Custom Pharmacy Policy and Procedure Manual
Custom P&P manuals are now a must! Every pharmacy must have written policies and procedures in a Policy and Procedure manual. According to the National Association of Boards of Pharmacy (NABP) every state and the majority of third party PBMs have specific policy requirements that the pharmacy is expected to incorporate into their manuals. More importantly, the pharmacy is expected to adhere to their own policies and procedures and document when necessary to be able to prove that they do so. This means that in certain instances the pharmacy must also be able to demonstrate adherence by additionally having accessible documentation to support that they actually do follow a specific policy and procedure. Merely possessing a generic P&P manual is not enough. The manual must be customized to the individual pharmacy operation and contain the required policies and reflect the actual procedures involved in the operation of that specific pharmacy.
The Reality of Pharmacy Policy and Procedure Manuals
Most of the pharmacy owners and pharmacists that we talk with are extremely busy dealing with the day-to-day business of making a living. Filling prescriptions, compounding IV’s, consulting with patients and all the other tasks that their jobs require them to deal with on a daily basis lead to items like developing and updating a P&P manual on the “back burner”. Additionally, the development and maintenance of a written Policy and Procedure manual simply is not their area of expertise and in most cases is not even on their “Must Do List”. The fact of the matter is that the majority of pharmacy owners are satisfied with a generic P&P manual. But is the State Board of Pharmacy, the FDA, the DEA, the PBM’s and the remainder of the regulatory agencies satisfied? The answer is no! What’s required are customized policies and procedures that are up-to-date, plus are regularly updated, maintained and strictly adhered to.
The Real Bottom Line
The bottom line is that all pharmacies are required to have a written P&P manual AND the pharmacy is expected to adhere to their own policies and procedures. In almost every case of a pharmacy receiving disciplinary or punitive actions from a State Board of Pharmacy, Federal Agency or a third party (such as a PBM), the results were dramatically worsened by two factors:
1. A lack of Policies and Procedures in place
2. A lack of documented adherence to the existing Policies and Procedures
In what is now being called “The Age of Documentation” in the pharmacy business, merely possessing a generic Policy and Procedure manual is not enough. This manual must contain the required policies and reflect the actual operational procedures of the pharmacy. Plus, it now lies on the pharmacy to prove that the established policies and procedures are being followed and adhered to by their employees! In addition to what most would consider the “normal” policies and procedures that are expected, many examples have been in the news for additional ones that most don’t even consider. Just a few examples include:
– Patient Consultations
– Pharmacy Security
– Pharmacy Emergencies
– Drug Recalls
– Dispensing Errors and Medication Errors
– HIPAA Compliance and Patient Records
– Drug Supply Chain Integrity Act Compliance (DSCSA)
The list is virtually endless.
Where Do You Start?
You start with HCC! Our regulatory and operations consultants can assist your staff in developing or customizing an existing Policy and Procedure manual that is sufficient and specific. We will also create a process that will allow your pharmacy manager to update and modify the policies as needed. HealthCare Consultants’ in-house experts have years of experience in Policy and Procedure development and operational evaluation and can provide your pharmacy team with valuable insights and recommendations. Let HCC help you.
Healthcare Consultants is a leading national Pharmacy Consulting company offering expertise in all areas of pharmacy consulting. Known for being one of the nation’s leading pharmacy staffing companies for over two decades, Healthcare Consultants has been in the business of Pharmacy Consulting for over 28 years now. HCC is in the business of helping pharmacists establish, run, improve and make their businesses profitable. Known nationally as one of the industry leaders in providing a full range of professional pharmacy consultation services to its vast array of clients, HCC is owned and operated by pharmacists. We can provide proven expertise and experience in all facets of pharmacy operations, including retail, hospital and all specialty pharmacy venues.
Don’t let “being to busy making a living” lead to potential issues and problems that can result in serious threats to your pharmacy! As the old cliché says: An ounce of prevention is worth a pound of cure! Contact us online or call us today for a Free Consultation at 800-642-1652 to discuss how we can help you.