Pharmacy CSI: Solving the Drug Diversion Mystery

Pharmacy CSI: Solving the
Drug Diversion Mystery
Contact
Information
June 2, 2015
Rutgers University-Busch Campus Student Center
Mitch G. Sobel, BS Pharm, MAS, FASHP
Director of Pharmacy Services
St. Joseph’s Health Care System




Disclosure Declaration
 I do not have (nor does any immediate family member
have) a vested interest in or affiliation with any
cooperate organization offering financial support or grant
monies for this continuing education activity, or any
affiliation with an organization whose philosophy could
potentially bias my presentation.
 This presentation is solely for informational purposes and
does not represent the views, statements, or opinions of
the New Jersey Board of Pharmacy, New Jersey Division
of Consumer Affairs and /or the New Jersey Office of the
Attorney General.
St. Joseph’s Health Care System
Department of Pharmacy Services
(973) 754 – 3028
(973) 754 – 3036 fax
[email protected]
703 Main Street, Paterson, New Jersey 07503
Objectives

Define classes of narcotics and controlled
substances

Describe the different rules and regulations
concerning the handling of controlled substances

Describe methods of controlled substances
documentation, surveillance, and preventing
diversion
1
Diversion
Overview

Controlled substances are managed at all levels:
Adherence to Federal and State laws
Procurement
Inventory management
Distribution
Dispensing
Surveillance and documentation
Diversion and system evaluation
Waste












There has been a fourfold increase in drug overdose deaths
from prescription drug abuse in the last decade
– 2011 – 6.1 M non-medical use including oxycodone,
oxycontin, hydrocodone, carisoprodol, and alprazolam†
40 Americans die daily from CDS prescription abuse
– Greater deaths than cocaine and heroin combined
15% of pharmacists are confronted with alcohol and/or drug
dependency
10% of nurses are dependent on drugs
– 3.1 M RNs in U.S. = 300,000 RNs dependent
8% of physicians are dependent on drugs
†2011 Annual National Survey on Drug Use and Health
Buzzeo, R, Neal, M, Hospital Drug Diversion and Abuse – Creating an Effective Surveillance
and Prevention Program, CEGEDIM Realtionship Mgt, 1/2013
http://www.nj.gov/lps/ca2/pmp/
Importance of Controlled
Substances Management
There a 3 factors that influence the need
for managing controlled substances.
Federal and State Laws and Regulations
2. Patient Safety
3. Pain Management and Practice
1.
Federal and State
Laws and Regulations

Controlled Substance Act (CSA)
– Title II of the Federal Comprehensive Drug
Abuse Prevention and Control Act of 1970,
under Title 21 United States Code, starting at
Section 801.
– Federal and State laws may differ in degree of
severity. Follow which ever rule is more
strict.
– www.dea.gov provides many links and
documents
2
Federal and State
Laws and Regulations
Federal and State
Laws and Regulations


Example of Controlled Substances Schedules.
– CI (~119 cmpds) Heroin, Lysergic acid diethylamide, Marijuana, 3,4methylenedioxymethamphetamine (ecstasy).
Controlled substances classified according
to:
– CII (~64 cmpds) Amphetamine, Fentanyl, Methadone, Opiates.
– Abuse potential
– Accepted medical use
– Potential physical or psychological dependence

– CIII (~66 cmpds) Anabolic steroids, Barbiturates, ketamine, opium
combination products (< 15 mg/dose hydrocodone, < 90 mg/dose
codeine).
– CIV (~68 cmpds) Barbiturates (Phenobarbital, Secobarbital),
Benzodiazepines (clonazepam, diazepam, midazolam), Chloral
hydrate.
Schedules are listed as CI to CV
– CV (~7 cmpds) Low dose combination of narcotic and non-narcotics
(e.g. Not more than 200 milligrams of codeine per 100 milliliters or
per 100 grams - Robitussin AC, Phenergan w/ codeine).
Federal and State
Laws and Regulations
Regulatory Agencies


Prescribing and handling of controlled substances
privileges granted to:


Physicians and Physician Assistants
Nurses (incl. Practitioners, Midwives, Anesthetists)
Optometrists
Ambulance Services
Pharmacists

Different States may vary in privileges and laws.
– Division of Department of Justice




Federal - Drug Enforcement Agency
NJ Department of Law and Public Safety
Office of the NJ Attorney General
– Bureau of Drug Control/Enforcement
– NJ State Board of Pharmacy
 Regulates practice of Pharmacy
 Can change schedules of controlled substances

NJ State Department of Health
– Enforces Fed and State Laws
3
Patient Safety

National Emphasis on Patient Safety
–
–
–
–


Institute of Safe Medication Practices (ISMP)
The Joint Commission (JC)
Det Norske Veritas (DNV)
United States Pharmacopoeia (USP) Medication Error
Reporting Program
Education and concern for narc prescription use
Separate and highlight Look/Sound Alike
medications
– Morphine vs. Hydromorphone (use “Equiv. to
Dilaudid®”)
– Morphine IR vs. Morphine ER

Co-sign, double check, and document all
transactions
HCAHPS Survey Questions
12. During this hospital stay, did you need medicine for pain?
・ Yes
・ No ・ If No, Go to Question 15
13. During this hospital stay, how often was your pain well
controlled?
・ Never
・ Sometimes
・ Usually
・ Always
14. During this hospital stay, how often did the hospital staff do
everything they could to help you with your pain?
・ Never
・ Sometimes
・ Usually
・ Always
Pain Management and Practice

Complex pharmacotherapy and formulations (patches, PCA,
concentrations)
Pharmacist interventions improve safety and outcomes
(monitoring, conversions)
 Essential Patient Right:

– Pain is the 5th vital sign.
– Pain assessment should occur before, during, and after pain
therapy.

HCAHPS – Hospital Consumer Assessment of Healthcare
Providers and Systems*
– Pain assessment is part of the 27 item survey for patients
– Developed by Centers for Medicare and Medicaid (CMS) and the
Agency for Healthcare Research and Quality (AHRQ)
– 2007 – Inpatient Prospective Payment System
*http://www.hcahpsonline.org. Centers for Medicare & Medicaid Services, Baltimore, MD. October, 29, 2012
HCAHPS Survey Questions
15. During this hospital stay, were you given any medicine that you
had not taken before?
・ Yes
・ No ・ If No, Go to Question 18
16. Before giving you any new medicine, how often did hospital staff
tell you what the medicine was for?
・ Never
・ Sometimes
・ Usually
・ Always
17. Before giving you any new medicine, how often did hospital staff
describe possible side effects in a way you could understand?
・ Never
・ Sometimes
・ Usually
・ Always
4
Sample DEA 222 Form
Procurement
Co-signatures are required for receiving
controlled substances inventory to provide
accountability and accuracy.
 Use DEA 222 Form to order CII. CIII to
CV may be ordered like all other legend
and OTC medications.
 DEA 222 Form (blue) and Purchase invoice
should be matched with delivery invoice.
 Store controlled substances into a locked
room or vault.

For ordering
CII narcotics
only
http://www.deadiversion.usdoj.gov
/pubs/manuals/narcotic/appendixb/222d.htm
CSOS
CSOS
Controlled Substances Ordering System
– Approval from D.E.A.
– Certificate Authentication
– Manufacturer specific
–
–
–
–
–
–
–
Takes some time and effort to set up
Very convenient, electronic, no paper work
Quicker turn-around time
Security
Computer specific
Increased accuracy
Decreased order errors

Enroll on-line
www.deaecom.gov
– Registrant
– Coordinator
– Power of Attorney
(POA)
www.deaecom.gov
5
Inventory management.
Automated controlled substances
dispensing system allows greater control
and security (CII Safe®, Omnicell®).
 Access should be restricted.
 Separate and identify look/sound alike
medications.
 Although CIII to CV may be stored with
legend inventory, it is better to store all
schedules (CII to CV) in vault for greater
security and accountability.
Sample Automated Controlled Substances Vaults

Distribution





Different pharmacist distributes narcotics to
patients or patient care areas than the one that
receives the wholesaler inventory.
Designate a different person to deliver controlled
substances to the patient care areas.
Limit the number of personnel that handles
delivery and transport of controlled substances.
Two pharmacists should perform periodic
inventory of controlled substances stock as a
“blind” count.
Two nurses should perform daily inventory of
controlled substances stock on patient care
areas as a “blind” count.
Pyxis CII Safe®
http://www.carefusion.com/medical-products/medication-management/
medication-technologies/pyxis-ciisafe-system.aspx
Omnicell Secure Vault®
http://www.omnicell.com/Products/Central_Pharmacy_
Automation/Controlled_Substance_Management_System.aspx#
Sample Automated Dispensing Machines
Located On Patient Care Units
Omnicell®)
http://www.ehealthreporter.com/en/noticia/verNoticia/291/omnicell
Carefusion Pyxis ®
http://www.carefusion.com/medical-products/medication
-management/medication-technologies/pyxis-medstation-system.aspx
6
Sample Controlled Drug Administration Record
(CDAR)
Dispensing
Controlled substances orders should have
automatic stop dates built into the patient
medication profile.
 Monitor patient profiles for duplicate
therapy.
 Assist nurses and physicians with
conversion formulas when switching types
and forms of controlled substances.
Joe's Medical Center


Controlled Substances Administration Record
Date
Time
Patient
Name
Room
Medication
Dose
Qty
Admin
By
Co-sig
for waste
Reason
for waste
Document all transactions with a co-signature.
NJ Prescription Monitoring Program
(NJPMP)







National epidemic of CDS prescription abuse
2 in 5 teenagers think CDS are safer than illicit
drugs
Each day 2,500 teenagers try CDS to get high
for the first time
Division of Consumer Affairs - N.J.S.A. 45:1-45
NJ Database – Daily record of Pharmacy CDS
and HGH dispensing
Prescriber and Pharmacist access
HIPAA compliant
Surveillance and documentation.

Co-signatures are the keys to preventing errors
and diversion and provide accountability.
– Document: Patient name, date, time, patient care
area, medication name and dose, quantity, physician
and/or nurse administering and/or wasting.



Automated dispensing machines (ADMs) can
match and follow transactions involving
ordering, receiving, dispensing, and delivery of
controlled substances.
Follow through on all discrepancies.
Inventory stock:
– Biennial Inventory
– Perpetual Inventory
7
Surveillance Reports









ADM
Compare – Comparison of patient care area and
narc vault ADMs transactions
Proactive Diversion – Standard Deviation of
users
Open Discrepancy Notification – real time alerts
Documented Discrepancy – validate reasons
entered
Waste and Return – excessive entries
Override – user overrides without prescriber Rx
All Events – management review for trends;
compare to pt record
Inventory Verification – perpetual spot check
Outdated Inventory – commonly overlooked
Usual rule to follow
http://meetville.com/images/quotes/Quotation-Proverb-funny-Meetville-Quotes-14354.jpg
http://41.media.tumblr.com/tumblr_m7teqt5aF81r36vzto1_500.jpg
8
Or this one…
Q&A

A good inventory management system
contains the following:
1.
Restricted access
Highlighted Look/Sound Alike drugs
Storage areas that provide accountability and
security
Co-signatures on documentation
“Just in Time” Inventory
Certain tasks are delineated by different staff
members
All of the above
2.
3.
4.
5.
6.
7.
https://lh6.googleusercontent.com/-FUeWScP0MDw/VDi1RBJpjfI/AAAAAAAALbw/1VJNIoZ9ZI8/w656-h577/10616471_10153165717999062_3784880976383473292_n.jpg
Q&A
Q&A

A good inventory management system
contains the following:

Which is not a good controlled substances distribution
method:
1.
Restricted access
Highlighted Look/Sound Alike drugs
Storage areas that provide accountability and
security
Co-signatures on documentation
“Just in Time” Inventory
Certain tasks are delineated by different staff
members
All of the above
1.
Different pharmacist delivers narcotics to patient than
the pharmacist that receives the narcotics wholesaler
order
Limited number of staff handles delivery and transport
of controlled substances
Periodic inventory validation of controlled substances
stock is performed to confirm known count
Controlled substances not picked up by patients should
be left on the front counter as a reminder
3 and 4
None of the above
2.
3.
4.
5.
6.
7.
2.
3.
4.
5.
6.
9
Q&A
Diversion and System Evaluation

Which is not a good controlled substances distribution
method:
1.
Different pharmacist delivers narcotics to patient than
the pharmacist that receives the narcotics wholesaler
order
Limited number of staff handles delivery and transport
of controlled substances
Periodic inventory validation of controlled substances
stock is performed to confirm known count
Controlled substances not picked up by patients should
be left on the front counter as a reminder
3 and 4
None of the above
2.
3.
4.
5.
6.
Use an interdisciplinary and collaborative
approach to prevent controlled substances
diversion.
 Joint policies and procedures.
 Create a non-punitive culture.
 Hospital personnel involved with diversion
are a danger to the patient, institution,
and themselves.

Diversion Red Flag!
Noticeable Trends of Diversion






Patient complaints of poor pain
management after pain therapy.



http://www.superstock.com/stock-photos-images/1660R-17157



https://www.mcssl.com/content/27384/mnct/sine-base-1.jpg
Behavioral/personality changes
Absenteeism
Declining job performance
Poor documentation
Unexplained disappearances
Numerous bathroom breaks
Excessive time with CDS
supply
Wearing long sleeves when
inappropriate
Deteriorating personal hygiene
Patient/staff complaints
Personal/professional isolation
http://www.vitaminddeficiency.me/always-tired-no-energy-no-motivation/
http://www.health.com/health/gallery/0,,20396232,00.html
http://tridiculous.blogspot.com/2011/05/stoned-sandwich-burrito-artists.html
http://www.deadiversion.usdoj.gov/pubs/brochures/drug_hc.htm
10
Methods of Enabling
Employee Diversion



Remember—Some diverters show no signs at all
DO NOT rely on physical trends as sole evidence
Philip Seymour Hoffman
Actor, born 7/23/1967;
died 2/2/2014





http://i.guim.co.uk/static/w-620/h--/q-95/sys-images/Guardian/Pix/pictures/2014/2/2/1391367146868/4cfcc77e-6643-4f93-8761-a46c19802f4c-620x372.jpeg
Narcotic Diversion Schemes

CDS pull for excessive amounts
of patients

Pull larger dose than patient
receives

Remove CDS from IV drips

Vial breakage is clean. Vials are
sheared without fragments.

Intact CDS thrown in trash
Disposal of CDS into sharps
containers
Fentanyl Patches removed from
patient
Pattern of broken vials and
ampoules. Excessive “accidents”.
Check rubber stoppers for
punctures.



Failure to recognize warning signs
Attributing signs to other causes (stress, illness,
etc.)
Provides coworker with password
Co-signing wastage not observed
Making excuses for person not following narcotic
handling procedures
Professional and legal responsibility to report CDS
abuse and diversion
– Health Care Professional Responsibility and Reporting
Enhancement Act
– DEA Form 106
Decoy
http://the-adventurers-club.typepad.com/the_adventurers_club/resident-evil/
http://www.organizeit.com/
mini-swing-top-trash-can-grey.asp
http://www.bringmethenews.com/2012/09/05
11
Narcotic Diversion Schemes
Decoy
continued…
www.mushsmush.com








Substituting diluent for active injectable
narcotic in IV bags
IV Pump tampering
Heated needle through IV bag
Curved needle used to go between metal
lid and rubber stopper on vials
Users are created and deleted in a short
period of time. Upon review, users are
fictitious
Employees work and make transactions
during off-shifts or unscheduled times
Substituting look alike legend drug tablets
for active narcotic tablets (Bingo cards,
blister packs)
Pulverized or broken tablets. Pieces of http://www.movingbusiness.net/1330/ http://www.fotosearch.com/yellow_pillls/
punching-the-clock-an-outdated-process/
tablet or powder of capsule missing
http://images.ddccdn.com/images/pills/nlm/634810623.jpg
http://images.medscape.com/pi/features/drugdirectory/octupdate/MMW01230.jpg
Drugs and Chemicals of Concern
Decoy
http://images.rapgenius.com/c49aa5f1f090653a27bb1f132db46024.259x194x1.jpg
https://02d4c74.netsolstores.com/images/email/UDDR-4.png
http://sr.photos3.fotosearch.com/bthumb/DGT/DGT389/42-29183923.jpg
Fentanyl
(Trade names: Actiq®, Duragesic®)
Gamma Hydroxybutyric Acid
(Street Name: GHB, Liquid Ecstasy, Liquid X, Goop,
Georgia Home Boy, Easy Lay)
Hydrocodone
(Trade Names: Vicodin®, Lortab®)
Hydromorphone
(Trade Names: Dilaudid, PalladoneTM)
Ketamine
(Street Names: Special K, "K", Kit Kat, Cat Valium)
Oxycodone
(Trade Names: Tylox®, Percodan®, OxyContin®)
Phencyclidine
(Street Names: PCP, Angel Dust, Supergrass, Boat,
Tic Tac, Zoom, Shermans)
Salvia Divinorum
(Street Names: Maria Pastora, Salvia)
Tramadol
(Trade Name: Ultram®)
http://www.nationaltreatmentcenters.org/l
http://ibogainetoday.com/ibogaine-treatment-for-oxycontin-addiction/
http://www.123rf.com/photo_4457127_close-up-of-colorful-tablets-and-pills.html
12
Future Diversion Trends

Future Diversion Trends
Expect continued pressure from the DEA against
hospitals
– Fines: $185 M from 2008-2012
– Hospitals, pharmacies, manufacturers and distributors
– Lack of Policies and Procedures
– Prescription Monitoring Programs


 “know your customer” initiatives

Expect diversion trends to continue to change:
– Was - manufacturer or distributor
– Then - Pain clinics and internet pharmacies
– Now - Healthcare community: MDs, nurses, or
pharmacists
– Future – diversion for sales users vs. dealers

Buzzeo, R, Neal, M, Hospital Drug Diversion and Abuse – Creating an Effective
Surveillance and Prevention Program, CEGEDIM Realtionship Mgt, 1/2013
Handling and Documentation of
Expired and Wasted Narcotics

An effective method of preventing drug diversion
is:
1.
Create joint policies with other professionals
Resolve discrepancies quickly
Be aware of behavioral changes of staff
Visually confirm narcotic waste and destruction
Recognize poor pain management control
Use a lock box for expired controlled substances
Utilize Public Flogging for staff members that
make errors
1 through 6

Documentation and cosignature required with
narcotic waste.
2.
Medication Pending
Destruction Report.
5.
Use at least two or more
pharmacists to verify,
document (DEA 41), and
destroy narcotics.
Expect increased U.S. State and FDA review of
compounding pharmacies.
– NECC
– Ameridose
– MedPrep
Q&A
Locked drop box - Secure
expired/wasted narcotics in
the pharmacy.

Expect comprehensive DEA investigations
– Policy and Procedure review
– File maintenance
– Compliance documentation
– Workflow process
Buzzeo, R, Neal, M, Hospital Drug Diversion and Abuse – Creating an Effective
Surveillance and Prevention Program, CEGEDIM Realtionship Mgt, 1/2013


Expect volume as a primary factor for DEA action
3.
4.
6.
7.
8.
http://www.pppmag.com/article/629/November_2009/Preventing_Controlled_Substances_Diversion/
13
Q&A

An effective method of preventing drug diversion
is:
1.
Create joint policies with other professionals
Resolve discrepancies quickly
Be aware of behavioral changes of staff
Visually confirm narcotic waste and destruction
Recognize poor pain management control
Use a lock box for expired controlled substances
Utilize Public Flogging for staff members that
make errors
2.
3.
4.
5.
6.
7.
8.
13:39-7.10 PRESCRIPTIONS
TRANSMITTED BY FACSIMILE

– original signed prescription forwarded to
pharmacist except:
 direct administration to a patient by parenteral,
intravenous, intramuscular, subcutaneous or
intraspinal infusion
 resident of a long-term care facility
 hospice patient from a hospice certified by
Medicare under Title XVIII or licensed by the State
1 through 6
Public flogging, although enticing, does not support a “Just Culture”
SUBCHAPTER 9.
PHARMACEUTICAL SERVICES FOR HEALTH CARE FACILITIES
13:39-9.10 PHARMACEUTICALS; DRUG SUPPLY;
INVESTIGATIONAL DRUGS;
CONTROLLED DANGEROUS SUBSTANCES

The pharmacist-in-charge shall be responsible for Drug
Supply as it relates to:
–
–
–
–

Types used for treatment of patient population – Formulary
Inventory Management – quality vs quantity
Pharmacy Buyer procurement process
Inventory purchase reviewed by RPIC or designated pharmacist
Policy and Procedures – control, content, and security
–
–
–
–
Inventory
Investigationals
Controlled Substances
Accountability
A pharmacist may fill a faxed prescription
for a Schedule II controlled substance
provided:
13:39-5.10 RESTRICTION ON STORAGE OF PRESCRIPTION
LEGEND DRUGS AND
CONTROLLED DANGEROUS SUBSTANCES

Prescription legend drugs, devices and controlled
dangerous substances shall be:
– Stored securely without access to general public
– Stored in a designated Pharmacy Area
 Exception: Healthcare facilities – automated
dispensing cabinets or locked cabinets in patient
care areas
– Secured after the pharmacy is closed in a secure
location with a drop-off device that is a one-way,
irretrievable and secure design.
– Secured on the premises with a security system
14
Theft or Loss
13:45H-2.5 PHYSICAL SECURITY CONTROLS
FOR PRACTITIONERS

Controlled substances listed in Schedules
II, III, IV and V shall be stored in a
securely locked, substantially constructed
cabinet.
– However, pharmacies may disperse such
substances throughout the stock of noncontrolled substances in such a manner as to
obstruct the theft or diversion of the
controlled substances.
13:45H-3.7 SEALING OF CONTROLLED SUBSTANCES

Securely affixed to the stopper, cap, lid
covering or wrapper of such container a
seal to disclose upon inspection any
tampering or opening of the container.

Theft or Loss
– Significant quantity
 5% rule
– Patterned loss

Notify*
–
–
–
–


Drug Control Unit
DEA
Local Law Enforcement
When in doubt, report it in!
*Notification is based
upon situation, impact,
and methodology of
loss or theft
DDC-52 form
Documentation is key!
13:45H-3.7 SEALING OF CONTROLLED SUBSTANCES


Securely affixed to the stopper, cap, lid covering
or wrapper of such container a seal to disclose
upon inspection any tampering or opening of the
container.
Good practice tip: Initial and date after sealing
MGS 9/8/13
http://www.novavisioninc.com/pages/prd_tamper_evident_tape.html
www.tampervue.com/tipseals
http://www.novavisioninc.com/pages/prd_tamper_evident_tape.html
www.tampervue.com/tipseals
15
Q&A

Which is not the best practice tip for storing opened
stock bottles of controlled substances
1.
Tamper evident tape or seal should be placed on the
stock bottle before putting away
The contents remaining in the bottle should be
counted
Narcotic quantity remaining should be documented on
a narcotics log
A label with the pharmacist's initials and date should
be placed on top of the tamper evident seal when the
dispensing activity is complete
The remaining count should be placed on the initials
and date label
2.
3.
4.
5.
Q&A

Which is not the best practice tip for storing opened
stock bottles of controlled substances
1.
Tamper evident tape or seal should be placed on the
stock bottle before putting away
The contents remaining in the bottle should be counted
Narcotic quantity remaining should be documented on a
narcotics log
A label with the pharmacist's initials and date should be
placed on top of the tamper evident seal when the
dispensing activity is complete
2.
3.
4.
The remaining count should be placed on the initials and
date label
5.
A “blind count” process should be practiced to prevent count bias and errors
Q&A

It is the responsibility of the Pharmacist to
store narcotics in a secure, locked,
substantially constructed cabinet with
appropriate surveillance mechanisms to
prevent and deter diversion
True or False
Q&A

It is the responsibility of the Pharmacist to
store narcotics in a secure, locked,
substantially constructed cabinet with
appropriate surveillance mechanisms to
prevent and deter diversion
Duh
16
Q&A
Q&A

Which scenario should be reported to the authorities?
A single occurrence of 5 tablets of Percocet® are
missing, you dispense 5,000 tablets per month
4 tablets of hydromorphone are found crushed inside
the manufacturer’s bottle
You dropped a vial of morphine 100mg/50ml
An intact bottle of 100 tablets of acetaminophen and
codeine #3 was found on the employee bathroom
floor
An Ewok came into the
Pharmacy and took 7 boxes
of fentanyl patches

Which scenario should be reported to the authorities?
1.
1.
A single occurrence of 5 tablets of Percocet® are
missing, you dispense 5,000 tablets per month
4 tablets of hydromorphone are found crushed inside
the manufacturer’s bottle
You dropped a vial of morphine 100 mg/50 mL
An intact bottle of 100 tablets of acetaminophen and
codeine #3 was found on the employee bathroom
floor
An Ewok came into the Pharmacy and took 7 boxes of
Fentanyl Patches
None of the above
2.
2.
3.
4.
5.
6.
3.
4.
5.
6.
None of the above
If you see an Ewok you need to
call a psychiatrist, not the police
http://cool-toy-spot.com/star-wars-wicket-the-ewok-vinyl-figure/
Documentation of Quantity Dispensed
Conclusion
New Jersey Board of Pharmacy Newsletter July 2012




Accurate records of all prescription medication
received and dispensed are maintained
Policies are in place regarding accurate
dispensing and labeling of prescriptions and that
such policies are followed
Pharmacist should clearly describe the situation
to the patient with complete instructions
regarding when to return to the pharmacy to
receive the remaining quantity
Pharmacist must document clear and concise
description of short fill on prescription record
Important and expected pharmacist
responsibility
 Document, document, and document
 Interdisciplinary involvement
 Education and training
 Policy and Procedures
 Be proactive, progressive, and vigilant.

N.J.A.C. 13:39-6.2(f)2; N.J.A.C. 13:39-6.2(f)3, Pharmacy Jurisprudence, L.L.C. and Select CE® 2013
17
Questions and discussion
http://www.dreamstime.com/
http://ocw.mit.edu/courses/health-sciences-and-technology
/hst-151-principles-of-pharmacology-spring-2005/index.htm
18