Important Advocacy Activities
Advocacy activities include developing relationships with other entities, assisting in developing policies and practice standards by other entities, developing MSHP policies and practice standards, and direct involvement in regulatory development.
- Objectives of the original Constitution and Bylaws related to legislative activity and minimum standards of practice.
- Representation on ASHP Councils and committees and comment on policies, resolutions, and guidance documents.
- Public comments on proposed federal laws and regulations.
- Annual Strategic Planning emphasis on advocacy and regulatory issues.
- Legislative/Public Policy Committee continuous monitoring of regulatory issues and developing policy statements, mission statements and practice guidance, especially related to pharmacist and technician scope of practice.
Board of Pharmacy
- Recognition of hospital practice as a separate practice setting with different regulatory needs.
- Addition of an institutional/hospital pharmacist as an appointed member of BOP.
- Development of first BOP Hospital Pharmacy rule, later rescinded after lawsuit.
- Appointment of hospital pharmacists to non-institutional member positions on BOP.
- Regular attendance by MSHP representatives at open session BOP meetings and appointment by MSHP of an informal liaison at BOP meetings.
- Legislation and rules that clarify pharmacist authority to engage in MTS.
- Continuous efforts for 40 years to improve technician education and training standards and expand technician scope of practice, resulting in an early Attorney General opinion and multiple legislative and rule proposals.
- Development of first Sterile Compounding Rule primarily for licensed pharmacies, and revisions that established standards of practice applicable to all settings, consistent with and in addition to USP 797.
- Establishment of a Hospital Pharmacy Working Group and a Hospital Advisory Committee.
- Establishment of Working Groups for specific issues based in part on hospital practice needs, including MTS rules, technicians, drug administration by pharmacists, and sterile compounding.
- Legislation that clarified BOP hospital authority, provided joint rule authority by BOP and DHSS, and established a permanent Hospital Advisory Committee,
- Discussion by Hospital Advisory Committee of full scope of activities that fall under BOP authority, and limited discussion of non-BOP authority issues.
- Addition of Class B Hospital Pharmacy section to BOP Practice Guide.
- Independent Practice Advancement Coalition that developed proposed language for pharmacist prescribing and controlled substance authority.
Department of Health and Senior Services
- Recognition of DHSS as having primary regulatory oversight of pharmacy services and medication use through hospital licensing authority.
- Clarification of BOP and DHSS jurisdiction for many practice issues.
- Establishment of general standards of practice through policy and hospital licensing rules.
- Year-long review of DHSS Pharmacy Services/Medication Management rule facilitated establishment of relationship with new non-pharmacist BOP Executive Director and re-establishment of relationship with MHA.
- Continuous successful partnership with DHSS Pharmacist Consultant for over 20 years.
Missouri Hospital Association
- Early support for administrative and program services through informal relationship.
- Later increased services support and potential legislative support through an informal affiliation agreement.
- Loss of relationship subsequent to BOP Hospital Pharmacy rule.
- Re-establishment of relationship through participation in DHSS Pharmacy/Medication rule review process.
- Invited to nominate members and participate on BOP Hospital Advisory Committee.
- Support for full scope of pharmacist practice and medication responsibility, advanced pharmacist practices and expanded technician scope of practice.
- Sponsorship of programs and webinars for hospital administrators, nurses and pharmacists on pharmacy issues.
- Development and promotion of legislative and rule proposals for TCT and remote technician supervision.
Missouri Pharmacy Association
- Early participation on MPA Executive Council by MSHP members.
- Continuing efforts to educate MPA management and membership about hospital pharmacy through participation in MPA professional and legislative activities.
- Two MSHP members serving on MPA Board of Directors in various committee and officer positions, including President of the association.
- Invited to nominate a member and participate on BOP Hospital Advisory Committee.
- Support from MPA in establishing Institutional Pharmacist position on BOP and submitting names to Governor for other appointments.
- Controversial relationship related to technician education, training and certification requirements.
Timeline of Advocacy Activities
- Objectives of the original Constitution and Bylaws included assuring the highest quality of professional care by establishment of optimal professional standards through various efforts, including legislative. One of three objective goals of the Board of Directors was establishing Minimum Standards of Hospital Pharmacy.
- Assisted the Missouri Nurses Association and the Missouri League for Nursing in development of IV therapy administration guidelines.
- Offered to participate on a pharmacy leaders committee of the Missouri Board of Pharmacy (BOP), but the offer was not accepted.
- Discussed hospital pharmacist representation on BOP with the Missouri Pharmaceutical Association (MPA). An MSHP member pharmacist was included on the MPA list of pharmacists recommended to the Governor for appointment.
- Developed an informal relationship with the Missouri Hospital Association (MHA) to obtain certain clerical and programming services.
- Participated in Missouri Professional Standards Review Organization (PSRO) review of standards or care for Medicare, Medicaid and other federal reimbursement programs.
- Developed a “Minimum Standard for Hospital Pharmacy” document including recommendations for high quality services.
- Successfully opposed a proposed bill that included an unworkable pharmacist to technician ratio.
- Joined the Midwest Health Congress and supported regulatory efforts for pharmacy practice into the 1990s.
- Recommended proposed regulatory language developed through a Missouri Regional Medical Program grant, separately from MSHP, to the Missouri Division of Health, but no action was taken by DOH.
- Successfully opposed a bill to prevent any person not licensed as a pharmacist from handling prescription drugs in a pharmacy.
- Placed the names of two hospital pharmacists on the MPA list of candidates for BOP appointment to the Governor.
- Developed revised proposed rule language and provided to BOP, including a request that a hospital pharmacist accompany the BOP inspector when inspecting a hospital, but no action was taken by BOP.
- Joined with MPA and the Missouri Foundation for Pharmaceutical Care (an MPA-derived organization) to form the Pharmacy Political Action Committee, which funded a lobbyist to promote legislation of interest to pharmacy.
- Obtained a pledge of support of MHA for any legislation to include a hospital pharmacist on the BOP.
- Met with the Department of Consumer Affairs regarding an institutional pharmacist on the BOP and differentiating institutional pharmacy in the pharmacy practice act.
- Formed a committee within PPAC to develop standards of practice for hospital pharmacy.
- Became more directly involved in lobbying legislators through the Legislative Committee regarding pharmacy practice bills, including one to add an institutional pharmacist to BOP.
- Established an informal affiliation with MHA that increased clerical and program support and provided the potential for lobbying services to the state legislature.
- Successfully promoted a bill along with PPAC that required one member of BOP to be an institutional pharmacist who provided pharmacy services to a hospital or long-term care facility on a full-time basis.
- Successfully promoted a hospital pharmacist to be appointed to the newly created BOP institutional pharmacist position.
- Provided proposed rule language to BOP referencing use of qualified personnel under a pharmacist’s supervision that prompted an Attorney General opinion regarding use of unlicensed persons in retail settings.
- Successfully supported the appointment of a hospital pharmacist to the newly created position of Executive Director of the Board of Pharmacy.
- Provided a draft rule for hospital pharmacy practice standards that became effective in 1984, but was rescinded in 1985 after a lawsuit by MHA.
- Unsuccessful bills promoted by PPAC were related to CE, third-party payors, and crime.
- Began annual participation in MPA Legislative Day, sometimes as an informal partner and sometimes making presentations.
- Supported the hiring of a full-time pharmacist with hospital pharmacy management experience by DOH.
- Supported a request by the Department of Health (DOH) for BOP to convene a committee on hospital pharmacy practice similar to the BOP Long-term Care practice committee, but the request was denied.
- Supported DOH/BNDD proposed rules regarding administration of controlled substances in emergency rooms and controlled substance disposal and recordkeeping procedures.
- Approved a resolution “Training, Scope of Responsibilities and Supervision of Pharmacy Technicians” opposing laws and regulations that create barriers to the use of technicians.
- Increased an effort to have a MSHP Board of Directors (BOD) member attend each open session BOP meeting, in addition to the DOH pharmacist and the BOP Institutional Member, who were both MSHP members.
- Sponsored the Missouri Consensus Conference on Technical Personnel with a grant from ASHP, developing 25 consensus statements.
- Developed “Strategies to Advance Pharmacy Practice in the State of Missouri” by the MSHP Research and Education Foundation (R&E) with a pharmaceutical company grant. The two-day meeting produced twelve areas for discussion and the group evolved into the Task Force on Pharmacy Practice in Missouri.
- Supported a BOP Sterile Compounding rule with language developed by an MSHP member.
- Subsequent to Missouri nurse collaborative practice law authorizing nurses to administer, prescribe and dispense drugs, supported a BOP proposed rule to allow “scope of practice protocols” with physicians that would allow a pharmacist to initiate, monitor or modify drug therapy, and a proposed rule allowing pharmacists to administer drugs. Both proposed rules were withdrawn due to opposition from physicians and nurses.
- The Task Force on Pharmacy Practice in Missouri developed nine goals and a “Mission Statement for Pharmacy in Missouri” that focused on pharmaceutical care and optimal therapeutic outcomes.
- Supported DOH revision of their Pharmacy Services rule as a completely revised Pharmacy Services and Medication Management rule, bringing all aspects of medication use in the hospital under the oversight of the Director of Pharmacy and the Pharmacy and Therapeutics Committee.
- Provided input to BOP bill that required registration of technicians, and referred specifically to technicians employed by a “hospital or licensed pharmacy”.
- Participated in BOP review and significant revision of the Sterile Compounding rule, including a requirement that all BOP inspectors receive specific sterile compounding training.
- Participated on the Governor’s Missouri Commission on Patient Safety, which recommended the formation of a state patient safety organization.
- Supported a bill that clarified that the Pharmacy Practice Act did not prohibit the use of auxiliary personnel under the direct supervision of a pharmacist in any of his or her duties.
- Monitored a Pharmacy Practice Act change intended to provide pharmacist authority to administer vaccines by protocol, administer medications by prescription order, provide medication therapeutic plans and provide medication therapy services (MTS) by protocol with a physician.
- Discussed the newly enacted MTS protocol allowances and asked BOP for guidance regarding hospital application. BOP stated rules would have to be promulgated first.
- Promoted extended scope of practice for technicians beyond what BOP considered acceptable during annual meeting, prompting BOP discussion that included a recommendation that all technician activity be supervised in person.
- Supported a formal request by DHSS for BOP to form a hospital pharmacy committee, but the request was denied. Continued to attend BOP open session meetings, comment on rules or policies from a hospital perspective, and generally encourage BOP coordination with and support of DHSS hospital pharmacy rules.
- Supported DHSS opposition to proposed BOP revision of Administration by Medical Prescription Order rule and request for significant revisions.
- Provided formal signature support for the ASHP Technician Initiative that recommended advanced levels of practice, ASHP-accredited training and certification as prerequisites for technician registration.
- Supported a DHSS request to appoint a BOP advisory group to draft rules for implementation of additional parts of the 2007 law allowing MTS by protocol with a physician.
- Continued a long tradition of the Legislative/Public Policy Committee and included advocacy/regulatory authority as the number two priority for a second year during annual Strategic Planning.
- Focused Public Policy Committee priorities on prescribing/ordering under the new MTS statute, administering by a pharmacist and technician use, and including discussion of these issues at open BOP sessions.
- Joined the Missouri Pharmacy Coalition (MPC) and participated in MPC advocacy for patient, professional and regulatory initiatives over a four-year period including recommendations for technician education and training and administration of medication by pharmacists.
- Appointed a Technician Task Force that developed the “MSHP Position Statement on Technician Education Requirements” and provided it to BOP.
- Informally appointed a Public Policy Committee member as a BOP Liaison to attend all open sessions and serve as MSHP representative when appropriate.
- Continued with DHSS to request rules for 2007 MTS protocol authority and participated in BOP MTS Rules Working Group, the first of several working groups requested by DHSS/MSHP over the next several years that provided clarification of hospital practice issues. The MTS which culminated in final rules becoming effective in 2012.
- Participated in extensive discussions of technician education, training and scope of practice with BOP and MPC.
- Supported DHSS review of hospital licensing rules affecting medication use such as nursing, medical records and construction standards.
- Participated in extensive discussions and development of proposed legislative language with the 18-member BOP Pharmacy Technician Working Group
- Participated in DHSS hospital licensing Pharmacy Services/Medication Management rule review and extensive proposed language revision.
- Requested five known technician training programs in Missouri to consider ASHP accreditation status, and one complied.
- Reviewed Kansas BOP regulation allowing remote supervision of technicians in rural hospitals and developed proposed regulatory language.
- Met with MHA to discuss common interests and a focus on patient safety issues.
- Re-established a close working relationship with MHA after being estranged for about 25 years, facilitated by both organizations participating in the DHSS rule review process and the BOP Hospital Working Group.
- Continued to advocate with DHSS on hospital practice issues which resulted in the formation, after about 25 years of requests, of a Hospital Pharmacy Working Group, with MHA and MPA as participating members.
- Participated in developing revised proposed BOP legislative language for technicians.
- Participated with MPC in developing proposed language for BOP Administration by Medical Prescription Order rule.
- Proposed 10 tasks at the top of the Strategic Planning list relating to advocacy for laws, regulations and standards to improve patient care.
- Formalized Public Policy Committee to include 7 specific goals relating to advocacy, including development of legislation/regulations, more timely dissemination of information to the membership, continuing a long tradition of monthly telephone conferences, beginning the tradition of a Public Policy article in each edition of the MSHP Newsletter and providing formal comment on federal regulatory issues.
- Participated in review of proposed BOP technician rule language for activities that a technician may not perform.
- Reactivated the Technician Task Force to develop recommendations separate from BOP due to reluctance of BOP to address training, education and certification.
- Developed a tech-check-tech (TCT) proposal.
- Developed the revised “MSHP Technician Training and Certification Requirements” position statement.
- Appointed a MSHP Pharmacy Practice Model Initiative (PPMI) Task Force and conducted a PPMI membership survey.
- Supported a bill that was the outcome of the Hospital Working Group that addressed BOP hospital authority, joint rules with DHSS, MTS and authority for a formal ongoing Hospital Advisory Committee, that became effective in 2014.
- Provided formal comment on USP 800.
- Promoted a MSHP member for appointment to BOP.
- Promoted a statewide Pharmacy Practice Model Initiative.
- Supported the appointment of an MSHP member to an open non-institutional BOP Member position.
- Participated with MHA in developing and presenting a webinar to discuss the hospital revisions of 2014 to the Pharmacy Practice Act.
- Began active participation in the newly appointed BOP Hospital Advisory Committee (HAC) that included BOP-appointed members from MHA, MSHP, MPA, DHSS licensed hospitals and BOP. Participated over the next five years in HAC review of numerous regulatory and practice standards that did not result in regulatory changes but helped establish standards of practice for hospital pharmacy services.
- Participated in a full review of the proposed DHSS Pharmacy/Medication Management rule with the HAC.
- Participated with HAC through 2017 in an extended review of BOP Administration by Medical Prescription Order rule, providing language that would not exclude administration in hospitals, that became effective in 2018.
- Included promoting partnership with MPA as a legislative performance priority for Strategic Planning.
- Began an annual effort to support and promote a Prescription Drug Monitoring Program bill, similar to annual bills that had been filed since 2004.
- Suggested changes with HAC to proposed language from MPC for the BOP Administration by Medical Prescription Order rule, which became effective in 2018.
- Participated in the reactivated BOP Technician Working Group that proposed three levels of technician registration.
- Participated in the BOP Sterile Compounding Work Group from 2013-2017 in extensive review and revised final language for BOP Sterile Compounding rule.
- Participated in a Practice Advancement Coalition of pharmacists representing organizations, regulators, educators and various practice settings that developed proposed bill language that provided authority to prescribe drugs and controlled substances under an MTS protocol.
- Began a focus on expanding pharmacist scope of practice, specifically obtaining pharmacist prescribing authority, as a Strategic Planning priority goal that continued for the next three years.
- Participated in another full review of the proposed DHSS Pharmacy/Medication Management rule which resulted in recommending elimination of many provisions to be in compliance with a new hospital statute requiring consistency with federal Centers for Medicare and Medicaid (CMS) rules through HAC.
- Participated with HAC in discussions resulting in a new section of the BOP Pharmacy Practice Guide for Class B Hospital Pharmacy licensees.
- Continued intense discussions in the BOP Technician Working Group resulting in proposed legislative language for three levels including certification, but the proposal was not accepted by the Governor’s office, possibly because of the Governor’s effort to reduce unnecessary or burdensome regulation.
- Participated with MHA and HAC in developing proposed bill and rule language for TCT and remote technician supervision, to be implemented through hospital licensing law and rules rather than through BOP.
- Discussed with MHA alternative proposed bill language to provide regarding pharmacist controlled substance authority, but no bill was filed.
- Participated in continuing discussions of MHA proposed TCT bill and rule language with HAC, BOP and DHSS.
- Developed medical marijuana policies.
- Provided formal comment on USP 797 revision.
- Joined with MHA to present a USP 797 revisions seminar to hospital administrators, nursing and pharmacy.
- Participated with MPA and the Practice Advancement Coalition in developing and filing a bill authorizing pharmacist prescribing and controlled substance authority that was not successful.
- Charged the Public Policy Committee through Strategic Planning to address prescribing authority with a goal of formal recognition of provider status to justify new reimbursement streams from third parties.
- Continued to support proposed DHSS TCT rule language over MPA and BOP objections.
- Reactivated Technician Task Force to develop “Guidance for Tech-Check-Tech (TCT) Program”, including training, certification and competency evaluation, based on DHSS opinion that rule language not necessary.
- Participated in continuing discussions of BOP Sterile Compounding rule to be consistent with USP 795, 797, 800 and 825.
- Participated in the MPA Pharmacy Practice Workgroup.
- Supported BOP complete revision of BOP Nuclear Pharmacy rule.
- Participated with HAC and DHSS in final revision of DHSS Pharmacy/Medication Management rule.
- Discussed numerous additional practice issues with HAC, including distribution between hospitals, non-Class B guidance issues, disposal of patient home medications, non-sterile packaging in clinics, distribution to and from Class B pharmacies, deliver of controlled substances to physician offices for administration, distribution of controlled substances to clinics, remote technician supervision, and a revised approach to regulatory oversight based on professional practice standards rather than prescriptive agency rules.