Inspector’s Corner: Is Your Dispensing
Software Up to Speed?
If you are planning to open a new pharmacy, or thinking
of buying a new computer system for your prescription department,
be certain that it meets all legal requirements and
is adaptable to changes in those requirements (for example,
Drug Enforcement Administration (DEA) requirements for
electronic prescribing of CS). As inspectors look at new pharmacies
and perform regular inspections, the software system
in place touches on many areas they are looking at, including
proper dispensing records. Of course, the dispensing software
plays a vital part in today’s practice to ensure that prescriptions
are lawful, and to prevent errors, create proper labels
and inserts, and other such things. Many pharmacies, from
the single independent to the major pharmacy corporations,
purchase or create systems that may not always be current
on changes in law or adaptable to new laws, rules, or other
legal requirements.
Software is generally not written by pharmacists, and even
if it is, it may not keep required data in legally acceptable
or adaptable form. If there is an error, it is doubtful that a
claims auditor or investigator will be very sympathetic to an
excuse that the computer did not work right when deciding to
refuse a reimbursement or looking at possible administrative
or criminal behavior. In the end, it is the pharmacy and its
pharmacists who are responsible for compliance.
A recent example is the change of scheduling of hydrocodone
combination products (HCPs) to Schedule II CS.
Nearly everyone could handle that. However, once changed
to Schedule II, how did you handle refills as allowed for
previously written prescriptions? What about the fact that
the federal guidance says that up to five refills of the pre-
October 6, 2014 HCP prescriptions could be honored, but
West Virginia law limits HCPs to no more than two refills?
What about the West Virginia limit of these dispensings
to no more than a 30-day supply at one time, versus the
federal law that does not have any limit on the amount a
single prescription can call for? These types of issues merit
a conversation with your programmers or vendors to ensure
that your pharmacy is compliant.
quoted from West Virginia Board of Pharmacy December 2014 Newsletter
Software Up to Speed?
If you are planning to open a new pharmacy, or thinking
of buying a new computer system for your prescription department,
be certain that it meets all legal requirements and
is adaptable to changes in those requirements (for example,
Drug Enforcement Administration (DEA) requirements for
electronic prescribing of CS). As inspectors look at new pharmacies
and perform regular inspections, the software system
in place touches on many areas they are looking at, including
proper dispensing records. Of course, the dispensing software
plays a vital part in today’s practice to ensure that prescriptions
are lawful, and to prevent errors, create proper labels
and inserts, and other such things. Many pharmacies, from
the single independent to the major pharmacy corporations,
purchase or create systems that may not always be current
on changes in law or adaptable to new laws, rules, or other
legal requirements.
Software is generally not written by pharmacists, and even
if it is, it may not keep required data in legally acceptable
or adaptable form. If there is an error, it is doubtful that a
claims auditor or investigator will be very sympathetic to an
excuse that the computer did not work right when deciding to
refuse a reimbursement or looking at possible administrative
or criminal behavior. In the end, it is the pharmacy and its
pharmacists who are responsible for compliance.
A recent example is the change of scheduling of hydrocodone
combination products (HCPs) to Schedule II CS.
Nearly everyone could handle that. However, once changed
to Schedule II, how did you handle refills as allowed for
previously written prescriptions? What about the fact that
the federal guidance says that up to five refills of the pre-
October 6, 2014 HCP prescriptions could be honored, but
West Virginia law limits HCPs to no more than two refills?
What about the West Virginia limit of these dispensings
to no more than a 30-day supply at one time, versus the
federal law that does not have any limit on the amount a
single prescription can call for? These types of issues merit
a conversation with your programmers or vendors to ensure
that your pharmacy is compliant.
quoted from West Virginia Board of Pharmacy December 2014 Newsletter
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