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Foreign Pharmacies Dispensing to USA

Foreign Pharmacies Dispensing to USA

Foreign Pharmacies Dispensing to US Patients

Legislation is currently being initiated which would actually allow for the Foreign Pharmacies Dispensing to USAdispensing of prescription drugs and medications from a licensed foreign pharmacy to patients in the US. With the massive debate currently under way in Washington regarding the health care repeal legislation, there will obviously be numerous amendments that are going to be presented on various health care matters that are focused on pharmacy. The cost of pharmaceuticals and the ever increasing cost associated with prescriptions and medications are placing pharmacy in the “center of the target” when it comes to regulations aimed at health care cost reduction. One such proposed amendment being considered is a provision in S. 469 which would allow for the dispensing of drugs from a licensed foreign pharmacy to patients here in the U.S.

S.469 – Affordable and Safe Prescription Drug Importation Act

Sponsored by Senator Bernard Sanders form Vermont, S.469 was introduced in February earlier this year. It has since been reviewed twice and now referred to the Committee on Health, Education, Labor, and Pensions. Basically, Senator Sanders and several other Senators are pushing this legislation (or “repeal bill”) to allow foreign pharmacies and offshore wholesale pharmaceutical distributors to provide prescription drugs to patients in the United States. The foreign pharmacies aren’t even required to have U.S. pharmacy licenses, nor U.S. licensed pharmacists or registered pharmacy technicians. Additionally, no inspections are required and no means of evaluating the pharmacies’ safety are included in the legislation as it now stands.  Furthermore, if they dispense the wrong drug or counterfeit medications to US citizens, it will be virtually impossible to discipline them because their staff and assets are all beyond U.S. borders, regulation and controls. As we all know, here in the US all pharmacies and pharmacy staff are regulated and licensed by the Department of Health and the Board of Pharmacy in each state to protect every patient’s safety. Additionally, federal regulatory agencies such as the FDA and DEA ensure that patient safety is of the utmost importance. Allowing pharmacies in other countries that cannot be disciplined to dispense medications to patients here in the USA is clearly dangerous to a patient’s safety. There would be virtually no control and little oversight over the use of unlicensed personnel or unapproved and untested products.

Florida Pharmacy Association Says: Take Action!

Kudos to the FPA (Florida Pharmacy Association) who contacted all of it’s members this week in an effort to stop this bill from passing. The FPA encouraged all of it’s membership to contact Florida Senator Bill Nelson and Florida Senator Marco Rubio to raise concerns over such a proposal. The FPA House of Delegates wants to make it clear to Washington that it is unable to support such a change and that the results will be detrimental and present a major danger to patient safety.

HealthCare Consultants Pharmacy Staffing is headquartered in Central Florida and involved nationally in pharmacy consulting and staffing for over 28 years now. We agree with the FPA’s call to take action and would recommend visiting their site where they have prepared an “Action Alert” for Florida pharmacists with a sample message and instructions. As always, HCC welcomes any feedback and will answer any questions that you may have on this topic (or on any others!). HCC is owned and operated by pharmacists and we provide proven expertise and experience in all facets of pharmacy operations, including retail, hospital and all specialty pharmacy venues. Contact us online or call us today at 800-642-1652 to discuss how we can help you.


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Florida HB 625 Managed Care Plan Provider Networks

Florida House Bill 625 Regarding Managed Care Plan Provider Networks:

Florida House Bill 625 was introduced and filed in the Florida State Senate in March 2017 and is now in committee/council (HIS). Many independent community pharmacies in Florida are strongly advocating for the bill as it relates to the current Managed Care Plan Provider Networks. Essentially HB 625 would prohibit a managed care plan from excluding any participating pharmacy that meets the credentialing requirements and standards established by the Agency for Health Care Administration (AHCA) and that accepts the terms of the plan. It also basically requires all managed care plans to offer the same rate of reimbursement to all pharmacies in the plan network.

Issues With the Existing Managed Care Plan Provider Network Rules:

Most independent community pharmacies are strongly in favor of the new rules. As many see it, the problems with the existing rules are that they are restrictive to what are considered “industry fair practices” and result in the patient facing limited options or choices in getting their prescriptions filled. To sum up the issues, the advocates of the new Florida House Bill 625 point out the following existing issues:
– The current rule allows Medicaid managed care plans to limit the pharmacies allowed in their Medicaid Networks based on meeting Federal Medicare network adequacy standards.
– AHCA adopted federal Network access standards currently only require plans to have a pharmacy within a 30-minute travel time for patients in urban areas and a 60-minute travel time for patients in rural areas. This access standard creates a hardship for Medicaid recipients who have limited transportation and resources.
– These closed networks have forced consumers to leave their local pharmacies that many Medicaid recipients often rely on for an array of medical services, advice and assistance.
– Several plans have negotiated pharmacy services using only 2 or 3 chain pharmacies, thus excluding hundreds of local Florida based pharmacies from participating in the Medicaid program.

Many organizations have rallied behind the proposed new Florida House Bill 625. An example is the Florida Independent Pharmacy Network (FIPN) who has been strongly urging that proponents of the bill to take action and reach out via phone &/or email.  Below is a list supplied from FIPN regarding the contact information for the Speaker of the House, the Committee Chairs and the Committee Members:
Representative Richard Corcoran (Speaker of the House)
District Ph: (813) 792-5177 – Capitol Ph: (850) 717-5000
Representative Travis Cummings (Health & Human Services Committee Chair)
District Ph: (904) 278-5761 – Capitol Ph: (850) 717-5018
Representative MaryLynn Magar (Health Innovation Subcommittee Chair)
District Ph: (772) 545-3481 – Capitol Ph: (850) 717-5082

Health Innovation Subcommittee Members:
Representative MaryLynn Magar – District Ph: (772) 545-3481 – Capitol Ph: (850) 717-5082
Representative Shawn Harrison – District Ph: (813) 910-3277 – Capitol Ph: (850) 717-5063
Representative John Cortes – District Ph: (407) 846-5009 – Capitol Ph: (850) 717-5043
Representative Daisy Baez – District Ph: (305) 442-6825 – Capitol Ph: (850) 717-5114
Representative Manny Diaz, Jr. – District Ph: (305) 364-3072 – Capitol Ph: (850) 717-5103
Representative Brad Drake – District Ph: (850) 951-0547 – Capitol Ph: (850) 717-5005
Representative Nicholas Duran – District Ph: (305) 860-7119 – Capitol Ph: (850) 717-5112
Representative Roy Hardemon – District Ph: (305) 795-1224 – Capitol Ph: (850) 717-5108
Representative Patrick Henry – District Ph: (386) 238-4650 – Capitol Ph: (850) 717-5026
Representative Sam Killebrew – District Ph: (863) 291-5254 – Capitol Ph: (850) 717-5041
Representative Paul Renner – District Ph: (386) 446-7644 – Capitol Ph: (850) 717-5024
Representative Bob Rommel – District Ph: (239) 417-6200 – Capitol Ph: (850) 717-5106
Representative Jackie Toledo – District Ph: (813) 281-5549 – Capitol Ph: (850) 717-5060
Representative Jay Trumbull – District Ph: (850) 914-6300 – Capitol Ph: (850) 717-5006
Representative Frank White – District Ph: (850) 595-0467 – Capitol Ph: (850) 717-5002

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The Pharmacy and Medically Underserved Areas Enhancement Act of 2015 (H.R. 592/S. 314)

Pharmacy and Medically Underserved Areas Enhancement Act of 2015:

HCC is committed to helping get The Pharmacy and Medically Underserved Areas Enhancement Act of 2015 (H.R. 592/S. 314) passed. The bill would amend title XVII (Medicare) of the Social Security Act to cover Pharmacist services. This would allow Pharmacists to help fill some gaps in the health care system in providing much needed patient care services to Florida’s neediest and underserved communities. To make this happen we all need to show our support!

I would like to share parts of a recent email that was received from Scott Tomerlin, the President-elect for the Florida Pharmacy Association. In it Scott shares several statistics that you may find to be helpful:

– 30 out of 67 Florida counties include areas designated as “medically underserved”

– Florida will be short 7,000 doctors by 2025, with 253 active physicians per 100,000 residents as of 2012 according to the Association of American Medical Collages.

– Southwest Florida is of 3 regions in the state where medical demand is expected to exceed supply by the highest amounts 10 years from now.

– For every $1 that is invested in Pharmacists provided services, a return on investment of $4 is realized in health care savings.

– In Florida alone, there are over 19,900 Pharmacists ready to help.

As Scott points out, while we can all agree that supply and demand changes for Pharmacists and the job market has shifted dramatically, this bill has the potential to be a viable step to help create more demand for Pharmacist provided services. We know the positive impact of Pharmacists provided services in the health care setting, and certainly those patients that receive these services do, but do our Legislators? How will they ever know if we sit silently on the sideline and wait for others to dictate the direction of our profession?

A Special Thanks to those Legislators in our state that have already co-sponsored this legislation, as well as those constituents in their district whom have reached out to those members. Currently, there are 161 Cosponsors (8 in Florida) in the U.S. House of Representatives and 22 Cosponsors (0 in Florida) in the U.S. Senate.

Current H.R. 592 Co-Sponsors (Florida) as of July 15, 2015 (and date of co-sponsorship)

Rep. Hastings, Alcee L. [D-FL-20]

Rep. Jolly, David W. [R-FL-13]

Rep. Ross, Dennis A. [R-FL-15]

Rep. Murphy, Patrick [D-FL-18]

Rep. Bilirakis, Gus M. [R-FL-12]

Rep. Curbelo, Carlos [R-FL-26]

Rep. DeSantis, Ron [R-FL-6]

Rep. Nugent, Richard B. [R-FL-11]

Current S. 314 Co-Sponsors (Florida)

If you do NOT see your representative on this list, we urge you to contact them today!
How do you contact them?

Use the FPA direct link to CAPWIZ – This will allow you to send an email to your local Congressman to urge them to co-sponsor the bill:

Now is the time that we act, not react, to what is happening around us in the Practice of Pharmacy and Health Care in general. I ask with the strongest urgency that you reach out TODAY to your local legislator to co-sponsor H.R. 592/S. 314 “Pharmacy and Medically Underserved Areas Enhancement Act of 2015”.

Please keep in mind – the legislators that you have voted in office are there to represent you and your interests – your beliefs, morals and ideals just to name a few. I would hope you would consider YOUR Profession of Pharmacy that you practice to be of utmost concern as you are interacting with your legislator. (and eventually voting for in the polls!).

Bob Miller

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DEA Approves Expanded Ways to Dispose of Old and Unwanted Medications

There is a new DEA regulation approved that allows consumers expanded ways to dispose of old and unwanted medications. For many people the only way to dispose of old, unwanted or expired medications was to flush them down the toilet, throw them away in the trash or take them to the local police station. Now the DEA is making it easier to get rid of unwanted drugs by consumers by allowing them to drop them off at their local pharmacies. The new DEA mandate will allow pharmacies to collect old prescription medications including narcotics and pain killers. This will allow consumers a safe and effective way to dispose of them in the future. It will also alleviate environmental concerns that currently revolve around disposal of medications in the garbage and toilet. By federal regulations in the past narcotics could not be taken back or returned to pharmacies for disposal. Under the new regulation that takes effect in a month, local community pharmacies and drugstores can serve as collection points for unused narcotics. This also includes hospitals with pharmacies and even drug treatment centers.

It is important to note that many consider the change long overdue. In 2013 alone there were over 230 million prescriptions written for narcotic pain killers in the United States. More people died in 2013 from drug over-doses than from car accidents. Dr. G. Caleb Alexander (Director of the John Hopkins Bloomberg School of Public Health Center for Drug Safety) made the point that “It’s baffling that it’s so easy to get a prescription for opioids and yet so difficult to dispose of these drugs safely”. Although the new rule is primarily focused on the disposal of unused narcotics, a DEA spokesman confirmed that it would also apply to the return of other drugs by consumers. It is important to note that there is no requirement for pharmacy participation. However, we at Healthcare Consultants strongly urge all pharmacies to get involved. Participation in this program would allow a local pharmacy to be involved in their community and to garner goodwill by providing a new and valuable service to it’s patients. It would also allow a pharmacy to distribute promotional and educational materials in their local community to patients and potential customers explaining how the program works and discussing the benefits of correct drug disposal.

As always, Healthcare Consultants is here to help. If you need assistance in any way or would like to talk about ideas on how to get started and participate in the new collection program….. call us today! With over 25 years experience in Pharmacy Consulting, HCC can of course help you answer any questions that you may have. Call us today at 800-642-1652 to talk with a customer service representative for a free consultation.

Bob Miller

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Pharmacy Ownership Law to Change in North Dakota

North Dakota is the only state left that still requires that pharmacies be majority owned by pharmacists who are licensed in their state. This may be changing in lieu of the fact that a vote aimed at changing North Dakota’s pharmacy ownership law will appear on the November 4th statewide ballot. If it passes, the state law would be amended to remove the requirements that all pharmacies in North Dakota be owned and operated by a licensed pharmacist in the state, a business that is controlled by licensed pharmacists in the state or a hospital pharmacy or post-graduate medical residency training program.

Many have claimed that the existing law and status in North Dakota has resulted in higher costs for prescription drugs and pharmacy related services by presenting people in the state with fewer options. A group aptly named the North Dakotans for Lower Pharmacy Prices has repeatedly pointed to a 2009 study by the Kaiser Family Foundation that they say supports their claim that the current law leads to inflated prescription prices in the state due to lowered competition. The study found that per-capita spending on prescription and non-prescription drugs in North Dakota was the fifth highest in the nation. The North Dakota Pharmacists Association still supports the existing law and has advanced its own studies letting voters know why the law should be kept in place by voters.

It is important to note that changing the pharmacy ownership law would allow giant national retailers such as Walgreens and Wal-Mart to finally operate pharmacies in the state.

Healthcare Consultants has been in business for over 25 years providing consultations to pharmacists and pharmacy owners on the topic of pharmacy ownership. If you have any questions regarding the laws and rules in your state on the subject of pharmacy ownership, we urge you to contact us online or call us today at 800-642-1652.

Keep in mind that HCC is a full service Pharmacy staffing and service provider that offers a broad range of additional services including:

– Pharmacist coverage – temporary, vacation & fill-in coverage
– Direct hire / permanent placement
– Provide pharmacy manager / PIC
– Equipment needs assessment
– Medicaid / 3rd party review
– Moving a pharmacy to a new location
– Exist strategies
– Out of state licensing
– Business plans/ Pro Forma
– Management consultations
– Audit / survey /mock inspections
– Regulatory agency review
– Expanding, redesigning or a complete overhaul of your pharmacy
– Compliance review for compounding pharmacies (USP 795 & 797)
– Policy & procedure recommendations

Bob Miller


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Pharmacy News – Tramadol Transitioning to Schedule IV

As many of you may already be aware, Tramadol is being converted into a Schedule IV controlled substance in the State of Florida. This action coincides with the DEA announcement that, effective August 18, 2014, Tramadol will be placed into Schedule 4 of the federal Controlled Substances Act. Several states, including Arkansas, Georgia, Kentucky, Illinois, Mississippi, New York, North Dakota, Oklahoma, Tennessee, West Virginia, Wyoming and the U.S. military had already classified Tramadol as a schedule IV controlled substance under state law.

Known as the brand name Ultram, tramadol has been used for the treatment of moderate to moderately severe pain in the United States for almost twenty years now. A centrally acting opioid analgesic, tramadol has always been a non-controlled legend prescription drug in the State of Florida. Studies have shown that tramadol is approximately equally potent when compared to codeine.

Recently the abuse of tramadol has been on the rise nationwide and has drawn substantial media attention. Recent studies have also shown that long-term usage of high doses of tramadol are associated with physical and psychological dependence. Withdrawal syndrome from tramadol use can be very severe and the possibility of convulsions exists. Other symptoms include anxiety, tremors, headaches, depression, severe mood swings, sweating and aggressiveness. As pharmacists, it is important to recognize these potential withdrawal symptoms if our patients are being taken off of tramadol or receiving lowered doses. Tramadol withdrawal can be dangerous and severe.

The new rule regarding tramadol in Florida was published in the federal register on July 2, 2014 and has an effective date of August 18, 2014. Many pharmacists have been asking how this transition should be handled. Although not a lawyer or providing legal counsel, Michael Jackson, BPharm (the Executive VP of the Florida Pharmacy Association) has provided the following recommendations:

– After August 18, 2014 any prescriptions filled or refilled for Tramadol should be in compliance with the federal (and state) controlled substance laws including but not limited to the 6 month or 5 refill restrictions.

– Pharmacists may want to review the prescribing practitioner to make sure that they have a DEA license and are authorized to prescribe controlled substances.

– Pharmacists should take a few moments to consult with the patient’s prescribing practitioner for those prescriptions written or on file that are outside of the recordkeeping and prescribing rules and regulations for controlled substances with a goal towards continuity of care.

– New written prescriptions will likely need to be on Florida approved tamper resistant prescription blanks.

– Pharmacies will need to add to their controlled substance inventory list Tramadol products and also consider plans to include reporting to e-Forcse sometime in the near future.

Although we here at HCC are not lawyers nor qualified to present legal counsel, we are here to help with any questions that you may have regarding this tramadol scheduling transition. Contact us online or call us at 800-642-1652 today if you have questions or require assistance. As always Healthcare Consultants Pharmacy Staffing is in the business of helping pharmacies and pharmacists!

Bob Miller


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HCC Pharmacy Staffing & Consulting – What Our Clients Say About Us!

Healthcare Consultants has been in the business of Pharmacy Staffing and Consulting for over 25 years now. Known as one of the nations leading full service Pharmacy Staffing companies, HCC is also one of the industry leaders in providing a full range of professional pharmacy consultation services. Owned and operated by pharmacists, in addition to our Pharmacy Staffing division, Healthcare Consultants can provide proven expertise and experience in all facets of pharmacy operations, including retail, hospital and specialty pharmacy venues.

But why take our word on how good we are? Read what some of our clients have been saying about us:

Healthcare Consultants Pharmacy Staffing and my company have been doing business now for over 10 years together. Regardless of any situation they have been walking side by side with me. They have resources to help maintain the highest standards in the industry as far as compliance quality assurance and personnel. I would recommend them to anyone in the industry. I consider all of their team an extended part of my family and staff.

– GT

I have been using HCC services since 2010 and have constantly received excellent service. HCC has been a great resource for finding quality pharmacists and consultants to conduct regulatory audits at my stores. Bob Miller’s company is the only one I know that you can call at 5:00 am and get a relief pharmacist at 9:00 am the same day. I will have no hesitation recommending HCC.


As a customer of over ten years, I am happy to say that HCC is a professional staffing organization with pleasant and helpful staff who are responsive to customers’ needs. They consistently provide high quality staff who have performed extremely well over the years and, therefore, are my first choice when needing temporary pharmacy staffing.


Having worked with Healthcare Consultants for the past five years, we have been extremely pleased with their ability to match our staffing needs with their candidates. We have used them for a variety of services, including both temporary and permanent placement of pharmacy staff, out of state licensing and consultation for regulatory issues. We have always experienced great success with their recommendations and have found them to be efficient, timely and very responsive to our needs. Bob Miller, the owner and President, is highly involved in understanding the ever changing pharmacy industry, as well as being completely in tune to the different needs of his clients. They are hands-on, responsive and extremely knowledgeable. I would highly recommend their services to anyone looking for pharmacy staffing and pharmacy consultative services.


Healthcare Consultants is a very polite, dependable and professional agency for pharmacy coverage. No matter the time of day or in an emergency situation, HCC finds reliable coverage. The pharmacist come in to fill the position as if they are apart of our family. We appreciate HCC for the assistance and look forward to HCC assisting our company in the years to come.

– RJ

In business for over 25 years, HCC can help you with any Pharmacy staffing or consulting needs YOU may have. As always we offer a free, no obligation consultation to discuss your needs and how we may help. Please contact us on line or call us today at 800-642-1652 to discuss how we can help you!

Bob Miller

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Compounding Pharmacies and the Horse Racing Industry

Every year many of us are captivated by the Triple Crown in horse racing and this year was no different. Many of us were hoping for California Chrome to become the first horse to win all three races since Affirmed accomplished this remarkable feat back in 1978. Well, the Triple Crown races are now over, but a compounding pharmacy in the horse racing industry has been generating a lot of press and news recently.

In early May of this year eight thoroughbred racehorses got sick or died when given an anti-protozoal drug compounded by a specialty pharmacy located in Kentucky. The horses were given a combination of toltrazuril/pyrimethamine, frequently used to treat or prevent equine protozoal myeloencephalitis, which affects the central nervous system in horses. Lexington based Wickliffe Pharmaceutical is now being sued by the owners of the promising race horses. The owners are suing for negligence, claiming Wickliffe allegedly compounded and dispensed the wrong dosages of the drugs, plus for the compounding pharmacy trying to then conceal the error. In addition, the FDA is now investigating! No FDA approved drug exists for the combination of toltrazuril and pyrimethamine for the treatment of EPM (plus the fact that toltrazuril is not approved for equine use). However, the pharmacy did compound the mixture with a veterinarian’s prescription.

This is not the first time that a compounding pharmacy has been in the news involving horses. A few years back, Franck’s Pharmacy in Ocala, Florida was accused of negligence when twenty-one polo horses died due to selenium poisoning from improper compounding of an equine nutritional product. that resulted in the FDA trying to stop Franck’s from compounding veterinary medicine and supplements.

If you own or operate a compounding pharmacy, do you have your policies and procedures up to date? Do you have documentation for your business practices in proper order? Are you compliant to USP 797? Keep in mind that proposed new legislation in the Michigan Senate includes additional compliance regulations for compounding pharmacies that even includes increased criminal penalties for many violations. Particulars of the proposed bill include:

  • Increased record keeping requirements
  • Mandatory bi-annual inspections
  • Designated Pharmacist In Charge at the facility
  • Ongoing licensing and accreditation requirements

If you are a compounding pharmacy, the time to act is now! Do not let small issues with regulatory compliance turn into serious threats to YOUR pharmacy. Be pro-active regarding your policies and procedures for compounding and dispensing preparations. Healthcare Consultants has been helping pharmacies since 1989. Let us help you ensure that your compounding pharmacy has no issues by contacting us today for a complete review of your existing policies and procedures. Reach us online or call today at 800-642-1652.

Bob Miller

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How Big Pharmacies Employ Pharmacists to Reduce Hospital Readmissions

As we have discussed in our previous blog, hospitals are currently in the process of adjusting to the Value Based Purchasing (VBP) system mandated by the Affordable Care Act.  One of the key measures hospitals are subject to is readmissions of recently discharged patients for the same condition (DRG), or so-called “bounce backs”.

An important driver of readmissions is a lack of compliance to post discharge care, including medication regimens.  Many studies have demonstrated the value of pre and post patient discharge medication reconciliation and education by pharmacists in decreasing the rates of readmission.  The problem is that hospitals do not have the necessary pharmacy staff to handle this level of workload.

This is where Walgreens smelled opportunity.  In several pilot programs, Walgreens will send one of their pharmacists to the hospital or patient’s home to perform the medication reconciliation and patient education, also bringing the patient their first fill of their discharge medication.

This appears to be a Win-Win-Win situation: the hospital realizes a reduction in readmissions (improving their potential for increased reimbursement from CMS), the patient receives individualized education with the hope for an improved outcome, and Walgreens captures a new customer as well as strengthens its relationship with the hospital.  The only losers here are independent community pharmacies who had been serving the patients previously (assuming such a relationship had existed).

Overall, this is a very astute program by Walgreens, and it will be interesting to watch and see how it evolves and who follows their lead.


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Pharmacists Help Hospitals Improve Patient Satisfaction Scores

Recently, healthcare administrators have become keenly focused on patient experience and satisfaction as a result of the new Value Based Purchasing (VBP) system, a requirement of the Affordable Care Act.  Under the VBP system, hospitals are paid for in-patient acute care services based on the quality of the care that is provided instead of just the quantity of services.
As part of the measurement of quality, patients are provided a questionnaire regarding their satisfaction, known as the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS).  The scoring of this questionnaire as well as other tools will impact the payment rate the hospital receives from CMS.

So where do pharmacists fit in?  Well, several of the questions within the survey are directly or indirectly related to pharmacy services.  This fact has not been lost on hospital administrators.  Pharmacists are now taking on new duties, becoming more involved in patient education, therapy management, and discharge medication reconciliation.

Though the few initial studies evaluating the effectiveness of these pharmacist interactions have been equivocal, the hope is that expanding and enhancing these pharmacists – patient exchanges will help increase patient satisfaction and improve the HCAHPS scores for the health systems.


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