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News & Press: Legislative and Regulatory News

Advancing the Practice through Telepharmacy

Tuesday, November 22, 2016   (0 Comments)
Posted by: Elizabeth Maynard
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Submitted by: Brian Sesack, RPh, MBA

The intent of this information is to bring to your attention an initiative, through regulatory action in Pennsylvania that would allow or permit the use of telepharmacy in a hospital that operates a hospital pharmacy.  This approach would be used at its satellites or remote locations for the purposes of allowing a pharmacist to supervise pharmacy technicians in the preparation and dispensing of I.V. medications and other sterile products.

“Telepharmacy” is defined as an electronic technology or process whereby each step in the ordering, verification and preparation of medications, such as I.V. admixtures, is captured electronically.  In addition, the preparation and the dispensing is verified through the use of a bar code tracking system and documented by means of digital photographs which are electronically recorded and preserved.  The pharmacist and trained technician are directly linked via live audio/video and an electronic workflow system.

Why Telepharmacy?

The objective of this change to our State Pharmacy Regulations is to be able to provide the same pharmacist oversight of our technicians, regardless of geographical location.  Remote supervision allows pharmacists to check medications from another location, such as another hospital pharmacy in the same health system.  It can enable flexible staffing to support changes in workload and staffing needs and emergency coverage due to pharmacist illness or weather related interruptions.  Telepharmacy streamlines workflow to allow pharmacists more time for clinical functions, patient education, and adverse reaction management.

What Regulatory Changes are Needed?

Currently in the Commonwealth of Pennsylvania, the pharmacist is required to “provide direct, immediate and personal supervision to pharmacy interns and pharmacy technicians working with the pharmacist.  Direct, immediate and personal supervision means the supervising pharmacist has reviewed the prescription or drug order prior to its being dispensed, has verified the final product and is immediately available on the premises to direct the work of interns and technicians and respond to questions or problems” (Section 27.12 Practice of Pharmacy and Delegation of Duties).  It does not appear that the pharmacist in Pennsylvania can currently participate in telepharmacy due to use of the wording “on the premises.”

The proposed changes would delete the words, “on the premises” and replace them with the following, “if the pharmacist is not on the premises, then telepharmacy would be utilized to enable the pharmacist who is directly linked by video and audio to the pharmacy intern or pharmacy technician to whom the task has been delegated.”

A Hospital Based Telepharmacy Example

The Smilow Cancer Center at the Yale-New Haven hospital, in the State of Connecticut, was successful in in having their state pharmacy regulation changed.  We propose to follow or replicate Connecticut’s practice in our Commonwealth.  Telepharmacy in that state is defined or summarized in the following manner:

Connecticut’s PA 12-28 allows the practice of telepharmacy to cover: 1) licensed hospital pharmacies and: 2) the dispensation of all sterile products, including IV admixture preparations. The act allows pharmacists at hospital pharmacies to use electronic technology at the hospital, its satellite, or remote locations to supervise pharmacy technicians in dispensing sterile products.

Under the law, “telepharmacy” means the process:  1) by which each step involved in the dispensing of sterile products is verified by a bar code tracking system and documented by digital photographs that are electronically recorded and preserved and : 2) which is monitored and verified through video and audio communication between a licensed supervising pharmacist and a pharmacy technician. A pharmacist must supervise a pharmacy technician by using electronic technologies. A supervising pharmacist must monitor and verify the pharmacy technician's activities through audio and video communication. If the electronic technology malfunctions, no sterile products prepared by the technician during the malfunction period could be distributed to patients unless an appropriately licensed person could: 1) personally review and verify all of the processes used in dispensing them or: 2) after the technology is restored, use the electronic technology mechanisms that recorded the pharmacy technician's actions to confirm that all proper steps were followed in dispensing the sterile products. All orders for medication must be verified by a pharmacist before delegating to a pharmacy technician for sterile product dispensing.

A hospital participating in the program must ensure that appropriately licensed health care personnel administered medications at the hospital's satellite or remote locations. All processes involved in operating the program are under the purview of the hospital's pharmacy director.

References

http://pharmacytoday.org/article/S1042-0991(15)30194-8/pdf

https://www.pharmacist.com/smilow-expands-universe-cancer-care-telepharmacy

https://www.cga.ct.gov/2013/rpt/2013-R-0423.htm


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