Tag: pharmacist in charge

Pharmacists: Protect yourself by spreading responsibility

The responsibilities of an Oregon pharmacist are extensive

A pharmacist licensed to practice pharmacy by the Oregon Board of Pharmacy has the duty to use that degree of care, skill, diligence and professional judgment that is exercised by an ordinarily careful pharmacist in the same or similar circumstances. See OAR 855-019-0200. The general responsibilities of a pharmacist are extensive, and there are many opportunities to make a mistake. See, e.g., OAR 855-019-0200(1)-(7) (listing some responsibilities). Moreover, a retail or institutional pharmacy may only only be operated when a pharmacist is physically present in the pharmacy to supervise the pharmacy. See OAR 855-041-1015(1). It should come as no surprise then, that most mistakes or problems will be assigned to the pharmacist on duty when the mistake is made or the problem arises in some damaging way.

Be wary, share the problem, and implement corrections

Although a practicing pharmacist will always be responsible for meeting professional standards, be wary of accepting responsibility for institutional problems, or the problems of others. If workload is too high to avoid medication or dispensing errors, or if technicians or cashiers are exceeding the lawful scope of their respective roles, or whatever the problem may be, expose and share the problem. Be proactive. Find and implement solutions. Otherwise, you may be assuming sole responsibility for problems and mistakes that will no doubt occur under your supervision.

Do not become isolated; report upstream; seek help

If problems are not easily corrected, do not sit of the problem. Do not become isolated with the problem. Instead, report the problem upstream. A friendly email spotting a potential problem and asking for help is a good place to start. Proposing a solution is even better. The worst thing you can do, however, is to become isolated and do nothing, all the while being responsible for an unsafe practice that will eventually result in a problem that is reported to the Oregon Board of Pharmacy. When that happens, blaming the pace of workplace, or the staff, or the corporate management, will not get you very far if you failed to address the problem you spotted on your watch, while you were supervising the pharmacy.

Report the problem to others licensed by Oregon Board of Pharmacy

Each pharmacy must have one pharmacist-in-charge employed on a regular basis at each location who shall be responsible for the daily operation of the pharmacy. See OAR 855-041-1010(1). Share the problem with your pharmacist-in-charge. If you are the pharmacist-in-charge, report up to management and ownership. Remember, the pharmacy is also licensed by the Oregon Board of Pharmacy, and the pharmacy must ensure that it is in compliance with all state and federal laws and rules governing the practice of pharmacy and that all controlled substance records and inventories are maintained in conformance with the keeping and inventory requirements of federal law and board rules. See OAR 855-041-1010(2). If you instead choose to “sit” on a problem until it results in a complaint to the Oregon Board of Pharmacy – because your believe you lack the authority to correct the problem, or your believe that management “won’t do anything” – then the problem will be your problem alone, when the Oregon Board of Pharmacy becomes involved. Don’t let this happen to you.

When all else fails

If you genuinely believe you have no one to report to that will help you, then the problem is truly yours to resolve. At this point, you will be best served to consult a pharmacy inspector, or an experienced attorney, for guidance. An experienced licensure attorney can contact the Board of Pharmacy looking for solutions, without disclosing your name. In the rare event that you are left with no other alternative than to report your pharmacy to the Oregon Board of Pharmacy, an experienced licensure attorney can make the report for you, in the most constructive fashion. The alternative is to sit on a ticking time bomb. Don’t do it.

For Pharmacists: Three medication errors could mean probation and loss of PIC

It is well accepted that dispensing or medication errors occur with some regularity in the practice of pharmacy. While most dispensing errors are never reported to the Board of Pharmacy, once they are, there are consequences for the dispensing pharmacist. For a first and second reported dispensing error, the dispensing pharmacist is at risk of professional discipline by the Board of Pharmacy, most likely a reprimand, and a fine ranging from $1,000 to $5,000.

During one recent case, however, it was revealed to me that the Board of Pharmacy is of the view that for a third reported dispensing error, the presumptive sanction is a fine, plus five-years of probation, and loss of pharmacist-in-charge (PIC) privileges. This is true even when pharmacy workload is a factor, and the prescription involves a look-alike or sound-alike drug.

What you need to know

You need to know that the Board of Pharmacy is imposing discipline upon pharmacists for dispensing errors even though pharmacists know, and the literature establishes, that dispensing errors cannot be fully prevented. For example, according to one study cited by the Institute of Medicine’s 2007 report, 1.7 percent of new and refill prescriptions are dispensed in error:

This more recent, large-scale study of both new prescriptions and prescription refills found an error rate of 1.7 percent (Flynn, et al., 2003). This dispensing error rate translates to approximately 4 errors per 250 prescriptions per pharmacy per day, or an estimated 51.5 million errors during the filling of 3 billion prescriptions each year. One study of medication errors at Medco Health Solutions, Inc., a large mail order pharmacy, carried out by Medco employees, found a dispensing error rate of 0.075 percent—16 dispensing errors among 21,252 prescriptions (Teagarden, et al., 2005).

Preventing Medication Errors: Quality Chasm Series (2007). Retrieved from: http://books.nap.edu/openbook.php?record_id=11623&page=113.

Applying the above error rate of 1.7% to a pharmacy filling 1,500 prescriptions per week indicates that 25 dispensing errors occur each week in that pharmacy. Dispensing errors are not, however, fully preventable, due to what has been described by Stuart R. Levine, et al., as a “latent failure” in the practice of pharmacy:

“Medication errors rarely occur from the failure of a single element or because of mistakes from a single practitioner. Rather medication errors are the result of the combined effects of ‚Äòlatent failures’ in the system and ‚Äòactive failures’ by individuals. Latent failures are weaknesses in the structure of the organization, * * * . By themselves, latent failures are often subtle and may cause no problems. Their consequences are hidden, becoming apparent only when they occur in proper sequence and are combined with active failures of individuals to penetrate or bypass the system’s safety nets. Many of the latent and active failures that were at the root of medication errors are not apparent until a root cause analysis is performed. [Footnote omitted] For this reason, providing an optimal level medication safety requires both recognition and correction of latent failures in the system. * * * . It is unrealistic to expect absolute perfection or error free performance from any person. * * * .”

Stuart R. Levine, et al., Guidelines for Preventing Mediation Errors in Pediatrics, p. 427.