After meeting on November 15 to discuss comments related to the economic impact of a new rule requiring mandatory oral counseling for all new prescriptions, including those dispensed via mail order, the Wisconsin Pharmacy Examining Board ("Board") ultimately declined to make any changes to its proposed oral counseling requirement. Therefore, the language requiring mandatory oral counseling will be subject to public comment at the next Board meeting on December 17.
In reaching this conclusion, the Board disregarded evidence from mail order pharmacies that detailed the economic impact on mail order operations based on an assumption that the proposed rule is no different than current practices. Essentially, the Board argues that, because some mail order pharmacies already provide oral counseling when it is "in the best interest of the patient," the proposed rule would not impose any additional compliance costs.