couple last minute questions -- sorry

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khydroxide

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Inspection is scheduled for next week.

Niosh -- separate them from other meds and create a list of what we have and organize them as table 1,2,3 drugs - does that sound ok ?

Drug retail price list : is there any way to get this list with prices already on there ? I think its ridiculous that we have to manually write in each price. Kinray doesn't even show the retail price for some items so what do we put in ?

reference: copies of access to laws, rules, regulations ( i guess just print everything from this link NYS Pharmacy:Laws, Rules & Regulations )
reference resources to carry on practice of pharmacy -- this one has me stumped. i have a usp40 nf35 from 2017 from the previous owner. is that sufficient ?

what does it mean to complete the CMS fraud,waste and abuse training ? I looked it up and there only seems to be some online references, some pdf files to read, etc. (Provider Compliance | CMS)
- don't see anything that provides proof of completing it or any way to acknowledge that it was done. Can someone point me in the right direction ?

I don't have a dea registration/certificate posted because the previous owner took it with him. not sure if this will be an issue or not.

Hope i didn't miss anything but if i did please let me know. Thank you guys again as always.

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Just reporting back on the inspection for any newbies like myself.

The inspector is not likely to be a pharmacist. They basically just go through a checklist which you can get on the bop website. They run through the pharmacy looking for expired meds, make sure your narc paperwork is readily available (initial inventory at closing/opening signed with time and date), sample rx label, signage (do not flush, retail price list available). i was not asked about CMS fraud, waste, abuse or hipaa or NIOSH but YMMV.

FYI daily logs and electronic prescriptions(including narcs and control) are not required to be printed by the bop. As long as you have a daily log signature book and you sign it everyday you are good. i always wondered why we had to sign that little book at cvs.... now i know

anyway it was really not a big deal. i got all nervous for no reason lol


BTW if anyone can offer insight on change of SP/PIC and how that works please let me know. Unfortunately i've decided to quit as soon as i started but i do not know what the proper procedure is. I am aware of the form that needs to be filled out but besides that is there anything else i have to do ? Any input would be greatly appreciated. Thanks.
 
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OP why are you sorry?
 
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Propranolol sometimes helps with anxiety.
 
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Anyone know if there is a cms fraud, waste and abuse for 2020? Or when it is likely to be posted. I looked on the website and didn’t find one.
 
Niosh -- separate them from other meds and create a list of what we have and organize them as table 1,2,3 drugs - does that sound ok ?

YES - HD's separated from the rest of stock. Procedures in place. Gloves and chemo wipes being used. Here's a post on this that might help: Post | Pharmacy Compliance

Drug retail price list : is there any way to get this list with prices already on there ? I think its ridiculous that we have to manually write in each price. Kinray doesn't even show the retail price for some items so what do we put in ?

All I can say on this is - NY makes you present a drug retail price list? That's insane... I've never had to do anything like that in my life.

reference: copies of access to laws, rules, regulations ( i guess just print everything from this link NYS Pharmacy:Laws, Rules & Regulations )
reference resources to carry on practice of pharmacy -- this one has me stumped. i have a usp40 nf35 from 2017 from the previous owner. is that sufficient ?


Not sure what your board requires, but you can download USP 800 here: http://go.usp.org/l/323321/2019-05-31/2dfgwl
immunize.org has stuff to get your vaccines/cold chain in order
Here are some opioid dispensing guidelines just to impress the inspector: https://www.cdc.gov/drugoverdose/pdf/Guidelines_Factsheet-a.pdf

If the board requires any other references, it should be spelled out clearly in the state pharmacy practice act or administrative rulings.

what does it mean to complete the CMS fraud,waste and abuse training ? I looked it up and there only seems to be some online references, some pdf files to read, etc. (Provider Compliance | CMS)
- don't see anything that provides proof of completing it or any way to acknowledge that it was done. Can someone point me in the right direction ?


Every year staff have to complete CMS FWA to be able to re-credential with insurance companies. Recently, CMS stopped requiring pharmacies to do so for their purposes (CMS Removes Compliance Training Requirements for Downstream Providers Under Medicare Advantage and Part D | Hall Render), but virtually every insurance company I've re-credentialed with requires it.

Here's a good article for some background on it:Why You Need to Complete a Yearly Pharmacy Medicare Attestation

Also, be sure you are checking for OIG exclusions, as well as state databases: Post | Pharmacy Compliance

To do it:
Have each staff register with this site: Login

Have them complete the two required training courses and print their certificates for you.

Keep them on file for 10 years (that's the required amount of time for this record).


I don't have a dea registration/certificate posted because the previous owner took it with him. not sure if this will be an issue or not.

Go to the DEA's website and reprint it here:Duplicate Certificate Login Screen

All you have to do is enter your info and you can download a new one in under 10 minutes.

Hope that helps!

Alex
 
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