Can a Washington pharmacist actually diagnose a patient under a collaborative drug therapy agreement, and can a physician or physician assistant authorize a pharmacist to do so?

Plain-English summary

Washington has a longstanding system of collaborative drug therapy agreements (CDTAs) under which a pharmacist may initiate or modify drug therapy according to written guidelines and protocols established by a physician or other authorized prescriber. As of 2018, more than 33,000 CDTAs were on file with the Pharmacy Quality Assurance Commission. Pharmacists use them for, among other things, vaccinations, certain birth control prescriptions, naloxone, antibiotics for urinary tract infections, and treatments for insect stings (the last to reduce the burden on urgent care and emergency rooms).

The Washington State Medical Commission asked the AG four interrelated questions about how far this authority extends. The bottom line:

1. Does "initiating or modifying drug therapy" include diagnosis? It depends. A pharmacist's application of a CDTA's protocols is statutorily authorized, even if it amounts to diagnosis of a patient's condition. RCW 18.64.011(28) authorizes pharmacists to "initiat[e] or modify[]... drug therapy in accordance with written guidelines or protocols," and identifying a condition that triggers a protocol is necessarily a precursor to initiating therapy. The opinion gives the example of a CDTA authorizing pharmacists to treat insect stings: the protocol must include criteria for diagnosing the sting and conditions requiring referral to another provider.

2. Can a physician or physician assistant enter into a CDTA permitting pharmacist diagnosis? Yes, in limited circumstances. The practitioner must be "authorized to prescribe drugs" (RCW 18.64.011(28)), in active practice (WAC 246-945-350(2)(a)(i)), and acting within their current scope of practice (WAC 246-945-350(2)(a)(ii)). For physician assistants specifically, the analysis is case-by-case and depends on the PA's individual practice agreement (formerly called a delegation agreement) approved by the Washington Medical Commission.

3. Must there be direct contact between the prescriber and the patient? No, under the statute or regulation. A CDTA may include such a requirement, but neither RCW 18.64.011(28) nor WAC 246-945-350 mandates it. In some cases, the absence of direct contact may amount to malpractice or unprofessional conduct, depending on the standard of care.

4. Is a pharmacist who diagnoses under a CDTA engaged in unlicensed practice of medicine (RCW 18.130.190)? Not when acting within statutory authority. The "other healing arts" exception in RCW 18.71.030(4) plus the express statutory authority in RCW 18.64.011(28) places CDTA-based pharmacist diagnosis within the scope of pharmacy practice, not the unlicensed practice of medicine.

The opinion repeatedly stresses that the authority is bounded: the CDTA must include detailed procedures, decision criteria, or plans (WAC 246-945-350(2)(b)(ii)); the practitioner remains responsible for the adequacy of the protocol; and pharmacists may not diagnose outside the scope of a CDTA. The AG also flagged that this is an area "that would benefit from greater statutory clarity."

Currency note

This opinion was issued in 2020. Subsequent statutory amendments, court decisions, or later AG opinions may have changed the analysis. Treat this page as historical context, not current legal advice. Verify current law before relying on any specific rule, deadline, or remedy mentioned here.

Common questions

Q: What is a CDTA?
A: A collaborative drug therapy agreement under WAC 246-945-350. The agreement, between one or more named pharmacists and a prescriber in active practice, identifies the diseases, drugs, or drug categories the pharmacist may initiate or modify therapy for, the procedures and decision criteria the pharmacist must follow, and how the pharmacist will document decisions and communicate with the prescriber. CDTAs are valid for two years from the date of signing, and any modification creates a new CDTA.

Q: How is a CDTA different from a standing order?
A: The opinion does not expressly distinguish them. A CDTA is structured by WAC 246-945-350 with specific content requirements. The substance is similar (a prescriber sets out conditions under which a non-prescriber can initiate therapy) but the regulatory wrapper is different.

Q: Can a pharmacist diagnose without a CDTA?
A: The opinion expressly says no. The opinion's authority for pharmacist diagnosis is grounded in the CDTA framework. A pharmacist diagnosing outside a CDTA could be engaged in the unlicensed practice of medicine.

Q: Does the opinion mean my pharmacist can diagnose me with anything?
A: No. The pharmacist's authority is bounded by the specific CDTA: the named diseases or drug categories, the named procedures and decision criteria. A CDTA limited to UTIs does not authorize a pharmacist to diagnose diabetes. Outside the protocol, the pharmacist is not authorized to diagnose.

Q: What about PAs in particular?
A: A physician assistant's ability to participate in a CDTA depends on their individual practice agreement (or delegation agreement, before the 2021 terminology change in Laws of 2020, ch. 80, §§ 5, 61) approved by the Washington Medical Commission. A PA is not necessarily authorized to prescribe drugs (WAC 246-918-035), and their scope of practice is limited by the agreement (WAC 246-918-055). So PA participation in a CDTA is case-by-case, even though physicians can do so more broadly.

Q: Does the prescriber have to see the patient first?
A: Not as a matter of statute or regulation. A specific CDTA may impose such a requirement. The opinion does note that in some circumstances, failure to require prescriber contact in the protocol could amount to unprofessional conduct or malpractice under RCW 7.70.040 or RCW 18.130.180(4).

Q: Where does the "other healing arts" exception come in?
A: RCW 18.71.030(4) exempts "practitioners of other healing arts" (including pharmacists, per RCW 70.124.020(3)) from the general prohibition on practicing medicine without a medical license. The pharmacist is not unlawfully practicing medicine when they perform tasks expressly authorized under their pharmacy license, including the CDTA-based authority in RCW 18.64.011(28).

Q: Is the pharmacy quality assurance commission's regulation entitled to deference?
A: Yes. WAC 246-945-350 (and its predecessor WAC 246-863-100, going back to 1981) is a contemporaneous interpretation of RCW 18.64.011(28), adopted just two years after the legislature added "initiating or modifying of drug therapy" to the pharmacy practice definition in 1979. The legislature has amended RCW 18.64.011 eleven times since 1982 without disturbing this interpretation, which the AG treated as legislative acquiescence (First Student, Inc. v. Dep't of Revenue, 194 Wn.2d 707 (2019)).

Background and statutory framework

The "practice of pharmacy" as defined in RCW 18.64.011(28) includes interpreting prescriptions, compounding and dispensing, drug therapy monitoring, and "the initiating or modifying of drug therapy in accordance with written guidelines or protocols previously established and approved for his or her practice by a practitioner authorized to prescribe drugs." The "initiating or modifying" language has been part of the definition since 1979 (Laws of 1979, ch. 90, § 5), and one purpose was to broaden access to certain therapies by eliminating the need to see a physician first.

The Pharmacy Quality Assurance Commission has implemented this authority through WAC 246-945-350 (effective July 1, 2020, superseding WAC 246-863-100, which had been in substantively the same form since 1981). The current rule requires a CDTA to identify the participating pharmacist and prescriber, specify the prescriptive authority granted (diseases, drugs, procedures, decision criteria), and require documentation and feedback to the prescriber. The prescriber must be in active practice, and the authority must be within the prescriber's current scope.

The interpretive question is whether the CDTA framework permits a pharmacist to engage in some degree of diagnosis. Diagnosis is generally considered the practice of medicine (RCW 18.71.011, .021), which is protected against unlicensed practice (RCW 18.130.190; State v. Wilson, 11 Wn. App. 916 (1974)). RCW 18.71.030(4) excepts practitioners of other healing arts (defined to include pharmacists at RCW 70.124.020(3)) from the unlicensed-practice prohibition when acting within their own license.

The AG read RCW 18.64.011(28) as containing implicit authority for diagnosis to the extent diagnosis is a predicate to initiating drug therapy under a protocol. "Diagnose" means to determine or identify a condition by symptoms or distinguishing characteristics (State v. Pac. Health Ctr., Inc., 135 Wn. App. 149 (2006); Yow v. Dep't of Health Unlicensed Practice Program, 147 Wn. App. 807 (2008)). Identifying a condition that triggers a protocol is logically inseparable from initiating therapy. The contemporaneous regulation (WAC 246-945-350 and its 1981 predecessor) confirms this reading.

The case-by-case treatment for physician assistants reflects RCW 18.71A.030(1), which limits physician assistants to practicing medicine only pursuant to an individual practice agreement (formerly called a delegation agreement, until the 2021 statutory terminology change effective Laws of 2020, ch. 80, §§ 5, 61) approved by the Washington Medical Commission, and only to the extent permitted by that agreement.

Citations and references

Statutes:
- RCW 18.64.011, particularly subsection (28); RCW 18.64 generally
- RCW 18.71, .011, .021, .030(4)
- RCW 18.71A, .030, .030(1)
- RCW 18.130.180(4), .190
- RCW 7.70.040
- RCW 70.124.020(3)

Regulations:
- WAC 246-945-001(11), -350 (current CDTA rule)
- WAC 246-863-100 (former CDTA rule, in force 1981-2020)
- WAC 246-918-035, -055 (PA prescribing and scope)

Cases:
- State v. Wilson, 11 Wn. App. 916 (1974)
- State v. Pac. Health Ctr., Inc., 135 Wn. App. 149 (2006)
- Yow v. Dep't of Health, 147 Wn. App. 807 (2008)
- First Student, Inc. v. Dep't of Revenue, 194 Wn.2d 707 (2019)
- Dep't of Ecology v. Campbell & Gwinn, L.L.C., 146 Wn.2d 1 (2002)

Source

• Landing page: https://www.atg.wa.gov/ago-opinions/practice-pharmacy-under-collaborative-drug-therapy-agreements

Original opinion text

Attorney General Bob Ferguson

PHARMACY QUALITY ASSURANCE COMMISSION—MEDICINE—PROFESSIONAL SERVICES—Practice Of Pharmacy Under Collaborative Drug Therapy Agreements

1. A pharmacist’s application of guidelines or protocols previously established in a collaborative drug therapy agreement is statutorily authorized, even if it amounts to diagnosis of a patient’s condition.

2. Under limited circumstances, a physician or physician assistant may enter into a collaborative drug treatment agreement that permits the diagnosis by a pharmacist of a patient’s condition.

3. There is no statutory or administrative requirement that a collaborative drug treatment agreement call for direct contact between a physician or physician assistant and a patient.

4. A pharmacist who diagnoses patients pursuant to a collaborative drug treatment agreement with a physician or a physician assistant does not commit an act of unlicensed practice of medicine under RCW 18.130.190 if the pharmacist acts within the scope of guidelines previously established under a collaborative drug treatment agreement.

December 14, 2020

John Maldon

Chair, Washington State Medical Commission

PO Box 47866

Olympia, WA 98504-7866

Cite As:

AGO 2020 No. 4

Dear Mr. Maldon:

By letter previously acknowledged, your predecessor requested our opinion on the following questions, which we have rephrased slightly:

Does the statutory definition of “practice of pharmacy” in

RCW 18.64.011(28), which includes “the initiating or modifying of drug therapy in accordance with written guidelines or protocols previously established and approved for his or her practice by a practitioner authorized to prescribe drugs[,]” incorporate diagnosis of a patient’s condition?

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Brief Answer: It depends. A pharmacist’s application of the procedures, decision-making criteria, and plans established in their collaborative drug therapy agreements (CDTAs) is statutorily authorized, even if it amounts to diagnosis of a patient’s condition.

May a physician licensed under RCW 18.71 or a physician assistant licensed under RCW 18.71A enter into a CDTA that permits the diagnosis of a patient by a pharmacist licensed under RCW 18.64?[1]

Brief Answer: In limited circumstances, yes. Insofar as “the initiating or modifying of drug therapy” involves some aspect of “diagnosis,” such “diagnosis” is permissible if it is “in accordance with written guidelines or protocols” and complies with other applicable statutes and regulations. For physician assistants, the ability to enter into a CDTA must be considered on a case-by-case basis in light of the individual physician assistant’s delegation agreement approved by the Washington Medical Commission.

If so, is there a statutory or administrative requirement for direct contact between the non-pharmacist practitioner and the patient?

Brief Answer: No.

Does a pharmacist who diagnoses patients pursuant to a CDTA with a physician or a physician assistant commit an act of unlicensed practice of medicine under RCW 18.130.190?

Brief Answer: It depends. If pharmacists act within their statutory authority under RCW 18.64.011(28) to “initiat[e] or modify[] . . . drug therapy in accordance with written guidelines or protocols previously established and approved for his or her practice by a practitioner authorized to prescribe drugs[,]” then they are not engaged in the unlicensed practice of medicine.

FACTUAL BACKGROUND

The legislature has defined the practice of pharmacy to include: “Interpreting prescription orders; the compounding, dispensing, labeling, administering, and distributing of drugs and devices; the monitoring of drug therapy and use; [and] the initiating or modifying of drug therapy in accordance with written guidelines or protocols previously established and approved for his or her practice by a practitioner authorized to prescribe drugs . . . .” RCW 18.64.011(28). The “initiating or modifying of drug therapy” has been expressly included in this definition since 1979. Laws of 1979, ch. 90, § 5. At least one purpose of allowing pharmacists to initiate or modify drug therapy is to increase availability of some health care services by eliminating the need for patients

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to see a physician or other health care provider before initiating some drug therapies. See, e.g., H.B. Rep. on Second Substitute H.B. 2681, 64th Leg., Reg. Sess. (Wash. 2016); Letter from Tim Lynch, Chair, Pharmacy Quality Assurance Commission, to Jeff Even, Deputy Solicitor General, State of Washington (July 26, 2018), at 6 (on file with author, 180807Saxe).

In addition to the statute, there is a rule related to pharmacists’ initiating or modifying drug therapy. WAC 246-945-350. That rule dictates the content of “a written guideline or protocol . . . that enables a pharmacist to exercise prescriptive authority.” WAC 246-945-001(11), -350. Originally, the rule required that guidelines or protocols be approved by the Board of Pharmacy. Wash. St. Reg. 80-08-035. In 1981, the Board of Pharmacy adopted the rule substantially in its current form. Wash. St. Reg. 81-19-086. In 1991, the rule was recodified as WAC 246-863-100, but it was not substantively amended. Wash. St. Reg. 91-18-057. On July 1, 2020, the Pharmacy Quality Assurance Commission adopted WAC 246-945-350 to supersede WAC 246-863-100. Wash. St. Reg. 20-12-072.[2] With minor exceptions, the new rule is substantively identical to WAC 246-863-100.

Under the current version of the rule, a CDTA must include:

(a) A statement identifying the practitioner authorized to prescribe and the name of each pharmacist who is party to the agreement;

. . . .

(b) A statement of the type of prescriptive authority decisions which the pharmacist is authorized to make, which includes:

(i) A statement of the types of diseases, drugs, or drug categories involved, and the type of prescriptive authority activity (e.g., modification or initiation of drug therapy) authorized in each case.

(ii) A general statement of the training required, procedures, decision criteria, or plan the pharmacist is to follow when making therapeutic decisions, particularly when modification or initiation of drug therapy is involved.

(c) A statement of the activities the pharmacist is to follow in the course of exercising prescriptive authority, including:

(i) Documentation of decisions made; and

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(ii) A plan for communication or feedback to the authorizing practitioner concerning specific decisions made.

WAC 246-945-350(2). In addition, the rule requires that the practitioner “be in active practice” and that “[t]he authority granted must be within the scope of the practitioners’ current practice.” WAC 246-945-350(2)(a)(i), (ii). CDTAs are “only valid for two years from the date of signing.” WAC 246-945-350(3). Any modification is treated as a new CDTA. WAC 246-945-350(4).

In practice, many pharmacists initiate and modify drug therapy, including exercising prescriptive authority, under CDTAs with practicing physicians or other authorized prescribers, including physician assistants. As of 2018, there were more than 33,000 CDTAs on file with the Pharmacy Quality Assurance Commission in Washington. Commenters have explained that in Washington CDTAs are used to authorize pharmacists to provide, among other things, vaccinations, certain birth control, access to naloxone for emergency treatment of opioid overdose, and antibiotics for urinary tract infections. The requester has also explained that certain pharmacy chains have agreements that allow pharmacists to provide drug therapies to treat insect stings in order to reduce patient need for urgent care and emergency room visits. Letter from Warren Howe, Chair, Washington Medical Commission, to Bob Ferguson, Attorney General, State of Washington (June 6, 2018), at 3-5 (on file with the author).

In sum, pharmacists in Washington routinely initiate and manage drug therapy under CDTAs. These agreements must provide procedures, decision-making criteria, or a plan that pharmacists must follow. The sample agreements we have reviewed restrict pharmacist discretion through detailed flow charts and patient assessment guides.

ANALYSIS

You ask whether a pharmacist may diagnose a patient’s condition pursuant to a CDTA and whether a physician or physician assistant may enter into a CDTA that permits a pharmacist to diagnose a patient’s condition. The answer to both questions is a qualified yes. Under RCW 18.64.011(28), the legislature has granted pharmacists specific authority to “initiat[e] or modify[] . . . drug therapy in accordance with written guidelines or protocols previously established and approved for his or her practice by a practitioner authorized to prescribe drugs . . . .” RCW 18.64.011(28). This also creates implicit authority for practitioners, including physicians and physician assistants, to create such written guidelines and protocols. This authority is limited, however. The practitioner must be “authorized to prescribe drugs,” RCW 18.64.011, and in “active practice,” WAC 246-945-350(2)(a)(i). In entering into a CDTA and creating written guidelines and protocols, practitioners must act within the scope of their current practice, exercise an appropriate degree of competence, and act within the accepted standard of care. See, e.g., RCW 7.70.040; RCW 18.130.180(4); WAC 246-945-350(2)(a)(ii). Additionally, a CDTA must include “procedures, decision criteria, or plan[s]” for pharmacists “to follow when making therapeutic decisions[.]” WAC 246-945-350(2)(b)(ii).

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A pharmacist may engage in some degree of diagnosis pursuant to the guidelines and protocols of a CDTA. We recognize that diagnosis is part of the practice of medicine and that, in general, no person may practice medicine without a valid license to do so. RCW 18.71.011, .021; see also State v. Wilson, 11 Wn. App. 916, 917-18, 528 P.2d 279 (1974). There is, however, an exception for practitioners of other “healing arts,” including pharmacists licensed under RCW 18.64, to engage in the practice of their professions. RCW 18.71.030(4); see also RCW 70.124.020(3) (defining “practitioner of the healing arts” to include a person licensed to practice pharmacy). The inquiry, then, is whether the definition of the practice of pharmacy in RCW 18.64.011(28) permits diagnosis pursuant to a CDTA.

For purposes of the definition of the practice of medicine, “to diagnose” means “to determine,” State v. Pac. Health Ctr., Inc., 135 Wn. App. 149, 166, 143 P.3d 618 (2006), and “to identify (as a disease or condition) by symptoms or distinguishing characteristics,” Yow v. Dep’t of Health Unlicensed Practice Program, 147 Wn. App. 807, 819, 199 P.3d 417 (2008) (quoting Webster’s Third New International Dictionary 622 (1993)).

Determining or identifying a condition in limited circumstances seems to fit within the authority the legislature granted via CDTAs in RCW 18.64.011(28). That provision gives pharmacists authority to “initiat[e] or modify[] . . . drug therapy in accordance with written guidelines or protocols previously established and approved for his or her practice by a practitioner authorized to prescribe drugs.” RCW 18.64.011(28). The word “initiate” means, as relevant here, “to begin or set going : make a beginning of : perform or facilitate the first actions, steps, or stages of . . . .” Webster’s Third New International Dictionary 1164 (2002). In the limited circumstances where a CDTA authorizes a pharmacist to identify a disease or condition, doing so would of course be a necessary predicate to initiating drug therapy. For example, one CDTA allows pharmacists to initiate drug therapy to treat insect stings. Request Letter, Ex. C. The written guidelines include criteria for diagnosing an insect sting that is appropriate for pharmacist-initiated drug therapy and conditions that require further evaluation by another healthcare provider. Request Letter, Ex. C.

The requirement that the written guidelines or protocols must be created by individuals licensed to engage in diagnosis of conditions supports the conclusion that the guidelines or protocols may themselves involve some degree of diagnosis. This opinion does not address whether—and should not be read to suggest that—pharmacists may engage in diagnosis outside the context of a CDTA.

The corresponding regulation, which has existed substantially in its current form since 1981, clarifies the authority of pharmacists. This longstanding regulation interprets RCW 18.64.011(28) to provide pharmacists with “prescriptive authority,” which includes the ability to “mak[e] therapeutic decisions” by applying “procedures, decision criteria, or plan[s]” set forth in the CDTA. WAC 246-945-350. The language was first adopted just two years after the legislature adopted what is now RCW 18.64.011(28). This contemporaneous interpretation of the statute is entitled to great weight, especially since the legislature has silently acquiesced by amending RCW 18.64.011 eleven times since 1982 without disturbing that interpretation. See First Student, Inc. v. Dep’t of Revenue, 194 Wn.2d 707, 718-19, 451 P.3d 1094 (2019).

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In sum, pharmacists have authority to apply the protocols, guidelines, procedures, decision-making criteria, or plans established in a valid CDTA to assess and evaluate patients as dictated in the agreement, and pharmacists may initiate or modify drug therapy according to the criteria in the agreement. Even if the initiation or modification of drug therapy undertaken in compliance with RCW 18.64.011(28) and WAC 246-945-350 constitutes “diagnosis” to some limited degree, such action is authorized if authorized in the CDTA. Because such activity is expressly authorized in RCW 18.64.011(28), it is within the scope of a pharmacist’s license and is not the unauthorized practice of medicine. See RCW 18.71.030(4).

You have also asked whether a physician licensed under RCW 18.71 or a physician assistant licensed under RCW 18.71A may enter into a CDTA that permits a pharmacist licensed under RCW 18.64 to diagnose a patient. For the reasons set forth above, we conclude that, in some circumstances, this is permissible.

There are, however, important limitations on the ability of physicians and physician assistants to enter into CDTAs. The practitioner must be “authorized to prescribe drugs,” RCW 18.64.011(28), the practitioner “must be in active practice,” WAC 246-945-350(2)(a)(i), and “[t]he authority granted must be within the scope of the practitioner[’s] current practice,” WAC 246-945-350(2)(a)(ii). Importantly, the practitioner must provide written guidelines or protocols that contain the “procedures, decision criteria, or plan the pharmacist is to follow when making therapeutic decisions[.]” WAC 246-945-350(2)(b)(ii); see also RCW 18.64.011(28). If the physician or physician assistant’s written guidelines or protocols are insufficient to allow a pharmacist licensed under RCW 18.64 to make an accurate diagnosis, then the physician or physician assistant may be engaging in unprofessional conduct and/or malpractice. See RCW 7.70.040; RCW 18.130.180(4).

The limitations on the ability to enter into CDTAs raise unique questions in the context of physician assistants. Physician assistants may practice medicine only pursuant to a delegation agreement and “only to the extent permitted by the” Washington Medical Commission. RCW 18.71A.030(1).[3] A physician assistant is not necessarily authorized to prescribe drugs. See WAC 246-918-035. Additionally, a physician assistant’s scope of practice is necessarily limited by a delegation agreement. RCW 18.71A.030; see also WAC 246-918-055. While physician assistants may, in appropriate circumstances, enter into CDTAs with pharmacists, a physician assistant’s authority will have to be determined on a case-by-case basis.

You have asked whether there is a statutory or administrative requirement for direct contact between the non-pharmacist practitioner and the patient before drug therapy can be initiated or modified under a CDTA. We are not aware of a statutory or regulatory provision that requires physician or other provider contact in every case before drug therapy can begin under an agreement. While a practitioner may include a requirement for such contact in the written

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guidelines or protocols, neither RCW 18.64.011(28) nor WAC 246-945-350 require it. There may, however, be instances where the failure of the written guidelines or protocols to require direct contact would amount to unprofessional conduct and/or malpractice. See RCW 7.70.040; RCW 18.130.180(4).

The legislature has provided authority for pharmacists and other practitioners to enter into CDTAs under which pharmacists may “initiat[e] and modify[]” drug therapy pursuant to “written guidelines and protocols” established by practitioners. RCW 18.64.011(28). The Washington Medical Commission and the Pharmacy Quality Assurance Commission retain important roles in regulating the adequacy of their respective members’ performance of their functions under CDTAs. Additionally, the legislature may revisit, at any time, the statutory authority permitting CDTAs, and this is certainly an area that would benefit from greater statutory clarity.

We trust that the foregoing will be useful to you.

ROBERT W. FERGUSON

Attorney General

s/ Karl D. Smith

KARL D. SMITH

Deputy Solicitor General

360-664-2510

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[1] The request framed this as the physician or physician assistant’s authority to “delegate the diagnosis of a patient to a pharmacist[.]” The concept of “delegation” may be imprecise in this context. The fundamental inquiry is whether the legislature has authorized CDTAs under which a pharmacist engages in some measure of “diagnosis.” We have re-framed the question to reflect this.

[2] The Pharmacy Quality Assurance Commission intends to repeal WAC 246-863-100. Wash. St. Reg. 20-12-072.

[3] Effective July 1, 2021, the term “delegation agreement” will be replaced by the term “practice agreement.” Laws of 2020, ch. 80, §§ 5, 61.