Wednesday, June 4, 2014

Montana Board of Pharmacy Reminds PIC of Duties

Compliance Corner: ‘Pharmacist-In-Charge’ Reminders
 
 
 

Montana Administrative Rule 24.174.301(28) states in definition,

“‘Pharmacist-in-charge’ [PIC] means a pharmacist licensed in Montana who

accepts the responsibility for the operation of a pharmacy in conformance

with all laws and rules [state and federal] pertinent to the practice of pharmacy,

who assures that the pharmacy and all pharmacy personnel working

in the pharmacy have current and appropriate licensure and certification,

and who is personally in full and actual charge of such pharmacy. . .” In

other words, as the PIC of a facility, you become responsible for all actions

and activities in your facility.

Maybe you are the owner PIC or you have been asked to be the nonowner

PIC. What does this mean to the Board, to Bob and Bill as inspectors

for the Board, and more importantly, to you, the PIC? By now, most of

you have been inspected multiple times in your facility and hopefully you

are on the same page as the Board and its inspectors. However, the Board

continues to see certain issues that you are responsible for that have somehow

been missed in some locations. With this in mind, the Board felt that

it was time for a PIC reminder related to what the Board will continue to

review and look for on each site visit/inspection. Some things to consider:

♦ Is your facility license, all of its endorsements, and its Drug Enforcement



Administration (DEA) license current and posted?

Is the license and certification of each employee current and posted



in your facility (this includes pharmacists, interns, technicians, and

technicians-in-training)?

Does each technician you employ have his or her certificate for being



a certified pharmacy technician and his or her CE file up-to-date

and on site?

♦ Is the DEA initial controlled substance inventory or biennial inventory



current and on site?

♦ Is the technician utilization plan (if you use technicians) up-to-date,



on site, and accessible?

♦ Are your policies and procedures for the facility and its employees



current and in line with the practice standards of pharmacy?

♦ Are your collaborative practice agreements current, signed, and on



site?

♦ Are all of your record keeping requirements current and available for



inspection (prescriptions, profiles, invoices, inventories, etc)?

♦ Are you and your facility Health Insurance Portability and Accountability



Act-compliant?

♦ Is your drug inventory properly stored and secured?

Is access to the facility properly defined?

♦ Is patient consultation taking place in an appropriate area in the



facility?

♦ Are you using any ancillary personnel to aid your facility and are they



properly identified?

♦ Do you have Internet access to use the Board’s web page (www.pharmacy

.mt.gov) and the Montana Prescription Drug Registry (MPDR) program

(www.mpdr.mt.gov)?



The Board recognizes this is a long list, but know that it is just the

beginning of the inspection process you are responsible for in your facility

In addition to all of the record keeping requirements, as the PIC you

also are responsible for all the actions of personnel working in the pharmacy.

So, how does a PIC stay on top of all of this, especially in a busy

facility? Some recommendations include that you need to be properly

trained as a PIC so that you can proactively train your staff, and then take

time to revisit any problem areas.

As all of you know, things are changing rapidly in the practice

of pharmacy and the facilities you work in. Communication is a key

component in getting all the staff on the same page to meet all of these

expectations. Whether you use policies and procedures, bring up files,

automatic reminders, read-and-signs, e-mails, staff meetings, or some

other avenue to get the information out to all your staff, it needs to happen.

Issues need to be addressed sooner rather than later, as they will not go

away on their own. The Board also suggests you actively use the Board

website at www.pharmacy.mt.gov to stay up-to-date on issues, rules and

regulations, Newsletters, and other important information from the Board.



No one said it would be easy, but it is expected!
quoted from here

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