Law Flashcards
Cesamet
Nabilone c2
Marinol
Donabinol cap
C3
Syndros
Dronabibol solution
C2
Epidolex
Cannabis derived
CV?
Farm bill
Removed hemp from definition of marijuanna
So cbd can be extracted and added to creams (topicals only)
Gamma hydroxybuyric acid
GHB C1
Sodium oxybate
C3
Zyrtec
Levophanol
C2
Hysingla
Hydrocodone
Zohydro
C2
Hydrocodone
Kadian
Morphine
Nucynta
Tapentadol
C2
Methamphetamine
C2
Tussicaps
Hydrocodone
Cocaine
C2
Codeine
C2
Levo alpha methanol LAAM
C2
Pentobarbital
C2
Secobarbital
C2
Benzphetamine
C3
Butrans
Buprenorphrine
C3
Butabarbital
C3
Fioricet (with codeine) fiorinal,
C3
Codeine/APAP
C3
1.8 g/100 mL codeine is C3 or 90 or less me/dosage unit
Ketamine
C3
Paregoric
C3
Fycompa
Peranpanel
C3
Peranpanel
Fycompa
C3
Phendimetrazine
C3
Testosterone
C3
Sonata
Zaleplon
C4
Adipex
Phentermine
C4
Qsymia
Phentermine/topirimate
C4
Edluar
Zolpidem c4
Intermezzo
Zolpidem
Suvorexant
C4
Nuvigil
Armodafinil
C4
Armodafinil
Nuvigil c4
Butorphanol
Stadol
C4
Stadol
Butorphanol
C4
Difenoxil/atropine
C4
Not more than 1 mg difenox and not less than 25 mcg atropine
***if difenoxil is less than 0.5 is is C5
Modafinil
Provigil
C4
Phenobarbital
C4
Tramadol
C4
Ultracet
Tramadol and apap
C4
Brivaracetam
C5
Epidiolex
Cannabidiol
CV
Codeine cough syrups
C5
Not more than 200 mg/100ml or 100g
Lomitil
Diphenoxylate/atropine
C5
Not more than 2.5 mg and not less than 25 mcg atropine
Lacisamide
Vimpat
C5
224
Requests 222 forms
222 forms
Copy 1 (brown): entity giving drugs Copy 2 (brown): DEA Copy 3 (blue): entity getting drugs
Opioid addiction buprenorphine
Probuphine and sublocade
With naloxone: suboxone, bunavail, zubsolv
Pain buprenorphine
Butrans belbuca, buprenex
Salagen
Pilocarpine
Cholinergic
Increases salivation often for chemo induced dry mouth
Palmar-plantar erythrofyesthesia
Capecitabine and fluoouracil
C2 barbs in combo or as suppository
C3
Diethylpropion
C4
Lorcaserin
C4
Carisoprodol
C4
Eluxadoline
C4
Ezogabine
C5
Meprobomate
C4
Prandin
Rapglinide
Meglitinides
Secretagogues
Before meals
Pure food and drug act
Wiley act
Ingredients meet standards of strength, quality, purity. Label can’t be false or misleading. Must list 11 dangerous ingredients. No adulterated or misbranded drugs can be sent through interstate commerce (FDCA did that too)
Food, drug, and cosmetic act
Must prove safety. Must list ingredients and not have misleading labeling. Birth of FDA
Adulterated
Identity, STRENGTH, quality, purity
Misbranding
Any lack in labeling or warnings, illegible, if ingredients differ from standard in USP monograph (strength, quality, purity), non packaged right according to poison prevention packaging act
Durham-Humphrey
Otc and RX
3 conditions make a drug rx: 1 habit forming 2 unsafe without supervision 3 limited to prescription use under NDA
Otc need adequate directions for use.
Labeling of unit dose
Kefauver Harris
Manufacture must prove safe AND effective
Phase 4 side effect reporting (manufacturer) and retrospective efficacy analysis (FDA 1938-1962). Informed consent. cGMP!
FDA to regular RX advertising and FTC for OTC advertising.
Drug listing act
Manufacturers must register drugs with FDA. Created NDC #
Anti tampering act
Required tamper resistant features for OTCs. Must list features on label. Exempt products include: insulin, lozenges and tooth cleaning powder
Orphan drug act
7 year exclusivity and 50%tax credit of clinical testing costs. Dx of <200,000 people in US. Or products with no reasonable expectation will pay off
Hatch waxman
Drug price competition and patent term restoration act. ANDA (or 505b2-paperNDA) and patent protection for innovators. Prove same API, route, dosage form, strength, and bio equivalent. Made 5 year patent exclusivity for brands.
Prescription drug marketing act
Can no reimport drugs. Sale of drug samples prohibited. Sale of coupons prohibited. Can no bring drug in US unless <90/day, only for pt, no trmt in US, serous condition, no risk. Wholesalers must be licensed. Hospitals can’t resell drugs
Omnibus budgeting act
Prospective DUR, counseling for all Medicaid beneficiaries.
States required to perform retrospective DUR
Dietary supplement and health education act
Considers supplements as food. Adulteration and misbranding still prohibited. FDA requires premarket review of safety data for new ingredients but doesn’t need FDA approval(must say on label). Cant make dx claims. Must say supplement on label. Must have supplement facts and ingredients list
FDA modernization act
Clinical trial registry, extended PDUFA, changed legend sentence to “RX only”, fast track approval of drugs
Drug addiction treatment act (DATA)
Allowed physicians to prescribe CS in office setting to treat opioid addition.
Comprehensive addiction recovery act (CARA)
Amendment of CS act
Allowed NP and PA to treat patients for opioid dependence
Allow partial fills of C2 (30 days)
Authorizes funding and regulatory help in response to opioid epidemic
FDA am me demented act (FDAAA)
FDA more power to ensure safety including REMS program
Biological price competition and innovation act
Abbreviated licensure pathways for biosimilars
Drug quality and security act
Response to NE compounding center incident. It’s an amendment to FDCA that includes: 1. Compounding quality act (traditional compounding vs outsourcing facility), 2. Drug supply chain security act (documentation of transactions through distribution chain-6 YEARS!!
Pregnancy and nursing labeling final rule
June 2020 replace ABCDX with: 1. Pregnancy (includes L&D) 2. Lactation (nursing mothers) 3. Females and males reproductive potential
Form 224
Applying for DEA registration or ordering 222 forms (check box 3) after that can order online (need DEA#, business name, telephone#), or call headquarters or specialist
225
Applying for DEA registration for manufacturer
225a for renewal every year
363
Applying for DEA registration for narcotic treatment programs
363a for renewal every year
Exempt from DEA registration
EMPLOYED BY( need dea reg if working at outside private practice): US Public Health Service, Federal bureau of prison, armed forces, Indian reservations
For administering, dispensing, or prescribing NOT to procure or purchase
Must give service ID number instead
224a
Renewal of DEA registration
224b for chains
Every 3 years
Medpak label
Pt name, serial # for medpak AND each drug, drug name/strength/description/quantity, directions, cautionary statement, storage, MD for EACH drug, prep date, BUD of pak (DNE 60 days), pharmacy name, address, telephone #, DEA # if applicable
Med pak record
Pt name and address, serial #for each drug, manufacturer name and lot #’s, info on design characteristics specs to help recreate it, prep date and BUD, special labeling, RPH initials
Hospice quantities in ADD
Analgesic c2-5: 50, 100, 150
Sedative/ANticonvuls c2-5 30, 60, 90
Ancillary c6: 25, 50, 75
Beds: 21
E-rx req going into effect 1/1/21 exemptions
C6, tech failure, waiver, out of state (or fed facility like veterans or Indians), LTC/nursing home to 1/1/23, compounded drugs, EPT, emergency, urgent public health matters, medical equipment, state/federal law (REMS), veterinarians
LTCF emergency kits
Analgesics c2-5: 45, 60, 75, 90
Sed/anticonvus c2-5: 15, 20, 25, 30
Beds: <50, 51-100, 101-150, >150
3:1
Methaqualone
C1
Sublimaze
Fentanyl
Codeine
Less than or equal to 90 mg per dosage unit is c3 I think-these are combination products
Didrix
Benzphetamine
C3
Oxandrin
Ocandrolone
C3
Propoxyphene
Darvon, darvocet
C4
Darvon
Propoxyphene
C4
TranXene
Clorazepate
223
Duplicate certificate of registration
510
DEA chemical distributor registration
CSR protection act
Federal investigation in robbery if more than 500 taken, interest ate or foreign commerce used, someone hurt or killed….25000 fine and/or 20 years, 35000 and/or 25 years of weapon used, 50000 and/ or life if death
Requires DEA records
222, invoices, POA, inventory, dispensed, distributed, self-certification (pse), 106, 41, DEA registration, transfers of CS
222
Has7 sets of forms, each pharmacy gets 6 books max unless need exceed limits
PSE rules
3.6/day
9/mo
7.5/ mo mail order
PSE amount per 3.6 grams
Ephedrine hcl 25: 175
Ephedrine sulfate 25: 186
Sudafed hcl 30: 146
Sudafed sulfate 30: 155
When can a fax be original for C2
- Compounded narcotic for direct administration parenteral
- LTCF
- Hospice narcotic RX certified and/or paid for by Medicare
Ryan haight
CSA amendment
Online pharmacy consumer protection act
Need a MODIFICATION of DEA registration
Medguides
Antipsyches, NSAIDS, estrogen, antidepressants, anticonvulsants, long acting opioids, amiodarone , ADHD stimulants, atomoxetine, antiarrythmics, REMS drugs
Form 130
When you want to manufacture a new CS that you aren’t register to manufacture
DATA waived patient limits
30, after 1 year 100, after another year 275
If not data waived can administer but not prescribe 1 days worth for up to 3 days til referral is arranged
Online reporting reqs
If over 100 CS rx or 5000+ dosage units
Peanuts/ soy allergy drugs
Cleidipine, propofol, progesterone
Egg allergy drugs
Propofol, clevidipine, yellow fever vaccine.
Flublok is egg free influenza vaccine
Luminal
Phenobarbital
C4
Mebaral
Mephobarbital
C4
Mephobarbital
Mebaral
C4
Brevital
Methohexital
C4
Methohexital
Brevital
C4
Prosom
Estazolam
C4
Dalmane
Flurazepam
C4
Dolene
Dextropropoxyphene
C4
Propocacet
Amobarbital
C2
Amytal
Critical info on med label
Patient name, drug name (brand and generic), strength, directions
Consumer medication information
Leaflet stapled to bag
Required for each NEW rx
Required for first fill
Not reviewed or approved by FDA
Patient package insert
Voluntarily provided by manufacturer
Require FDA approval
Given with new AND refills
LTC/hospital prior to first dose and every 30 days thereafter
Medguide reqs
FDA approved
Drug with serious health concerns- adherence necessary or serious ADR
Supplied by manufacture
Give with new AND refill rx, first time given to provider for outpatient administration, pt asks, medguide revised
REMs
- Communications plans
- Elements to assure safe use
- Implementation systems
- Medguides
Developed by manufacturer and approved by FDA
Who can you share PHI with
Patient, those authorized by patient, other healthcare providing care, for treatment, payment, or operational purposes. Law enforcement: DEA FDA medical board inspectors/pharmacy board inspectors (for public health or abuse concern), limited data for research, public health, or institutional operations
Patient written authorization for PHI disclosure
- Who it’s being shared with
- Purpose
- Expiration
- Patient signature
HIPAA privacy notice
Given in first day of care and whenever there are Changes. Try to get signature acknowledging but can still give care without it. Patient can request privacy disclosures for past 6 years so keep HIPAA signed privacy disclosure form for 6 years.
Contain contact for department of health and human services as well as for someone in pharmacy
Certificate of fitness log book
Date, name and address of person, kind, quantity, price, intended use
Closing pharmacy
14+ days before give board: name, address, phone#, MCSR#, certificate of fitness#, pharmacy permit#, date of closure, procedures, adequate Notice, procedures for disposal/transfer of cs
Transferring CS to different pharmacy
Give to board in 14 days: name/address/phone# (both) pharmacy permit# (both), MCRS# (both), name/RPH registration# of manager(both), date, and intended security procedures. Send copy of inventory over in 10 days(note for manager change inventory doesn’t get sent to board, just sworn statement kept on file)
Transferring rx
CS: void, on back: pharmacy, RPH (receiving), DEA, address- on back
CS/C6: log: pharmacy, RPH transferring, date, RX number
Advertising
NO: safety, efficacy, indications
YES: proprietary name, generic, quantity of API when one API, strength when more than one API, dosage form, price for filling RX
Prospective DUR
Duplication, over/under utilization, drug drug, drug-dx, drug-allergy, abuse, incorrect dose/duration, any changes in drug/dose/directions
Counseling
Name/description, DF dose route duration, instructions for prep/admin/use, missed dose, storage, self monitoring, ADR/CI/interaction/precautions, refills
Nuclear pharmacy record retention
3 years
Form 483
Deficiencies from FDA inspection
RPH vaccines
Flu, TD/Tdap, varicella, HPV, zoster, MMR, PSV23, meningococcal, HepA, HepB, polio
Vaccine class
12 hours self study with assessment
8 hours live with final exam
Hands on
CDC, ACoR approved
Rx can’t change
Pt name, md name, drug, signature, earliest fill date
Note: date written can be changed
And supervising MD can be changed
Rx changes without consultation
DEA#: can add if omitted
Pt address: add if omitted( must consult to change)
“No sub” “pt can request less” if omitted
Can change 30 to 90 days supply if not a PMP drug
Documentation for RX changed
Date, change, MD, RPh
License reactivation reqs
How loss has affected you, activities since loss, remedial activities, plans to resume and measures to ensure following law, have they engaged in pharmacy activity since, document of completion of out of state reqs, reinstatement questionnaire, resume with employment since loss, 3 recs one must be RPH must know you since loss of license. Valid for 90 days. Must send within 90 days. If denied must wait 2 more years
License reactivation after expiration
Documentation of CEs in past 2 years, written statement from each employer since expiration, statement from each state where licensed. retake MPJE. If not been practicing in pharmacy May require personal appearance, retraining, and/or naplex
Fridge/freezer temps
Fridge: 2-8 Celsius
Freezer: -25 to -10
Note for naplex freezer is -50 to -15
Check at least daily
Failure to follow up with c2 HC
Report to DEA, US department of justice, commissioner of public health, Mass department of public health
Date to send plan B report by
8/1 for period of 7/1-6/30 of prior year
Prescriber d/c practice
Can fill up to 90 days but only 30 days at a time unless insurance wants more
Pilot or demonstration research project
Can not exceed 18 months
Advanced standing status
Dx stats credentials. Can also get if at least 1 year part time totally 400 hours working in particular dx
Don’t have to complete training program, can just take the exam
Can not retake exam UNLIKE people who took the program:Can retake exam twice without having to retake program
Dx credentialing
Recertification every 4 years. Need 12 CEs (max of 3 per year for 4 years) they can count towards regular CEs
Must take and pass exam again too
CE audits
Deficient <5: complete 3 CE for each deficient
Deficient >= 5: 3 for each Deficient and discipline which may include 2+ wk suspension
Board will audit you for next 3 cycles
Vet e-kit
Can dispense 120 hour supply if can’t get to compounding pharmacy
Pharmacy must get pt specific rx for each med removed within 7 days
RPH must reconcile, inspect and restock every 10 days
When do pharmacist need to register with the commissioner
CDTM
Registration with the commissioner
Good for 1 year (except c1 research registrations- max of one year)
Must re-register no more than 60 days before expiration
Manufacture quarterly report for commissioner
Sent on 15th of the month following
Stocks of Non-narcotic substances C1-3 on hand at beginning and end of quarter. receipts, dispositions, manufacturing and packaging of all CS
Notice of inspection
Name/title of registrant, name/title of owner or operator if different from registrant, name/address of premises, date, acknowledgment of right to decline
Nursing quality assurance
Weekly
Non resident pharmacies
Submit annually and 30 days after change in office: letter certifying good standing from in stare board
Record of drugs dispensed to MA sent to BOP annually
Rx label reqs
Pt name, MD name, pharmacy name and address, drug, directions, cautionary statements, quantity, RPH initials, date, serial#
For compounds: should say it’s a compound and have telephone
C2-4: federal transfer sticker
Practitioner dispensing drug label
MD name and address, pt name, date, drug name/dose/strength per unit, directions, cautionary statement
Cmr says expiration for samples
Physician record for dispensing drug
Drug name/dose/strength, volume of units, date, name and address of pt
Rx reqs
MD: name/address/ registration #, name of MD rep if oral, date, drug name/dose/strength per unit, (DF and quantity per federal), serial # if oral, pt name and address (DOB per federal), directions, cautionary statements, refills
MLP/RPH name of supervising MD (unless PA) and MLP phone#
Midwives not included
If C2 statement about partial fill
PSE self certification
Renew every year (online)
Loss/theft of PSE
Notify in 15 days
Tech training program
120 theoretical, 120 practice
Nuclear pharmacist training
200 hours formal training (no more than 60 in lab)
3 months OR 500 hours on the job
Clinic or hospital pharmacies can dispense to…
Inpatients/outpatients,
Employees, employee spouse/children that live in same household
Receiving transfer info
Original date of issuance, original dispensing date, last refill, original refills, refills remaining, Pharmacy name/address/DEA#, rx #, transferor pharmacist name
Board submits report to DPH
Annually before 12/31 detailing investigatory and discipline actions
Scientist CS registration for quantitative and qualitative analysis
Annual
Retail sterile/non sterile and institution sterile compounding license
Renew annually
Naloxone reporting
January 15th
Name and zip code of pharmacy, number of doses dispensed and number of doses paid for by insurance
CE grace period
Pharmacist granted license on or after 10/1. Granted grace through 4/30 to get previous years CEs
Non resident outsourcing facility
Requires proof of good standing from their state licensing/registration authority within 3 months
Compounding pharmacy telephone
For sterile or non-complex must staff telephone every day and not less than 56 hours per week
Drug formulary commission
Create the orange book with the DPH
Comprised of nine people
Community program rx limitations
37 day supply with one refill
CEs for post graduate academic programs
3 CE for each academic credit
Pharmacist absence
Do not exceed 30 mins for each shift of at least 6 consecutive hours
How can electronic copies of rx be sorted
Patient name, MD name, drug name, date filled
Biennial inventory
Does not need to be submitted to DEA
Neither is POA
Partially filling a C2 for LTCF or terminally ill
Must document that on rx (unlike adhd for C2 med)
Must also write: date, quantity dispensed, quantity remaining; RPh ID
Who can prescribe EPT
Physician, PA, NP, nurse midwife
CS registration for charitable events/volunteer activities
If practitioner has current CS registration, does not need separate registration when activities do not exceed 10 hours/month
PMP addiction drug
Used recreationally, diverged for misuse, contribute to OD/seen in blood of OD
When prescribers use PMP
First time prescribing C4 or C5
Each time prescribing C2, C3, or BZD
Opioid red flags
3 or more early refills, focusing on opioid in visits beyond 3 visits
Who issues MCSR
DPH drug control program
SeParate MCSR / DEA registration reqs
Need separate for for each location
Also need separate MCSR for each activity
Physician follow up times
C2: every 4 months
C3-6: every 6 months
Independent pharmacy
Less than or equally to 9 stores. No more than 20 RPhs
BOP term
3 years
Can serve 2 consecutive and can be re-elected after not serving 1
Hearing for removal: 21 day notice
Rehab committee
Term is 4 years
1 chairperson and 1 vice chairperson
3 members are a quarum
BOP advisory committee
7 members plus commissioner or rep
Ch. 71, ch. 797, ch. 795, microbiologist, phamacoeconomics, cGMP for aseptic processing, clinical pharmacology,
Term is 3 years: If filling vacancy it’s for remainder of term
Meet semi-annually, no compensation, no liability, can be reappointed
CS exempted from scheduling drug limitations
4 ounces in 48 hours
Low risk sterile compounds
1-3 sterile additives
No more than 2 entries into sterile container
14 days in fridge, 48 hours room temperature
Medium risk sterile compounds
More than 3 sterile additives
Parenteral nutrition
IV batches
9 days in fridge, 30 hours room temperature
High risk sterile compounds
Non sterile ingredients or equipment is used
3 days in fridge, 24 hours room temperature
End product must be sterilized
Should be tested for sterility
Consent agreement
- In writing and signed by board and licensed
- Facts upon which the agreement is based, provisions/conditions for reinstatement
- States that voluntary surrender deprives registrant from rights and is not subject to judicial review
- Placed in permanent record
Restricted pharmacy
Trust, fund, pension plan, combination plan, profit sharing plan
Nuclear pharmacy required texts
USP, remingtons, texts on the practice of nuclear pharmacy and radiation safety
Nuclear pharmacy must have stuff
Dose prep station, dose calibrator, exhaust hood, refrigerator, chromatographic apparatus, portable radiation survey meter canals of detecting 0.005 microcuries of radio-nuclides, area radiation detection room monitors, personnel dosimeters, scintillation analyzer, necessary supplies: multi dose vials, syringes, etoh swabs, shielding
Emergency radiopharmaceutical timeframe
Need rx in 72 hours
Radiopharmaceutical emergency dispensing records
Name of MD and institution, amount, date supplied, date administered, rx #
Should also have md verification when bulk. Radioactivity is not used
Radiopharmaceutical label
Radioation symbol, caution radioactive material, name, chemical or common name, amount, if liquid-volume, auxiliary labels/warning, expiration
HD list
Update every 12 months
HD risk assessment plan
Reviewed every 12 months
HD storage
Antineoplastics and HD api must be stored separately and 12 ACPH, reproductive risk only and final DF antineoplastic can be stored with regular stuff
Fridge in negative pressure 12 ACPH
Can store sterile and non sterile together
Negative pressure
0.01-0.03 inches of water column relative to adjacent areas
Water sources and drains location
At least one meter away from C-pec
External ventilation
Required for sterile HD, non sterile can also use redundant HEPA filter
BSC
Non sterile can use class 1 or 2, sterile uses class 2 or 3
For class 2: types A2, B1, B2
HD SCA
Needs 12 ACPH, still must be in negative pressure area (0.01-0.03)
Sink must be a meter away
Only category 1 HD can be prepared here
Sterile HD pressure
I buffer room is 0.01-0.03 and ante room is minimum 0.02
Sterile HD sink
In ante-room at least one meter away from buffer room
Containment supplemental engineering controls
CSTDs
Can’t replace c-pec, limited evidence
Use when DF allows and use when administering antineoplastics
HD environmental wipe sampling
Done every 6 months at least
Do detect HD contamination
Changing PPE HD
Gloves every 30 mins
Gowns every 2-3 hours or per manufacturer
Respirators
Unpacking HD: elastomeric half mask with multi-gas cartridge and p100filter
N95 do not protect against gases and vapors
HD training
Must be reassessed every 12 months
Deactivating and decontaminating HD areas
Under c-pec work tray-monthly -must use respiratory protection
Compounding personnel
Evaluated at least annually
Withdrawal time
How long to withhold animal treated tissues from human food supply
Must be on label of food producing animal patient
Tech programs
Must submit materials at least every 5 years
Maintain documents for at least 5 years
Above actionable EM
If more than once in 60 days must engage industrial hygeinist, microbiologist, or infection control professional
Must stop compounding in ISO 5 (one the affected one) until remediation complete
Iso7: high risk bud until remediation complete
ISO8: high risk for items made from non sterile components
Medium rush for items made from sterile starting components
Vet e-kits
Agreement/formulary reviewer annually
It’s for compounded medications only in C6
Vet must have MCSR
Central fill pharmacies
C2-5 must be delivered to original pharmacy
C6 May be delivered to the patient
Can no be done for sterile or complex non sterile compounds
C2 loss extra reqs
Attestation of perpetual inventory every 10 days
Reconcile 222 forms for 3 months back- say what it revealed
Technician license by reciprocity
At least one license must have been active for at least one full year
Psych med ADR after RPh administration
Report within 24 hours unless: death, life threatening, hospitalization , addition testing/monitoring in hospital/ED, incapacitating - then much tell MD immediately
CSP strength percent variance
10%
Water containing csps that are non sterile during any point
Are sterilized within 6 hours
Media fill test
Done at least annually for low risk and medium risk, semi annually for high risk
Also done initially, along with written tests
Incubated first 14 days, if two temps required do 7 days each
Sterility tests for autoclave CSPs
Required for batches of more than 25 under
Exposing sterile ingredients to worse than iso 5 air for more than one hour
High risk
Also assuming contents of ingredients without evidence and what not
Immediate use CSP
Can only be low risk, not medium or high, can not be HD
Preparation can not exceed one hour
Bud: 1 hour
Single dose vials expiration after opening
Use in 1 hour if less than iso 5, can use up to 6 hours if opened in iso 5
Ampules can not be stored for any amount of time
Multi dose vial bud
28 days or per manufacturer
Compounding facility temperature
20 degrees or cooler
Positive pressure
0.02-0.05 inch water column
ACPH iso 7 sterile compounding
30
If iso 5 is used the area can have 15 ACPH as long as combined is at least 30
HEPA filtered air
Introduced at the ceiling with returns low on the wall
Sterile compounding water sources
Buffer area shall not contain drains or water sources
Iso class for presterilzation and weighing and mixing
Iso 8 or better
Environmental sampling
Every 6 months as part of recertification
Recertification of pecs
Every 6 months
Air velocity between buffer area and ante area
0.2 m/s or 40ft/min
Non viable particle testing
To test pecs
Viable airborn particle testing
To test personnel and hygiene
Air sampling frequency
Semi annually
Actionable air cfu
Iso 5, 7, 8
> 1, 10, 100
Cleaning frequency
Pec- view picture
Counters/surfaces-daily
Floors- daily
Walls, ceilings, storage shelving-monthly
Gloves fingertip test
Low/medium risk- annually
High risk- semi annually
Initially for everyone
3 times each hand
ACTIONABLE level is >3 cfu total
Surface sampling sterile compounding frequency
Periodically
Sterile compounding ingredients without expiration
Max 1 year expiration
Non sterile is 3 years
Automatic compounding device accuracy assessment
Reviewed at least weekly
POison preventionpackaging goal
Stop 80% of children under 5 while allowing 90% of adults to open it
Sterility testing for high risk
More than 25 packages prepared in fridge for more than 12 hours or at room temp for more than 6 hours before they are sterilized shall meet sterility test (same for bacterial endotoxins)
If it goes out before results, test specimens must be monitored and it should be recalled if needed
Alert patient and Md
Room temperature
20-25 degrees
Sterile compounding QA programs
Reassessed on an annual basis
How many days to send board documentation of CEs when requested
7 days
Searchable website that includes enforceable actions, ADRs, and compounding facilities
Searchable by pharmacy, pharmacist, or medication
Must include information for at least 10 years
All data should be provided to the commissioner within 30 days that it becomes available
If board assesses pharmacy and orders correction
Penalty not more than 24k, not more than 1k/day for each day after
Hearing upon written request within 15 business days
Assessment made 30 days after notification or 15 days after resolution of appeal
How long can people in Community programs who were trained to administer medications do so?
2 years, then mist get recertification
Storage of meds in community program
Non self administering meds must be locked
Self administering C2-c5 must be lock and C6 can be unlocked if determined that there is no risk
Community program documentation of meds
Med and dose, indication, possible ADRs and staff response, CI, possible allergic rxns, special instructions, missed dose instructions
Community programs documentation of administration
Required for non self administrating including off site administration and OTC. Also day programs must communicate with residential programs and vice Versa.
No required for self administering
Community programs accounting of meds
Required for non self administering patients meds in c2-c5
Reconciled at the end of each shift
What can optometrists prescribe
Topical agents in C6 for things other than glaucoma
Weird department registration with the commissioner rules
Chemical analyst and lab must register
Teacher using CS must register but facility doesn’t have to
Note: pharmacist instructors for pharmacy programs are exempt when purchasing C6 for educational purposes
Who is automatically registered with the commissioner
Physicians, podiatrists, dentists, vets
But only for C6
Registration with the commisioner: when to notify of termination of it
30 days before
Registration with the commissioner: when to apply for new one in event of name/address change
Can apply up to 90 days in advance
Note: 60 days in advance for DEA registration. They send form 50 days before, call if not received 30 days before
When to report theft or loss to the commissioner
Within 24 hours of discovery
If picking up PMP drug without ID and Rph belies withholding the drug would result in serious hardship
Patient must print name and address on back of rx and sign name
When must you submit written request for hearing of summary suspension of registration with commissioner?
Within 14 days
Additions and exceptions list
No drugs on exceptions list
Exception: A rated but can not be interchanged
Additions: not A rated but can be interchanged
Glutethimide
C2
Transferring CS not c2, needed documentation
Drug, DF, strength, quantity, date.
Name/address/DEA registration of parties involved
Registration requires to wholesale PSE
Chemical distributor
Form 510
Theft or loss how soon to notify DEA
One business day
CS inventory reqs
Date, time (opening or close), drug, finished form (ex 10 mg tablet), number of units per container, number or containers, count
222 form purchased required to fill in
Name of item, quantity, package size
Upon receipt document actual quantity received and date of receipt
Cancelling c2 order
Notify supplier in writing and they will draw line through item and write “cancelled” on items shipped space on copies one and two
If the supplier cancels order they write “void” and they notify purchaser in writing
Lost order form
Prepare statement with date and serial number and verify drugs ordered were not received and attach it to second order form sent to supplier and retain a copy of statement with both copy 3’s
Immediately notify DEA
Same for electronic but everything is electronic and you use a tracking number instead of a serial number. First order is “not accepted” if subsequently received. Attach that to record of the statement and order record.
Invoice reqs
Date received, name, finished form, number of units per container, number or containers
Cs refill printout report
Within 72 hours
LTCF partial fill documentation
Must put on back: date, RPh, quantity filled, quantity remaining
Must put “LTCF” or “terminally ill”
How soon must you complete modification of DEA application before using internet to sell CS
30 days. Filling out the app constitutes notifying the DEA
Mist also notify states boards 30 days in advance
Can perform activity of retail pharmacy and internet pharmacy at the same time
Notify DEA 30 days prior to changing web address
Central fill pharmacy: what must be written on script?
Central fill, name/address/DEA reg of Central fill pharmacy, date, name of RPh sending it over
PSE log
Name, address, signature, product, quantity, date, time
Not needed if not more than 60 mg
Only armed forces can accept military Id
Don’t have to be 18
What must advertising contain? (Not pharmacy advertising)
Name, at least kind indication, most significant risks
False or misleading statements about advertising
Misbranding
Drug strength different from official standards
Adulterated
Purity or quality lower than what’s listed on label or compendia
Adulterated
If ingredients differ from strength quality and purity as determined by the test laid in the usp monograph
Misbranding
Unit dose label requirements
Drug, quantity of active ingredient, manufacturer, lot number, BUD, any cautionary statements
What does it mean if a drug is listed in the orange book
It means the generic has demonstrated pharmaceutical equivalence and bioequivalence
Expiration of donated drugs
Must be at least 6 months away
Can not donate CS
When can manufacturers give out samples?
Only to prescribers, hospital pharmacy, or other healthcare entity at the written request of the prescriber
This does NOT include retail pharmacies
Drugs except from security track and tracing
Providing drugs to provider for office use, ultimate user, and drug samples
Defective drug prep log
Drug, potency, DF, reason for recall, amount made, amount dispensed/distributed, actual potency and DF, and ADRs
Retain for 10 years
Made available to the board in 7 days or recall
Significant loss of control in ISO 5
> 15 CFU
Recall csps, provide adverse event surveillance, contact prescribers, and engage microbiologist/industrial hygeinist/ID professional
Above actionable level EM must include what are the minimum
Root cause analysis, repeat EM, corrective action and preventable action plan
If you have only one iso 5 workbench or a non commercially available workbench and you failed EM testing and are remediating, what is the BUD?
Immediate use
Vet e-kit label
Generic name, strength, date of prep, lot number, BUD, storage/handling, cautionary, statement that it is compounded preparation
ADD record
ID of person accessing, location, type of transaction with date/time, name/strength/DF/quantity, name or other identifier of patient, reconciliation of all inventory activities
What is included in the email of notification of loss/theft
Pharmacy name, address, pharmacy license number, manger name, date of possible loss, drug name/strength/DF, reason for loss
When double dipping for law and compounding CE, what must the course be titled
Must be “law” and have compounding requirements necessary
When does manager of record have to ATTEST to training of staff in lean concepts
Upon renewal of pharmacy license
For complex non sterile and sterile compounding
When does a petition for license reinstatement expire?
90 days
Note: one extension per petitioner may be considered
When denied: its 2 years from the date of denial NOT original submission
When a pharmacist or intern has a question about the interval between mental health injections they are administering
It is recommended but NOT required to contact MD
Note: pharmacies must be CPR certified
Does an optometrist require MCSR to get and use drugs for diagnostic purposes?
No
How long is an out of stare c3-5 script good for
30 days
Who can write scripts for out of state c3-5
Authorized practitioners
Who can write scripts for out of state c2s
Physicians
Maybe NP and PA too?
When can a doctor only prescribe a 7 day supply of opioid?
Opioid naive
Every time prescribing for a minor
If giving more must document reason in medical record and indicate than a non-opioid alternative was not acceptable
This is for pain not SUD
When must pharmacist give pamphlet about opioids?
When dispensing narcotic or CS in schedule 2 or 3
How is a toll free number provided for counseling getting meds delivered
It’s printed on label that goes on bottle
Must also do this for drugs that are sterile and complex-non sterile compounds
For which schedules does the department calculate mean and median prescribing percentile for opioids
Schedule 2 and 3
Done annually
Master formulation record
Name/strength/DF, calculations needed, description of ingredients and quantities, compatibility, stability, storage, references, equipment needed, mixing instructions (order, temp, duration)
Compounding record
Official/assigned name, strength, DF, master formulation referenced, names and quantities of components, sources/lots/expirations of components, total quantity compounded, name of: preparer, person who did quality control, and RPh who approved, date, rx#, BUD, duplicate container label, description, results of quality control procedures, documentation of quality control issues/ADRs/preparation problems reported by patient or caregiver
222: when must supplier report transaction to dea
By the end of the month
CSOS: when must the supplier report transaction to DEA
Working 2 business days of filling the order
Other downside is it can’t be endorsed to another supplier
All schedules can be ordered here
What must be on an rx for buprenorphine that doesn’t include and X DEA#
“For pain”
What schedules need back up method for recording refills when computer is down?
C3 and c4
When do c5s have a 6 month expiration?
When transferred or partially filled
Institutional limits
C2: 7 day
C3-5: 34 day supply or 100 dosage units
When can a pharmacy compound c2-5?
Aqueous, oleaginous, or solid DF
Does not contain more than 20% CS
Only distributed to prescribers registered to dispense CS
Can 222, original rxs, and inventory records be stored at a central location?
No
What is required on an OTC label?
Principle display panel large enough to have all required info: drug name-drug class, quantity, name/address of manufacturer/packer/distributor, Directions, drug facts panel,
NDC requested NOT required
What is on a drug facts panel that goes on OTC label?
API, purpose, uses, warnings, directions, other info, contact info
What are some things that central pharmacies can not do?
Fill emergency c2
Dispense controls without RX (c5 sale allowed in some states)
PSE mail order report
Submitted to DEA on 15th day of month following
Not needed if: samples of2 solid dosage units or equivalent (10 mL or less). Not more than once in 30 days
Not needed if distribution by retail distributors
Not needed for LTCF
Not need if there’s an RX
Do technicians from other states and territories need to take a test for licensure in mass?
No as long as requirements are similar
Who has the final say in decisions about rehab of pharmacist/interns/techs?
The BOP. The rehab committee give recommendations
Who appoints the members of the advisory committee of the board?
Commissioner
Independent pharmacy: where are the store counts included?
Just in Massachusetts
When does BOP member term start
1st day of month following appointment
Who can sell alcohol?
Pharmacist or non pharmacist adult under the supervision of a pharmacist
Can not sell to a minor, just like the controls, UNLIKE pse I think
How often does a CIVAS or sterile compounding pharmacy have to report to the board all that stuff?
Every 6 months
What extra step must be completed when you inter change a drug to the generic?
Document manufacturer on the label and RX!
Can a midwife write an RX?
Must be nurse midwife not regular midwife!
When do wholesalers have to submit changes to the board by?
Within 30 days of the change
Hood certification and status reporting
Should be certified annually, but it’s one of the things that gets reported every 6 months (along with number and type of scripts, states they went to, iso, status of CIVAS approvals, attestation of following 797
Traditional compounding 3 exemptions
CGMP, labeling with adequate directions for use, need for FDA approval
What must be done when you can not provide the remainder of a partially filled c2 within 72 hours of partially dispensing it?
You must notify the MD!
Note: when partially filling a c2 you note the quantity supplied on the front of the rx
What does not need to be on a label?
DF and dose
Medpak: DF
Doctor dispense: DF
QRE: when does pharmacy’s have to notify patient / doctor
Immediately
When does QRE have to be documented?
On the same day of discovery
Documented by the DISCOVERING pharmacist
How often do CDTM pharmacists have to complete opioid training
Initially prior to obtaining Cs registration and then biennially
When must physician remain within their scope of practice?
CDTM
Do non resident outsourcing facilities requires a MCSR?
No
What can prescribers not own?
Outsourcing facility, pharmacy
FDA records retention time
5 years
BOP inspection form record retention time
2 years
What is excluded from scheduling if it can be sold over the counter
Non-narcotic
Who does commissioner notify of temporary scheduling of a substance?
Inpatient hospitals in MA, chairs of the joint committee of public health, attorney general of US, all local and regional boards of health
Who has to file 106 with local police?
Dispensers
Distributors just have to do state police
What must be noted when partially filling a c2 upon patient request
The fact that it was partially filled and the quantity dispensed
Must be available to the MD upon REQUEST
Which schedules is lock box sign needed for?
C2-5
Should a new POA be filed for each renewal of the DEa registration?
No, only if the renewal is signed by a different person
Does a central fill pharmacy need a separate DEA# to do retail work?
Nope
Are LTCF registered with dea ?
Not usually
Note: ADS electronically records dispensing thus maintaining records for the pharmacy
Bla
Biologic application
Nembutal
Secobarbital
Electrolyte limits on OTCs
Sodium: 140
Calcium: 3.2g
Magnesium: 600
Potassium: 975
PPI and medguide directed at who?
PPI: healthcare
Medguide: patient
Who needs a machine specific dea # and MCSR for add?
Retail pharmacies-They must also monitor machine by video
Hospice ADDs-also video monitor
What schedules can be stored in LTCF emergency kits?
2,3,4,5,6
Vet e kit label
Generic name, strength, quantity, date of prep, BUD, lot number, storage handling, cautionary, name/address/telephone of pharmacy, compounded drug
When to submit application for waiver in by for requirement to use electronic ordering for controls starting January 2021
By October 1st to get waiver in time
What schedules can you fill a failover for?
C6
“Partial fill upon request” required for which scripts?
ALL SCHEDULE 2s
was previously just opioid c2s but was expanded
Fax rx to hospice or, what kind of drug must it be?
C2 NARCOTIC! Same for compounded parenteral
Note LTCF it can be any c2
When do IC rules not have to be followed?
Medical emergency
Patient must print name on rx
RPh must document: date, hour, nature of emergency on Back
For CDTM when must patients be at least 18?
Community
Also need referral and consent