PIC change control count

[VictorOfHungerGames]

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So the previous pic left about a month and half ago and pharmacy had some management issues and didnt have a pic for awhile. If i were to go in as a new pic, anyone know how much time i have until i have to do the incoming pic control count?

 

[zelman]

It should be done your first day IIRC.

 

[VictorOfHungerGames]

It should be done your first day IIRC.

Ok cool. So its mostly done but there are some discrepancies bw the control book count and actual count. Different fill in pharmacists were working for a month so no way for me to investigate or find out what happened. Do i just reset and make current count as default and start fresh and document?

The whole point of control count is to make sure out going pic doesnt take anything right? And you just keep the count as for your record?

 

[zelman]

Ok cool. So its mostly done but there are some discrepancies bw the control book count and actual count. Different fill in pharmacists were working for a month so no way for me to investigate or find out what happened. Do i just reset and make current count as default and start fresh and document?

The whole point of control count is to make sure out going pic doesnt take anything right? And you just keep the count as for your record?

You want to be able to establish any discrepancies that come up existed before you were responsible. Reconcile what you can, but that will probably just be CIIs. I think the bigger concern tends to be missing 500ct bottles of CIII-Vs because they’re harder to track down.

 

[PharmDBro2017]

Ideally you and whomever was interim PIC should complete a narc count together on your first day of being new PIC, and both sign off on it being accurate.

 

[VictorOfHungerGames]

You want to be able to establish any discrepancies that come up existed before you were responsible. Reconcile what you can, but that will probably just be CIIs. I think the bigger concern tends to be missing 500ct bottles of CIII-Vs because they’re harder to track down.

Ok. Thanks. Just wasnt sure if this is something i have to report to the state board or something. Or something that they check closely when they make their visits. Since the entire inventory was trashed from poor management and some fill in pharmacists werent recording c2s in the book, there seem to be no way for me to investigate the discrepancies.

 

[VictorOfHungerGames]

Ideally you and whomever was interim PIC should complete a narc count together on your first day of being new PIC, and both sign off on it being accurate.

Right. Thats what i thought but this pharmacy apparently was missing a pic for a while. Not sure if that was even legal lol but new owner took over and he brought me over as a pic recently.

There is record of outgoing pic doing the control counts before he left the pharmacy and i checked the list against the balance in the book. They match up. Only problem is, there is a month gap bw me and him and during that month, there were other pharmacists that filled in.

 

[owlegrad]

Well you can run a dispensing history report and check that against the logs, right? Why is there “no way for you to invest what happened”?

Also you are aware that all ‘significant’ losses have to be reported to the DEA, right? And probably your state BOP as well but I suppose that will depend on the state.

 

[VictorOfHungerGames]

Well you can run a dispensing history report and check that against the logs, right? Why is there “no way for you to invest what happened”?

Also you are aware that all ‘significant’ losses have to be reported to the DEA, right? And probably your state BOP as well but I suppose that will depend on the state.

Yes i can investigate but what i mean is, if there is a discrepancy, i dont know what happened. For example, was there a miscount? Someone lose a pill or two? Was there theft? Haha hope not.

Discrepancies, about 4 drugs, are very small. Like 1-5 pills missing. Again, i dont know if thats just human error that happened during poor management of pharmacy or something else. Nothing big that will warrant reporting to DEA i dont think.

 

[VictorOfHungerGames]

I suppose my ultimate question is, if the book is logged and updated, wouldnt that be the most important thing?

 

[lord999]

I suppose my ultimate question is, if the book is logged and updated, wouldnt that be the most important thing?

You passed your state's MPJE?

No. If there are serious unacceptable discrepancies, you inform the Board or the DEA within the time period. I'd recommend that if you don't have an accountable PIC, another pharmacist serves as second. In cases of discrepancies, that is a DM problem if not a regulatory one. Depending on the state, you are supposed to refuse the PIC should there be reportable discrepancies until they are accounted for either internally or externally.

By the way, based on what you say, probably not, but you have to update the books as the baseline inventory unless you're in a state crazy enough to have a 100% inventory in certain ones. You should re-read the DEA manual and the state CSA again for permissible filing.

 

[zelman]

You passed your state's MPJE?

I mean, you can pass most tests with a significant knowledge gap. I probably got every oncology question on my NAPLEX wrong, but passed based on my other areas of knowledge.

 

[PharmDBro2017]

If narc inventory is incorrect, missing, and you can't reconcile it.... you fill out a DEA Form 106 online on the DEA website. My state makes you send a copy to the department of health and board of pharmacy as well.

 

[VictorOfHungerGames]

You passed your state's MPJE?

No. If there are serious unacceptable discrepancies, you inform the Board or the DEA within the time period. I'd recommend that if you don't have an accountable PIC, another pharmacist serves as second. In cases of discrepancies, that is a DM problem if not a regulatory one. Depending on the state, you are supposed to refuse the PIC should there be reportable discrepancies until they are accounted for either internally or externally.

By the way, based on what you say, probably not, but you have to update the books as the baseline inventory unless you're in a state crazy enough to have a 100% inventory in certain ones. You should re-read the DEA manual and the state CSA again for permissible filing.

Haha thanks for your concern. I did pass the mpje with flying colors.

Since ive never been in this situation before where previous pic wasnt there for the exchange of duties, i want to make sure im doing things correctly.

When ever state board visited in my previous pharmacies, they usually asked about the log book and where we kept the c2 scripts and what not.

Anyone have experience in the state board asking about control counts from previous pic?

 

[johnpharm01]

Haha thanks for your concern. I did pass the mpje with flying colors.

Since ive never been in this situation before where previous pic wasnt there for the exchange of duties, i want to make sure im doing things correctly.

When ever state board visited in my previous pharmacies, they usually asked about the log book and where we kept the c2 scripts and what not.

Anyone have experience in the state board asking about control counts from previous pic?

This thread is frightening. As PIC you are accountable to the state BOPs and the DEA as well as the FDA. Check your state board regs but I believe it is 72 hours to do the controlled substance inventory at the beginning or end of shift and the inventory must state so. Then significant discrepencies must be reported to the dea in 24 hours of discovering them. In states I worked in the state as well. If you don't think that a few tablets is significant, you could be very wrong. Maybe its record keeping error maybe theft. Take your physical inventory and compare it to the logbook ( I take it is a perpetual paper inventory). For all the ones which are off go back and make sure all additions (orders) have been logged. Then look at the subtractions (primarily dispensed prescriptions but returns and destroyed rxs) are entered. Double check the math, make sure the entries have been logged in under the correct drug (i.e. a norco 5 rx was subtracted from the norco 10 page). If you still have discrepencies that cannot be accounted for log them in, have a witness initial the entry. Every tablet or ml of drug should be accounted for from the time it enters the pharmacy to the time it leaves.

Another thing, you come across as being flippant. I would get dead serious. If you do have a diversion problem the diverter will notice and hammer you. If its record keeping the staff need to know to pay better attention.

Finally, make sure you get on the POA for C 2s so you can order them legally.

 

[VictorOfHungerGames]

This thread is frightening. As PIC you are accountable to the state BOPs and the DEA as well as the FDA. Check your state board regs but I believe it is 72 hours to do the controlled substance inventory at the beginning or end of shift and the inventory must state so. Then significant discrepencies must be reported to the dea in 24 hours of discovering them. In states I worked in the state as well. If you don't think that a few tablets is significant, you could be very wrong. Maybe its record keeping error maybe theft. Take your physical inventory and compare it to the logbook ( I take it is a perpetual paper inventory). For all the ones which are off go back and make sure all additions (orders) have been logged. Then look at the subtractions (primarily dispensed prescriptions but returns and destroyed rxs) are entered. Double check the math, make sure the entries have been logged in under the correct drug (i.e. a norco 5 rx was subtracted from the norco 10 page). If you still have discrepencies that cannot be accounted for log them in, have a witness initial the entry. Every tablet or ml of drug should be accounted for from the time it enters the pharmacy to the time it leaves.

Another thing, you come across as being flippant. I would get dead serious. If you do have a diversion problem the diverter will notice and hammer you. If its record keeping the staff need to know to pay better attention.

Finally, make sure you get on the POA for C 2s so you can order them legally.

Thankfully I was able to reconcile all the drugs this morning. Log book was not kept up to date with other fill in pharmacists and some drugs were placed in wrong spots.

Still wondering what state board looks for when they visit a pharmacy with pic change.

 

[lord999]

I mean, you can pass most tests with a significant knowledge gap. I probably got every oncology question on my NAPLEX wrong, but passed based on my other areas of knowledge.

Agreed, although the comment was more from the "missing the forest for the trees" matter. The most important thing isn't getting the count right, rather, it's making the regulatory bodies believe that the count is under control even with discrepancies.

 

[VictorOfHungerGames]

Agreed, although the comment was more from the "missing the forest for the trees" matter. The most important thing isn't getting the count right, rather, it's making the regulatory bodies believe that the count is under control even with discrepancies.

Lol stop these insults! I was just asking about how to handle this situation from those who has experience. Sheesh.

I got it figured out but thanks for your concern.

 

[owlegrad]

Lol stop these insults! I was just asking about how to handle this situation from those who has experience. Sheesh.

I got it figured out but thanks for your concern.

Lol I am not sure what you expected. A bunch of “sure don’t worry about it, it’s just a few here and there and besides you weren’t even PIC yet” comments? Of course the only people who are going to comment are the sticklers who think ever tab must be GPS tracked. 😉

I am not sure what you mean by “what they look for” for a change of PIC. If they look for anything it will be that the physical inventory took place within the specified time period. In my state you also have to give the board notice when you become (or stop being) PIC. What else would they look at?

 

[johnpharm01]

The states I have worked in do not specifically require inspections when PIC is changed. The inspectors come in for two reasons generally: 1. Routine inspections annually. 2. Inspections sparked by a complaint. But states vary so check your board regs. One state I worked in provided a checklist for PICs to help with compliance it was located on the BOPs website. As long as you are compliant with the board regs, dea regs, fda requirements you will be ok. Go over the last inspection the pharmacy had (before you got there) and make sure those deficiencies are remedied- repeat deficiencies are a no no.

I am guessing you are new to being a PIC. Good luck and anymore questions answered will require a consultant fee. Remember you are being paid to figure this out not the folks on this forum.

 

[CetiAlphaFive]

Ok. Thanks. Just wasnt sure if this is something i have to report to the state board or something. Or something that they check closely when they make their visits. Since the entire inventory was trashed from poor management and some fill in pharmacists werent recording c2s in the book, there seem to be no way for me to investigate the discrepancies.

https://www.deadiversion.usdoj.gov/21cfr_reports/theft/index.html

Right. Thats what i thought but this pharmacy apparently was missing a pic for a while. Not sure if that was even legal lol but new owner took over and he brought me over as a pic recently.

There is record of outgoing pic doing the control counts before he left the pharmacy and i checked the list against the balance in the book. They match up. Only problem is, there is a month gap bw me and him and during that month, there were other pharmacists that filled in.

Wait... "new owner"? Is this an independent?

RUN.