Drug Enforcement Agency (DEA) Compliance- Are you ready?

DEA has increased their initial facility inspections, on demand inspections, and random facility inspections.

Is your facility in compliance with DEA regulations for controlled substance ordering, stocking, dispensing, and record keeping?

  1. DEA registrant of record
  2. Power of attorney staff members
  3. Controlled substance ordering
  4. Division of duties
  5. Secure stocking at all times
  6. Documentation compliance
  7. Auditing and diversion prevention procedures
  8. Disposal processes and documentation

Medication Vendors-How do I choose?

With the opening of a new center comes the inevitable need to order supplies, equipment, and medications. Why should you choose between vendors, such as, Mckesson, Henry Schein, Cardinal, or Morris and Dickson?

I can provide insight into the pros and cons of each vendor. Directly or indirectly I have worked with all the vendors.

What to consider?:

  1. Variety of selection.
  2. Feedback of other customers with your type of facility.
  3. Acceptance of your group purchasing organization (GPO).
  4. Ease of ordering.
  5. Delivery time frame.
  6. Customer service process for errors in ordering and returns.

Once you have narrowed down a vendor, I can get you in touch with the representative for your area.

Pharmacy Consulting Services

  1. Assist in obtaining Pharmacy Licenses, DPS controlled substance licenses, DEA controlled substance licenses for each facility.
  2. Obtain Pharmacist in Charge (PIC) status for the facilities.
  3. Develop policy and procedures for medication processes to maintain compliance with the state board of pharmacy.
  4. Assist in choosing the type of automatic dispensing devices to meet the centers’ needs.
  5. Set up and stock the automated dispensing devices includes adding authorized users and warning alerts.
  6. Assist in creating a drug formulary for the centers.
  7. Consistent on-call availability for drug information, process questions, and trouble-shooting.
  8. Assist in set up vendor for drug and IV fluid purchasing.
  9. Create processes for ongoing drug and IV fluid ordering to maintain sufficient stock.
  10. Create a crash cart list and stock crash carts for each center.
  11. Maintain appropriate antidotes and emergency drugs with information on their use.
  12. Determine the type of temperature monitoring device to use and set up a process to have 24 hour temperature monitoring and warning system.
  13. Initial and ongoing training of staff on policies, procedures, drug preparation, and use of automated dispensing machines.
  14. Provide drug references for the staff including: IV drug preparation, poison control center contact information, and quick reference.
  15. Weekly visits to monitor medication records for compliance, ordering, restocking, and training.
  16. Chart audits to verify compliance on dispensed medications versus administered medications and proper documentation of allergies and adverse drug reactions.
  17. Monthly inspection of medications for expired medications and segregate those expired medications for return to a reverse distributor.
  18. Attend any applicable center committee meetings and/or quarterly medication safety  meetings.
  19. Willingness to be on site for State Board of Pharmacy inspections, Joint Commission, and Department of Health, depending on availability.
  20. Assist in determining performance improvement and patient safety goals and reporting  the medication related data each month.

Automated Dispensing Machines- to have or have not?

Automated Dispensing Machine

 

When deciding whether your facility should invest in automated dispensing machines, the following should be considered

Benefits:

  1. Patient specific transactions recorded with date and time stamp.
  2. Inventory list and quantities available up to date by report.
  3. Expiration date tracking available by report.
  4. Ability to add dispensing warnings for specific medications.
  5. Controlled substance tracking and witness documentation.

Cons:

  1. Significant upfront costs for the machine(s), installation, and training.
  2. Staff member(s) must be trained to replenish medications within the machine and troubleshoot problems.
  3. It does require maintenance of the medication lists within the database, user access, and any restrictions applied to the medications.
  4. Some practice sites could work efficiently without the machine using tackle boxes/kits.