Board of Pharmacy inspection- C2 discrepancy

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Lisochka

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I am a new PIC (since November of 2014), had a board of pharmacy inspection last week. I thought it went well, but today I got a email from the BOP inspector and she states that after receiving paperwork from the corporate about the three drugs that she inventoried last week, two drugs have significant discrepancy…

She did not say what kind of discrepancy…But I am freaking out. I pulled an item movement report and it seems to me that I am short on Hydrocodone/Apap 10-325 the whole bottle of 500 pills, and it seems that on MS-contin I am in surplus of 80 pills…That s according to my counts..

I am so worried!

Can I lose my license over these drug discrepancies?

I asked few of my friends and they all said that they never had any discrepancies…What the heck! Nobody ever had any discrepancies in C2’s???

I keep thinking, why would I need to worry about my license with thesediscrepancies while being a PIC...I never even wanted to be a PIC...May be I should step down and be just a pharmacist and just worry about pharmacist problems...I don't want to lose my pharmacist license over PIC stuff...
Please advice...I am freaking out!

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33 people looked and nobody knows? :-(
 
Well, theoretically you could, but you probably won't, lose your license over CII discrepancies. The most likely negative scenario would be you got your license put on probation & you couldn't be a PIC anymore.

What you need to do is find out where the drugs went to, and then have an action plan to prevent the discrepancies from happening again. Yes, every pharmacy will have discrepancies, but they should be very rare, like prescription errors. Also, normal discrepancies are along the lines of being like 5 over or under because someone miscounted. If you are missing a whole bottle, that really sounds like someone is stealing drugs.

So, first you need to ascertain that the drugs really are missing (like did someone stick a bottle of hydrocodone in with the ibuprofen? Unlikely, but it could happen.) So check the pharmacy carefully, every shelf, to rule out anything being misfiled. Next go through your invoices and see who signed them, do what you can to ascertain that you actually received the drugs from your wholesaler on that day. Next, check for inventory adjustments, did someone miscount a drug and adjust the inventory in error? Next, run a record for every prescription filled for the drugs in question from the last 3 months--see if anything stands out in your memory about them or seems questionable (like Mr. Jones MS Contin strength changed, and someone put in back in stock, but didn't delete the fill out of the computer? or maybe someone's hydrocodone script had been put through the computer twice, but they only picked up 1 fill of it...that kind of thing.)

I would I would think your corporate would want to drug test everyone (don't most places do this when there is a significant drug discrepancy?)

Do you have any pharmacists or technicians working with past abuse issues?

If you are lucky, you will be able to account for the errors that way. More likely, someone is stealing, and you need to figure out who. Inventory the drugs in question after each shift (I've know PICS who came after the pharmacy had closed & before it opened to inventory certain drugs.) If you have any discrepancies then note who worked that shift (and review video if available, if you don't have video in your pharmacy, then you need to get it. )

Basically, if you can figure out the problem, stop it, and take steps to prevent it from happening again, the board should be happy. If you can't figure it out, you still need to take steps to stop it from happening again, this will probably make the board happy. If the board thinks you are turning a blind eye to missing drugs, then they will not be happy, and may sanction your license.
 
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These are C2s. You should have a perpetual inventory so I don't know why you didn't know about the discrepancies. Don't you do a monthly count?

You shouldn't need to pull any reports on this. Your balance on hand should match your perpetual inventory. If it doesn't, it should have been caught right away and documented.

Usually small errors (like a few pills but not on a monthly basis) can be attributed to wrong counting, or a bottle missing a pill. You let that stuff go. But those kinds of discrepancies should have been caught like right away because each c2 script is logged manually or electronically (if you have electronic perpetual inventory).
 
These are C2s. You should have a perpetual inventory so I don't know why you didn't know about the discrepancies. Don't you do a monthly count?

You shouldn't need to pull any reports on this. Your balance on hand should match your perpetual inventory. If it doesn't, it should have been caught right away and documented.

Usually small errors (like a few pills but not on a monthly basis) can be attributed to wrong counting, or a bottle missing a pill. You let that stuff go. But those kinds of discrepancies should have been caught like right away because each c2 script is logged manually or electronically (if you have electronic perpetual inventory).
not everybody does perpetual inventories - I think it is silly not to, but I know some people that don't. I worked at a crazy high volume c2 store and we did weekly audits (24 hour store). In the year I was there, I think I found a dozen or so small discrepancies (1 pill here, 2 pills there). I just kept a log and cc'd my PIC. The missing bottle of 500 concerns me. It is more likely there is a accounting error somewhere, or a bottle misplaced. But there is a chance that is diversion. Being 80+ on the MS contin? Go through and run a report and look at your log. Are there any rx's for exactly 80 that got ran twice in the system, or reversed out, or something like that? That is often the case with a round number like that.
 
Thank u :) let's say if I step down and stop being a pic ... Can they still go after my license and suspend it even though I am a stuff Rph and not a pic anymore?
 
Are u sure u are guaranteed a staff position if u step down? Usually they try to give you a part time floater position.
 
Are u sure u are guaranteed a staff position if u step down? Usually they try to give you a part time floater position.
My store has no staff pharmacist, maybe they will put me as a stuff pharmacist. Why would they try to put me as a part-time?
Regardless, it doesn't really matter where they put me. I just don't want my license to be suspended or put on probation. So do you guys think if I step down then become just the stuff pharmacist, the board of pharmacy wont do anything with my license? Or they still can?
 
I think your first step should be to find out if tablets are actually missing or if there is an error with the number that you think you should have. Maybe you were shorted a bottle, or somehow the computer thinks you should have another bottle when you shouldn't. If the records are correct, then the bottle is probably misplaced/stolen. Find the last time an inventory was done and view all invoices since then?

Either way I highly doubt that you would lose your license over this, unless you personally stole the bottle. The fact that it's -500 tells me that someone either stole/misplaced a full bottle or there's an issue with record keeping/drug order. Obviously not a counting issue.

I wouldn't worry about steeping down to staff pharmacist. If you really want to bring this up to your employer, at least wait awhile until this issue is resolved so it doesn't look like you are freaking out like you are, lol.
 
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You need to work with your employer to resolve this discrepancy. You need to make sure you followed all of the laws of your state and the policies of your employer. You could have an internal theft problem. But legally, you are responsible.
 
not everybody does perpetual inventories - I think it is silly not to, but I know some people that don't. I worked at a crazy high volume c2 store and we did weekly audits (24 hour store). In the year I was there, I think I found a dozen or so small discrepancies (1 pill here, 2 pills there). I just kept a log and cc'd my PIC. The missing bottle of 500 concerns me. It is more likely there is a accounting error somewhere, or a bottle misplaced. But there is a chance that is diversion. Being 80+ on the MS contin? Go through and run a report and look at your log. Are there any rx's for exactly 80 that got ran twice in the system, or reversed out, or something like that? That is often the case with a round number like that.

I wouldn't be comfortable in a store like that. If I worked at a store like that, I would document the quantity that was in the bottle prior to me dispensing a script and the quantity after with my initials on it.

C2s should easily be investigated b/c if you do keep a perpetual log.
 
Thank u :) let's say if I step down and stop being a pic ... Can they still go after my license and suspend it even though I am a stuff Rph and not a pic anymore?

The discrepancies happened while you were a PIC so I don't think stepping down would help. I am also shocked that there was no perpetual inventory but I guess you must be in a state with more lenient regulations.
 
How on earth do you misplace a 500 ct bottle of hydrocodone/APAP? I can understand misplacing and losing track of a hydromorphone bottle mainly because they're tiny. That's a pretty significant loss IMO.
 
If you are worried about penalties then go to the board of pharmacy website and see what happens.

I don't know what company you work for, or how often you are required to inventory your narcs, but there are steps in place that this doesn't happen. Of course people have discrepancies, and in some states even when you are short 1 pill, you need to report it. It is possible for BoP to come in and find a discrepancy because inventory was done few weeks back. In that case, you dig in and fix it.
 
Thank u :) let's say if I step down and stop being a pic ... Can they still go after my license and suspend it even though I am a stuff Rph and not a pic anymore?

Even if you step down today, you are still responsible for everything that happened while you were PIC. Regardless of whether you choose to step down, you still need to figure out the discrepancy, and/or take steps to prevent anymore theft/to catch the thief. I also have a feeling, the board would not look kindly on your suddenly stepping down, it just looks like it would be suspicious, I think you need to be responsible and remain PIC until you have accounted for the discrepancy/stopped the theft.
 
I pulled reports on both drugs and recounted them and did not find shortage... There is overage on one drug ... May be I should ask her to send me the report that she is using...

I have another question.. Can a stuff Rph lose their license if there is a discrepancy on c-2s? Obviously, if thIs Rph is not doing anything illegal... I am thinking, why do I even need to be a pic... May be I should clear this mess and after that step down and be just a stuff Rph...
I don't want to lose my license ...
 
I pulled reports on both drugs and recounted them and did not find shortage... There is overage on one drug ... May be I should ask her to send me the report that she is using...

By pulling reports, do you mean you checked your current inventory against the computer says you should have? The report you need to pull is the one that shows all the movement of a drug over the last 3 months, then you look for any manual inventory adjustments, the inspector is most likely referring to a manual inventory adjustment.

I have another question.. Can a stuff Rph lose their license if there is a discrepancy on c-2s? Obviously, if thIs Rph is not doing anything illegal......

It depends on whether the board has reason to think the staff RPH is behind the discrepencies, or if the board thinks the staff RPH is not properly supervising technicians who stole the drugs. Yes, staff RPH's can lose their license over CII discrepencies, but this is not common. *IF* you are doing your job properly, you really don't have anything to worry about. If you are leave CII's sitting around all day for anyone to have access to (instead of only getting them out for an individual prescription & then immediately putting them away), if you ignore discrepencies instead of immediately reporting them to a supervisor, if you know or suspect a problem with someone else in the pharmacy stealing drugs and don't report it to a supervisor, this is the kind of stuff that can get a staff RPH in trouble.

Remember, as staff RPH, you are responsible for everything your technicians are doing on your shift. As PIC, you are responsible for everything everyone is doing in your pharmacy. So, yes PIC has a lot more responsibility, but staff RPH still has responsibility over other people (unless you always work completely alone on all your shifts?)
 
I wouldn't be comfortable in a store like that. If I worked at a store like that, I would document the quantity that was in the bottle prior to me dispensing a script and the quantity after with my initials on it.

C2s should easily be investigated b/c if you do keep a perpetual log.
I hated the place, but hey, I just did my job - they kept a perpetual inventory, but obviously they never back counted their pills, but then again, on average (this is before Hydrocodone beamse c2) - we filled 40-60 C2's every day
 
Thank you guys! I will try to figure out what is going on...
 
Also make sure that the NDC being used is correct. If your store uses an electronic system, putting the wrong NDC (100 count v. 500 count) will really mess up the count.

I caught quite a few discrepancies with that, esp. since CVS' preferred was 500 count norcos for a while. I also caught with xanax and soma (1000 count bottles).

Good luck. Hopefully this will force you to be more stringent with your perpertual inventory. I would make sure after every C2 rx dispensed, the verifying RPH will check BOH is correct every single time.
 
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