access health care and DEA under the law is for the practice of
medications. Arguably one of the most Telehealth Involving Controlled telemedicine performed by a practitioner
dramatic shifts has been the major increase Substances: the Ryan Haight Act who has obtained a special registration from
in telehealth usage and the expansion of At present, prescribers of CS operate under the DEA administrator. The original Ryan
health care services that can be provided strict federal and state requirements for how Haight Act suggested DEA would eventually
using the internet. According to a Centers and under what circumstances they can issue issue regulations effectuating this provision.
for Disease Control and Prevention analysis, prescriptions to new and existing patients. Congress reiterated the need for DEA to
the number of telehealth visits increased Federal requirements for CS are outlined allow for the practice of telemedicine as
by 50% during the first quarter of 2020, in the 1970 Controlled Substances Act part of the SUPPORT for Patients and
compared with the same period in 2019. (CSA), which granted Drug Enforcement Communities Act in 2018. Yet, to date,
And, generally, telehealth has been well Administration (DEA) the authority to DEA has not acted. Thus, even before the
received. In addition, a study recently establish regulations promulgating CSA pandemic, DEA had – and continues to
published by the COVID-19 Healthcare requirements pertaining to the production, have – the legal authority to allow expanded
Coalition found that of over 2,000 patients prescribing, and distribution of CS, and telemedicine prescribing of CS.
who participated in at least one telehealth to enforce violations. In 2008, Congress
visit during the pandemic, the majority also added several new provisions to the Ryan Haight Flexibility During
found the experience overwhelmingly CSA in passing the Ryan Haight Online the COVID-19 Pandemic
positive, with 79% responding that they Pharmacy Consumer Protection Act. The During the COVID-19 pandemic, DEA has
were satisfied with their telehealth visit and act was named in remembrance of Ryan exercised its authority to waive the in-person
73% expecting to continue using virtual Haight who, at 18 years old, died of an visit prescriber requirement under another
health care services beyond the pandemic. overdose of a combination of painkillers exception for PHEs. Starting in March
Just over half of those patients (51%) were that had been prescribed to him online by 2020, DEA authorized providers to issue
prescribed a medication during their virtual a doctor who had never met him in person prescriptions for CS regardless of the location
visit and almost all (92%) found the process and did not conduct an adequate medical of the patient and without first conducting
of obtaining their prescription easy. evaluation. The painkillers were delivered an in-person examination, provided that
Whether those telehealth services will by an online pharmacy that was aware all of the following conditions are met:
continue to be a readily available option of the physician’s dangerous prescribing • the prescription is issued for a
for many patients largely depends on what habits. As the name suggests, the act was legitimate medical purpose by a
actions Congress and government agencies designed to impose legal requirements for practitioner acting in the usual course
take as we transition into a post-pandemic dispensing CS through the internet, including of their professional practice;
world. Many of the laws and regulations by way of “rogue” online pharmacies. • t he telemedicine communication
enacted in response to the COVID-19 is conducted using an audiovisual,
pandemic were provisional and set to expire DEA Authority to Implement real-time, two-way interactive
with the conclusion of the federal public ‘Practice of Telemedicine’ communication system; and
health emergency (PHE). While the PHE Exemptions • t he practitioner is acting in accordance
is not expected to end this calendar year, Recognizing that there is value in allowing with applicable federal and state laws.
Congress has already started to explore licensed practitioners to prescribe CS
which laws and regulations to make using the internet, the Ryan Haight Act Thus, in essence, the pandemic has forced
permanent. Much of the federal attention outlined several circumstances that would DEA to embrace telehealth technology and
has been on telehealth reimbursement for qualify for a “practice of telemedicine” the new channels to health care access that
certain services through federal programs exemption, thereby allowing practitioners have exponentially evolved and expanded
like Medicare. However, both members of to prescribe CS without an initial in-person since the Ryan Haight Act was first passed in
Congress and federal agencies, such as the visit. However, given the rapid evolution 2008. What remains to be seen is whether
2 | AUGUST 2021
POLICY PERSPECTIVES
Libby Baney, JD Jillian K. Brady, MS Megan S. Herber, MPH
Faegre Drinker Biddle & Reath LLP Faegre Drinker Biddle & Reath LLP Faegre Drinker Biddle & Reath LLP
the use of these services over the last year extent of providers’ adoption of telehealth Forecasting the Future of
has also introduced weaknesses that are to prescribe CS during the pandemic Telehealth for Controlled
now being exploited in what was previously is still largely unknown. A preliminary Substances
a completely “closed system” for the study conducted by RTI International has Over the coming months, as Americans
manufacture, distribution, prescribing, and shown that while substance use disorder see the light at the end of the pandemic
dispensing of CS, and whether any negative (SUD) providers embraced the adoption tunnel, and the state and federal landscape
consequences are overshadowed by increased of telehealth for outpatient services (97%) continues to evolve, policymakers in
access to services. and group counseling (77%) during the Congress, across federal agencies, and in
Advocates for a DEA-established COVID-19 pandemic, far fewer used it to statehouses will determine the future of
telehealth provider special registry system prescribe buprenorphine (17%) and other health care and whether Americans will
contend that allowing telemedicine providers medications (16%). be allowed to continue to access care and
to continue to prescribe CS without a prior prescriptions virtually. While CS must be
in-person medical evaluation is critical Do Not Forget State Laws handled with care and only accessed when
to patients’ access to care, especially for Adding complexity, providers need to also clinically appropriate, much can be done to
addiction treatment and child and adolescent comply with state law requirements. Pre- update federal rules to ensure that they are
mental health care. Some public health pandemic, state laws varied as to whether not overly restrictive and limiting access to
experts argue that DEA and state legislatures they allowed, prohibited, or were silent on legitimate care.
should embrace permanent changes to the remote prescribing of CS without a prior This article was written by Libby Baney,
the Ryan Haight Act, but only for select in-person medical evaluation. Further, some JD; Jillian K. Brady, MS; and Megan S.
medications. In a report conducted by the states have prohibited online prescribing Herber, MPH, with Faegre Drinker Biddle
George Washington University Regulatory of CS even if there has been a prior in- & Reath LLP. Please note, the opinions and
Studies Center, researchers argue that person consult. During the pandemic, states views expressed by Faegre Drinker Biddle &
DEA and the Substance Abuse and Mental embraced the expanded use of telehealth Reath do not necessarily reflect the official
Health Services Administration should and many are already moving to make views, opinions, or policies of NABP or any
execute their legal authority to extend the temporary provisions permanent. For member board unless expressly stated.
flexibilities after the PHE by waiving the example, in July 2020, New Hampshire
in-person visit requirement for providers passed a law eliminating the requirement for
issuing buprenorphine prescriptions to an in-person exam prior to a virtual visit for
treat opioid addiction. They contend that providers treating patients with SUD. And in
easing restrictions will allow patients in rural January 2021, Florida lawmakers in both the
communities who lack access to nearby state’s House and Senate introduced bills that
opioid treatment centers to receive care would permanently allow the prescription of
and improve compliance. Real-world data CS via telemedicine.
demonstrating the effectiveness of DEA’s
pandemic policy changes will take years.
Unlike with other telehealth services, the
AUGUST 2021 | 3
INTERVIEW WITH A BOARD INSPECTOR
Krystal Brashears Stefanyk, CISCI
Director of Inspections, North Carolina Board of Pharmacy
How long have you been serving In North Carolina, do inspectors also
as an inspector for the Board? conduct investigations for other
What was your role prior to health regulatory boards?
working for the Board? We work in conjunction with other regulatory
I was an inspector for nine years and associate boards if it is related to pharmacy and
director of investigations and inspections whatever professional practice a regulatory
for three years. I have been director of board is investigating. For example, if an
inspections for the past three years. Prior investigation involves a dispensing physician
to joining the Board, I was in college, or nurse practitioner who was dispensing,
obtaining a degree in criminal justice and we work those cases with the Medical Board
also working as a pharmacy technician. or Board of Nursing, respectively. Those
investigations are pretty straightforward, and
What tools or skills are a must-have we are there to look at the dispensing side.
North Carolina in a pharmacy inspector’s toolkit? We also work a lot of cases with Drug
Board of Pharmacy One of the most important skills to have is Enforcement Administration (DEA). Those
logical thinking. The best class I ever took cases can be pretty complicated. I have
in college, which has helped me every day in worked an investigation involving a large
Number of Board
my career, had nothing to do with criminal volume of diversion, where over 100,000
Members
5 pharmacist members justice or pharmacy. It was a deductive logic dosage units were taken out of a pharmacy.
and 1 public member class. That class taught me to look at several A pharmacist and three technicians – who
different components at the same time and were working independently of each other
separate what was important from what was – were diverting for their own uses. That
Number of not important to get a complete picture of was a very interesting case because it took
Compliance
a situation. To me, that describes pharmacy many different twists and turns. I worked
Officers/Inspectors
13 inspections and investigations perfectly. As with several agencies, local law enforcement,
an inspector, you must be able to look at the North Carolina State Bureau of
everything that is going on in a pharmacy in Investigation, and DEA.
Rules & Regulations
a very detailed manner and put those details
Established by together for a complete picture of how the What advice would you give
Board of Pharmacy pharmacy is operating. to a new board inspector?
Ninety percent of the time our job is to
What are some common issues that educate and teach our pharmacists and
you have witnessed and addressed pharmacy staff how to get into compliance.
Number of
Pharmacist Licensees
as an inspector with the Board? The advice that I give to new inspectors
17,009 We have been focusing on compounding is to take the time to learn the rules and
over the last several years. A lot of common regulations and the meaning behind those
issues that we see on the compounding rules and regulations, so they can be ready
side are lack of documentation, a need for to educate our pharmacists and pharmacy
Number of staff training, and gaps in knowledge of staff. There is a time and place to do what
Pharmacies
the standards of compounding. On the we need to do if there is a disciplinary
3,466 (in-state)
retail pharmacy side, which is a majority matter that needs to be addressed
of our pharmacies, we also see a lack of immediately, but for the most part, 90%
Number of Wholesale documentation. In addition, we see a lot of of our job is educating and teaching.
Distributors pharmacies that are overwhelmed and filling
Wholesale drug a lot of prescriptions. This can lead to issues
distributors are not
such as cluttered shelves and disorganization.
regulated by the Board.
4 | AUGUST 2021
ASSOCIATION NEWS
NABP Educates Consumers on
Dangers of Rogue Online Pharmacies
Educating consumers about the dangers of Websites Program or have earned NABP’s
buying medicine from unlicensed pharmacies Digital Pharmacy Accreditation will display
online and through social media sites is the as “Verified,” and the campaign urges You Can Help Share the
focus of NABP’s 2021 consumer awareness consumers to use these resources when buying Buy Safely Message
campaign. NABP has found that patients medication online. Sites that appear to be out
continue to buy medicine online because they of compliance with NABP patient safety and Boards of pharmacy
think it is easy, cost-effective, and safe, and are pharmacy practice standards, or applicable interested in sharing the
unaware of the dangers of rogue websites and law, will display as “Not Recommended.” message about safe ways
social media accounts selling fake, substandard, This year’s campaign includes television and to buy medications online
are encouraged to use the
and counterfeit prescription medications online. radio public service announcements (PSAs)
sample social media posts,
These unlicensed sites often sell unapproved or that feature Ed and Mary Ternan (pictured
images, video links, and
fake medications that may contain toxic fillers above), founders of the nonprofit charity Song sample articles included in
such as drywall, rat poison, sawdust, or deadly for Charlie (www.songforcharlie.org), who share the social media kit that
amounts of fentanyl. The various elements of how they lost their son to a fake prescription NABP provided to all board
the campaign seek to educate patients on these pill purchased through social media in 2020. executive officers. The kit
dangers, and provide safe alternatives. The television and radio PSAs are being sent is available on the NABP
to broadcast stations around the country, are website at https://safe
Campaign Overview available on NABP’s YouTube channel, and will .pharmacy/resources.
Throughout the campaign, NABP urges be used in various digital advertising campaigns
patients to visit its consumer website at throughout the year. Also, in August 2021, Ed
www.safe.pharmacy to use its free search Ternan and NABP President Caroline D. Juran,
tool to check whether the online pharmacy BSPharm, DPh (Hon), will be interviewed by
they are using is safe. Sites that have been several local and national television and radio
verified through NABP’s .Pharmacy Verified stations during a satellite media tour.
AUGUST 2021 | 5
Disciplinary Data
Sharing Through
NABP Clearinghouse
Offers Numerous Board Benefits,
Protects Public Health
W hen pharmacists face disciplinary action, they are required to disclose that information to
the boards of pharmacy in jurisdictions where they are licensed. However, some licensees
neglect to do so in a timely manner. For this reason, it is possible for licensees who have faced serious
repercussions for professional misconduct to continue to operate in other states without those
states knowing. This has long been an issue with licensed professions managed at the state level. In
pharmacy, NABP helps by providing its member boards with access to alerts created by the NABP
Clearinghouse, a national database of disciplinary information and other important licensee records
submitted by the Association’s member boards.
These records serve as a vital resource in helping boards make the best-informed decisions about
licensure for all applicable licensees. However, to be most effective, these records must be submitted
by the boards in a timely manner.
NABP Clearinghouse Review pharmacies, pharmacists, pharmacy technicians, and interns. NABP
As of summer 2021, there are more than 91,000 has estimated that about 1% of the country’s pharmacist population
records currently in the NABP Clearinghouse. has at least one record in the database. When a new record is
These records are submitted by member boards submitted by one state against a licensee who is registered in other
of pharmacy on all actions taken against all states, the other states receive an alert that contains the report and
license holders, including wholesale distributors, any other available information about the action. The receiving states
6 | AUGUST 2021
or jurisdictions may then determine if any action needs to be taken
0
ACTIONS
TAKEN
by their board as well. Making member boards aware of disciplinary
actions taken against licensees who may be registered in multiple
states is vital to protecting the public health.
The reports generated by the NABP Clearinghouse can also
be used for tracking less critical but still important licensee data.
Notably, this includes whether licensees are current on their
continuing pharmacy education (CPE) requirements. While Boards of pharmacy now have the option to
CPE compliance is rarely a disciplinary issue, licensee continuing report “zero” when they have no disciplinary
education status is still something that some states and individual actions to submit on individuals or
boards prefer to track and record, when appropriate. organizations. Contact clearinghouse@nabp
The NABP Clearinghouse also plays a vital role in license .pharmacy for more information.
verification, which is required by some NABP services such as the
Electronic Licensure Transfer Program® (e-LTPTM). When verifying
a license through the e-LTP process, NABP manually checks the
database for any disciplinary records. As with disciplinary alerts, these details regarding the reported action, we find that most states are
checks help boards make well-informed licensure decisions. willing to cooperate in providing additional information.”
“The biggest advantage of using the Clearinghouse is getting Ellen Mitchell, recently retired investigation support coordinator
a clear disciplinary history of North Carolina licensees or permit for the Idaho State Board of Pharmacy, had similar advice for other
holders who are located in other states,” said Cindy Parham, boards. “The most critical thing for states to do is to report on a
CISCI, an enforcement specialist with the North Carolina Board regular basis,” she said. “We have been reporting consistently for
of Pharmacy. “Reports give us a clear picture of disciplinary history about 17 years. NABP staff was key in helping us to understand the
during facility applications with the state. This also helps us to weed importance of reporting and how we support our sister boards by
out the bad actors before they become licensed or permitted.” doing so. While older information can be helpful, it is much more
helpful to see the actions as they happen.”
Timely Reporting Is Vital
NABP has long considered its Clearinghouse NABP Can Help With Reporting
database to be extremely important to the shared There are some burdens that may make submitting
mission of the Association and its member boards timely reports to the Clearinghouse more difficult.
of pharmacy in protecting the public health, Among these, NABP recognizes that the federal
particularly in situations that involve dangerous misconduct and/ requirement for state boards of pharmacy to submit
or severe disciplinary actions. In fact, because timely reporting is disciplinary records to the National Practitioner Data Bank (NPDB)
essential to maintaining the integrity and value of the database, may take priority over submitting these records to NABP. In these cases,
NABP’s Constitution and Bylaws require member boards to report boards may also be concerned that their staff may need to duplicate work
their disciplinary actions to the Clearinghouse as part of their by submitting disciplinary reports multiple times. NABP has taken steps
membership to the Association. to help boards of pharmacy in these circumstances.
Unfortunately, reporting is sometimes delayed in some states. Specifically, NABP and 34 state boards of pharmacy have entered
When other priorities take precedence, such as the coronavirus disease into agreements that allow the Association to be their reporting
2019 pandemic, it may seem less important to devote resources to agent to NPDB. This can reduce the amount of board time and staff
submitting disciplinary reports. However, the boards of pharmacy may needed and make it easier to keep reports for both databases up to
want to keep in mind how vital this data can be for other states. date. More information about using NABP as an NPDB reporting
Compliance Analyst David Meryman, PTR, and Enforcement agent is provided in the Members section of the NABP website under
Program Manager Robert Rivera, PTR, of the Texas State Board of Clearinghouse.
Pharmacy make regular use of the reports received by the NABP However, even if boards choose not to utilize NABP as a reporting
Clearinghouse. “My advice to anyone who would be using these agent to NPDB, there are other ways that the Association can make
records is to review the reports routinely and not let too much time reporting easier for its member boards. NABP wants the boards of
elapse before acknowledging incoming reports,” Meryman stated. pharmacy to take full advantage of the NABP Clearinghouse and works
Meryman also noted, “I would encourage participation from states that directly with them to help identify the best reporting methods. In many
may not think they have the resources or manpower. In Texas, we have cases, automated reporting to NABP is possible. NABP Clearinghouse
found that the process is not too involved. We receive the notification and staff can also assist boards to determine the best and most efficient option
decide what we need to do. We usually do not need to expend a lot of staff that works with their current processes and resources.
resources at our agency to process the incoming notifications.” In addition, the NABP Clearinghouse services and access are
Rivera added, “It is surprising how often we get a notification regularly improved. Upgrades are planned for the coming year, and
we never heard about, even years after the action. We are getting a more information will be shared through the appropriate channels.
chance to take a look at information that we might not have known NABP thanks its member boards for all they do to keep their
about had the licensee not reported it. If we determine we need more numbers updated regularly.
AUGUST 2021 | 7
ASSOCIATION NEWS
Association Seeks Item Writers for NABP Examinations
• c ompound, dispense, or administer
drugs, or manage delivery systems; and
• evelop or manage practice or
d
medication-use systems to ensure safety
and quality.
The MPJE combines federal and state-
specific questions that test an individual’s
knowledge in pharmacy jurisprudence
and includes the following areas:
• pharmacy practice;
• licensure, registration, certification,
and operational requirements; and
• general regulatory process.
Writers for the MPJE are typically
assigned by the participating jurisdiction;
however, in some cases, individuals may
be selected to participate independently
of board of pharmacy affiliation.
The FPGEE content areas cover curricula
of accredited United States pharmacy
programs, including:
• basic biomedical sciences;
NABP is seeking volunteers to apply to serve as designated examination program. Item
• pharmaceutical sciences;
item writers for the Association’s examination writers will then engage in the development • s ocial, behavioral, and administrative
programs. Item writers develop test questions of new test items that will be considered for pharmacy sciences; and
for NABP programs, including the North inclusion in NABP licensure, certification, • clinical sciences.
American Pharmacist Licensure Examination® and assessment examination programs. The PCOA is suitable for students in all four
(NAPLEX®), the Multistate Pharmacy Some item writing workshops may be professional years. The assessment follows a
Jurisprudence Examination® (MPJE®), the held virtually and others will be at NABP’s blueprint that is representative of curricula of
Foreign Pharmacy Graduate Equivalency Headquarters in Mount Prospect, IL. Please accredited US pharmacy programs, including:
Examination® (FPGEE®), and the Pharmacy check the Meetings section of the NABP
• basic biomedical sciences;
Curriculum Outcomes Assessment® (PCOA®). website for updates.
• pharmaceutical sciences;
Item Writer Selection Process Overview of Exams • s ocial, behavioral, and administrative
The opportunity to participate as an item The NAPLEX focuses on content pharmacy sciences; and
writer is currently available to pharmacists relating to the knowledge, judgment, • clinical sciences.
in all areas of practice and to faculty from and skills that an entry-level pharmacist
schools and colleges of pharmacy. Item writers is expected to demonstrate. There are six How to Apply
will be selected based on the specific needs of competency areas for the examination: Interested individuals should complete
the programs. Those who are selected will be the online NABP Item Writer Volunteer
• o btain, interpret, or access data,
asked to participate in an item development medical, or patient information; Interest Form located on the Meetings
workshop and training. Attendees will receive page of the NABP website and upload a
detailed instructions and training materials
• identify drug characteristics;
current résumé or curriculum vitae.
describing the item development process • develop or manage treatment plans;
and content-related requirements for their • perform calculations;
8 | AUGUST 2021ASSOCIATION NEWS
NABP Inspectors Identify Dangerous Scheme
Involving Over-the-Counter Insulin Products
With decades of experience providing an important treatment option for diabetes Scheme Exploits Insulin Laws
accreditations and inspections on a national patients who lack or have inadequate To make nonprescription insulin more
level, NABP inspectors and surveyors have insurance to help with the high cost of accessible to patients, one of the top
a unique perspective when it comes to drug prescription treatment options. Although manufacturers of insulin began working with
safety issues and trends. That perspective these insulins are not displayed in the community pharmacy chains. The drug’s
recently allowed NABP staff to observe several OTC section of retail pharmacies, upon retail price for patients is often below the
schemes related to nonprescription insulin request, they can be sold to patients. In wholesale price of other insulin products sold
that may pose a serious health risk to patients. this situation, the pharmacist is a frontline to pharmacies. A label on this insulin states,
Recently, unscrupulous distributors resource for these patients. “ONLY FOR RETAIL SALE BY [CHAIN
posing as patients have purchased a brand DRUGSTORE] AND ITS AFFILIATES.”
of over-the-counter (OTC) insulin made for NABP became aware of a scheme
and sold exclusively at retail pharmacies of a involving insulin purchased by a facility it
large national pharmacy chain. The insulin is was inspecting that was collected from several
collected in large quantities, then resold into chain drugstore pharmacies over a single
the wholesale market. Wholesalers have then weekend. This scheme was carried out by
purchased this diverted insulin and resold it to an organized group that sold the purchased
retail pharmacies and, in some cases, to other insulin to a wholesale distributor, which
wholesalers. This deliberate scheme to subvert then sold it to a mail-order pharmacy. Upon
the supply of insulin is exposing patients further investigation, NABP discovered that
to the high risk of receiving an adulterated this is the typical pathway in which diverted
drug in the form of subpotent insulin due to insulin is resold into the marketplace.
unknown storage conditions. The risk to patients with this type of
While the specific pharmacies and According to NABP’s 2021 Survey of corrupt distribution is very high, as they are
wholesalers involved in these schemes cannot Pharmacy Law, only 15 states require a receiving and injecting potentially adulterated
become accredited by NABP until they license for wholesale distribution of OTC insulin that is very likely subpotent due to
take corrective action and have ceased these drugs, including nonprescription insulin. improper storage.
activities, patients may still be at risk from Notably, these insulin products are not To combat the nationwide threat posed by
non-accredited facilities. subject to the traceability requirements this scheme, Georgia has enacted a law that
that are part of the Federal Drug Supply criminalizes the resale of nonprescription
Review of Insulin Regulation Chain Security Act of 2013 (Title II of the insulin that was first obtained through an
and Proper Handling Drug Quality and Security Act), which was OTC sale. Insulin sold in this manner is
Diabetes medications, including insulin, enacted to protect the integrity of drugs deemed adulterated under the law.
usually require a prescription. However, some from adulteration and counterfeiting by NABP encourages the boards of pharmacy
older forms of insulin can be purchased OTC. implementing requirements for traceability, to be aware of and to watch for variations
In fact, they remain the only injectable human among other protections. of this scheme. Pharmacies and wholesalers
drugs that can be sold without a prescription Insulins are complex biological products should maintain awareness and verify the
under federal law. These drugs were on the that are sensitive to temperature variations. source of insulin products before purchasing.
market without a prescription prior to the As a result, manufacturers recommend that Pharmacies that turn a blind eye to the
enactment of certain provisions of the Federal insulin be stored in refrigerated conditions purchase and sale of insulin that is clearly
Food, Drug, and Cosmetic Act, which (36o-46o F). At these temperatures, insulin labeled as being exclusively for sale by a chain
created prescription-only status drugs, and are maintains its potency through the labeled pharmacy cannot claim ignorance of the
grandfathered in to retain OTC status. As a expiration date. Once opened, insulin will source of the diverted insulin.
result, these forms of insulin are not subject continue to be effective for up to 28 days In the interest of the shared mission
to the same state and federal supply chain at room temperature (59o-86o F). Insulin of NABP and the boards of pharmacy to
regulations as prescription insulins. can degrade and lose efficacy when exposed protect the public health, the Association will
Diabetes advocacy groups, including the to extreme temperatures, either freezing continue to monitor these issues and trends
American Diabetes Association, support temperatures or high heat. and report on any relevant updates.
availability of nonprescription insulin as
AUGUST 2021 | 9ASSOCIATION NEWS
Task Force Offers Recommendations for Improving
Pharmacy Technician Regulations and Policies
The Overview Task Force on Pharmacy Assessment, task force members discussed the Requirements for Pharmacy Technician
Technician Education, Practice Responsibilities, career progression and time frame for each Education, task force members questioned
and Competence Assessment was the fifth task level of pharmacy technician practice – from whether it was feasible to encourage state
force established in response to Resolution applying as a candidate to becoming certified boards of pharmacy to license or register
115-4-19, which was approved by the NABP to earning an advanced certification. Members ancillary personnel, including cashiers, clerks,
membership at the Association’s 115th Annual agreed that it is crucial to require technicians and delivery drivers. After extensive discussion,
Meeting in May 2019. The task force met in to complete an accredited education and members agreed that NABP should not
December 2020 and members reviewed the training program in order to increase encourage boards to register ancillary personnel
recommendations of the previous task forces in standardization across the country. Members or add a definition for such personnel to the
order to synthesize and consolidate them and also agreed with the previous task forces’ Model Act. However, members did agree that
review the NABP Model State Pharmacy Act conclusions that the training component must NABP should continue to encourage state
and Model Rules of the National Association of be site-specific. In addition, they recognized boards of pharmacy to license all certified
Boards of Pharmacy (Model Act) to determine that the current certification examinations pharmacy technician candidates and certified
whether any updates are warranted. (See the measure knowledge, but not necessarily pharmacy technicians and to maintain the
bottom of page 11 for the official charge.) competence, and they noted that it is difficult definitions of both terms, as revised by the
In reviewing the recommendations of the to measure the competence of a certified previous task forces and 2020 Committee on
Task Force on Requirements for Pharmacy pharmacy technician candidate. Law Enforcement/Legislation report.
Technician Education and the Task Force Upon further review of the Task force members also discussed and
on Pharmacy Technician Competence recommendations of the Task Force on agreed with the addition to the Model Act
Task Forces Convened in Response to Resolution 115-4-19
2019 Task Forces
Overview Task Force on Requirements
for Pharmacy Technician Education, Task Force on Requirements for Task Force on Pharmacy Technician
Practice Responsibilities, and Pharmacy Technician Education Competence Assessment
Competence Assessment
2020 Task Forces
Overview Task Force on
Task Force on Pharmacy Technician Pharmacy Technician Education,
Practice Responsibilities Practice Responsibilities, and
Competence Assessment
In 2020, NABP held two task force meetings related to pharmacy technician practice and education. Both task forces were established
in response to Resolution 115-4-19, which was approved by the membership at the Association’s 115th Annual Meeting. This 2019
resolution was also the impetus for three other pharmacy technician task forces held in 2019.
10 | AUGUST 2021ASSOCIATION NEWS
regarding a definition of and licensing process • ABP should encourage state
N Task force members included:
for “advanced level certified pharmacy boards of pharmacy to recognize, as
technician.” However, the 2021 Committee a best practice, pharmacy technician • Malcolm Broussard, RPh (chair)
on Law Enforcement/Legislation agreed that education that includes a didactic • Cindy Fain, PD
curriculum from an accredited
a new pharmacy technician category may
provider and experiential training for
• Jacqueline L. “Jackie” Hall, MBA, RPh
be burdensome to boards of pharmacy and • Kristina Jonas, PharmD, RPh
all levels of pharmacy technicians.
ultimately decided not to add the definition
to the Model Act. • ABP should encourage state boards
N • Franklin J. “Rocky” LaDien, RPh
Regarding existing technician certification of pharmacy to license all certified • Julie Lanza, CPhT, CSPT
examinations, the task force agreed that it pharmacy technician candidates and • Edward G. McGinley, MBA, RPh, DPh
certified pharmacy technicians. The
was not necessary for NABP to perform
Association should not, however,
• Helen Pervanas, PharmD, RPh
a gap analysis on the examinations or to • Jeenu Philip, RPh
encourage boards to register other
develop an additional examination. Members
agreed, however, that NABP should perform
ancillary personnel, such as cashiers, • Kari Shanard-Koenders, MSJ, RPh
clerks, or delivery drivers. • Kristen Snair, CPhT
a gap analysis of accreditation standards for
pharmacy technician education programs,
• ABP should perform a gap analysis of
N • itchell G. “Mitch” Sobel,
M
accreditation standards for pharmacy MAS, RPh, FASHP, CPGx
with the goal of recommending accreditation
technician educational programs.
standards that encompass future growth of • Julienne Tran, PharmD, RPh
• ABP should retain and/or amend
N
pharmacist and pharmacy technician scopes of
Model Act language pertaining to • radley S. Hamilton, BSPharm,
B
practice, as recommended by the Task Force RPh, Executive Committee liaison
“certified pharmacy technician”
on Requirements for Pharmacy Technician
and “certified pharmacy technician
Education. candidate” and include a definition The task force report was approved by the
Lastly, the task force discussed remote practice for “advanced level certified pharmacy Executive Committee during its February
and shared services – particularly related to technician,” but, as noted previously, 2021 virtual meeting and is available in the
the coronavirus disease 2019 (COVID-19) was subsequently removed. Reports section at www.nabp.pharmacy.
pandemic – and agreed that relevant Model
• ABP should review Model Act
N
Act language that restricts or prohibits these language that prohibits remote practice
types of practices should be reviewed. and consider removing or qualifying
After careful review and deliberation, other provisions that have been
the task force submitted the recently amended or waived due to the
following recommendations: COVID-19 pandemic.
Task Force Charge
The task force was charged with the following objectives:
1 Review the reports of the Task Force on Requirements for Pharmacy Technician
Education, the Task Force on Pharmacy Technician Competence Assessment, and the
Task Force on Pharmacy Technician Practice Responsibilities.
2 Synthesize these task forces’ recommendations into one consolidated set of
recommendations.
3 Examine the language in the Model State Pharmacy Act and Model
Rules of the National Association of Boards of Pharmacy addressing
all aspects of pharmacy technician regulation and recommend
amendments, if necessary, that support technician education, competence
assessment and practice, all in the best interest of patient care.
AUGUST 2021 | 11Sharing
Sharing Solutions,
Solutions,
Advancing Regulation
Advancing Regulation
NABP Interactive Executive Officer Forum | September 28-29, 2021 | Northbrook, IL
INTERACTIVE
EXECUTIVE OFFICER
Executive officers, join your colleagues in person on September 28-29, 2021, to network, gain new insights, and
discover solutions to shared challenges facing the boards of pharmacy.
FORUM
No registration fees. Travel, hotel, and meals paid by NABP.
September 28-29, 2021
NABP Headquarters
The Interactive Executive Officer Forum will take place at the Hilton Chicago/Northbrook in Northbrook, IL.
Executive officers will be sent invitations in August 2021. For questions, contact meetings@nabp.pharmacy.
Mount Prospect, ILASSOCIATION NEWS
Task Force on Medication-Assisted Treatment
Recommends Adding MAT Definition to NABP Model Act
During the Task Force on Medication- who are going through withdrawal to Lastly, task force members discussed the
Assisted Treatment virtual meeting held seek treatment. The task force determined likelihood of pharmacists being added to
in November 2020, members reviewed that the pharmacist’s role should involve the list of Drug Addiction Treatment Act of
current federal and state laws and regulations initiation of short-term MAT therapy, 2000 (DATA 2000)-waived practitioners, as
related to medication-assisted treatment including counseling on the medication and well as the likelihood that the Mainstreaming
(MAT) and examined relevant language the need for further care, thus providing a Addiction Treatment Act (MAT Act) of
in the Model State Pharmacy Act and “bridge” to long-term care. 2019, which would eliminate the DATA
Model Rules of the National Association 2000 waiver requirement, would be passed.
of Boards of Pharmacy (Model Act). The task force was informed that NABP is
The task force meeting began with supportive of the MAT Act and is working
guests sharing their experiences with the to educate federal legislators and regulators
current trends that they are witnessing about the importance of the act in treating
in various parts of the country regarding OUD patients.
opioid use disorder (OUD) treatment, After careful review and deliberation,
including progress in addiction treatment, the task force recommended that NABP
the increase in OUD patients due to the In addition, task force members discussed amend the Model Act by adding a definition
coronavirus disease 2019 pandemic, the how to best implement pharmacist-initiated of MAT that includes a footnote to clarify
lack of available and/or willing providers, MAT in light of current state and federal that MOUD is the new term used by
how some patients feel stigmatized because restrictions, as many states do not allow SAMHSA, and by adding an emergency-
of their disorder, and the redundant shift pharmacists to obtain a state controlled use prescribing and dispensing provision
to the use of methadone from the use of substance (CS) license. Task force members to Section 6. Pharmacist Care Services that
buprenorphine in some areas. acknowledged that many states currently allows a pharmacist to prescribe and dispense
Task force members also discussed the allow pharmacists to prescribe MOUD MAT on an emergency-use basis for patients
term “medication-assisted treatment” and through the use of collaborative practice with OUD. The language specifies that
how it compares to “medications for opioid agreements with practitioners who are when initiating MAT, pharmacists must use
use disorder” (MOUD), the current term licensed to prescribe CS at the state and professional judgment to assess the clinical
used by the Substance Abuse and Mental federal levels. Members agreed, however, appropriateness of the request and the length
Health Services Administration (SAMHSA). that access to treatment would be greatly of treatment needed until the patient obtains
While there was extensive discussion expanded if pharmacists had independent treatment by an authorized practitioner.
regarding which term should be used to best authority at the state level to initiate The task force also recommended that
further the presidential initiative of former MOUD for patients suffering from opioid NABP encourage state boards of pharmacy to
NABP President Timothy D. Fensky, RPh, withdrawal, rather than having to enter into promulgate regulations that allow pharmacists
DPh, FACA, task force members agreed collaborative practice agreements. to obtain CS licenses in order to prescribe
that both terms should be referenced in the
Model Act. They also agreed that the barriers
to OUD treatment are more at issue than the
term that is used.
Regarding patient outcomes, task force
Task Force Charge
members and guests engaged in a robust 1 Review current state laws and regulations related to
discussion as to whether counseling was medication-assisted treatment.
necessary for OUD patients. After some
conversation, all agreed that psychological 2 Examine the language in the Model State Pharmacy Act
counseling should not be an eligibility and Model Rules of the National Association of Boards of
requirement of MAT for OUD patients Pharmacy and, if necessary, recommend amendments
seeking immediate treatment. Discussion that allow pharmacists to be key leaders in opioid safety
also ensued regarding whether pharmacies and patient care.
are an appropriate setting for patients
AUGUST 2021 | 13ASSOCIATION NEWS
CS at the state level and obtain a federal CS • Debra Feinberg, JD, RPh, FASHP Invited guests for the task force included
mid-level practitioner registration from Drug • Robert Giacalone, JD, RPh James J. Gasper, PharmD, BCPP, College of
Enforcement Administration. Psychiatric and Neurologic Pharmacists; Jake
• Michael J. Godek, RPh
The Task Force on Medication-Assisted Nichols, PharmD, Professional Recovery
Treatment was established pursuant to • Fiona Karbowicz, RPh
Associates; and Erica Schlesinger, PharmD,
former NABP President Fensky’s initiative, • Samuel Lanctin, MBA Tennessee Department of Mental Health and
which is to promote pharmacist-provided • illiam T. “Bill” Lee,
W Substance Abuse Services.
MAT for patients diagnosed with OUD. MPA, DPh, FASCP The task force report was approved by the
Task force members included: • Karen M. Ryle, MS, RPh Executive Committee during its February
• 2021 virtual meeting and is available in the
• Jeanne D. Waggener, RPh, DPh (chair) Katy Wright, MBA,
Reports section at www.nabp.pharmacy.
PharmD, DPh, BCPS
• James “Jim” Bracewell
• Luke Daniel, JD • icole L. Chopski, PharmD, BCGP,
N
ANP, Executive Committee liaison
AROUND THE ASSOCIATION
Board Member Appointments Services, Division of Public Health, • nthony D. Peterangelo, PharmD,
A
• oung Chang, MBA, RPh, has been
Y Licensure Unit. Borcher’s appointment RPh, has been appointed a member of
appointed a member of the Georgia will expire November 30, 2021. the Wisconsin Pharmacy Examining
State Board of Pharmacy. Chang’s • odd M. Larimer, RP, has been
T Board. Peterangelo’s appointment
appointment will expire July 1, 2022. appointed a member of the Nebraska will expire July 1, 2023.
• harles E. Page, RPh, has been
C Department of Health and Human • Michael Walsh has been appointed
appointed a member of the Georgia State Services, Division of Public Health, a public member of the Wisconsin
Board of Pharmacy. Page’s appointment Licensure Unit. Larimer’s appointment Pharmacy Examining Board. Walsh’s
will expire October 31, 2025. will expire November 30, 2024. appointment will expire July 1, 2024.
• Christina Solis has been appointed • harles T. Tomlinson, PharmD,
C • Shana Weiss has been appointed
a member of the Guam Board of RP, has been appointed a member a public member of the Wisconsin
Examiners for Pharmacy. Solis’ of the Nebraska Department of Pharmacy Examining Board. Weiss’
appointment will expire May 12, 2023. Health and Human Services, Division appointment will expire July 1, 2023.
of Public Health, Licensure Unit.
• rik Maki, PharmD, RPh, has been
E
Tomlinson’s appointment will
appointed a member of the Iowa Board Board Member Reappointments
of Pharmacy. Maki’s appointment expire November 30, 2025. • J . Andrew “Andy” Bowman,
will expire April 30, 2024. • ischelle Johnson Corbin has been
M PharmD, RPh, has been reappointed
appointed a public member of the North a member of the North Carolina
• hristopher Harlow, PharmD,
C
Board of Pharmacy. Bowman’s
RPh, BCGP, has been appointed a Carolina Board of Pharmacy. Corbin’s
appointment will expire June 1, 2025. appointment will expire May 1, 2026.
member of the Kentucky Board of
Pharmacy. Harlow’s appointment • allace Nelson, RPh, has been
W • achael DeBarmore, RPh, has been
R
will expire January 1, 2024. appointed a member of the North reappointed a member of the Oregon
Carolina Board of Pharmacy. Nelson’s State Board of Pharmacy. DeBarmore’s
• J onathan Van Lahr, RPh, has been
appointment will expire June 30, 2024.
appointed a member of the Kentucky appointment will expire April 30, 2025.
Board of Pharmacy. Van Lahr’s • ileen Ortega, RPh, has been appointed
E • Cyndi Vipperman, CPhT, has
appointment will expire January 1, 2024. a member of the Puerto Rico Board been reappointed a member of the
Pharmacy. Ortega’s appointment Oregon State Board of Pharmacy.
• J effrey Nikolaisen, RPh, has been
Vipperman’s appointment will
appointed a member of the Montana will expire November 23, 2024.
expire February 16, 2024.
Board of Pharmacy. Nikolaisen’s • iffany O’Hagan, MBA, PharmD,
T
appointment will expire July 1, 2025. RPh, has been appointed a member of • eri Ferreira, RPh, has been
T
the Wisconsin Pharmacy Examining reappointed a member of the Washington
• evin C. Borcher, PharmD, RP, has
K
Board. O’Hagan’s appointment State Pharmacy Quality Assurance
been appointed a member of the Nebraska
will expire July 1, 2024. Commission. Ferreira’s appointment
Department of Health and Human
will expire January 28, 2024.
14 | AUGUST 2021INTERVIEW WITH A BOARD MEMBER
Julie Lanza, CPhT, CSPT
Member, Massachusetts Board of Registration in Pharmacy
When were you appointed to the great job developing and approving policies
Board and as what type of member? and guidelines to assist the pharmacy
I am a pharmacy technician who was appointed community while new regulations
to the Massachusetts Board in December 2017. are waiting for promulgation.
In 2019, I was elected secretary, and I am
currently president for 2021. What advice would you give to a
new board member?
What steps should a board member Get involved and enjoy every moment. The
take to be successful in their role? opportunity to serve on a board is an honor
The most important thing a board member and a privilege. That said, every regulation,
should do is listen to their fellow board every meeting, every discussion is an
members. There is a wide range of specialty opportunity to learn something and become
areas within the world of pharmacy, and we more well-rounded. It is okay to ask questions.
Massachusetts Board of cannot be an expert in every area. Being able I was nervous and did not know what to expect
Registration in Pharmacy to listen to other board members who have the when I was first appointed, but I quickly
expertise and knowledge in an area unfamiliar learned that everyone on the Board was on the
to you may help you make informed decisions. same team and working toward the same goal.
Number of Board As a hospital-based pharmacy technician, In my three years on the Board, I have had the
Members
I have been able to expand my knowledge honor of serving with some amazing members
8 pharmacist members
2 public members in a host of areas simply by listening and of the pharmacy community.
1 pharmacy technician learning from other board members.
1 physician Have you served as a member of any
1 nurse What are some recent policies, NABP task forces or committees, or
legislation, or regulations your attended NABP or district meetings?
Number of Board has implemented? In January 2020, I attended the NABP
Compliance
Recently, the Board has approved a policy Interactive Member Forum and participated
Officers/Inspectors
1 compliance officer allowing vaccine administration by qualified in the panel discussion Compounding by the
and 12 inspectors pharmacy technicians. As a technician, this Numbers – Unlocking the Data of the MOU.
was very exciting and another step in the right Additionally, I participated virtually in
Rules & Regulations direction toward technicians in advanced roles. December 2020 in the Overview Task Force
Established by This past year, I believe it has become more on Requirements for Pharmacy Technician
Board of Registration evident that pharmacy technicians in advanced Education, Practice Responsibilities, and
in Pharmacy roles have a positive overall impact on the Competence Assessment. Both experiences
practice of pharmacy. They allow pharmacists were wonderful, but very different. The virtual
Number of to have more patient-facing time and for the meeting was very informative, and I was able to
Pharmacist Licensees implementation of more clinical services. Being hear other thoughts and opinions on the topics
13,936 involved with NABP gave me the opportunity presented. The benefits of the in-person meeting
to connect with board members from other were gaining knowledge, but then also talking to
states that already allowed this regulation. others about it. Comparing thoughts, ideas, and
Number of
Being able to ask questions and learn from processes with colleagues from other states in real
Pharmacies
1,124 (includes home them allowed me to bring back to the Board time was beneficial for me to be able to bring
infusion, mail-order information that was important for the back what I learned to the Board. I was able to
pharmacies, and development and implementation of this policy. connect with multiple people at the in-person
nuclear pharmacies) meeting whom I have since been able to contact
Has the Board encountered any for their opinions on my quest for technician
Number of challenges to developing new advancement. I feel as though any involvement
Wholesale
Distributors
policies or regulations? with NABP is beneficial, and what I was able to
37 Implementation of any new regulation or take away from those experiences was far greater
legislation takes time. My Board does a than what I expected.
AUGUST 2021 | 15You can also read
