John walk with me step by step through this. I'm determined that you understand this single point if nothing else.
Step 1. Your own link establishes, and you acknowledged, that while an unlicensed non medical staff member may dispense meds, supervision by a person who is licensed and certified in the field of medicine is required.
Step 2. HLA had no such staff member, either on the premises, or contracted through another organization to make routine visits as part of monitoring the situation.
Step 3. Having the phone number of a local pharmacist on hand to ask questions of is hardly the same thing as being supervised. The pharmacist is not going to come to HLA to ensure the receptionist, Assistiant Counselor, or student handing out meds is doing their job correctly. They aren't going to come by once a week and look over any reports taken, pointing out discrepancies, asking questions over why something was done a certain way, or certifing that things are being done properly.
Therefore, we can establish that since we know step one is true, and we know step two is true, it would then stand to reason that HLA was in violation of the law. Do you agree?