ATTORNEY GENERAL'S OFFICE

[Filed June 15, 2018, 9:32 a.m.]

NOTICE OF REQUEST FOR ATTORNEY GENERAL'S OPINION

WASHINGTON ATTORNEY GENERAL

The Washington attorney general routinely publishes notice of an opportunity to comment for opinion requests that we receive from the heads of state agencies, state legislators, and county prosecuting attorneys if we anticipate publishing a formal opinion in response to the request. We do so in order to provide members of the public with a chance to provide any legal analysis that they would like us to consider as we develop our opinion. In preparing any comments, please be aware that our opinion will provide our considered legal analysis of the question presented, and therefore comments that address the interpretation of the law are more helpful than comments that express an opinion as to what the law should be.

If you are interested in commenting on a request listed in this volume of the register, you should notify the attorney general's office of your interest by July 13, 2018. This is not the due date by which comments must be received, and we will consider any comments we receive before we complete our opinion. However, if you do not notify the attorney general's office of your interest in commenting on an opinion request by this date, the opinion may be issued before your comments have been received. You may notify the attorney general's office of your intention to comment by email to OpinionComments@atg.wa.gov or by writing to the Office of the Attorney General, Solicitor General Division, Attention Jeff Even, Deputy Solicitor General, P.O. Box 40100, Olympia, WA 98504-0100. When you notify the office of your intention to comment, you may be provided with a copy of the opinion request in which you are interested, information about the attorney general's opinion process, information on how to submit your comments, and a due date by which your comments must be received to ensure that they are fully considered.

If you are interested in receiving notice of new formal opinion requests via email, you may visit the attorney general's web site at http://www.atg.wa.gov/ago%E2%80%90opinions for more information on how to join our AGO opinions list.

The attorney general's office seeks public input on the following opinion request(s):

Opinion Docket No. 18-06-03

Request by Dr. Warren Howe, Chair

Washington Medical Commission

The request poses the following questions in the context of cooperative arrangements between a physicians or physician assistants and pharmacists:


1.	Does the phrase "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" include the act of diagnosing a patient's condition?
2.	If the answer to tt I above is yes, is there a statutory or administrative requirement for direct contact between the non-pharmacist practitioner and the patient?
3	May a physician licensed under RCW 18.71 delegate the diagnosis of a patient to a pharmacist licensed under RCW 18.64?
4.	Does a pharmacist who diagnoses patients pursuant to a CDTA with a physician commit an act of unlicensed practice of medicine under RCW 18.130.190?
5.	May a physician assistant licensed under RCW I8.71A delegate the diagnosis of a patient to a pharmacist licensed under RCW 18.64?
6.	Does a pharmacist who diagnoses patients pursuant to a CDTA. with a physician assistant commit an act of unlicensed practice as a physician assistant under RCW 18.130.190?

Reviser's note: The typographical errors in the above material occurred in the copy filed by the Attorney General's Office and appear in the Register pursuant to the requirements of RCW 34.08.040.