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Washington Department of Health Boyer Letter Re Controlled Substance Medications 2010

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Olympia, Washington 98504
May 13, 2010

All Pharmacies
All licensed Residential Treatment Facilities

Controlled Substance Medications

I am writing to address concerns regarding federal requirements for management, use and control
of controlled substances in residential treatment facilities.
Current state and federal regulations require that pharmacies providing pharmaceutical services
to residential treatment facilities provide only patient specific medications. The only exception
is a pharmacy may utilize an automated drug distribution device (for example Pyxis) in the
facility with staff credentialed to administer medications. A pharmacy is responsible to obtain a
Board of Pharmacy approval (WAC 246-872) for all automated drug distribution devices.
Additionally a pharmacy then must obtain a DEA registration for that specific machine in that
facility location when controlled substances are involved.
The Board of Pharmacy recommends residential treatment facilities pursue methods for
providing patient specific medications.
1. Use of a 24 hour retail or long term care pharmacy
2. Use of a 24 hour hospital pharmacy
For all other controlled substances, an automated drug distribution device approved by the board
and DEA is the only method.
These methods need to be in place by December 31, 2010. After December 31, department
inspectors will require plans of corrections for facilities failing to meet this requirement. Please
contact Tim Fuller, board pharmacist consultant, for the approval process for automated drug
distribution devices. Tim can be reached at

Susan Teil Boyer, RPh, Executive Director
Washington State Board of Pharmacy, and Clinical Facilities
Office of Health Professions

Grant Chester, Chief Investigator
Ruth Carter, DEA Regional Supervisor
Barbara Runyon, RN, Nurse Consultant
Tim Fuller, Pharmacist Consultant