A violation from Board of Pharmacy

[Lisochka]

Hi Guys,
Need your advice...
We got a violation from a Board of Pharmacy because they found an expired med on the shelf...
What do those violations mean? Is the BOP going to come back to check on it again withing the next month or so?
Can you guys just tell me of the process because I've never had it before...

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[RDL042]

Depending on whether you are retail or not, a warning is usually given by the BOP and a drug usage report is usually required to be printed to see if any patients have received any medication from that bottle/ lot # post-expiration.

Haven't experienced it myself, but have heard of a few cases.


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[Lisochka]

I am in retail. They have not asked me to print any logs for them. They just said to email an action plan to improve it.
I guess what I am trying to ask is if the BOP will follow up with a visit on any violations? What do they usually do with violations? Do they say:"Next year if you will get a violation you will lose your pharmacy license?" Or what do they usually do with violations?

 

[MrBonita]

From my experience working at a closed door pharmacy per diem. The board came the first time and issued a fine. The pharmacist who was the pharmacist in charge quit. The newly hired pharmacist in charge then got another visit from the board. Not sure if the board of pharmacy returned just to do it or returned because a new pharmacist in charge was taking over. How much was the fine?

 

[ChalupaBatman86]

Totally depends on what state you are in

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[Lisochka]

They did not give me any fine...
They just gave me two violations and made me write a letter to the Board of Pharmacy director...
I just hope they dont come back soon...

 

[M0df]

As was said... State by State. Inspector by Inspector. You want to make sure they don't find same issues on their next visit. Write a nice corrective action plan... and pull your outdates. Some states just want your money. In some states, inspector will stop by twice a year. You can go on your state's disciplinary actions page and see if this type of violation leaves a permanent public record.

Btw, what happened to c2 discrepancies you were concerned about? I don't recall the outcome there.

 

[Estrace]

Depends on the state. In Texas, they won't fine you on the spot.

 

[Lisochka]

As was said... State by State. Inspector by Inspector. You want to make sure they don't find same issues on their next visit. Write a nice corrective action plan... and pull your outdates. Some states just want your money. In some states, inspector will stop by twice a year. You can go on your state's disciplinary actions page and see if this type of violation leaves a permanent public record.

Btw, what happened to c2 discrepancies you were concerned about? I don't recall the outcome there.

Discrepancies turned out all ok...
I had 2 discrepancies:
1) BOP last year said I had a discrepancy, turned out I did not. She missed some invoices and after I involved my district manager, BOP inspector wrote me a letter saying that there is no discrepancy and my corporate sent her wrong sales report...Apparently, BOP inspector did the same thing at other stores too...Anyway, I did not have a discrepancy, it was BOP inspectors mistake
2) Then couple of weeks I thought I had 120 pills of Hydromorphone missing, so I emailed loss prevention and they pulled reports and said I am missing only 2 pills, so I am good...

We will see if the BOP inspector will email me about discrepancies after this years visit...Hopefully not...

as far as pulling outdates, we were pulling outdates every month... Every tech is responsible for few shelves...May be I should go after techs every time myself and check? But can you imagine doing yourself outdates every month? I just dont have the time ...How can I make techs to not miss an outdated drug? Do you guys have any suggestions?

 

[Lisochka]

if they come back and find same violation again, can they close the pharmacy? Can I lose my license as a manager?

 

[BidingMyTime]

if they come back and find same violation again, can they close the pharmacy? Can I lose my license as a manager?

Well, they could, but that is extremely unlikely unless it was a very serious or flagrant violation (or an extremely outdated medicine.)

My experience with an outdate violation was in the 90's with a hospital pharmacy (I was not the manager/director.) A single outdated medication was found it was noted, but the pharmacy wasn't fined, and nothing else ever came of it. As you said, mistakes happen and even when pulling outdates every month, something can get missed. I would suggest making sure that you are keeping records of who is doing the outdates each month and on what date they were done. I can see a board perhaps fining these days, since most states need the extra revenue, but I can't see them closing a pharmacy or revoking a license over a missed outdated medication.

Something else that is often overlooked...who is to say you didn't get the outdated medication from your wholesaler? I have seen that happen before. Not sure what to do about that, since who has the personnel to check the expiration date on all the meds coming it? But if you've special ordered a rarely used med, it would be wise to check the expiration date on that.

 

[Sine Cura]

Any discovered outdates that should have been pulled = write-up the techs responsible for their assigned bays. You could audit a "randomly selected" bay to check for outdates (i.e., anything with slow mover brand medication or one-off medication never used). If they are dyslexic, too bad.

Shortdates or outright outdates from wholesaler is definitely another problem...

 

[Lisochka]

Thank you so much, guys...I did tell the techs that if I find an outdated med in their bays I will write them up...Thank you again for your help