Virginia Board of Pharmacy Frequently Cited Deficiencies

Frequently Cited Deficiencies

The deficiencies referenced below may be reviewed in

Guidance Document 110-9, found at www.dhp.virginia

.gov/pharmacy/pharmacy_guidelines.htm.

Perpetual inventory (Major Deficiency 15) continues

to be the most frequently cited major inspection

deficiency. Board Regulation 18VAC110-20-240 states

that each pharmacy shall maintain a perpetual inventory

of all Schedule II drugs received and dispensed, with

reconciliation at least monthly. This includes slow moving

and expired drugs. During the inspection, you will

be asked to provide the inspector with documentation

of compliance for 10 different drugs over a six-month

period. The perpetual inventory record must accurately

indicate the physical count of each Schedule II drug

“on-hand” at the time of performing the inventory. To

comply with the requirement to perform the required

“reconciliation” of the perpetual inventory, an explanation

for any difference between the physical count and

the theoretical count must be noted (refer to Guidance

Document 110-16).

The second-most frequently cited minor deficiency

(Minor Deficiency 13) is when a required inventory is

taken on time but does not include the required components,

such as not being signed and dated by the person

taking the inventory; failing to indicate whether the

inventory was taken prior to the opening of business or

after close of business; and not listing drugs in Schedule

II separately from drugs in Schedules III, IV, and

V. Additionally, it is cited when pharmacies are open

24/7 and fail to clearly document whether the receipt

or distribution of drugs on the inventory date occurred

before or after the inventory was taken.

Guidance Documents

Board Guidance Documents are available at www.dhp

.virginia.gov/Pharmacy/pharmacy_guidelines.htm. The

following Guidance Documents have been added or

amended since December 2013:

♦♦110-9: Pharmacy Inspection Deficiency Monetary

Penalty Guide

♦♦110-17: Instructions for Graduates of Foreign

Schools of Pharmacy

♦♦110-23: Practitioner of the Healing Arts Selling

Controlled Substances Inspection Deficiency Monetary

Penalty Guide

♦♦110-22: Use of Dispensing Records to Identify

Pharmacist Responsible for Dispensing Error

♦♦110-27: Pharmacist-in-charge Responsibilities

♦♦110-36: Compliance with USP Standards for Compounding

♦♦110-38: Requirement for Non-resident Pharmacies

 

 

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