Brinkley review Flashcards
recall classifications
Class I – worst, reasonable likelihood of serious AEs
Class II – temporary or reversible AEs
Class III – least concerning, not likely to cause AEs
patient package inserts (PPIs)
- required for estrogen- and progestin-containing products
- must be given to inpatient at first administration and q30 days thereafter
Med guides
- required for many different products that FDA deems necessart
- no requirement for inpatient distribution
major exclusions from Poison Prevention Packaging Act
- bulk containers not intended for household use
- drugs for institutionalized patients
- several products intended for emergency/rapid use
- several products commonly dispensed in unit dose forms
A medication regimen review must be performed for LTC patients every _______
-every 30 days
This is a CMS requirement
mailing prescriptions by USPS
- allowed provided contents are not alcoholic beverages, poisonous, or flammable
- controlled drug outer packaging cannot contain any words/symbols indicating its contents
- UPS and FedEx can deliver any Rx drugs and are not subject to above restrictions
For what purposes can a pharmacy use/disclose PHI without authorization from the patient?
- for treatment
- for payment
- for healthcare operations
- gov’t functions: LEOs, PMPs, adverse event reporting
How long do pharmacies have to respond to patient requests for their own PHI?
-within 30 days, but can request an extension for another 30 days
How long do pharmacies have to respond to patient requests to amend their PHI or obtain record of disclosures?
within 60 days, but can request extension for another 30 days
Notification requirements when there is a breach of patients’ PHI
- notify patient within 60 days of discovery
- for breaches < 500 individuals, maintain log and reports to HHS annually
- for breaches > 500, notify HHS and local media within 60 days
DEA form for applying for a DEA number
Form 224 (for prescribers and dispensers)
Can federal/military prescribers write CII’s in Texas?
- only if on official TSBP prescription pad, which requires DEA registration in Texas
- otherwise can be filled only at federal facility/base
A new owner can use the previous owner’s DEA for up to how long after the purchase?
- up to 45 days
- previous owner must grant POA to purchaser
What’s the highest concentration a pharmacy can compound narcotics?
- up to 20%
- any more and the pharmacy would need to be registered with DEA as a manufacturer
scheduling concentrations of codeine
- CIII 18 mg/ml
- CV 2 mg/mL or 90 mg per dosage unit
scheduling concentrations of opium
- CIII 5 mg/ml
- CV 0.5mg/mL (less than that of federal limit)
where do triplicate forms of 222 go?
- Purchaser keeps copy 3, sends copies 1 and 2 to supplier
- supplier keeps copy 1, sends copy 2 to DEA
If a C-II order cannot be completed in its entirety, the supplier has ____ days to do so
60 days
What items must the C-II purchaser record on their copy of the 222 form after receiving the shipment?
- number of containers received
- date received
Invoices for controlled substances must be initialed/dated by that pharmacist, except in what cases?
Class C-ASC and Class F pharmacies
5% rule
- a pharmacy can distribute of up to 5% of the total controlled substances dispensed during a 12-month period
- any more requires registering with DEA as a distributor
storage of controlled substances
- can be in a secure locked cabinet or unsecured scattered throughout – but not together on an unsecured shelf
- C-II’s must be securely locked in Class C and Class F pharmacies
how long to report CS theft or significant loss
- 1 business day
- can take time to investigate before submitting form 106, but keep DEA updated, esp. if taking longer than 2 mos
form for theft/loss of controlled substances
DEA form 106
“Federal law prohibits transfer of this drug to any person other than…” is required for which drugs
CII through CIV only, although post pharmacy systems will include this on CV as well
form for disposal and destruction of controlled substances
DEA form 41
-must be submitted at least 2 weeks prior to proposed destruction date
how many must witness destruction of controlled substances
at least 2 witnesses
how often does DEA require an inventory of CSs
every 2 years (biennial)
how often does TSBP require inventory of CSs
annually
exact vs estimated count during inventory
- exact for all CII’s
- exact for all containers holding > 1000 tablets
- estimates allowed for the rest
when is a perpetual inventory required?
- CII’s in class C pharmacies
- all controls at remote locations
- all controls at class C-ASCs
- all controls at class F