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Landing Gear Is Down And Locked!

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  1. Landing Gear Is Down And Locked!

  2. PHARMACY LAW UPDATE 2014 Hollywood Casino September 6, 2014 Gregory Cameron, R.Ph Assistant Professor of Pharmacy Practice Husson University Field Coordinator, Community Sites

  3. OBJECTIVES • Changes in DEA status of Tramadol & Vicodin • Updates on “Drug Take back” regulations • PIC responsibilities • New Maine Pharmacy Law Updates Pharmacy Law Update 2014- G. Cameron

  4. Electronic Prescriptions for Controlled Substances Notice of Approved Certification Process • Before any electronic prescription or pharmacy application may be used to transmit prescriptions: • a third party must audit the application for compliance with the requirements of 21 CFR part 1311, or • a certifying organization whose certification process has been approved by DEA must verify and certify that the application meets the requirements Pharmacy Law Update 2014- G. Cameron

  5. Electronic Prescriptions for Controlled Substances Notice of Approved Certification Process (Cont.) • A Notice by the Drug Enforcement Administration on 8/20/2014 • The Drug Enforcement Administration (DEA) is announcing one new DEA-approved certification process for providers of Electronic Prescriptions for Controlled Substances (EPCS) applications • Certifying organizations with a certification process approved pursuant to 21 CFR 1311.300(e) are posted on DEA's Web site upon approval. Pharmacy Law Update 2014- G. Cameron

  6. Electronic Prescriptions for Controlled Substances Notice of Approved Certification Process (Cont.) On July 25, 2014, DEA approved the certification process developed by Comply Smart, LLC. Relevant information has been posted on DEA's Web site: http://www.deadiversion.usdoj.gov/ecomm/e_rx/thirdparty.htm • The following list provides the names of certifying organizations whose certification processes have been approved by DEA. Pharmacy Law Update 2014- G. Cameron

  7. Electronic Prescriptions for Controlled Substances Notice of Approved Certification Process (Cont.) InfoGard Laboratories, Inc. (October 19, 2011) Drummond Group Inc. (August 1, 2012) iBetaLLC (August 1, 2012) Global Sage Group, LLC (March 26, 2013) ComplySmart, LLC (August 20, 2014) The list of certifying organizations for EPCS does not constitute an endorsement by the DEA of these companies or their products or services. Pharmacy Law Update 2014- G. Cameron

  8. National Prescription Drug Take Back Day September 27, 2014 Pharmacy Law Update 2014- G. Cameron

  9. May 8, 2014 - DEA’S National Prescription Drug Take-Back Days Meet a Growing Need for Americans by dropping off more prescription pills than ever on April 26, 2014 • 780,158pounds (390 tons) of pills were brought in • 6,072collection sites that DEA and its 4,423 state, local, and tribal law enforcement partners set up • When added to that collected at previous DEA-coordinated Take-Back events • 4.1 million pounds (2,123 tons) of prescription medications have been removed from circulation.  Pharmacy Law Update 2014- G. Cameron

  10. Tramadol • Moved to a CIV on August 18, 2014 • Every DEA Registrant who possesses any quantity of Tramadol must take an inventory • Any person who becomes registered after 8/18/14 must take an initial inventory of all stocks of controlled medication, including Tramadol • Included in Biennial Inventory • Records must be maintained • All prescriptions must comply with 21 U.S.C. 829 and 21 CFR part 1306 & part 1311 Pharmacy Law Update 2014- G. Cameron

  11. RESCHEDULING OF HCPs • DEA to Publish Final Rule Rescheduling Hydrocodone Combination Products • AUG 21, 2014 (WASHINGTON)–On Friday (08/22/2014) the U. S. DEA will publish in the Federal Register the Final Rule moving hydrocodone combination products (HCPs) from Schedule III to the more-restrictive Schedule II • This Final Rule imposes the regulatory controls and sanctions applicable to Schedule II substances on those who handle or propose to handle HCPs Pharmacy Law Update 2014- G. Cameron

  12. RESCHEDULING OF HCPs (cont.) • It goes into effect in 45 days • October 6, 2014 Pharmacy Law Update 2014- G. Cameron

  13. HOW DID HCP GET TO CII STATUS • The rescheduling of HCPs was initiated by a petition from a physician in 1999 • The DEA submitted a request to HHS for a scientific and medical evaluation of HCPs and a scheduling recommendation • In 2013, the U. S. FDA held a public Advisory Committee meeting on the matter, and the committee voted to recommend rescheduling HCPs from Schedule III to Schedule II by a vote of 19 to 10 Pharmacy Law Update 2014- G. Cameron

  14. HOW DID HCP GET TO CII STATUS (Cont.) • Consistent with the outcome of that vote, in December of 2013 HHS sent such a recommendation to the DEA • Two months later, on February 27, the DEA informed Americans of its intent to move HCPs from Schedule III to Schedule II by publishing a Notice of Proposed Rulemaking • Public comments on the proposal, of which almost 600 were received • Small majority of the commenters supported the proposed change. Pharmacy Law Update 2014- G. Cameron

  15. Orders for HCPs. Every DEA registrant who distributes HCPs must comply with order form requirements, pursuant to 21 U.S.C. 821, 828, 871 and in accordance with 21 CFR parts 1305 and 1307 as of October 6, 2014 • In other words DEA Form 222 • Prescriptions. All prescriptions for HCPs must comply with all the CII requirements as of October 6, 2014 • No prescription for HCPs issued on or after October 6, 2014 shall authorize any refills • Any prescriptions for HCPs that are issued before October 6, 2014, and authorized for refilling, may be dispensed in accordance with 21 CFR 1306.22-1306.23, 1306.25, and 1306.27, if such dispensing occurs before April 8, 2015 HOW DID HCP GET TO CII STATUS (Cont.) • Orders for HCPs. Every DEA registrant who distributes HCPs must comply with order form requirements, pursuant to 21 U.S.C. 821, 828, 871 and in accordance with 21 CFR parts 1305 and 1307 as of October 6, 2014 • In other words DEA Form 222 • Prescriptions. All prescriptions for HCPs must comply with all the CII requirements as of October 6, 2014 • No prescription for HCPs issued on or after October 6, 2014 shall authorize any refills • Any prescriptions for HCPs that are issued before October 6, 2014, and authorized for refilling, may be dispensed in accordance with 21 CFR 1306.22-1306.23, 1306.25, and 1306.27, if such dispensing occurs before April 8, 2015 Pharmacy Law Update 2014- G. Cameron

  16. Theft or Drug-Related Misconduct of Pharmacy Intern • The preceptor shall notify the board via letter, fax or email of any resignation or discharge from an internship program or termination of employment for any of the following reasons, provided that the report shall be made by a pharmacist in charge or supervising pharmacist if the reason for the resignation, discharge or termination arose outside of the IPPE/APPE • Notice shall be provided within 48 hours after the termination: • Any drug-related reason, including but not limited to • adulteration, abuse, theft or diversion; • Theft of non-drug merchandise; or • Theft of cash or credit/debit card data. Pharmacy Law Update 2014- G. Cameron

  17. Pharmacist in Charge • Responsibilities • The pharmacist in charge is responsible legally and professionally for all activities related to the practice of pharmacy within the retail pharmacy for which the licensee is registered as pharmacist in charge • For the pharmacy’s compliance with the provisions of the Maine Pharmacy Act, the rules of the board, and the federal laws and rules Pharmacy Law Update 2014- G. Cameron

  18. Orders for HCPs. Every DEA registrant who distributes HCPs must comply with order form requirements, pursuant to 21 U.S.C. 821, 828, 871 and in accordance with 21 CFR parts 1305 and 1307 as of October 6, 2014 • In other words DEA Form 222 • Prescriptions. All prescriptions for HCPs must comply with all the CII requirements as of October 6, 2014 • No prescription for HCPs issued on or after October 6, 2014 shall authorize any refills • Any prescriptions for HCPs that are issued before October 6, 2014, and authorized for refilling, may be dispensed in accordance with 21 CFR 1306.22-1306.23, 1306.25, and 1306.27, if such dispensing occurs before April 8, 2015 • The responsibilities of the pharmacist in charge include, but are not limited to: • The pharmacy’s procedures for the procurement, storage, compounding and dispensing of drugs; • The recordkeeping systems required in the practice of pharmacy for the purchase, sale, possession, storage and repackaging of drugs; • The security of the prescription filling area and its contents; Pharmacy Law Update 2014- G. Cameron

  19. The responsibilities of the pharmacist in charge include, but are not limited to: (Cont.) • Ensuring that the prescription filling area is operated in conformance with good pharmaceutical practices; • Notifying the board of termination of status as pharmacist in charge via letter, fax or email within 7 days of the termination; • The supervision of pharmacy technicians and performance of administrative responsibilities • Ensuring that each pharmacist employed at the pharmacy for which the pharmacist in charge is responsible is licensed with the board. Pharmacy Law Update 2014- G. Cameron

  20. Maine Board of Pharmacy Actions • Pharmacist had a Misfillof a prescription (Error) • Letter of Warning & $250 Fine • Technician- Passing a worthless instrument • Letter of Warning & $250 Fine • Pharmacist - Substance Abuse • License on Probation • Substance Abuse Monitoring Program • Pharmacist - Answered YES on renewal of license for conviction OUI • Denied renewal • Offered consent agreement Pharmacy Law Update 2014- G. Cameron

  21. Maine Board of Pharmacy Actions (Cont.) • Pharmacist - Unprofessional Conduct • Missing Medications • 36,487 hydrocodone/APAP • Probation for a year • $1,500 Fine Pharmacy Law Update 2014- G. Cameron

  22. Pharmacy Technician Notice of Change of Work Site or Contact Address A pharmacy technician shall notify the board of a change in work site, cessation of employment as a pharmacy technician or a change of contact address via letter, fax or email within 10 days after the change. Pharmacy Law Update 2014- G. Cameron

  23. Pharmacy Technician Duties • No person other than a pharmacist or pharmacy intern may perform any of the following duties unless a valid pharmacy technician license is held: • Acceptance of an original or renewal prescription drug order; • Receipt of a transferred prescription for a noncontrolleddrug • Prescription data entry; • Prescription drug selection from inventory; or • Counting, packaging and labeling of prescription drugs for delivery • The assignment of any of the above duties to a pharmacy technician lies within the discretion of the pharmacist on duty. Pharmacy Law Update 2014- G. Cameron

  24. Notice of Employment and Non-Employment of Pharmacy Technicians • The pharmacist in charge shall notify the board via letter, fax, email or on line within 10 days after the commencement or cessation of employment of any pharmacy technician at a pharmacy for which the pharmacist in charge is responsible • Notice of Termination of Employment For Drug-Related Reasons or Theft • The pharmacist in charge or a designee of the pharmacist in charge shall notify the board of the termination of employment of a pharmacy technician for any of the following reasons and shall include in the notice the reason for the termination. Notice shall be provided within 7 days after the termination: • adulteration, abuse, theft or diversion; • Theft of non-drug merchandise; or • Theft of cash or credit/debit card data. Pharmacy Law Update 2014- G. Cameron

  25. Security Cameras • A retail pharmacy shall deploy security cameras sufficient in number to monitor the critical areas of the pharmacy department, including, at a minimum • prescription filling area • self-service customer kiosks • dispensing machines that are part of an automated pharmacy system • controlled drug storage areas • checkout area • compounding area (if applicable) • Shall operate continuously 24 hours per day • Requirement of security camera coverage of the compounding area (if applicable) and controlled drug storage areas goes into effect on July 1, 2014. Pharmacy Law Update 2014- G. Cameron

  26. Reporting of Theft, Loss and Unresolved Inventory Discrepancies of Controlled Drugs • A pharmacist shall report any significant theft, loss or unresolved inventory discrepancy of C/S no later than 7 days after discovery • When determining if a theft, loss or unresolved inventory discrepancy is “significant,” a pharmacist should consider, among others, the following factors: Pharmacy Law Update 2014- G. Cameron

  27. When determining if a theft, loss or unresolved inventory discrepancy is “significant,” a pharmacist should consider, among others, the following factors: • The actual quantity of controlled substances lost in relation to the type of business • The specific controlled substances lost • Whether the loss of C/S can be associated with access by specific individuals • A pattern of losses over a specific time period • Are these C/S likely candidates for diversion • Local trends Pharmacy Law Update 2014- G. Cameron

  28. For Administration of Influenza Vaccines • Pharmacist who holds a certificate of administration shall verify as necessary that the patient is 9 years of age or older • For administration of all other vaccines pursuant to a prescription, the pharmacist shall verify • That the patient is the person to whom the prescription was issued • That the patient is 18 years of age or older. Pharmacy Law Update 2014- G. Cameron

  29. Administration of Drugs and Vaccines by Pharmacy Intern A pharmacy intern who is under the direct supervision of a pharmacist holding a certificate of administration and has obtained the drug administration training required by 32 MRSA §13832(3) may administer drugs and vaccines to a person 18 years of age or older. Pharmacy Law Update 2014- G. Cameron