Be careful how you define counseling? It doesn't mean you can't answer any questions. It means you can't counsel as defined by The Pennsylvania Code:
[SIZE=+1]§ 27.19. [/SIZE]Prospective drug review and patient counseling.
(1) An offer to counsel shall be made to each patient or caregiver when the pharmacist fills, delivers or sends a new retail or outpatient prescription.
(2) The pharmacist or designee of the pharmacist shall orally make the offer in person if a patient or caregiver comes to the pharmacy. If the pharmacist in the exercise of professional judgment in the interest of a patient believes that an oral offer would be less effective than a written offer, the pharmacist may substitute a written offer. The following are examples of situations in which a pharmacist might substitute a written offer:
(i) The patient or caregiver is hearing impaired.
(ii) The patient or caregiver is not an English speaker.
(3) If neither the patient nor caregiver comes to the pharmacy, the offer to counsel shall be made in one of the following ways:
(i) The pharmacist or designee may telephone the patient or caregiver.
(ii) The pharmacy delivery person may orally make the offer to the patient or caregiver.
(iii) The pharmacist may send a written offer to counsel together with the filled prescription which is delivered or sent to the patient.
(4) A written offer to counsel must include the telephone number of the pharmacy.
(5) A pharmacy shall provide toll-free telephone service if its primary patient population is beyond the local or toll-free exchange.
(6) A mail order pharmacy shall make the offer to counsel either by telephone or by sending a written offer together with the filled prescription. The written offer must include a toll-free telephone number of the pharmacy which a patient or caregiver may use to obtain counselling.
(7) The obligation to make an offer to counsel will be fulfilled by making one offer in accordance with this subsection.
(e) Counselling.
(1) Only a pharmacist may counsel.
(2) If a patient or caregiver who comes to the pharmacy indicates that he wants counseling, the pharmacist shall counsel the patient or caregiver in person, or, at the discretion of the patient or caregiver, by telephone.
(3) If the filled prescription is sent or delivered to the patient or caregiver, counselling shall be by telephone.
(4) The following are examples of matters which a pharmacist in the exercise of professional judgment might deem significant and discuss with the patient or caregiver:
(i) The name and description of the medication.
(ii) The route of administration, dosage form and duration of drug therapy.
(iii) Special directions and precautions for preparation, administration and use by the patient.
(iv) Common severe side effects or interactions and therapeutic contraindications that may be encountered, including their avoidance, and the action required if they occur.
(v) Techniques for self-monitoring drug therapy.
(vi) Proper storage.
(vii) Prescription refill information.
(viii) Action to be taken in the event of a missed dose.
(5) If a pharmacist discovers a specific problem with a medication during the course of a PDR, the pharmacist shall intervene to attempt to resolve the problem.
