Medication Management: Managing the Medicine Cabinet on - PowerPoint Presentation

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Medication Management:

Managing the Medicine Cabinet on CenterMarch 9, 2016Shannon Bentley, RNGary Strokosch, MDLizzy Drobnick, MPH, MASlide2

Goals

Provide students’ medications safely and within the scope of your state’s professional practice lawsEnsure safety and monitoring precautions are in place Teach students self management skills within the boundaries of maintaining student safety

Have medication readily

available just like a medicine

cabinet

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DISCLAIMER*

The National Office is taking an interest in medications on center, and there will be more information shared in the near future

Professional practice laws vary tremendously from state to state

These laws apply to Pharmacy, Nurse, Physician, Dentist, and other healthcare professions

Know your state’s practice acts, as well as other applicable

statutes

and

regulations Practice within your scope of care

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Pharmacy Laws

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Pharmacy Laws

Cover pharmacies, pharmacists, pharmacy technicians, pharmacy practice, and medication management Statutes or ActsWritten laws passed by legislative bodyBroad scope Regulations or Rules

Written

laws

issued and adopted by executive agencies

Provide the details to implement the statute

Usually adopted through state board of pharmacy

Both statutes and regulations are laws Slide adapted from ASHP

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Pharmacy Laws

Statute Examples Pharmacy Practice Act of the State of Illinois (State – Illinois) Controlled Substances Act (CSA) (Federal) Regulation Examples

TITLE

68: PROFESSIONS AND

OCCUPATIONS, CHAPTER VII: DEPARTMENT OF FINANCIAL AND PROFESSIONAL

REGULATION, SUBCHAPTER

b: PROFESSIONS AND

OCCUPATIONS, PART 1330 PHARMACY PRACTICE ACT (State – Illinois)Title 21 United States Code (USC) Controlled Substances Act (Federal) 6Slide7

Rules and Regulations Agencies(2013

)

Light

Purple

– Division of Occupational Professional Licensing

Yellow

– Board of Pharmacy & Department of Licensing and Regulatory Affairs

Dark Green

– Board of Pharmacy & Division of Public Health

Light Green – Pharmacy Examining Board

Blue – Board of Regents

Gray

– Board of Pharmacy & General Assembly

Blue

– Board of Regents

Turquoise

–Board of Pharmacy

Orange

– Board of Pharmacy

&

Department of Health

Dark Pink

– State Board of Pharmacy

&

Department of Financial and Professional Regulation

Light Pink

- Department of Financial and Professional Regulation

&

Department of Consumer Protection

Dark Purple

– Board of Registration in Pharmacy

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Pharmacy Laws: Key Lessons

Both statutes and regulations are lawsYour center must be aware of and in compliance with all laws

So

what? Why does this matter to me? I’m not a pharmacist

?

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Common Center Issues

Does your center:Stock prescription medications for dispensing?Repackage medications for evening or weekend doses?Use bubble packs that, when broken apart, do not contain all of the labeling information?Allow residential

or

security

staff to administer medications on evenings and weekends?

Dispose of medications by throwing them in the trash or flushing them?

Not dispose of medications after a student has left Job Corps?

If you answered yes to any of these questions, your center may be violating your state’s pharmacy laws9Slide10

State Pharmacy Laws

State pharmacy laws include, but are not limited to:DispensingLabelingRepackaging Monitoring and record keeping

Administering

Educating / Counseling (consumer

medicine

information)

Disposing

Please note that other laws, such as the Nurse Practice Act or Physician Practice Act, also cover administration and pharmaceutical management10Slide11

Commonalities Between State Pharmacy Laws

If state pharmacy law or federal law has stricter requirements on the same issue, the stricter requirement must be followedPractice laws outline information to be included on the label, although labeling differs greatly between states

While

physician

or dentist dispensing

is permitted in most states, it is often carefully regulated and restricted to samples or conditions of immediate

need

Some states require dispensing doctors to have a special permit or license, or they need to be registered with their state’s Board of PharmacyPrescriptive authority varies widely by state and practitioner type; for example, clinical nurse specialists have prescriptive authority in 26 states 11Slide12

Did you know?: Example of State Pharmacy Laws

No chain pharmacies allowed in North Dakota The North Dakota’s Pharmacy Ownership Law from 1963 states that only a licensed pharmacist or group of pharmacists can own and operate a pharmacy within the stateAll prescriptions are supposed to be submitted electronically in New York starting in March 2016Federal institutions are currently exempt from this law, but please follow up with your regulatory agency in NY to confirm

The 2005

federal Combat Methamphetamine Epidemic Act (CMEA) was established to regulate OTC

pseudoephedrine (PSE) sales; but, Oregon and Mississippi have sticker state laws that classify PSE

as a Schedule III substance, requiring a

prescription

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ROCA Examples: Concerns

Example 1: For weekends, the nurses repackage medications on Friday afternoons into separate envelopes for each dose. The medications are in labeled envelopes with the date and time of administration written on the envelope. This violates state law as the envelope labels do not contain all of the required information.

Example 2:

LPNs in this state are not allowed to dispense or administer OTC medications in accordance with their practice act. However, the LPNs on center regularly dispense OTC medications to students.

Example 3:

When a student separates from the center and is not provided with their medication, the center keeps the medication on center and does not dispose of it, given cost concerns. Medication prescribed for a former student is then used for current students so the center does not have to purchase more medications. This violates state law.

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ROCA Examples: Promising Practices

Example 4: The center has a pharmacy license. Under state law, licensed nurses are allowed to dispense medication, and trained non-medical personnel are allowed to observe medication self-administration. Weekend medications are stored on an open medication cart, which is placed in the hallway of the locked HWC. A security staff member trained in medication self-administration opens the HWC and observes the students taking their medication.Example 5: All scheduled medications and most other medications are sent to the center in bubble packs. The center has a stock supply of some frequently used antibiotics that, under the CP’s direction, can be dispensed by the center nurse. State

pharmacy

act 65-1635

(c) permits this activity.

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Assessing Compliance: PIN 15-27

Make sure you keep current copies of your pharmacy and nursing practice acts and applicable regulations According to PIN 15-27, each center must have printed copies of the pharmacy and nursing acts. It should be available for review by assessor(s) during an assessmentCompliance will be reviewed during ROCA,

and if

a copy of the pharmacy act is not available for review, it

will be cited as a concern under 6.12 R5: Professional Standards of Care:

All center health staff and providers shall follow accepted professional standards of care and

are subject to prevailing state laws

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Medication on Center

Key information for HWMs, Wellness staff, Center Directors, and Other applicable staff 16Slide17

In the Health & Wellness Center

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Managing Medication In the Health & Wellness Center

New students’ medications should be brought to the Health and Wellness Center (HWC) to be logged in; evening doses should be made available for students if the HWC is closedEach student medication should have a medication administration record (MAR) to track medication and complianceEach student initially should come into the HWC daily for their prescription medications

For psychotropic medication, the CMHC should collaborate

with center physician and Health-and-Wellness staff on psychotropic medication monitoring of stable

students

and document monitoring in the SHR

All prescription medications must be documented in the student health record via a center created medication administration (MAR)sheet with additional notes taken on the SF-600, Chronological Summary of Medical Care, if necessary

All OTC medications must be documented on the SF-60018Slide19

Controlled Substances

Centers shall comply with all state and federal regulations regarding controlled medications Controlled substances include narcotics and psychostimulantsKnow the PRH requirements outlined in Chapter 6, 6.12 R6Check your state pharmacy laws, state police and local pharmacies on the available ways to dispose of left over or expired medications

Any miscounts or missing medications identified during the inventory shall be immediately reported to the Regional Office by the Center

Director

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On Center Outside the Health & Wellness Center

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Personal Authorizations for Non-Health Staff

Monitor students’ use of prescription medicationsMake available prescription medication for self-administrationMake available over-the-counter medications and devices (e.g., Tylenol, Maalox, condoms)Obtain and record vital signs including:Temperature

Pulse

Respiration

Blood pressure

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Give basic first aid for major problems including:

Cardio-pulmonary resuscitation

Treatment of shock

Control of bleeding

Splinting or stabilizing of fractures

Conduct alcohol testing based on suspicious behavior

Call HWM or Officer of Day, who will contact RN or MD

Call the RN or MD directly

Send the student to the ERSlide22

Medication Management in Residential Living

Prescriptions are packaged according to state lawsMedication is made readily available like a medicine cabinetStudents self-administer all medication Sign-out sheets must be used to monitor and track all medications that

are

made available to students

All student prescription medications must be secured in a lock box in the residential advisor

office

RAs should not handle or administer any medication

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Residential - Prescription Medication Observation Records

MORs should include:Student’s name at topPlace for student signaturePlace for staff namePlace for staff signatureDate

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Examples of Making

Prescriptions Available Outside HWC HoursExample 1: Students have mailboxes with locks in HWC for weekend and evening doses. Trained security staff let students into the HWC where the student unlocks their own mailbox and self-administers their medication. Observation is recording on a Med Observation Record (MOR).Example 2: A filled and locked medication cart is set up in the HWC or Safety after hours and trained security staff makes the medication readily available for student self-selection. Observation is recorded on a MOR.

Non-medical staff should only observe medication self-administration; non-medical staff should not administer medication

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Examples of Making

Prescriptions Available Outside HWC HoursExample 3: Medications are sent to residential in secure lock box. The RA opens, makes available, and observes the student self-administer their medication; this is similar to a medicine cabinet. Observation is recorded on a MOR.Example 4: Daily dosing made available during HWC open hours. Assigned nurse works evenings and weekends to make available individual dosing for all students on prescribed medications.

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Managing OTC Supplies in Classrooms, Dorms, & Other Areas

Process: Have a student sign-out sheetStudent self-selectsGoals:Help students learn to manage minor conditions

Teach employability skills

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Over-the-Counter (OTC) Sign Out Sheets for Dorms, Classrooms, & Other Areas

Should include:Slot for name of OTC medicationPlace for student namePlace for student signaturePlace for staff namePlace for staff signatureDate and time

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First Aid Kits in Dorms and Classrooms

Acetaminophen and/or IbuprofenTweezersAlcohol wipesAntiseptic hand cleanerMedical adhesive tapeSterile gauze (four inch squares are best)

Elastic bandages

Several sizes of adhesive bandages

Insect bite swabs

Triple-antibiotic ointment

Hydrogen peroxide

Bandage scissorsTriangular bandagesInstant cold packs

Exam gloves

Barrier device for CPR

Important contact numbers- nurse on call, duty officer, emergency numbers, 911

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Leaving the Center

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Student Travel and Medications

Prescription medications should be available to students when they travel on weekend pass or on break Travel packaging must comply with your state’s labeling lawsStudents may self-prepare their medications for travel in a travel-friendly container if it complies with state laws

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Separated Students and Medications

If a separation occurs when the HWC is open, all separated students should be provided with their medications when they leaveIf a separation occurs when the HWC is closed, students should be provided with their medications through:Mail: All prescribed medications should be sent overnight to the student if allowed by sending and receiving states’ laws

Pharmacy in student’s home town: Call in an order for a supply until the student can see a new provider; this can be done by the CP, referred prescriber, or personal physician

Communication is key between center departments to ensure Wellness is aware that a student has departing and medications can be made available when student leaves

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Ideas for Medication Management on Center

Disclaimer: The National Office is looking at medications on center, and there may be more coming out from them in the near future. For now, please be sure you know your state professional practice laws, and it is suggested each center have written medication policies to ensure the safe delivery of medications to students.

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SOPs

Each center is recommended to have the following SOPs:Prescribed MedicationsControlled SubstancesOTC Medications

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Know the Statutes

Example: A center discovered that in their state the center could get a limited pharmacy license with the CP named as the responsible professional. Under these circumstances, the nurse can act as a pharmacy tech under the supervision of the CP and dispense medications, as long as their CP is on center. They can also train residential advisors to administer medications under the supervision and training of the nurse and CP. SOPs have been written to describe these policies. The center invited a pharmacist to inspect their program and policies for consistency with state statutes.34Slide35

SOPs

Most center have no SOPs regarding the prescription, dispensing, and administration of OTC or prescription medicationsAlthough required in the disability program, NONE are currently required in the HW program, except for a rarely read instruction in PRH Change Notice 12-06 (Job Corps Health History Form) from Nov 26, 2012: “Each center should have an SOP for handling alert questions”It is suggested that each center have SOPs for medication management

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Examples of Medication Management Language for SOPs

Pre-packaged bubble packs or punch packs by local or mail order pharmaciesApplying for pharmacy license (if applicable) to be able to dispense stock doses of certain medications, such as antibioticsLocal pharmacies “take back” unused or expired medications to dispose of properly

Utilizing local law enforcement that set aside several days a year for medication disposal

Using mailboxes kept in locked area for prescription doses when HWC is closed with individual student keys; students self-administer doses

Allowing students to self-package their medications for travel or weekend doses

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Disclaimer: Laws vary by state; Be in compliance with your state and federal laws. Slide37

Example: Medicine Administration Record (MAR)

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Example: Prescription Medication Observation Record (MOR)

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Example:

Controlled Substance Medication Observation Record (CMOR)39Slide40

Over-the-Counter (OTC) Sign Out Sheet

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Questions shall

be answered in a forthcoming document. Please submit questions electronically via chat or email to be included in the Q & A document.Thank you! 41