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Position Statements



Statements Adopted by the Board

Safe Pharmacy Practice Statement for Licensees

Adopted February 11, 2022 

The Oregon Board of Pharmacy recognizes the hard work and perseverance of pharmacy personnel in all practice settings who have provided essential care to the residents of Oregon during the COVID-19 pandemic. The board also recognizes that pharmacists, technicians, and interns have been challenged by an increase in work demand, a decrease in available staffing and more frequent lapses in civility. In community pharmacy settings, this has adversely impacted pharmacy operating hours, wait times for prescriptions, and opportunities for pharmacists to address their patients’ medication-related questions or concerns. The board continues to receive a high number of complaints from licensees and the public about these conditions.

Sufficient staffing of pharmacies is a critical component of protecting public health and safety. The board is updating rules to facilitate communication with the public about hours of pharmacy operation, to remove barriers to Pharmacy Technician licensure, and to allow alternative methods of prescription dispensing with Remote Dispensing Site Pharmacies and Pharmacy Prescription Lockers. The board has also convened a workgroup of Oregon licensed pharmacists, technicians, and members of the public to solicit feedback on current practice conditions and make recommendations on rule changes.

Pharmacies are encouraged to employ strategies to provide sufficient staffing to assure that the public can receive their medications, vaccinations, counseling, and other patient care services in a safe and timely manner.


Statement on Immunization Services Under DHHS Guidance

November 30, 2020
On October 20, 2020, U.S. Department of Health & Human Services (DHHS) issued the third amendment to a declaration under the Public Readiness and Emergency Preparedness Act (or PREP Act). This declaration provides liability protection and authorizes both qualified pharmacy technicians and State-authorized pharmacy interns acting under the supervision of a qualified pharmacist to administer FDA-authorized or FDA-licensed COVID-19 vaccines to persons ages three or older and to administer FDA-authorized or FDA-licensed ACIP-recommended vaccines to persons ages three through 18 according to ACIP’s standard immunization schedule. The DHHS guidance lists requirements that qualified pharmacy technicians and State-authorized pharmacy interns must satisfy.
The declaration states that the authorization preempts any state and local law that prohibits or effectively prohibits those who satisfy requirements as set forth in the declaration from administering COVID-19 or routine childhood vaccines. The Oregon Board of Pharmacy will not take disciplinary action against persons who act in accordance with this DHHS guidance considering DHHS’s position that state law is preempted. The Board does not take a position on whether DHHS’s position on the preemption of state law is valid. If a complaint is received relating to activities covered under DHHS guidance, the Board will expect the licensee to provide documentation of full compliance. Failure to do so may result in disciplinary action.



Statement Regarding Sterile Syringe Access and Harm Reduction

Adopted February 2018
There is an opioid, heroin and methamphetamine crisis occurring across Oregon and the US. Evidence shows that access to sterile syringes and naloxone are effective strategies to reduce negative health outcomes and the spread of disease related to injection drug use, including HIV, Hepatitis B and C and overdose. Reuse of syringes is common when new syringes are unavailable; this increases intravenous drug users (IDUs) risk of infections and communicable diseases. 

Oregon was the first state to squarely face the question of syringe access as a public health measure. Prior to 1987, syringe sales were not regulated. In that year, the legislature passed a paraphernalia law based on the model statute but heeded the advice of state health officials to explicitly exclude syringes from the definition of paraphernalia (ORS 475.525(3)). In Oregon, it is therefore legal to sell syringes not only in pharmacies but also in other retail outlets, and to distribute them free through Syringe Exchange Programs (SEPs) or other mechanisms. Of note, the sale of syringes in Oregon does not require a prescription. However, a pharmacist must use good professional judgment when selling syringes to minors (individuals less than 18 years of age) see ORS 475.744. The Oregon approach has minimized the legal barriers to syringe access.  

Public health studies have proven legal syringe access reduces syringe reuse and sharing, does not promote injection drug use, and does not increase criminal activity in surrounding areas. When pharmacies or pharmacists choose to directly or indirectly restrict syringe sales to IDUs, or to not carry naloxone, the opportunity to decrease or prevent individual and community harm from addiction and injection drug use are lost. 

The Board recommends and encourages pharmacies and pharmacists to increase access of sterile syringes and naloxone to the public. Pharmacies are important public health partners for infectious disease and drug overdose prevention. Existing laws in Oregon have positioned pharmacies and pharmacists to support public health efforts to increase community member access to sterile syringes and naloxone, deliver health education, and refer IDUs to local health care and recovery services. Removing the stigma of selling sterile syringes and prescribing and dispensing naloxone will improve patient care in the short and long term. 

Statement Regarding Cultural Competency Continuing Education

Adopted August 2014
The Oregon Board of Pharmacy is charged with preserving and protecting the health of our state’s citizens in the delivery of pharmacy related healthcare. Oregonians are growing increasingly diverse, and inequities in access to quality health care are apparent according to the Oregon Health Authority’s Office of Equity and Inclusion. The Office has identified that racial and ethnic populations, lesbian, gay, bisexual and transgender communities, low literacy level individuals and rural Oregonians experience health disparities. The Board believes that increasing understanding and awareness of the necessity to provide culturally competent health care is a patient safety priority.
 
The National Institutes of Health (NIH) speaks to the critical importance of healthcare practitioner’s awareness and competency in equal care given to patients across cultural lines. The NIH provides the following background to define Cultural Competence: 
  • Culture is often described as the combination of a body of knowledge, a body of belief and a body of behavior. It involves a number of elements, including personal identification, language, thoughts, communications, actions, customs, beliefs, values, and institutions that are often specific to ethnic, racial, religious, geographic, or social groups. For the provider of health information or health care, these elements influence beliefs and belief systems surrounding health, healing, wellness, illness, disease, and delivery of health services. The concept of cultural competency has a positive effect on patient care delivery by enabling providers to deliver services that are respectful of and responsive to the health beliefs, practices and cultural and linguistic needs of diverse patients.
 
Cultural competency continuing education is a life-long process of examining values and beliefs while developing and applying an inclusive approach to health care practice in a manner that recognizes the context and complexities of provider-patient interactions and preserves the dignity of individuals, families and communities. Continuing education in cultural competency should teach attitudes, knowledge and skills to care effectively for patients from diverse cultures, groups and communities. The Office of Equity and Inclusion states that such training enables health care providers to work effectively in cross-cultural situations.
 
The Board recommends and encourages licensees to pursue ongoing continuing education opportunities for cultural competency. For purposes of maintenance of licensure, the Board considers continuing education (CE) in cultural competency to be relevant to the current practice of all licensees, and licensees may use this type of continuing education toward satisfying the required CE hours for license renewal. The Board will document licensees’ voluntary participation in cultural competency CE through the license renewal process beginning in 2015.
 
In order for Oregon to achieve the triple aim of improving health, improving care, and lowering cost, providers must be responsive to the needs of diverse populations. Cultural competency training for health care providers is one method for helping Board licensees adapt to the needs of Oregon’s socially and culturally diverse communities.


Statement Regarding Optimizing Patient Safety & Reducing Medication Errors in Oregon 

Adopted October 2008
Beginning in 2000, in response to the number of medication errors and medication distribution issues, state boards of pharmacy across the country began to convene committees and work groups to research and report back to the boards about ways to reduce medication errors. In response to the Oregon Board of Pharmacy’s interest in promoting an awareness of and ultimately a decrease in medication errors, the Board convened its Medication Error Reduction – Patient Safety Research Council. 
 
The charge of Oregon’s 12-member multi-disciplinary Research Council was to investigate procedures designed to reduce medication errors and evaluate the role the Board currently plays in supporting medication error reduction efforts. The Research Council was also asked to recommend measures the Board could take to improve patient safety through medication error reduction programs in the state. The Research Council has developed a document that reflects optimum standards for providing patient care in today’s pharmacies. While the document is not intended to be a comprehensive list of goals that are completely achievable on a continual basis, it does suggest a number of specific procedures that can be implemented in pharmacy practice settings in an effort to enhance existing quality improvement programs.  This list is not exclusive of other improvements and may be supplemented by the Board from time to time.
 
Optimizing Patient Safety and Reducing Medication Errors, the 23-point document developed by the Research Council, was based on a review of current literature and work done in other states. The recommendations have been modified and edited specifically for use in Oregon pharmacies. The Board would like to acknowledge the work done by the National Association of Boards of Pharmacy’s 2007-08 Task Force on Continuous Quality Improvement, Peer Review, and Inspecting for Patient Safety, the Massachusetts Board of Registration in Pharmacy, and The Institute for Safe Medication Practices. 
 
It is the Board’s position that all pharmacies and pharmacists should review these recommendations as a high priority and should consider implementation of those measures that are appropriate to the particular pharmacy setting. The Board believes that adoption and institution of these practices will lead to optimal patient safety through enhanced pharmacy medication delivery systems, improved performance generally and, ultimately, a significant reduction in medication errors.