Licensed California pharmacist. On site, not on a call.
Who this is for
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The surveyor asked who is responsible for pharmaceutical services and how often that person is on site.
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Your last consultant pharmacist report is a checklist someone emailed, not a signed visit.
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The quarterly certification is due and the person who used to sign it is gone.
Medicare requires every certified ASC to have a designated individual responsible for pharmaceutical services (42 CFR 416.48), whether or not the center holds a Board of Pharmacy clinic license; most California surgery centers do not hold one and do not need to. Centers that do hold a section 4190 license also need the quarterly visit, the written certification, and the self-assessment signature under section 4192.
Not for centers that want a pharmacist to sign a report without visiting. We do not sign what we have not seen.
Pharmacist-led. On site, not on a call.
Every visit is on site, walking the drug's path from receiving to waste, not a checklist emailed to the nurse manager.
The report lands the same week, scored, with an owner and a due date on every finding, and the next visit starts by checking the last report.
Surveyors are told to ask how often the responsible individual is on site and what documentation shows active oversight. Our visit log and signed reports are that documentation.
We hold the license side too when a center needs it: 4190 applications, changes of ownership, DEA registration, and the policies the statute requires.
300+ California sites a year and 10,000+ audit visits since 2018, across health systems, surgery centers, clinics, and pharmacies.
What a quarter looks like
1. Baseline visit. We walk the medication path, interview staff the way a surveyor will, and score what we find.
2. Policies rewritten to match the room. Storage, security, labeling, controlled substances, waste, emergency drugs, and training, approved with your medical director and administrator.
3. Quarterly on-site review with a signed report the same week, findings tracked to closure.
4. For Board-licensed centers, the written quarterly certification section 4192 requires and the Surgical Clinic Self-Assessment, co-signed before July 1 of every odd-numbered year.
5. Survey readiness. Mock interviews for your circulator, pre-op nurse, and anesthesia provider before the surveyor asks them first.
One agreement. Four visits a year. A report after every one.
A standing consultant pharmacist relationship: the on-site visit, the written report, the documentation file a surveyor asks for, and the questions that come up between visits. If your center also needs the 4190 license or a change of ownership filed, that is a defined project on its own, with every round of Board correspondence answered until final action. Scope is set on the discovery call.
Questions we hear first
Do we need a consultant pharmacist if we are not licensed with the Board? Medicare requires a designated individual responsible for pharmaceutical services, and its surveyor guidance says the center should ideally have a pharmacist providing oversight or consultation (42 CFR 416.48; State Operations Manual, Appendix L). A consultant relationship is how a center without an in-house pharmacist meets that. Thirty minutes on the phone settles what applies to you.
Can you take over mid-year from another consultant? Yes. We start with a baseline visit and your last report, and the documentation continues without a gap.
What does the report say? What we found, scored, with corrective actions, an owner, and a due date. For Board-licensed centers it doubles as the written quarterly certification, and we do not sign what we have not seen.
Do you handle the 4190 license itself? Yes, for the centers that need it: applications, changes of ownership, and DEA registration.
Talk to a pharmacist consultant this week.
Who signed your last consultant pharmacist report, and when were they last in the building?
If the surveyor asked for the visit log today, what would it show?
Centers do not lose a survey on the medication process. They lose it on the paper that was supposed to prove someone looked.
Bring your last survey report. Thirty minutes, free, and you leave knowing what we would look at first.
Free. No proposal unless you ask for one. You get a written summary of what we saw by the next business day. A person confirms your booking the same business day.