Sterile Compounding: Highlights of the New Law

Similar documents
Regulation of Hospital Pharmacy. Board of Pharmacy Authority. The New & Proposed Changes to the Hospital Licensing Rules. Conflict of Interests

Advanced Sterile Product Preparation Training and Certificate Program

Submitted electronically via: May 20, 2015

2017 Pharmacy Education Series

Hospital and Other Healthcare Facilities

The Leader in Guidance for the Health Information Management Profession. Patient Safety Monitor Journal

The Joint Commission

About OMICS Group Conferences

An Overview of Sterile Compounding. Marshall Moleschi, Registrar Ontario College of Pharmacists

Profiles in CSP Insourcing: Tufts Medical Center

2018 Pharmacy Education Series

PCAB Compounding Accreditation Accreditation Summary

PHARMACY SERVICES / MEDICATION USE

11/4/2016. Sterile Compounding: USP<797> Revisions and the Compounding Quality Act. In the 1930 s and 40 s, 60% of all medications were compounded.

Implementation of Remote Management of Compounded Sterile Products through the use of a Telepharmacy System

Understanding USP 797

Learning Objectives. A Pharmacist s Guide to Proposed Regulations: An Update from the MA BORP. Chapter 159 of the Acts of 2014: Pharmacy Reform

JCAHO Med Management

Report of the Task Force on Centralized Prescription Filling

US Compounding 2515 College Ave Conway, AR (800)

The ACHC-PCAB Pharmacy Accreditation Program

Clinical IQ, LLC September 2, 2009

The Impact of FDA s New Compounding Guidance: A Primer. Jillanne M. Schulte, JD ASHP Director of Federal Regulatory Affairs

SECTION HOSPITALS: OTHER HEALTH FACILITIES

DC Board of Pharmacy and Pharmaceutical Control Update

COMMUNITY PHARMACY PRACTICE ACCREDITATION CARMEN CATIZONE LOWELL ANDERSON MEMBERS OF CPPA BOARD OF DIRECTORS

PHA 5104 Dosage Forms & Contemporary Pharmacy Practice 2 Semester Credit Hours

Missouri Board Of Pharmacy

A Systematic Approach to Consultant Pharmacy Services

Definitions: In this chapter, unless the context or subject matter otherwise requires:

A Review of Senate Bill 808 and the Revised Class B Hospital Pharmacy Permit

Disclosures. Objectives. Leveraging and Developing Your Team for Optimal Outcomes. None

Accreditation of Hospital Pharmacies Update

Integrating the LLM / JCPP-PPCP Seena Haines, PharmD, BCACP, FASHP, FAPhA, BC-ADM, CDE Jenny A. Van Amburgh, PharmD, RPh, FAPhA, BCACP, CDE

D DRUG DISTRIBUTION SYSTEMS

Radiopharmaceutical. Qualification. Checklist

USP <797> does not apply to the administration of medications.

Pharmaceutical Services Requirements: formerly 10D and 10C.7

Improving Sterile Compounding: Impact of New Regulations, Standards and Guidelines PharMEDium Lunch and Learn Series LUNCH AND LEARN

Licensed Pharmacy Technicians Scope of Practice

4/18/2018. Improving USP <800> Compliance in a Community Healthcare Organization. Disclosures. Learning Objectives

Objectives. Institutional Pharmacy Practice. Medicare, Medicaid, What s the difference? Medicare Modernization Act

Research Pharmacy Services

Hospital Pharmacies Benefit from Practice Advisor Visits

Objectives. Institutional Pharmacy Practice. Medicare, Medicaid, What s the difference? Medicare, Medicaid, What s the difference?

A Systematic Approach to Consultant Pharmacy Services

RULES OF THE TENNESSEE BOARD OF PHARMACY CHAPTER INTRODUCTORY RULES TABLE OF CONTENTS

UW HEALTH JOB DESCRIPTION

Introduction to Pharmacy Practice

Implementing USP

*State Board of Pharmacy Updates

Session 74X Leveraging Your Hospital's Hidden Assets to Drive Meaningful Change

What s New? Objectives. Disclosures. PTCB Certified Pharmacy Technicians: Playing a Critical Role in Practice Model Change

Compounding Conundrums: Outsourcing Shortages, Clean Room Design, and Hazardous Drugs 2012 Midyear Clinical Meeting

247 CMR: BOARD OF REGISTRATION IN PHARMACY 247 CMR 21.00: REGISTRATION OF OUTSOURCING FACILITIES. Section

Objectives. Reality Tech Check: Standardizing Certification of Pharmacy Technicians. Pre Test Question. Pre Test Question.

Compounded Sterile Preparations Pharmacy Content Outline May 2018

UNIVERSITY OF WISCONSIN HOSPITAL AND CLINICS DEPARTMENT OF PHARMACY SCOPE OF PATIENT CARE SERVICES FY 2017 October 1 st, 2016

USP 797: A FOCUS ON ANTIMICROBIAL RISK LEVEL KAREN MILKIEWICZ, PHARMD

FSMA Update. Samantha Shinbaum. October 3, 2017

4/8/2016. This knowledge based activity is accredited for 1.0 contact hour Target audience: Certified Pharmacy Technicians (CPhT)

Look WHAT They ve Done to Us: Law Update 2014 October 2014 Greg Baran B.S. Pharm., M.A., FMPA

BPOC/eMAR Spotlight on Performance Improvement

Achieving Wisconsin Pharmacy Quality Collaborative (WPQC) Certification

CE Activity Announcement

Research Pharmacy Services

Web Download ACCOUNT SETUP INSTRUCTIONS IMPORTANT CONTACT INFO

Improving the Patient Experience Through Pharmacy

Health Literacy and Prescription Container Labeling. Update from USP Advisory Panel Co-chairs: McEvoy and Schwartzberg

Investigational Drug Service (IDS) Rotation Tool APPE Student Rotation

Implementing USP 800 ASHLEY DUTY, PHARMD, MS JOANNA ROBINSON, PHARMD, MS

Implementing USP 800 ASHLEY DUTY, PHARMD, MS JOANNA ROBINSON, PHARMD, MS

Reducing the risk of serious medication errors in community pharmacy practice

Committee on Pharmacy Practice

PRS 101 FOUNDATIONS OF PHARMACY REGULATION PRS INTRO TO PHARMACY REGULATION:

ACPE Standards for Continuing Pharmacy Education. Standard 1: Mission and Goals of CPE. Standard 1: Goal and Mission of the.

Presentation Topics 3/25/2016

KPIC Aseptic Technique Training Program

KPIC Aseptic Technique Training Program Friday, August 24 th Saturday, August 25 th, 2018

JACK H. RABER, PHARM. D.

Accreditation Commission for Health Care

7:30 a.m. 8:05 a.m. Welcome/Introductions and Tips for Success

THE CALIFORNIA STATE UNIVERSITY Office of the Chancellor 400 Golden Shore Long Beach, CA (562)

SJN DO CB Field Alert Reports. Edwin Ramos Director of Compliance Food and Drug Administration San Juan District Office

Effective Date: 11/09 Policy Chronicle:

Overview. Diane Cousins, R.Ph U.S. Pharmacopeia. 1 Pharmacy Labeling with Color

A Game Plan to Surviving a Joint Commission Survey. May Adra, BS Pharm, PharmD, BCPS

External Assessment Specifications Document

Missouri Board Of Pharmacy

Medication Errors: Improving Medication Safety through Medication Error Prevention

Practice Spotlight. Children's Hospital Central California Madera, California

Draft Version Presentation Draft

ASHP Guidelines on Evaluating and Using Home or Alternate-Site Infusion Service Providers

ORGANIZATION OF AMERICAN STATES

Report of the Task Force on Standardization of Technicians Role and Competencies

Accreditation Council for Pharmacy Education Accreditation Standards for Continuing Pharmacy Education

Penn Specialty Pharmacy Program mypennpharmacy bringing the Pharmacy to Patients

340B Program Overview

C DRUG DISTRIBUTION SYSTEMS

A LETTER FROM THE EXECUTIVE DIRECTOR REPORT ON NANP S CONTINUING PARTICIPATION IN CORAR MEETINGS INCREASING JCAHO INFLUENCE ON NUCLEAR PHARMACY?

Transcription:

Patricia C. Kienle, RPh, MPA, FASHP Director, Accreditation and Medication Safety Cardinal Health Innovative Delivery Solutions Sterile Compounding: Highlights of the New Law 2

Please explain the difference between Sections 503A & 503B of the Drug Quality and Security Act. 3

When a 503B outsourcing facility is registered with FDA, is a pharmacist required to be on site to oversee the sterile compounding processes? 4

Can you clarify: does Section 503B apply to both sterile and nonsterile compounding? How does the new law apply to the preparation of investigational drugs? 5

We are an inpatient pharmacy that mixes BCG for the hospital s own urology practice. Is it OK to do so? Or do the office personnel have to mix the BCG before administering to their in-office patient. 6

Please discuss further how Section 503B of the new law applies to central-fill hospital pharmacies that compound only for facilities under common ownership and not for distribution across state lines. 7

Would allergy antigen testing kits be required under Section 503B of the Drug Quality and Security Act? 8

I seemed to hear contradictory information about whether full cgmps are required for outsourcing facilities that are registered under Section 503B. Can you clarify? 9

Under Section 503B, does an outsourcing facility need to apply for an NDC number? How long must they maintain a product for sterility testing? 10

How does the use of USP-grade vs. commercial-grade chemicals affect high-risk compounding? 11

How do hospitals obtain instructions to compound preservative-free ophthalmic sterile preparations? 12

USP <797> does not have adequate standards to ensure compounding of either single-dose or multiple ophthalmic sterile drugs. What is the best source or reference to use? 13

How can a pharmacy obtain a list of hazardous drugs? 14

If nuclear pharmacies are used by the hospital, what should the hospital pharmacy have on file? Should the pharmacy visit the nuclear facility that provides the outsourced product and inspect? 15

Melissa Madigan, PharmD, JD Policy and Communications Director National Association of Boards of Pharmacy State Boards of Pharmacy and NABP Efforts Related to the New Law 16

What is meant by nonresident pharmacy in a particular state? 17

Which 2 states require pharmacies to be in the Verified Pharmacy Program (VPP)? 18

Due to lack of resources, many state boards of pharmacy do not conduct on-site inspections of existing pharmacies. In many cases, these BOPs rely on a self-assessment by the Pharmacist-in-Charge. How does this affect the VPP program? 19

What is the difference between VPP and VIPPS? What is the cost of VPP? 20

Can anyone access the VPP information or only state boards of pharmacy? 21

How can a pharmacist become an NABP compliance officer? 22

Can hospitals or pharmacists gain access to NABP s inspection reports after its oversight of compounding facilities? 23

I work with many pharmacies in both acute care and alternatesite settings throughout the U.S. and have noticed that only a minority of pharmacists supervising sterile compounding operations have the education, experience, or skill set to perform this responsibility effectively. Therefore, they tend to rely on the most experienced pharmacy technician or the way they have always done things. What is FDA, NABP, or others doing to address this weakest link in our sterile compounding system? 24

How can we obtain the assessment guide used by the NABP to inspect compounding pharmacies? 25

Lynn Paulsen, PharmD Director, Pharmacy Practice Standards University of California, Office of the President Outsourcing of Sterile Compounding: The Experience at UC Health 26

How are extended stabilities validated, supported, and documented by outsourcing pharmacies? 27

Are outsourcing facilities required to use pharmacists for compounding their sterile products? 28

What ongoing quality assurance should facilities require from an outsourcing facility? For non-sterile, such as LET gel For sterile, such as phenol 29

Please discuss further the regulatory requirement that each facility must perform a stability study. Is this a facility policy, state rule, or law? 30

In reference to the outsourcing facilities used by UC Health hospitals: Were their policies, procedures, and practices significantly better than those that are commonly found in hospitals? 31

Just because a facility is registered with the FDA does not ensure that an inspection has taken place. Also, cgmps are complex, and compliance may require months or even a year or two. Do you wish to comment? 32