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BOP Hospital Advisory Committee

17 Nov 2017 9:48 AM | Deleted user

Author: Bert McClary, RPh (retired)

The HAC met on October 12 in Jefferson City. Proposed pharmacy legislation was discussed, including the BOP technician registration proposal and the pharmacy practice advancement proposal. Committee members provided information about the technician registration proposal related specifically to hospital practice that is being developed in cooperation with the Missouri Hospital Association. Members also provided a brief review of the practice advancement proposal that is being discussed with MHA.

Discussion was held regarding the implications of SB 501 and SB 50, which have identical language relating to DHSS hospital licensing rules. Any DHSS hospital licensing rules that are duplicative of or conflict with CMS Conditions of Participation will become invalid July 1, 2018. DHSS and MHA have begun a review process to determine which current rule language should be retained and if any new language should be added. Current law allows DHSS to promulgate rules which provide a higher degree of patient safety over CMS COPs, and recommendations for retention of current language or addition of new language will be proposed as new rules.

HAC previously reviewed the proposed DHSS 19 CSR 30-100 Pharmacy Services and Medication Management rule that was proposed by a multidisciplinary DHSS rule review committee several years ago but has not been promulgated. HAC previously made recommendations for changes and DHSS accepted those recommendations. Since DHSS has no staff pharmacy expertise they are now requesting another thorough HAC review to determine which parts of the proposal are not duplicative of or in conflict with CMS COPs. They will give priority consideration to promulgating these based on providing a higher level of patient safety.

The DHSS hospital licensing rules also address all other hospital functions. Almost 20 of those rules have either specific language or a significant effect on pharmacy/medication management, such as definitions, anesthesiology, medical staff, construction standards, medical records and respiratory therapy. Most of the medication related language was proposed to be deleted in favor of the revised pharmacy/medication management rule. Since the proposed language was never promulgated, the current language remains the same.

Initial recommendations were to not retain most of the current or proposed rule language for the sections reviewed on October 12. Recommendations were made to retain partial language from the current rule or the proposed changes, or to provide revised language, pertaining to the following topics:

  • Technician education, training and authorized activities
  • Compounding, repackaging and dispensing records
  • Medication storage conditions
  • Controlled substance inventories and discrepancy reporting
  • Patient medication records
  • Receiving medications from outside pharmacy suppliers

Rule topics that will likely be considered at the next HAC meeting November 14 include:

  • DHSS hospital premises definition
  • Medical staff privileges and membership for pharmacists
  • Distribution within the hospital and to outside locations
  • Distribution to patients when pharmacist is not available
  • Who may order medications, and medication order requirements
  • Who may administer medications, and training requirements
  • Medication use monitoring
  • Infection prevention and control
  • Quality assessment/performance improvement
  • CMS COPs for Critical Access Hospitals

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