Oklahoma State Board of Pharmacy [newsletter], 2012 annual

              Oklahoma State
Board of Pharmacy
4545 N Lincoln Blvd, Suite 112 • Oklahoma City, OK 73105-3413
This special newsletter is published by OSBP in addition to the quarterly electronic newsletter which is published in conjunction with the National Association of Boards of Pharmacy Foundation, Inc. (January, April, June and July) available at http://www.nabp.net/publications/oklahoma-state-board-of-pharmacy-newsletters/.
“TOP 10 COMPLIANCE LIST”
This list reflects SOME of the most commonly observed inspection violations and does not represent a comprehensive list. Registrants should review all applicable laws to ensure compliance. (This list is random and not in any specific order.)
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Telephoned prescriptions: Pharmacists must take new telephoned prescriptions from a physician’s office. Technicians are prohibited by law from receiving telephoned prescriptions. [OAC 535:15-5-7.5.]
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Transferred prescriptions: Prescription transfers must be between two pharmacists or interns. Technicians are prohibited from taking prescription transfers. [OAC 535:15-3-12.]
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Invoice Files: Three (3) files for invoices must be maintained. Schedule II, Schedule III-V, and unscheduled. [OBN 475:25-1-4.]
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CII Orders: DEA 222 forms must be completed when received.
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Documentation: A new telephoned prescription should be immediately reduced to writing immediately by the pharmacist with documentation of the pharmacist who took the prescription. Pharmacy policy and procedure should address this, and the PIC is responsible for assuring accurate documentation policies and procedures are followed. If the pharmacist who took the prescription cannot be identified, responsibility for the prescription is assigned to the PIC.
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Signed Logs: Prescription logs must be signed on a daily basis by each pharmacist who was involved in dispensing prescriptions that day. [OAC 535:15-3-21 and CFR 1306.22]
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Employee Identification: Technicians must not work as clerks while wearing a “TECH” name badge. [OAC 535:15-3-2(e)]
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New Telephoned Prescriptions: A new telephoned prescription MUST be entered into the computer system as a new prescription. If the pharmacy scans new prescriptions, then the new telephoned prescription must be scanned and entered as a new prescription. Retrieving a patient’s old prescription information from the computer and creating a new one from that data, even if it is by the same physician and for the same medication and directions, is not permissible. The new telephoned prescription which is reduced to writing will have the receiving pharmacist’s identification and thus MUST be filed for documentation of responsibility.
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Document Invoices: All CIII-V invoices must be dated when received. [21 CFR 1304.21(d)]
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Electronic Prescriptions (e-prescribing): Electronic prescriptions are becoming more and more common. A pharmacy may receive an electronic prescription via computer or fax machine. But beware, not all electronic prescriptions are legal. The prescription is valid ONLY for medications that are not controlled. An electronically prescribed CDS prescription is not valid for dispensing since there is no manual physician signature. Pharmacists must contact the prescriber for a valid phone prescription. For an electronically prescribed CDS prescription to be legal it MUST be transmitted on a software system certified by the DEA or a DEA approved certification provider. Software vendors must provide pharmacies and physicians with a copy of the certification upon request. If this type of prescription is received, it must still be printed off and filed as a written prescription. As always, faxed prescriptions for CDS signed manually by the physician before faxing are valid, but must be printed by the receiving pharmacy and filed as a written prescription. [21 CFR 1311.170]
One CDS Drug Allowed per Written Prescription
OBN regulations require that each prescription for a CDS must be written on a separate prescription. The following regulation is specific to written prescriptions for CDS.
Title 475 – Oklahoma State Bureau of Narcotics and Dangerous Drug Control
475:30-1-4(c)(3). Manner of issuance of prescriptions
(3) Each scheduled drug shall be written on a single prescription form, and no other prescriptions (controlled or non-controlled) shall be written on the same prescription form.
Page 1 March 2012