law stuff Flashcards
what must pharmacy staff name tags say
name & license status
when must licensees join the BOP’s email notification list?
within 60 days of being licensed
how many pharmacies can a PIC supervise
2 pharmacies as long as they’re within 50 driving miles away
when should the BOP be notified about a PIC change
old PIC must report within 30 days
when is the biennial Self-Assessment form due
before july 1st of each odd numbered year
when should additional Self-Assessment forms be done
- within 30 days if a new permit was issued
- if there’s a new PIC
- when pharmacy moves to a new location
how long is the Self-Assessment form kept
3 years
what services can RPhs do
- administer drugs & biologics
- provide consultation, training & education
- be in multidisciplinary reviews
- furnish self-administered hormonal contraceptives
- furnish travel meds
- furnish prescription nicotine replacement products
- independently initiate & administer immunizations to ≥3
- order & interpret tests
what CE do RPhs have to do
- 30 hours of CE during each 2 year license renewal
- ≥2 hours of pharmacy law & ethics
what day do RPh licenses expire
- on the last day of their birth month
how long do RPhs have to keep their certification for
4 years
how many interns per RPh
2 interns
how many techs per RPh in community setting?
1 tech with 1st RPh, 2 per additional RPh
how many techs per RPh in hospital setting
2 techs per RPh
how many tech trainees per RPh
1 per RPh for 120-140 hour training period; 340 hours if externship is between hospital & community
how many clerks per RPh
reasonable number per RPh’s discretion
what are advance practice pharmacists do
initiate, adjust & d/c drug therapy per protocol
criteria to be an advanced practice pharmacist
- earn certification in relevant area of practice
- complete residency
- provide clinical services for 1 year [≥1500 hours] under CPA or protocol w/ physician, Collaborative Drug Therapy Management or within health system
requirements to be an intern pharmacist
- be currently enrolled in ACPE-accredited or BOP-recognized pharmacy school
- be graduate of a pharmacy school & has application pending to be a licensed CA RPh
- be graduate of foreign pharmacy school w/ certification from NABP’s FPGEC
tech-check-tech
- in hospital settings w/ clinical pharmacy programs & RPhs are in patient care areas
- another tech can check after tech fills unit-dose distribution system, floor stock or ward stock
- RPh must check compounded & repackaged drugs before tech fills unit-doses
what can pharmacy clerks do
put drugs on the shelf & give pts their prescriptions during transaction
what is the pharmacist recovery program for substance abuse & mental illness
- evaluates drug abuse and/or mental illness, develops trx plan, monitors progress & provides suport
- accepts referrals on voluntary basis
- BOP may refer RPh to recovery program in lieu of discipline
when must a RPh report to the BOP about a licensed staff member who is chemically, mentally or physically impaired to the extent that it affects their ability to work OR found for theft, diversion or self-use of drugs
14 days
who can keep an extra key to the pharmacy
pharmacy owner, building owner or manager in tamper-evident container for purpose of delivering the key to a RPh
what’s the difference between a policy and a procedure
policy: course of action for a specific activity
procedure: steps that must be carried out by the staff [written in policy]
what are required policies & procedures?
- action when staff is chemically, mentally, or physically impaired
- action when staff is engaged in theft, diversion or self-use of prescription drugs belonging to the pharmacy
- operation of pharmacy during RPh’s breaks/meal periods
- assuring confidentiality of medical info
- delivery of drugs/devices to storage facility when pharmacy is closed & no RPh present
- compliance with Combat Methamphetamine Epidemic Act of 2005
- reporting requirements to protect the public
- how a pt will get their med when RPh has conscientious objection to dispensing it
- preventing dispensing when RPh decides it would cause a harmful interaction
- helping pts with limited/no English proficiency to understand their meds
how long must drug acquistion & disposition records be kept
at least 3 years
how long are hospital pharmacy chart orders for controls maintained for
7 years
how long are patient acknowledgements of HIPAA kept for
6 years
how long is transaction info, history and statement for most prescription drugs under Drug Supply Chain Security Act kept for
6 years
how long must a certificate for completion of CE be kept for
4 years
how long must community or clinic pharmacy prescriptions be kept for
3 years
how long must hospital pharmacy chart orders for non-controls be kept for
3 years
how long must be quarterly C-II inventory be kept for
3 years
how long must DEA forms 222, CSOS records, & power of attorney forms be kept for
3 years
how much purchase invoices for all prescription drugs be kept for
3 years
how long should self-assessment forms be kept for
3 years
how long should documentation of drug returns be kept for
3 years
how long should documentation of transfers be kept for
3 years
how long should theft/loss reports of controls be kept for
3 years
how long should biennial controlled substances inventory be kept for
2 years
how long should pseudoephedrine. ephedrine, phenylpropranolamine & norpseudoephedrine sales logs be kept for
2 years
how long should pt med profiles be kept for
1 year
how long should med error/quality assurance reports be kept for
1 year
when should a change of RPh address or name be reported
within 30 days
when should a change of PIC be reported
within 30 days
when should changes in the pharmacy permit be reported
within 30 days
when should theft by or impairment of a licensee be reported
within 14 days
when should loss/theft of controlled drugs be reported
report to DEA immediately [1 business day]
report to CA BOP within 30 days
when should bankruptcy, insolvency or receivership be reported
immediately
when should a completion of self-assessment form be done
- every odd-number year before July 1
- within 30 days if there’s a new pharmacy permit, change in PIC or change in pharmacy location
when should biennial controlled substance inventory be done
every 2 years
when should RPh CE [30 hours] be done
every 2 years, except first cycle
when should C-II inventory be done [CA requirement]
every 3 months
when should med error investigations be done
within 2 days of error
when should submitting dispensing data to CURES be done
within 1 business day of dispensing
what are options for filing controlled substances paper prescriptions
- 3 separate files → C II, C III-V, non-controlled
- 2 separate files → C II, all others [CIII-V need red C stamp]
when should a new PIC do a C II inventory
within 30 days of their appointment as PIC
when is inventory counted (time)
beginning or close of business → not during business hours
inventory counting - unopened containers
exact count needed → use number listed on bottle
inventory counting - opened containers
- C I & II need exact count
- C III-V with ≤1000 units can be estimated
- C III-V with >1000 units need exact count
how can pharmacies have off-site storage of records
- BOP has to approve waiver → signed copy goes to pharmacy within 30 days
when must pharmacies produce records if the BOP requests it
within 2 business days upon request
how long do you keep non-control Rxs
- at least 1 year at the pharmacy
- 2 years off-site after initial year
- throw away after 3 years
how long do you keep control Rxs
- at least 2 years
- 1 year offsite after initial year
types of DME
- blood glucose monitors, test strips, lancet devices & lancets
- nebulizers & nebulized drugs
- CPAP machines
- prosthetics, orthotics & supplies
- ostomy supplies
- walkers, scooters, canes & commode seats
how can we bill Medicare for DME
with DWO → need prescriber’s signature & date + detailed description of item
drug supply chain security act of 2013
outlines steps to build system to track & tract drugs as they’re distributed in the US → prescription meds for human use
what must be maintained for each product received
- transaction information
- transaction history
- transaction statement
transaction history
statement w/ transaction info for each prior transaction
transaction info
- Proprietary or established name or names of the product
- Strength & dosage form of the product
- NDC of the product
- Container size
- Number of containers
- Lot number
- Date of transaction
- Date of shipment, if more than 24 hours after date of transaction
- Business name & address of person from whom ownership is being transferred
- Business name & address of the person to whom ownership is being transferred
transaction statement
statement that entity transferring ownership in a transaction:
- is authorized
- received the product from a person that is authorized
- received transaction info & a transaction statement from the prior owner of the product
- didn’t knowingly ship a suspect or illegitimate product
- had systems & processes in place to comply with verification requirements
- didn’t knowingly provide false transaction info
- didn’t knowingly alter the transaction history
adulteration
involves the drug itself → quality
- filthy, putrid, decomposed
- prepared/store in unsanitary conditions
- contaminated
- lack of quality control
- recognized in official compendia but lower than official standards
- not recognized in official compendia but quality is different from label
misbranding
involves incorrect or missing info on the label
- lack of required info
- false/misleading ifno
- improper packaging
- ingredients differ from standard quality
when must the hospital drug supply be checked
every 30 days
how long are the records kept for the hospital drug supply checks kept
3 years
when must irregularities found during hospital durg supply check be reported
within 24 hours to PIC & director or chief executive officer
how are controlled drugs stored
locked cabinet or dispersed throughout the other drug stock
how are investigational new drugs stored
separate from other drug stock
how are repackaged/resold drugs stored
separate from other drug stock, assigned a BUD
how are recalled drugs stored
separate from other drug stock
how are expired drugs stored
separate from other drug stock
how are drug samples stored
separate from other drug stock, not allowed in retail pharmacies
how are drug supplies for medical emergencies supplied at nursing units or service areas
portable container sealed by RPhs → contents listed on outside cover & have earliest expiration date of any drugs within
drug recall
drug is removed from market bc its defected or potentially harmful
what is the RPh responsible for in a class I recall
determining which pt got the med & notifying their prescriber
who is the manufacturer responsible for notifying during drug recalls
customers → distributors & patients
class I drug recall
reasonable probability that use or exposure to the drug will cause serious adverse health consequences or death
class II drug recall
use or exposure to drug will cause temporary or reversible adverse health consequences
class III drug recall
use of or exposure to the drug isn’t likely to cause adverse health consequences
when can a pharmacy or outsourcing contact recipient about a recalled compounded drug?
- use of or exposure can cause serious adverse effects or death AND
- recalled products was dispensed or intended for use in CA
when should the recipient pharmacy, prescriber or pt be notified about a compounded drug recall
within 12 hours
when should the BOP be notified about a compounded drug recall
24 hours
when must a pharmacy report to FDA MedWatch about a compounded drug recall
within 72 hours
when must an outsourcing facility report to FDA MedWatch
within 15 calendar days
can drugs be donated in CA
- SNFs, HHC & mail-order can donate drugs in single-use or sealed packages to repository and distribution programs
- drugs must be unused & not expired → no controls!!
FDA flush list
Buprenorphine [Butrans, Belbuca, Brixadi, Buprenex, Sublocade]
Diazepam rectal gel [Diastat]
Fentanyl-containing products [Actiq, Fentora, Duragesic, Subsys]
Hydrocodone-containing products [Norco, Lortab, Vicodin]
Hydromorphone [Dilaudid, Exalgo]
Methadone [Dolophine, Methadose]
Methylphenidate transdermal system [Daytrana patch]
Morphine [MS COntin, Kadian]
Oxycodone-containing products [Ocycontin, Percocet]
Oxymorphone [Opana]
Tapentadol [Nucynta, Tapenta, Palexia, Yantil, Tapal, Aspadol]
pharmacy take-back program
- pharmacies register with DEA to take back unwanted drugs
- only reverse distributor can remove the liner with drugs → 2 pharmacy staff must witness
- controls can be mixed with non-controls
- cannot put sharps, needles & illicit drugs
- pharmacies cannot use for their own expired/recalled drugs
- can give pre-paid, pre-addressed envelopes to mail drugs to destruction location [waterproof, spill-proof, tamper evident, tear resistant & sealable]
when should establishment of the drug take-back service be reported to the BOP
within 30 days
when should discontinuation of the drug take-back service be reported to the BOP
within 30 days
when should any tampering with a collection bin be reported to the BOP
within 14 days
when should theft of deposited drug be reported to the BOP
within 14 days
when should disclosure of service & location of each receptacle be reported to the BOP
annually, at time of facility license renewal
when should a written report about child abuse, elder abuse and neglect by done
within 2 working days or 36 hours of receiving the info concerning the incident
type of prescribing/furnishing authority - physician
independent authority → controls & non-controls
type of prescribing/furnishing authority - dentist, podiatrist, veterinarian
independent authority, limited to scope of practice → controls & non-controls
type of prescribing/furnishing authority - optometrist
independent authority, limited to scope of practice → non-controls & C II-IV [no V!!]
- must be certified with board of optometry to prescribe → T at end of license number
- codeine or hydrocodone-containing meds: max 3 days
type of prescribing/furnishing authority - naturopathic doctors
independent authority → only epi, natural/synthetic hormones, vitamins, minerals. etc
- need furnishing number to prescribe → starts with NDF
dependent authority
- all non-controls & C III-V [no C II]
type of prescribing/furnishing authority - RPhs
independent authority, limited to:
- emergency contraception, self-administered hormonal contraception
- travel meds
- routine immunizations
- naloxone
- Rx NRT
- PrEP [max 60 days Q2 years]
- PEP
dependent authority:
- all other non-controlled & C II-V
type of prescribing/furnishing authority - CNM, NP, PA
dependent authority → non-controls & controls
what can prescribers self-prescribe
non-controls
what can prescribers prescribe for family members
non-control & controls if there’s a valid physician/pt relationship, legitimate medical purpose & good faith exam
how long is a prescription from a deceased prescriber valid for
until all refills are gone & NMT 6 months from date written [controls] or 1 year [non-controls]
can RPh fill out of state prescriptions
yes if prescriber has license equivalent to CA prescriber → may need to verify license
can RPh fill foreign prescriptions
no; only if from District of Columbia & US territories [Puerto Rico, Virgin Islands, Guam & American Samoa]
requirements for a valid prescription
- patient name & address
- drug name & quantity
- directions for use
- date of issue
- prescriber info
- condition/purpose if requested by patient
- prescriber signature
how long must non-control chart orders be kept for
3 years
how long must control chart orders be kept for
7 years
medi-cal prescription form requirements
- prevent unauthorized copying of a completed or blank prescription form → “void”, watermarks
- prevent erasure/modification of info → quantity check-off boxes, preprinted text
- prevent use of counterfeit prescriptions → serial number, thermochromic ink, microprint sig line
when can you dispense a 90 DS with an initial prescription that specified a shorter time period
- Rx isn’t for a control or psych med
- pt completed initial 30 DS with no negative effects or previously got 90 DS
- total quantity dispensed doesn’t exceed amount authorized on prescription
- RPh notified prescriber of larger quantity dispensed
when can you NOT dispense a 90 DS with an initial prescription that specified a shorter time period
- prescriber indicates no change to quantity
- prescriber indicates that dispensing prescribed amount is medically necessary
dispensing hormonal contraceptives
- CA allows pts to get 12 month at one time → oral contraceptives, patch, ring & injection
- health plans are required to cover
- total quantity can’t exceed amount authorized on prescription
refill limits
- no limit for non-controls but can’t dispense after 1 year from date of issue
- all controls expire in 6 months
- no limit for C V
- restrictions for C II-IV
- no refills for C II
PRN refills
- allowed for non-controls → don’t refill after 1 year
- not allowed for PRN controls
emergency refills
- can do without authorization → judge if not filling will interrupt pt’s ongoing care or have significant & attempt to contact prescriber
- no limit for non-controls
- reasonable amount for C III-V
- can’t give for C II → can get emergency verbal order
refill pharmacies
- fill new prescriptions & refills → need contract or same owner to use common e-file
- originating pharmacy is responsible for counseling pts, maintaining medication profiles & performing drug utilization review
prescription refills
- must be between 2 RPhs or interns
- no limit for non-controls as long as there’s refills
- C III-V can be transferred once → unless there’s a shared database
- cannot transfer C IIs
requirements for prescription labels
- pt name
- drug name, strength, quantity
- directions
- indication
- prescriber name
- physical description of drug
- exp date
- name & address of dispenser
- serial/Rx number
- date of issue
critical items on prescription
- 12 pt font
- pt name
- drug name & strength
- clear & simple directions for use
- condition or purpose
less critical items on a prescription
- less prominent location
- pharmacy name, # & prescriber name
dispensing brand name vs generic name on label
- brand name: no need for manufacturer
- generic: must also say generic for ___ & drug manufacturer
expiration dates
- manufacturer’s exp date or 1 year from date dispensed
- no exp date = misbranded
labeling format
50% of label in 12 pt sans serif typeface
- pt name
- drug name & strength
- directions
- indication
translation on labels
- must have translated directions at request
- supplemental document
- can use translations made by BOP
- RPh isn’t required to provide translated direction for beyond the languages the BOP made available
poison prevention packaging act of 1970
- requires use of child-resistant containers for many OTC products, most PO prescription drugs & dangerous household chemicals
- can have one size of OTC in non C-R if same product is available as C-R
- new plastic container & closure needed for each prescription dispensed
- replace top closure only for glass containers
exceptions to C-R packaging
- sublingual NTG
- oral contraceptives
- hormone replacement therapy
- powdered unflavored aspirin
- effervescent aspirin
- powdered iron preparations
- effervescent APAP
waiving C-R packaging
- prescriber can waive C-R for single prescription
- pt can give blanket waiver for all → must document
consumer medication information
- useful written pt info is given to pts with each new prescription
- CMI handouts have drug info & added with prescription bag
- explain how to use the drug, receive benefit & avoid harm
patient package inserts
- all oral contraceptives must be dispensed with FDA- approved PPI
- outpatient/retail: each time its dispensed
- institutional:; prior to first dose & every 30 days after
medication guides
- FDA-approved pt handouts for meds that have serious & significant health concern
- how to prevent SEs & adherence to special instructions
- manufacturers must supply MedGuides so pharmacy can print them out
- give when:
- initial fills & refills in outpatient
- first time dispensed to HCP to administer to pt
- pt or caregiver asks
- MedGuide has been revised
- REMS drugs
drug classes where MedGuides should be given
- antidepressants
- NSAIDs
- insomnia drugs
- LABAs
- ADHD drugs
- diabetes drugs
- antipsychotics
- antiarrhythmics
- retinoids
- others: anticoagulants, bisphosphonates, mAbs, FQs, enbrel, ESAs, opioids, CNIs, controls, chantix
REMS
- from FDA amendents act of 2007 → to ensure benefits > risks
- communication plans, elements to assure safe use, implementation systems, MedGuides
- for thalidomide, isotretinoin, clozapine, phentermine/topiramate [Qsymsia], opioid analgesics, flibanserin [Addyi]
REMS - thalidomide
- risk: severe birth defects
- negative pregnancy test required before dispensing each prescription
REMS - isotretinoin
- risk: severe birth defects
- iPledge
- 2 negative pregnancy test before first fill & 1 negative test before each subsequent fill
REMS - clozapine
- risk: neutropenia
- monitor ANC
REMS- phentermine/topiramate [Qsymia]
- severe birth defects
- MedGuide required, healthcare training program, dispensed only through certified pharmacies
REMS - opioid analgesics
- risk: high abuse potential, life-threatening respiratory depression
- educate providers by completing REMS-compliant training & taking tests
- dispense with MedGuide
- educate on safe use, risks, storage & disposal
REMS - flibanserin [Addyi]
- risk: hypotension & syncope due to an interaction w/ alcohol
- no alcohol use while taking it
how long do you keep pt med profiles active
1 year
prospective DUR
- evaluation of pt’s med profile prior to dispensing → done by dispensing RPh each fill
- purpose to optimize pt’s therapy
retrospective DUR
review of drug therpy after drug is dispensed → done by state, medical institutions or insurance
concurrent DUR
ongoing monitoring during course of trx
when must pts be counseled
- Rx drug hasn’t been previously dispensed to pt
- refill is being dispensed in diff dosage form, strength or w/ new written prescription
- if pt requires counseling
- when RPh feels its necessary
what must counseling include
- directions for use & storage
- important of compliance w/ direction
- precautions & relevant warnings
when must RPh be available for counseling
RPh must beat least 6 days of the week & at least 40 hours per week
notice to consumers
- lets pts know they have certain rights → receiving counseling from RPh & pt’s right to ask questions
- easy-to-read type, interpreter services & drug prices
- in public view
HIPAA 1996
- protects privacy of PHI → ensure pt info is secure regardless if electronic, verbal or written
- PHI can be shared with HCPs, healthcare facilities & health insurance companies
- need HIPAA
- violations = fines & imprisonment
what’s included as PHI
- pt’s past, current or future physical or mental health
- healthcare provided to pt
- past, present or future payment for providing healthcare to pt
- when associated with health information: name, address, birthdate, SSN
who can you share PHI with
- pt
- HCPs
- payment/operational purposes
- limited data for research
- law enforcement
- DEA, FDA & BOP inspectors [for public health purpose]
incidental disclosures
unavoidable & acceptable under HIPAA
- oral coordination pt care at nursing station
- HCP discussing over phone with another HCP, pt or family member
- discussion between providers on rounds
- RPh discussing Rx w/ pt or HCP
privacy notice
- in prominent location within pharmacy
- give to pt on first day & any time requested
- good faith to get written acknowledgement
- distribute when there’s changes
- can still provide services if pt refuses to sign
- signed HIPAA privacy disclosure
how long must signed HIPAA privacy disclosure forms be kept for
6 years
CA rules for pt obtaining a copy of their records
must be able to inspect medical records within 5 business days & get copies within 15 business days
Orange Book
approved drug products w/ therapeutic equivalence evaluations
how to use the orange book
2 letter code system
- 1st letter: indicated if drug is therapeutically equivalent
- 2nd letter: additional info
first letter A: therapeutically equivalent
- AB: bioequivalence in vivo & in vitro
- AA, AN, AO, AP, AT = in vitro bioequivalence & no in vivo bioequivalence issues
3 character code
- when there’s more than 1 RLD of the same strength under the same heading
when can RPh substitute a diff formulation
to improve pt compliance → must have same active ingredients of equivalent strength & duration of therapy
which formulations can’t be switched
- long-acting and short-acting
- combo drugs and multiple single agents
biosimilar
highly similar to FDA-approved biologic [reference product]
substituting biologics
- cannot automatically substitute bc not considered therapeutically equivalent
Purple Book
licensed biological products w/ reference product exclusivity & biosimilarity or interchangeability evaluations
formulary
- preferred drug list w/ safest & most effective drugs while considering cost
- determined by P&T
P&T committee
- create & update formulary, conduct MUE/DUEs, monitor/report ADRs, conduct med error safety initiatives & develop clinical care plans/protocols
therapeutic interchange protocol
- made by P&T to dispense therapeutically similar drugs to meds prescribed
- cost-effective strategy
- ex: PPIs, statins, antacids, H2RAs, hypnotics, ACE-Is, ARBs, potassium supplements, ABXs, insulins, topical steroids, laxatives & stool softeners
legitimate mail order pharmacies
dispense meds pursuant to Rx from prescriber who has performed a good faith medical exam
ryan haight online pharmacy consumer protection act of 2008
prevents illegal sales of controlled substances via the internet
requirements for telepharmacy
- within 150 miles from supervising pharmacy
- RPh isn’t on site → techs are but do non-discretionary tasks
- techs can’t accept new prescriptions, compound meds or other discretionary tasks
- single RPh [off-site] can supervise 2 techs
- responsible tech has key
- counseling required → remotely
- drugs are stored at remote site → controls stored separately [management captured on video & keep for 120 days]
- countersign for control deliveries
- RPh must go on site at least once monthly
dispensing epi auto-injectors
- can dispense to pre-hospital emergency medical care person, lay rescuer or authorized entity
- physician must have written order to specify # dispensed
- can dispense for school based on written order
- dispense with product info sheet [name to who it was issued, Section 1797.197a responder””, “First Aid Purposes Only”, dosage, use & exp date
dispensing blood clotting products for home use
- have 24 hour on-call service available every day
- obtain all FDA-approved blood clotting products
- supply all necessary infusion equipment & supplies
- ship within 2 business days
dispensing during federal, state or local emergency
- can dispense in reasonable quantities
- keep record of date, pt’s name and address & drug/device name, strength and quantity dispensed
when does the mobile pharmacy have to cease activity after the emergency is over
48 hours
CA end of life option act of 2016
for mentally competent, terminally ill adults to self-administer drugs to end their life in peaceful, humane manner → death with dignity or physician-assisted
- ≥18 years
- CA resident
- mentally competent
- diagnosed with terminal illness that will lead to death within 6 months [confirmed by 2 physicians]
procedure for end of life seppuku
- pt makes request to MD & discuss
- after 15 days, pt makes second request
- after 1st request, makes written request
- after all 3 requests, furnish drugs directly to pt or send Rx to RPh
- MD must notify RPh & hand-deliver, mail or e-send prescription
- pt gets med
- pt does final attestation form & give to attending within 48 hours before taking the med
meds for aid in seppuku
CII secobarbital [cap] & pentobarbital [sol]
- take anti-emetic 1 hour before
requirements for ADDS in SNFs
- RPh reviews each med order & pt profile before drug is removed → override only in emergencies
- RPh stocks ADDS if stocking directly in facility
- RPH, intern or tech can restock if outside facility → tamper-evident
when must pharmacies that remotely operate ADDS register ADDS with the BOP
within 30 days of installing the device & then annually
requirements for repackage meds labeling
drug name, strength, dosage form, manufacturer’s name and lot #, exp date & quantity per repackaged unit
centralized hospital packaging
- BOP has specialty license for hospital pharmacy that does centralized packaging & one or more general acute care hospitals under common ownership and within 75 miles
section 503A
- traditional compounding
- allows RPhs to prepare small batches of a compound in advances based on dispensing hx
- pharmacies can sell compounds to prescribers for administration to pts in their office [needs to send purchase order]
- vets can buy compounds to furnish/dispense a 120 hour supply
- can compound pt-specific parenteral therapy for other pharmacies
section 503B
- permits specially licensed compounding facilities to operate as an outsourcing facility → can make bulk meds w/o prescription
- sterile drugs for humans
outsourcing facility requirements
- compliance with CGMPs
- listed as outsourcing by FDA & CA BOP
- cannot be licensed as sterile compounding pharmacy at the same time
- cannot perform functions of a pharmacy
- subject to inspection
- preparations are made/under supervision by licensed RPh
manufacturing characteristics
- regulation: FDA
- standards: FDA drug approval, USP, CGMPs
- NO individual prescription required
- interstate distribution: yes
traditional compounding characteristics
- regulation: state board
- standards: 503A, USP
- individual prescription required
- interstate distribution: up to 5% of total sales
outsourcing compounding characteristics
- regulation: FDA, state board
- standards: 503B, USP, CGMPs
- NO individual prescription required
- interstate distribution: yes
common HDs
antineoplastics, teratogenics, hormones, transplant drugs
minumum requirements for handing HDs
- engineering controls: closed-system transfer devices & negative pressure ventilated cabinets [hood or BSCs] → negative air pressure
- PPE: chemo gown, respiratory protection, goggles, 2 shoe covers, chemo gloves
- safe work practice, spill kits & disposal requirements
nuclear pharmacy requirements
sterile compounding permit from BOP
when must all actions to test ordering, interpreting & management be documented
within 24 hours
SB 493
allows RPhs to administer drugs & biologics by other routes [not PO & TOP] → need adequate training
who can CA RPhs administer routine immunizations to
≥3 year olds
requirements to administer vaccines
- complete CDC or ACIP-approved immunization training program
- maintain BLS certification
- complete 1 hour of CE every 2 years
immunization recordkeeping requirements
- notify PCP & prenatal care provider within 14 days
- report to CAIR
- update pt vaccine administration record
emergency contraception drugs
- levonorgestrel [Plan B One-Step] → OTC
- ulipristal [Ella] → Rx
- effective during first 72 hours → up to 120 hours [5 days]
- can furnish high dose birth control pills as off-label EC
furnishing EC protocol
- option if pt doesn’t have a prescription & wants to use insurance coverage
- RPhs need to finish 1 hour of CE
- ask about allergies, timing [up to 5 days], will not interfere with established/implanted pregnancy, & say to follow up with HCP
- can furnish for future use
- give fact sheet
- keep inventory of EC meds & adjunct meds
- can give up to 12 non-spermicidal condoms to each Medi-Cal & Family PACT beneficiary
naloxone
opioid antagonist that binds to & displaces opioid from receptor sites
- reverse action of opioid & overdose symptoms
- abrupt reversal can cause opioid withdrawal in chronic users
how to administer naloxone spray w/ assembly
- take off yellow caps
- put on white caps
- take purple cap off naloxone
- screw on naloxone capsule into syringe barrel
- insert white cone into nostril & give short strong push → ONE HALF OF CAPSULE INTO EACH NOSTRIL
- repeat in 2nd nostril if no reaction in 3 min
how to administer injectable naloxone
- remove cap from vial & uncover needle
- insert needle through rubber plug w/ vial upside down & draw 1mL
- inject into upper arm or thigh
- give 2nd dose if no reaction in 3 min
opioid overdose symptoms
- extreme or unusual somnolence
- respiratory difficulty
- miosis
- bradycardia
furnishing naloxone protocol
- can furnish w/o Rx
- must do 1 hour of CE
- only offer to those who request it & those at highest risk of overdose
- cannot waive pt counseling
how long must records of furnishing naloxone be kept
3 years
who are at highest risk of opioid overdose
- hx of prior overdose
- use of ≥50 MME/day
- concurrent BZD use
- recent period of opioid abstinence
- chronic illness that affects lung, liver or kidney