How do we handle interruptions to our quarterly pharmacy inspections as required in Standard D-01 Pharmaceutical Operations? In 2020 the pharmacy inspections were missed due to the COVID-19 pandemic.
Over the past few months, NCCHC has received many questions on how to handle changes to operations due to COVID-19. While we understand that there may be changes to daily operations, we are asking facilities to do their best to address the needs of their patients, follow the standards, document the changes made, and return to normal operations as soon as possible.
Throughout 2020, many facilities operated under their emergency management plan with surges in COVID-19 cases. As facilities return to normal operating procedures, NCCHC requires accredited facilities to work with their consulting pharmacists to conduct quarterly on-site inspections. If COVID-19 cases are surging at a facility, the pharmacist can conduct a virtual consultation. The responsible health authority and the health services administrator can work with the consulting pharmacist to ensure that the facility’s pharmaceutical services are operating safely, properly, and according to the law. Given that medication dispensing, administering, and procuring are high-risk endeavors, it is imperative that quarterly pharmacy inspections resume whether on-site or via a virtual consultation.
— From CorrectCare Volume 35, Issue 1, Spring 2021
Since we do not have a staff pharmacist, standard D-01 Pharmaceutical Operations says that a consulting pharmacist should be used for documented inspections and consultation on a regular basis, not less than quarterly. Does a pharmacist have to be the one to physically conduct the inspections, or can a pharmacy tech do the inspection as long as it is reviewed and signed off by a pharmacist?
No. The intention of this standard is that a consulting pharmacist actually conducts the inspections. A situation where another type of staff member conducts the inspection and then has a pharmacist sign off would not be in compliance with the standard.
— From CorrectCare Volume 23, Issue 4, Fall 2009