California Board of Pharmacy AB 1503 Special Edition Newsletter

C ALIFORNIA ST A TE BO ARD OF PHARM A C Y THE SCRIPT

January 2026

BE AWARE & TAKE CARE: Talk to your pharmacist! SPECIAL EDITION!

Contents

President's Message ............................ 2

Establish Pharmacy Technician

Advisory Committee ........................... 3

Title Change to Advanced

Pharmacist Practioners....................... 4

Dene Pharmacist................................ 4

Dene Technician Trainee ................. 4

Self-Assessment Process.................... 5

Enforcing Pharmacy Law................... 5

Standard of Care................................... 6

COVID-19 Oral Therapeutics............. 7

Emergency Rell Provisions ............. 7 AB 1503 Sunset Measure Pharmacy Records and

Digital Conversion................................ 8

Board of Pharmacy Extends Operations Ownership Prohibition....................... 8

Nonresident Pharmacies ................... 9

Inspections of Nonresident Assembly Bill (AB) 1503 (Berman, Chapter 196, Statues of

Pharmacies ...........................................10 2026) is the sunset measure for the California State Board of

Pharmacy (Board) and extends operations through January 1, Reporting to CAMER .........................11

1. The measure includes a number of policy issues raised Pharmacist-in-Charge, by the Board in its 2025 Sunset Oversight Review Report. The Stang...................................................11

measure was approved by Governor Newsom on October 1, Chain Community Pharmacy 2025. Employee Notice ................................11

Pharmacy Technician Duties ..........12 Given the comprehensive nature of the measure, signicant

implementation activities will be ongoing. For educational High Risk Patients...............................12

purposes the Board is releasing this special edition newsletter Retired Pharmacists License...........13

describing some of the changes resulting from enactment Mail Order Pharmacies .....................13 of AB 1503 as well as some of the implementation activities Fees: Medically under way. Underserved Area ..............................13

See AB 1503, Page 3

PRESIDENT'S MESSAGE

The Board has already spent specic practice requirements for substantial time discussing delivering these services. While the recommended actions well intentioned, these protocols to implement the extensive served as a barrier to care for changes made through patients. Assembly Bill 1503 (Berman, The Board has released a policy Chapter 196, Statutes of 2025. statement regarding standard We are hopeful that this special of care practice model and edition of The Script will provide is providing some further some further clarication and information in this edition of The information. This AB 1503 Special Script. It is more important now Edition newsletter includes than ever for pharmacists to truly several important legal changes be condent in their knowledge, and is intended to highlight skills, and abilities but also By Seung Oh, President, key updates and provide understand their limitations and Board of Pharmacy clear, helpful, and educational what they can and cannot do information to licensees. Happy New Year! I hope and to provide patient care in safe wish everyone the best of 2026 One of the most important manner. We are hopeful, that and many years to come! In light changes, under AB1503, is a these advances would allow of this special edition of the transition of several pharmacist- further access to patient care by Script for Assembly Bill 1503, provided patient care services pharmacists in many new and the Board's Sunset Measure, I to a standard of care practice dierent ways. would like to take a moment to model. The standard of care AB 1503 also transitions a share my deepest gratitude and practice model gives pharmacists pharmacist's authority to appreciation to the governor, the necessary exibility independently initiate and legislature, legislative sta, Board within their scope of practice, administer vaccines for persons Members, Board sta, and all enabling them to determine three years of age and older those that has worked tirelessly the most appropriate care for to a standard of care practice advocating to advance patient their patients. This builds upon model. This approach aligns care and consumer protection. eorts laid by Assembly Bill 1286 pharmacists with other health While I was appointed to the (Haney, Chapter 470, Statutes care practitioners who exercise Board in March 2020, it feels of 2023), which reinforced similar practice authority. like it was just yesterday. At the pharmacist autonomy and time of my appointment, the the importance of preserving, The Board notes that the pandemic was in full swing, with maintaining and exercising standard of care practice so much uncertainty about the pharmacists' professional model does not apply to all future. Despite these challenges, judgment. areas of pharmacy practice. the Board had progressed in so For example, pharmacists AB 1503 advances the many ways to advance patient engaged in compounding must pharmacist-provided patient care and consumer protection. continue to comply with all care services rst established And the cornerstone of the Board regulations, as well as under earlier laws, including Board's eorts is our sunset bill, all applicable state and federal -Senate Bill 493 (Hernandez, AB 1503. I am so proud of this bill laws governing compounding. Chapter 469, Statutes of 2013). and what I am hopeful will be a Further, the standard of care That earlier framework relied on steppingstone for many more practice model does not extend a more prescriptive approach, evolutionary and revolutionary to business operational matter which required pharmacists changes to advance and further such as the need to properly to adhere to standardized patient care for Californians. protocols that outlined the See President's Message, Page 3

President's Message AB 1503

Continued from page 2 Continued from page 1

follow all laws and regulations The information provided in this newsletter is summary information governing pharmacy operation. only. The Board strongly encourages licensees to review the measure in its entirety to gain a full understanding of changes. In We understand these changes addition, the Board has posted a compilation of changes in various may bring some anxiety or statues that impact the pharmacy profession which is available here. hesitation to the regulated public. We are condent this The Board will be releasing its Pharmacy Law Update, 2026 Edition approach will further the online webinar in the rst quarter of 2026. mission, vision, and goals of the Board and create better patient Establish Pharmacy Technician outcomes. As I reect back on the road we've traveled and Advisory Committee the roads ahead, the future as always is uncertain. The world New Section 4001.5 we live in at times may seem uncertain. I am condent The Board will establish a Pharmacy Technician Advisory that if we work together to Committee to advise and make recommendations to the Board on build bridges, bring dierent matters relating to pharmacy technicians. opinions, and share a common The committee shall consist of four licensed pharmacy technicians goal of doing what is best representing a range of practice settings; two licensed pharmacists, for people, together we will one of whom shall be a member of the Board; and one public overcome the new challenges member. that lay ahead. I look forward to further advancing the Appointee terms will be four years, with the ability to be vision and goals of the Board, reappointed once. expanding on the changes made in AB 1503 to continue The rst appointment tenures will vary in length to stagger to advocate for and to advance appointments in the future. what I know is good for patient Pharmacy technician positions include: care and outcomes.

1. 1 position representing community pharmacy practice
2. 1 position representing hospital pharmacy practice In closing, I am proud to be

3. 2 positions unspecied practice part of a healthcare profession
   so deeply committed to patient Application process will be online and include the following: care. I would like to sincerely

4. 1 Letter of intent thank everyone for all you do

5. 2 letters of recommendation to take care of your patients.
   (including one from a current employer and one from a The Board truly appreciates California licensed pharmacist.) all those out there doing all

6. CV or resume that you can to provide and -help people in need. We are
   Licensed appointees shall have at least three years of experience as so grateful for your dedication a pharmacist or pharmacy technician in a single setting. and commitment for all of you to help us achieve our vision Applicant license shall be current and in good standing. "Healthy Californians through quality pharmacist's care". Individuals interested in applying to serve on this committee Thank you all! should monitor the Board's website for updates on the appointment process.

Title Change to Advanced Pharmacist Practitioners

Amended Sections 4016.5, 4210, and 4233

The title of "advanced practice pharmacist" changed to "advanced pharmacist practitioner." The denition for and authorities granted to an advanced pharmacist practitioner remain the same. Specically, advanced pharmacist practitioner means a licensed pharmacist who has been recognized as an advanced pharmacist practitioner by the Board, pursuant to Section 4210. A Board-recognized advanced pharmacist practitioner is entitled to practice advanced practice pharmacy, as described in Section 4052.6, within or outside of a licensed pharmacy as authorized. Licensed advanced pharmacist practitioners will receive a license reecting the new license title as part of the general renewal process over the next two years. Individuals seeking an updated license reecting this change in title prior to their normal renewal date will need to submit a request for the reissuance of the license along with the required $75.00 fee.

Defne Pharmacist

Amended Section 4036

The denition of "pharmacist" is updated to remove limitations on the ability for a pharmacist to practice outside of a licensed pharmacy. Specically, as amended, the denition provides that a pharmacist is the holder of an unexpired and active pharmacist license issued by the Board that is entitled to practice within or outside of a licensed pharmacy. As part of the Board's discussion on implementation activities related to this change in denition, the Board voted to initiate a rulemaking to establish provisions for remote processing. Individuals interested in learning more about the regulation proposal should consider joining the Board's rulemaking mailing list to keep apprised of the rulemaking status. To be added the mailing list, email your information to: PharmacyRulemaking@dca.ca.gov.

Defne Pharmacy Technician Trainee

Amended Section 4038

The denition of "pharmacy technician trainee" was amended to also allow for an individual enrolled in an accredited employer-based pharmacy technician training program to perform as such a trainee. - With this change in denition, a "pharmacy technician trainee" includes an individual who is enrolled in a pharmacy technician training program that is:

• Operated by a California public postsecondary education institution
• Operated by a private postsecondary vocational institution
• An accredited employer-based program.

Self-Assessment Process

New Sections 4040.6 and 4102

AB 1503 includes provisions that establish the self-assessment process in statute. (Note: Prior to this change, except for the self-assessment requirement for surgical clinics, these requirements were previously included in various sections of Title 16 of the California Code of Regulations (CCR). As included in the statute, with the exception of the self-assessment process for surgical clinics, the self- assessment process must be performed July 1 of every odd-numbered year, as well as within 30 days after a new license is issued, within 30 days after there is a change in pharmacist-in-charge or designated representative-in-charge or when the facility moves to a new location. Surgical clinics are required to perform the assessment every odd-numbered year. As a reminder, existing law requires, as part of the renewal process for a surgical clinic license every odd- numbered year, submission of the most recently completed self-assessment form. Consistent with the requirements of the statute, the Board will be approving the revised self-assessment forms during public meetings. Such an approach provides interested stakeholders with an opportunity to provide feedback on the draft forms before Board approval. As a precursor to consideration by the Board, it is anticipated that the Board's Enforcement and Compounding Committee will undertake review of revisions to the various self-assessment forms as agendized. As self-assessment forms are approved by the Board, the updated versions will be available on the Board's website. The Board will also release a subscriber alert. Interested stakeholders should consider monitoring agendas for the Enforcement and Compounding Committee for scheduled discussion and consideration.

Enforcing Pharmacy Law

Amended Section 4014

The measure included provisions to make clear that the Board shall have exclusive authority to interpret and enforce provisions of Pharmacy Law regarding the practice of pharmacy and the licensing of pharmacists and pharmacies. As amended, the section further provides that any violation of this chapter -by a licensee shall be determined only by the Board. The Board sought these changes to address unfair practices by pharmacy benet managers and other payors clawing back reinbursements for drugs based on potential technical violations of the law where the Board had not made such a nding.

Standard of Care

Amended Sections 4050, 4051 and 4052

Changes in AB 1503 transition pharmacist practice to a more robust standard of care (SOC) practice model for specied services described further below. With this change, prescriptive requirements are removed in favor of the SOC practice model. The Board notes that an SOC practice model already exists in pharmacist practice where pharmacists exercise independent clinical judgment to take care of their patients. To facilitate this transition to a more robust SOC practice model. The statute establishes a denition, "accepted standard of care" is the degree of care a prudent and reasonable pharmacist licensed pursuant to the Pharmacy Law, with similar education, training, experience, resources, and setting, would exercise in a similar situation." [Reference BPC §4051(a)] Under the provisions of the measure, pharmacists are authorized to provide specied services and activities consistent with the accepted standard of care, including when authorizing the initiation of a prescription. This includes:

1. Furnish epinephrine

2. Furnish FDA-approved or authorized medications
   for preventative health care services that do not require a diagnosis, including the following:

3. Emergency contraception,

4. Contraception,

5. Smoking cessation,

6. Travel medications,

7. Anti-viral or anti-infective medications.

8. Order and interpret tests.

9. Furnish medication used to reverse opioid overdose and medication used to treat substance use
   disorder (e.g. Naloxone).

10. Complete missing information on a prescription for a noncontrolled medication if there is
    evidence to support the change. -6. Initiate and administer immunizations for persons three years of age and older. [Reference BPC §4052]

See Standard of Care, Page 7

Standard of Care

Continued from page 6

The law also provides that a pharmacist should not provide a service or function if the pharmacist has made a professional determination that (1) they lack sucient education, training, or expertise, or access to sucient patient medical information, to perform the service or function properly or safely; (2) performing or providing the service or function would place a patient at risk; or (3) pharmacist stang at the pharmacy is insucient to facilitate comprehensive patient care. Provisions also establish a notication requirement to a patient's primary care provider as specied. As part of the transition to a standard of care practice model for certain pharmacist-provided health care services, some provisions of law that established prescriptive requirements and/or required pharmacists to follow standardized procedures and protocols have been repealed, for example, former sections 4052.01, 4052.02, 4052.03, 4052.3, 4052.8, and 4052.9 and the Board is in the process of repealing numerous related regulations included in Title 16. As part of the Board's implementation activities, the Board released a policy statement on the SOC practice model. As included in this statement, it is the responsibility of each pharmacist to determine whether they have sucient education, training, experience, resources, and setting to perform these authorized duties. The Board notes that the SOC practice model does not apply to all areas of practice and where legal requirements exist, compliance with such requirements is necessary.

COVID-19 Oral Therapeutics

Amended Section 4052.04

Assembly Bill 1503 removes the sunset date for pharmacist-furnished COVID-19 therapeutics. It is important to note that while the sunset date was removed, the law remains specifying the conditions under which pharmacists may provide this health care service.

Emergency Rell Provisions

Amended Section 4064 -

AB 1503 amended emergency rell provisions to provide greater exibility for pharmacists to take care of patients. Recent amendment removes the requirement for a pharmacist to make every reasonable eort to contact a prescriber before providing a rell where a pharmacist has determined that failure to rell the prescription might interrupt the patient's ongoing care and have a signicant adverse eect on the patient's well-being.

Due to an editorial oversight, a previous version of this newsletter included a section on Dispensing Hormone Therapy summarizing a provision of AB 1503 that did not become operative. That section has been removed.

Pharmacy Records and Digital Conversion

Amended Sections 4081 and 4105

BPC Section 4081 is amended to specify that policies and procedures related to pharmacy personnel and pharmacy operations must also be maintained in a readily retrievable format. The section further now provides that such records that are maintained electronically shall provide an audit trail for revisions and updates of each record for 3 years and establishes provisions the maintaining prior versions. This amendment allows paper records to be converted into a digital format and maintained in a noneditable digital format. Certication that the digitized records have not been altered may be required by the Board. [Reference BPC §4105]. The Board notes that while provisions in Pharmacy Law have changed to allow for digitizing records, licensees must remain apprised of requirements of other regulators, including DEA legal requirements, which may place some restrictions on the conversion of paper records to digital records.

Ownership Prohibition

Amended Section 4111

Amendments to BPC Section 4111 update ownership provisions to now allow for pharmacy ownership when the applicant shares a community or other nancial interest with a prescriber. Under the law, the prescriber must have no direct or indirect ownership in; including, disavowing any community or nancial interest in the license, and the pharmacy must be transmuted into the separate property from the person seeking the license. -The Board's applications and instructions have been updated to reect these changes. Individuals interested in learning more should contact phystatus@dca.ca.gov. The Board also would like to highlight that where a pharmacist owns or owns and operates a pharmacy and is also issuing drug orders, the pharmacist must oer to provide a prescription to the patient that the patient may elect to have lled at a pharmacy of their choice, unless prohibited as a condition of a collaborative practice agreement. Full patient consultation is also required.

Nonresident Pharmacies

Amended Sections 4112, 4113, and 4113.1

Any pharmacy located outside California that is involved in the preparation, dispensing, shipping, mailing, or delivery, in any manner, of controlled substances, dangerous drugs, or dangerous devices into California is considered a nonresident pharmacy, and a person shall not act as a nonresident pharmacy unless the person has obtained a license from the Board. Under changes enacted in AB 1503, several changes specically related to nonresident pharmacies have occurred. Eective July 1, 2026: New PIC Requirement Eective July 1, 2026, any nonresident pharmacy applying for initial licensure or renewing its license with the Board must comply with all California Pharmacy laws. Additionally, as a prerequisite to licensure or renewal, nonresident pharmacy must identify a California-licensed pharmacist employed and working at the nonresident pharmacy to be proposed to serve as the Pharmacist-In-Charge (PIC) over the pharmacy's California operations. Consistent with existing requirements of California pharmacy law, the proposed PIC shall be subject to the Board's approval. Further, the individual designated as the PIC for a nonresident pharmacy must be fully vested with all authority necessary to ensure operational compliance with California law, including, but not limited to, oversight of dispensing, record-keeping, labeling, patient consultation, controlled substance compliance, and stang decisions. The Board notes, however, that, as a policy matter, it will not require the individual designated as the PIC for California operations to be the PIC on record for the resident state. To assist impacted licensees with gaining a full understanding of the changes, the Board released an alert highlighting actions to be taken to ensure compliance. This information was also sent directly to nonresident pharmacies with an email address on record with the Board. Below is the information shared. Be Prepared and Take Steps Now to Ensure Compliance To ensure you comply by July 1, 2026, we recommend the following steps:

1. Identify a pharmacist to propose as the PIC for California operations
   • Locate a pharmacist who holds or is eligible to obtain a California pharmacist license. • Ensure the identied pharmacist will be employed and actively working at the nonresident facility (or the portion of the facility handling California prescriptions).

2. Ensure that the pharmacist obtains or maintains California licensure
   • If the individual does not yet hold a California pharmacist license, begin the pharmacist exam application process immediately. - • The individual must pass the North American Pharmacist Licensure Examination and the California Practice Standards and Jurisprudence Examination (CPJE), consistent with the requirements of Business and Professions Code section 4200.

See Nonresident Pharmacies, Page 10

Nonresident Pharmacies

Continued from page 9

Upcoming CPJE Exam Dates (Check the Board's website for additional dates) • February 2, 2026 • March 3, 2026 • April 4, 2026 • May 13, 2026 • June 11, 2026 Notify the Board • Report the PIC's name, California pharmacist license number, and the eective date of designation to the Board within 90 days of appointment. A Change of Pharmacist-in-Charge (PIC) application (is available on the Board's website. • Additionally, notify the Board within 90 days of any change in the PIC. PIC Training Requirement Finally, note that all designated PICs--including those designated as the PIC of a nonresident pharmacy's California operations--must have completed the Board-provided PIC training within two years prior to the date of application to serve as a PIC. (See California Code of Regulations, title 16, section 1709.1.) The training course is available via the Board's training platform here: https://pharmed.thinkic.com/ collections. The Board may verify completion of this training during the application, renewal, or inspection process. Nonresident pharmacies must ensure that their California-licensed PIC has completed the Board's PIC training within the required timeframe and maintain documentation of completion at the pharmacy for Board review. To learn more about the autonomy of the PIC and specic authority vested with a PIC, please read the Board's policy statement on The Role of the Pharmacist-in-Charge.

Inspections of Nonresident Pharmacies

Under new authority, operative July 1, 2026 the Board has authority to inspect nonresident pharmacies and recover the costs of such inspections. When an inspection is required, the Board will provide the licensee with notication of the Board's estimated costs of performing -the inspection. The licensee must deposit the amount before the inspection occurs. Following the inspection, the Board will issue an invoice for any remaining costs. The law provides that the Board shall not renew a license until all inspection costs, along with any applicable renewal fees, are fully paid. [Reference BPC §4112]

Reporting to CAMER (California Medication Error Reporting)

AB 1503 updated medication error reporting requirements for nonresident pharmacies. As amended, such pharmacies are only required to report medication errors related to prescriptions dispensed to California residents. [Reference BPC §4113.1] Additional information regarding CAMER is available here.

Pharmacist-in-Charge, Stang

Amended Section 4113

Consistent with changes to BPC Section 4113, the pharmacist-in- charge shall make stang decisions to ensure sucient personnel are present in the pharmacy to prevent fatigue, distraction, or other conditions that may interfere with a pharmacist's ability to practice competently and safely. If the pharmacist-in-charge is not available, a pharmacist on duty may adjust stang according to workload if needed. This does not apply to facilities of the Department of Corrections and Rehabilitation. The section also requires the PIC to determine appropriate pharmacist to technician ratio, which may not exceed 1 pharmacist to 3 pharmacy technicians (1:3). Additional information is included in the Board's policy statement previously referenced.

Chain Community Pharmacy Employee Notice

Amended Section 4113.6

BPC Section 4113.6 was amended to establish a requirement for a chain community pharmacy to post, in a prominent place for pharmacy personnel, a notice that provides information on how to le a complaint with the board. www.pharmacy.ca.gov The Board is developing a sample notice that could be used to meet these notice requirements. -

Pharmacy Technician Duties

Amended Section 4115

Several clarifying changes to BPC Section 4115 were made to the provisions establishing authorized duties for a specially trained pharmacy technician. The amendments clarify the authorized duties of a specially trained pharmacy technician may perform and the conditions that must be met to perform the additional functions. This section also establishes authority for a pharmacy technician to compound or administer vaccines outside of a licensed pharmacy, if performed under the direct supervision and control of a pharmacist. Changes were also made to the pharmacist to pharmacy technician ratio, as discussed elsewhere in this newsletter.

High Risk Patients

Amended Section 4118.5

As enacted, AB 1503, establishes a requirement for a pharmacist at a hospital pharmacy to obtain an accurate medication prole for each high-risk patient upon discharge (in addition to upon admission) under specied conditions described below. A pharmacist at a hospital pharmacy shall obtain an accurate medication prole or list for each high-risk patient upon admission and discharge of the high-risk patient under the following conditions: • The hospital has more than 100 beds. • The accurate medication prole or list may be acquired by the pharmacist during the hospital pharmacy's hours of operation. Notwithstanding any other law, a pharmacy technician or an intern pharmacist may perform the task of obtaining an accurate medication prole or list for a high-risk patient if both of the following conditions are satised: • The hospital pharmacy has a quality assurance program to monitor competency. • The hospital has established policies and procedures for training and proctoring pharmacy technicians or intern pharmacists by the hospital pharmacy department and the pharmacy technician or intern pharmacist has completed that training and proctoring. - The hospital shall establish criteria regarding who is a high-risk patient for purposes of this section and shall determine the timeframe for completion of the medication prole or list, based on the patient populations served by the hospital. This shall not apply to the State Department of State Hospitals.

Retired Pharmacists License

Amended Section 4200.5

BPC Section 4200.5 was amended to establish a pathway for pharmacist with a retired license to request to restore their pharmacist license to active status within three years of issuance of the retired license. The request shall be accompanied by the renewal fee established in subdivision (e) of Section 4400 and demonstration that, within the two years preceding the request for restoration, the pharmacist has successfully completed continuing education consistent with the requirements set forth in subdivision (b) of Section 4231. If more than three years have elapsed since the issuance of the retired license, the retired pharmacist shall reapply for licensure as a pharmacist consistent with the provisions of Section 4200. To assist interested individuals, the Board has updated its retired pharmacist application to include the provisions for reactivation of the license.

Mail Order Pharmacies

New Section 4317.6

AB 1503, as enacted, adds new section 4317.6, providing the Board with the authority to issue a citation and ne of up to $100,000 to a mail order pharmacy. The section denes mail order pharmacy as a nonresident pharmacy that dispenses medications and ships them to patients via the postal service or other mail delivery method. This new statutory authority is similar to statutory authority granted to the Board a few years ago that provided the Board with authority to issue higher nes to chain community pharmacies under specied conditions.

Fees: Medically Underserved Area

Amend Section 4400

Provisions included in AB 1503, establish authority for the Board to waive the application and renewal fee for a pharmacy providing in-person patient care services in a medically underserved area. -The statute denes medically underserved area as a geographic area that does not have within 50 road miles a physical pharmacy that provides in-person patient care services by a pharmacist and serves the general public.

This newsletter is published by the California State Board of Pharmacy Department of Consumer Aairs 2720 Gateway Oaks Drive, Suite 100 Sacramento, CA 95833 (916) 518-3100 Fax: (916) 574-8618 www.pharmacy.ca.gov BOARD MEMBERS Seung Oh, Pharm.D. President Jessica Crowley, Pharm.D. Vice President Trevor Chandler, Public Member Treasurer Renee Armendariz Barker, Pharm.D. Je Hughes, Public Member Kartikeya "KK" Jha, Licensee Member Claudia L. Mercado, Public Member Jason Newell, Public Member Ricardo Sanchez, Public Member Satinder Sandhu, Pharm.D. Maria D. Serpa, Pharm.D. Nicole Thibeau, Pharm.D. STAFF Anne Sodergren Executive Ofcer Julia Ansel Deputy Executive Ofcer Sara Jurrens Editor Victor Perez Layout/Design

California State Board of Pharmacy