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White Paper

Automated Drug Dispensing
Authors: Gerry Hinkley, Caitlin Bloom Stulberg, Jamin L. Agosti


California regulators have read new limitations into state statute that would bar the exchange of automated drug dispensing system “pockets” by health care facility staff.

  • The California Board of Pharmacy has adopted a position contrary to the plain text of state statute, putting pharmacy operators of ADDS in a tight spot.
  • Pharmacists and health care facilities using non-pharmacy staff to exchange stocked ADDS pockets may be at risk of enforcement action.
  • To properly enforce its interpretation, the Board of Pharmacy will need legislative action.

Despite its plain text, the California Board of Pharmacy (the “BoP”) has adopted an interpretation of state statute requiring stocked removable pockets for automated drug dispensing systems (“ADDS”) to be transported to and inserted into an ADDS by pharmacy staff. The California Department of Public Health (“CDPH”) has publicly stated that it will follow the BoP’s interpretation.1 While the continued use of non-pharmacy staff to transport or insert stocked ADDS pockets carries the risk of enforcement actions from these agencies, the BoP’s interpretation requires legislative actions to formally implement.

Read more: Automated Drug Dispensing

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