Unforeseen barrier to tech-check-tech endeavor

I’ve been on a mission, however small it may be, to get pharmacy technicians more involved in the operational aspect of acute care pharmacy. And by more involved I mean using a tech-check-tech model to free pharmacists up for more patient related clinical activities. I’ve posted my thoughts on the use of tech-check-tech before.

The reason for rehashing the issue is due to a conversation I had with a colleague last week. This particular colleague and I were having a light hearted discussion over the possibility of using a tech-check-tech model with automated packagers like those I described in a post earlier this week.

The 2010 Lawbook For Pharmacy, which is available at the California Board of Pharmacy website, has provisions for the use of tech-check-tech in certain situations. I’m referring to Title 16, Division 17, Article 11, Section 1793.8 –Technicians in Hospitals with Clinical Pharmacy Programs, which reads:

(a) A general acute care hospital, as defined in Health and Safety Code 1250 (a), that has an ongoing clinical pharmacy program may allow pharmacy technicians to check the work of other pharmacy technicians in connection with the filling of floor and ward stock and unit dose distribution systems for patients admitted to the hospital whose orders have previously been reviewed and approved by a licensed pharmacist. Only inpatient hospital pharmacies as defined in 4029(a) that maintain a clinical pharmacy services program as described in 4052.1 may have a technician checking technician program as described. The pharmacy shall have on file a description of the clinical pharmacy program prior to initiating a technician checking technician program.
(1) This section shall only apply to acute care inpatient hospital pharmacy settings.
(2) Hospital pharmacies that have a technician checking technician program shall deploy pharmacists to the inpatient care setting to provide clinical services.
(b) Compounded or repackaged products must have been previously checked by a pharmacist and then may be used by the technician to fill unit dose distribution systems, and floor and ward stock.
(c) To ensure quality patient care and reduce medication errors, programs that use pharmacy technicians to check the work of other pharmacy technicians pursuant to this section must include the following components:
(1) The overall operation of the program shall be the responsibility of the pharmacist-in-charge.
(2) The program shall be under the direct supervision of a pharmacist and the parameters for the direct supervision shall be specified in the facility’s policies and procedures
(3) The pharmacy technician who performs the checking function has received specialized and advanced training as prescribed in the policies and procedures of the facility.
(4) To ensure quality there shall be ongoing evaluation of programs that use pharmacy technicians to check the work of other pharmacy technicians.

The problem with the above section of pharmacy law is the part that says “(b)Compounded or repackaged products must have been previously checked by a pharmacist and then may be used by the technician to fill unit dose distribution systems, and floor and ward stock” because in the previous section of the law book – Title 16, Division 17, Article 11, Section 1793.7 – Requirements for Pharmacies Employing Pharmacy Technicians – it states that “(a) Except as otherwise provided in section 1793.8, any function performed by a pharmacy technician in connection with the dispensing of a prescription, including repackaging from bulk and storage of pharmaceuticals, must be verified and documented in writing by a pharmacist.” It’s kind of a circular reference, but basically says you can’t use tech-check-tech on tablets packaged by an automated packager.

I originally thought I could get an exemption to the rule, but my college was kind enough to point me to the January 2005 issue of The Script Newsletter from the California Board of Pharmacy. That particular issue addresses tech-check-tech related to items packaged through the use of automation. In the article the Board states that “Any licensee implementing such a protocol will be subject to discipline for any errors that do occur (as would any licensee responsible for errors from any other delivery system). It is possible the severity of the violation may even be greater where the error could have been caught had not such a sampling protocol been in place.” The article goes on to say that “In the absence of any statutes or regulations exempting a dispensing pharmacist or pharmacy working with an automated drug delivery system from the general requirements pertaining to prescription accuracy and propriety of drug delivery, it is the responsibility of the dispensing pharmacist and pharmacy to ensure 100 percent accuracy of the dispensing. Licensees electing to save costs by reducing their level of error checking do so at their own risk and that of the patient.”

I have to say that the opinion of the Board makes absolutely no sense. To assume that having a pharmacists eyes look at something is better than a technicians eyes is ignorant. In addition, the use of an automated packager is a safe and effective way to unit-dose tablets. The use of an automated unit-dose packager with tech-check-tech combined with a well-developed QA audit process is a win-win situation for both pharmacy practice and patient safety. I just don’t understand the logic of the Board.

I plan to contact the California Society of Health-System Pharmacists (CSHP) to see what they can do to help me correct this egregious oversight in the law. I’m also hoping that the American Society of Health-System Pharmacists (ASHP) will address issues like this at the upcoming Pharmacy Practice Model Initiative Summit in November. Don’t let me down boys and girls.