CA BOP violation?

[hye345]

So, I got a letter today from the CA BOP. Apparently, based on an audit and investigation this past January, a compounded rx went out without the ingredients listed on the label. I haven't worked at this particular store for several months, and only 1 shift as a pharmacist, during which I don't remember any compounded meds. I'm waiting to hear back from the current PIC about what I should do. The letter said that if there is anything I wish to mention (action plan, causative effects, etc...) I have 2 weeks to do so. Can anyone who has been in a similar situation comment?

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[Its Z]

Is this an accusation letter?

 

[hye345]

Is this an accusation letter?

I don't think so: a specific patient was never mentioned. My super suggested that it's the result of an audit, as opposed to a patient complaint.

 

[Its Z]

That's not what I'm talking about.

Is the letter from the Attorney General's office on behalf of CA BOP signed by Virginia Herold? That you have violated CCR and either your license will be revoked, suspended, or go on probation?

 

[Sine Cura]

Retail pharmacists every day are subject to citations by violating HSC 11162.1

 

[hye345]

Well, the letter is from the CA BOP, but it's not from Virginia Harold, or Attorney Generals office; it's from a board inspector. It doesn't mention any penalties, just talks about what happened (it did mention specific CCR), and that they will keep me updated as to the ruling. Kinda freaking out here.

 

[Its Z]

Well, the letter is from the CA BOP, but it's not from Virginia Harold, or Attorney Generals office; it's from a board inspector. It doesn't mention any penalties, just talks about what happened (it did mention specific CCR), and that they will keep me updated as to the ruling. Kinda freaking out here.

Don't take it laying down. If you're not responsible for it, fight it. Request your corporate legal to represent you. You can email the BOP inspector to inquire about the investigation/audit to find out exactly why and how you were involved with the infraction. Do everything you can to prevent getting a ding on your license. It will follow you rest of your career.

I don't find your situation is very serious compared to what I have seen. Nonetheless, if you didn't violate any rules, you need to let them know.

 

[catalyzt]

Get with your DM and write an action plan that addresses the complaint, then e-mail it to the board inspector and ask for feedback. Remember, even if you did not make the error, you are still held responsible for everything that occurs in the pharmacy by being the PIC. This is one thing about floaters that drives me crazy. I and my staff pharmacist (after I had a couple of talks with him) make sure that we include the ingredients (abbreviated) on the label. Just putting 'Magic Mouthwash' for example is not enough to meet BOP requirements and allow an emergency medical worker, nurse, physician, etc. to determine the contents in the **super rare** chance of an overdose or major recall or ADE, etc.

 

[zelman]

I and my staff pharmacist (after I had a couple of talks with him) make sure that we include the ingredients (abbreviated) on the label. Just putting 'Magic Mouthwash' for example is not enough to meet BOP requirements and allow an emergency medical worker, nurse, physician, etc. to determine the contents in the **super rare** chance of an overdose or major recall or ADE, etc.

I recommend including the auxiliary label info in the SIG, too. Don't assume whoever is processing a refill will do anything right.