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Vol. 1 No.

October 2003

Hospital Pharmacy
Regulation Report

Detecting medication
Read how Brigham and
Womens Hospital in Boston
reduced serious medication
errors by 55% on p. 5.
A sample tool that will help
you track adverse drug events
is on pp. 6 and 7.

Counterfeit drugs
See how you can protect your
facility against counterfeit
drugs, an issue that has
steadily risen since the 1990s,
on p. 8.

Prescription plan update

Read how the budget deficit
could affect the pharmacy
prescription drug plan on
p. 10.

After-hours access
to pharmacy

Four ways to catch medication errors

Many medication errors could go
unnoticed if you dont have methods in place at your organization
to catch them.
Such detection methods are important because medication errors
represent the largest category of
medically preventable deaths, according to an Institute of Medicine
report cited in the 2002 VHA
study, Monitoring adverse drug
events: Finding the needles in the
haystack. As many as 7,300 patients, 6,000 of whom are inpatients, die annually of medication
errors, the Institute of Medicine
report says.
Check out what VHA New England
hospitals are developing in order

to catch errors. The hospital network is grading different medication

error detection methods and will
help members tailor the procedures
to their needs, says Arnold Mattis,
RN, MSN, EdD, senior director of
clinical and consulting services at
VHA New England.
Methods vary by hospitals

VHA New England will receive

advice from experts on the following four systems:
Medical record trigger reviews
Observational method
Computer surveillance
Practitioner intervention method
Each method that VHA New England grades has its benefits, Mattis
> p. 4
says. The medical record

JCAHO standard of the month

A sample policy on how to

handle after-hours pharmacies
is on p. 11.

Automated system ensures accuracy

HIPAA quick tip

Using a computerized physician

order entry (CPOE) system recently helped one New England facility reduce errors, comply with
medication standards, and direct
its focus to patient care.

Dont display patient

information on medication
charts on p. 12.



The Joint Commission on Accreditation of Healthcare Organizations

(JCAHO) medication standard
MM.4.10 requires organizations to
review all prescriptions to ensure
the appropriateness of the drug,
dose, and frequency. The JCAHO

also requires a pharmacist to review all medication orders unless

a delay would harm the patient.
The 606-bed Maine Medical Center
in Portland, ME, has used CPOE
for more than 20 years, and recently upgraded its system in July to
include medication alerts and a
standardized nationwide database
of drug interactions, says Miriam
Leonard, RPh, MS, vice president
of operations and patient safety
> p. 2

Automated system

< p. 1

How the system works

The new CPOE system uses the Multum database,

which alerts a physician to any possible drug interactions that could occur and provides alternative
A physician can override the alert, but he or she
must acknowledge that the alert occurred, Leonard
says. A pharmacist can also receive the alert, allowing him or her to question the physician about the
The physician logs onto the
CPOE system and selects the
medication, chooses the medication strength, adds any instructions, and sends it to the
Physicians can also log onto
Maine Medical Centers system
from their homes or offices.

physicians assistants can enter orders into the system in some cases. A pharmacist would still have to
review the order later.
The hospital stores some medications on the floor
for emergency use, and the pharmacy has a stat
pager that allows staff to call in orders from care
areas in an urgent situation.

Pharmacy employees run some medications to

physicians, while pharmacists can rush other medications to areas of the hospital
through a network of tubes similar to those at bank drive-up
The automated system reduces
questions about similar-sounding or
similar-looking medications and
Handling after-hours access
illegible handwriting.
Maine Medical Centers pharmaMiriam Leonard, RPh, MS

The pharmacist reviews the order, checks for allergies and other side effects, and then processes the
order. For unit-dose prescriptions, a robotic arm then
picks out the drugs based on a package code and
fills the order. Pharmacists still fill intravenous medication orders manually, Leonard says.
Reducing confusion

The automated system reduces questions about similar-sounding or similar-looking medications and illegible handwriting, Leonard says. Staff members can
spend more time focusing on the patients treatment
than on correcting medication errors, she says.
It takes away a lot of the problems of interpretation,
she says.

cy is open 24 hours a day, so

after-hour access issues do not
arise, Leonard says. A pharmacist
is always on duty.

TIP: If you dont have a pharmacy that is always

open, create a process that allows a pharmacist to
review emergency and after-hours orders.
For example, the pharmacist reviews the order as
soon as he or she is available after the emergency or
as soon as the pharmacy opens. (See a sample policy on after-hours access to the pharmacy on p. 11.)
Any error detection system requires staff education.
Medication administration is primarily the nursing
staffs responsibility, so Maine Medical Center ensures
that all new nurses receive comprehensive training
in their orientation, Leonard says.

TIP: Clarify any questions about the medication with

the physician prior to filling the order.

For example, nurses in the oncology department must

be aware of chemotherapy standards and medications
used in that specialty, in addition to general medication administration practices.

The hospital maintains a policy for emergency situations, Leonard says. Authorized nurse practitioners or

Nurses must also undergo annual competency training and skills updates, she says.

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2003 HCPro, Inc.

Hospital Pharmacy Regulation ReportOctober 2003

Train staff annually

Physicians must receive continuing education on an

annual basis as well. The physicians professional organization and the hospital both participate in that
education, which consists of a number of hours
determined by the professional group and hospital
requirements, Leonard says.
Education is also a priority when a hospital puts a

new medication error detection system in place. Staff

members must become oriented with state, federal,
and accreditation requirements and standards as well
as the systems operating procedures.
Maine Medical Center created online training for its
new CPOE system, allowing physicians to learn how
to enter orders and pharmacists to verify and fill
them, Leonard says.

Standard MM.4.10
Hospitals review prescriptions and medications for appropriateness
Elements of Performance for MM.4.10

- Therapeutic duplication

A pharmacist checks all medication orders before

giving them out, unless a licensed independent
practitioner orders and distributes the drugs or
unless any delay would cause harm to the patient.

- Allergies or sensitivities

A qualified staff member reviews orders when an

on-site pharmacy is not open 24 hours a day.

- Other impairments to treatment

The pharmacist reviews the order once he or

she is available or the pharmacy opens.

- Possible interactions between the drug and

other medications, food, or laboratory values

- Any variation from hospital policy regarding

medication use
- Other relevant issues

The hospital reviews all prescriptions

for the following:
- The dose, frequency, and administration methods

HPRR Subscriber Services Coupon

The person prescribing the medication addresses

all concerns, issues, or questions before a pharmacist fills the order.

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Page 3

Medication errors

< p. 1

trigger review trains people to look at a patients

record to check for unanticipated events, any prescribed antidotes, or additional treatments.
Staff members investigate the events to determine
whether an error occurred, and identify process failures rather than assign blame.
Almost 25 VHA member hospitals participated in a
trigger review beginning in 2001, says Ken Smithson,
MD, VHA, vice president of integration services.
Physicians, nurses, and graduate nursing students
conducted the reviews, which cost about $1 per scan
form. (See the sample trigger review tool to help you
track adverse drug events on pp. 67.)
They can get into the business with relatively no
investment, Smithson says.
How the methods work

The VHA trigger review recommended that hospitals

review 100 records per quarter to get an accurate
understanding of what occurs.
Keeping error definitions consistent is also important,
Smithson says. He points to one organization that, in
order to maintain consistency, hired an outside contractor to conduct a review of its eight facilities.

The aid of technology

Computers can also allow physicians to order prescriptions, with

safeguards preventing major
errors. Brigham and Womens
Hospital in Boston saw an 80%
reduction in overall medication errors, says David
Bates, MD, of Brigham and Womens Hospital in
Boston (see how Brigham and Womens cut its error
rates on p. 5).
In the practitioner intervention method, the pharmacist checks the orders to see whether they are consistent with the patients needs, asks the physician why
he or she prescribed that medication, and writes down
any changes made to the original order. Pharmacies
and hospitals can then design prevention programs
based upon the prescribing errors detected.
Research shows that more than half of all medication errors are prescribing errors, Mattis says. Causes
range from illegible handwriting, to similar-sounding
drug names, to accidentally writing a medication
order in someone elses chart, he says.
The more prescribing mistakes that are found and
intercepted, the more likely it is for one to slip
through, ultimately, Mattis says.
Weighing the efforts

The observational method is one of the more effective detection systems, Mattis says. An observer follows a nurse, records any medications administered,
and checks the patients medical orders to see what
should have been given. The organization then compiles statistics to track medication errors and identify
their root causes.

While some hospitals have used

these active detection methods
in the pastsome organizations
may have used the observational method for the last 15 yearsmany are not convinced that they are worth the cost and effort, Mattis

Computer surveillance allows hospitals to compare

the medication prescribed to medical records and
specific laboratory values. For example, if a patient
receives potassium supplements, the computer system will question whether he or she needs more
medication with potassium in it, Mattis says.

Most organizations use a self-reporting system,

where staff members are responsible for reporting
errors they commit or discover. Along with cost and
time, the fear of reprimand or harm to ones reputation may cause staff members not to report an error,
Mattis says.

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Hospital Pharmacy Regulation ReportOctober 2003

It is also possible for an exempt error to be made

without anyones knowlwdge. Many times the errorreporting process is tedious. People are busy, and if
the error isnt serious, it might not get reported,
says Mattis.
VHA New Englands board of directors asked the
Medication Error Prevention Initiative (MEPI), a
VHA New England task force, to begin reviewing
error detection methods, Mattis says. The MEPI told
the board of directors that there is no effective
way to know how many errors occur with the selfreporting method in place, he says.
This is an opportunity to look proactively for mistakes, Mattis says. Most people dont yet see the
full value of them.
Create a system to meet your needs

Some organizations worry about finding the necessary

manpower, training staff, and covering additional costs.
While a hospital could hire an external firm to run
the observation method, it is typically an employee
effort, Mattis says.
The costs and time involved do not vary much
from other existing procedures, Mattis says. Many
methods are similar to infection surveillance programs

that already exist at most hospitals, he says. A single

error detection process will probably not meet an
organizations needs on its own, Mattis says. While
the observational method has caught hundreds of
errors more than other systems, observers only catch
administration errors; prescribing errors go unnoticed.
The same holds true for the practitioner intervention
system. While a pharmacist might catch an error
before filling the order, the prescriber still provided
the wrong information.
The trigger review would complement a computerized physician order entry system (CPOE) because
hospitals could review an order and compare it to a
patients record to find any adverse drug events,
Smithson says. Community Hospital in Indianapolis
participated in the VHA medical record review in
anticipation of starting its own CPOE, he says.
Each approach has its own limitations, Mattis says.
Were looking at them as a collection of approaches that could be used as a hybrid.
Editors note: VHA New England held a conference
on Cape Cod, MA, from September 2426. Future
editions of HPRR will highlight key findings to help
improve upon safe care at your facility.

Computer system helps hospital cut medication errors in half

Brigham and Womens Hospital in Boston saw a
55% reduction in serious medication errors and
an 80% reduction in overall medication errors
after adopting a computerized physician order
entry (CPOE) system in 1995.
The CPOE lets physicians order medications online and helps catch errors before they reach the
pharmacy, says David Bates, MD. The CPOE
connects hospital physicians, laboratories, and
pharmacies on one network, allowing them to
communicate easily with each other.
Brigham and Womens CPOE allows its physicians

to do the following:
Write a patients order online. The computer
system allows physicians to see whether less
expensive drugs are available or whether the
drug is appropriate for the patient.
Select the drug type and how to give it to the
Take into account the patients age and kidney
function to determine the correct dose, how
often the patient should take the medication,
and suggest this to the physician.
Check for allergies or other known drug problems. Physicians can override any warning
> p. 8
screen that appears, but they must

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Page 5

Sample adverse drug events tool

Marking Example: Correct Mark X
0 1 2 3 4 5 6 7 8 9 A B C D E F
Hospital member ID # _________________________________
Patients reference #___________________________________
Patients age ____yrs

Patients gender __ Female __ Male

Length of stay [days]

Total number of medications [meds]
Total number of doses of medications [doses]
Which triggers appeared in the patients chart?
(Mark all that apply)

Adverse drug events (ADE):

If an ADE occurred, mark the highest harm category.

Diphenhydramine (Benadryl)

Vitamin K (Aqua-mephyton)

Flumazenil (Romazicon)


Naloxone (Narcan)


Sodium Polystyrene (Kayexalate)

Serum potassium > 6

Serum glucose < 50

C. difficile positive

PTT 6 X hospitals upper limits

INR > 3

WBC < 3000

Platelet count < 50,000

Digoxin level > 2

Lidocaine level > 5

Serum creatinine increased >1.0 over admission baseline

Gentamicin or Tobramycin levels: peak > 10, trough > 2

Amikacin levels: peak > 30, trough > 10

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Hospital Pharmacy Regulation ReportOctober 2003

Which triggers appeared in the patients chart?

(Mark all that apply)



Vancomycin trough > 15

Theophylline level > 20



Abrupt medication stop

Transferred to a higher level of care

Readmission within seven days of discharge

ADE not associated with any of the above triggers

Total number of distinct ADEs found in the patients chart


Area of the hospital where each distinct ADE occurred (mark one area per ADE)

Prior to admission






ER OR ICU Step-down Floor Other

ADE Preventable?

Harm categories
Category A: events that have the capacity to cause error
Category B: the error did not reach the patient
Category C: the error reached the patient but did not cause patient harm
Category D: the error reached the patient and required monitoring/intervention to confirm that it resulted in
no harm to the patient
Category E: contributed to temporary harm to the patient and required intervention
Category F: contributed to temporary harm to the patient and required initial/prolong hospitalization
Category H: required intervention to sustain life
Category I: contributed to the patients death

Source: VHA, Inc. Reprinted with permission.

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Page 7

Medication errors

< p. 5

provide a reason, allowing the pharmacist to

see the physicians rationale.
Approve the order and send it electronically to
the pharmacy.
Improved efficiency saves money

Brigham and Womens saves between $5 million

and $10 million each year because of increased
efficiency with the CPOE, Bates says. Most of the
savings result from use of less expensive drugs,
lower costs of extra treatments due to drug-related errors, and increased use of critical pathways
for patients.
For example, CPOE plans out critical pathways
for coronary bypass patients by establishing a
daily schedule for their hospital stay. Physicians
can outline a patients stay from admission to preoperative sessions to recovery treatments.
The hospital also uses a computerized adverse
drug event monitor to check medical records for
signals that an error may have occurred, Bates
says. For example, if a patients record shows a
high potassium level, pharmacists can see
whether the patient is using drugs that could

cause that problem.

Next, a pharmacist or other appropriate staff
member can look at medical records, lab test
results, and other data to investigate a possible
Up-front costs makes hospitals leery

Only about one-third of the nations hospitals use

a CPOE or have plans to create one, mainly because
of cost. It costs between $20,000 and $40,000 to
put a network in place between pharmacy, laboratory, ordering, and other systems. Computer
order entry can cost between $5 million to $20
million overall, Bates says. Brigham and Womens
built its own CPOE system for $1.4 million and
spends $500,000 each year to maintain it, he says.
One potential drawback to CPOE is speed, Bates
says. Some hospitals do not have fast computer
programs, which makes it faster for doctors to
handwrite a medication order.
While about a third of hospitals have CPOE, less
than 5% have doctors ordering 80% of their prescriptions with it, Bates says.

Check on wholesalers to avoid counterfeit drugs

Hospitals and pharmacies must check their drug
wholesalers backgrounds to protect themselves
from counterfeit drugs.
The issue of counterfeit drugs is important to pharmacists because counterfeit drug cases have steadily risen
since the 1990s. The Food and Drug Administration
investigated 22 counterfeit cases in 2002, up from
four in 1998, according to its Web site,
Part of the problem is that counterfeiting technology
has improved, allowing more people to take part in

the lucrative drug trade, says Susan Winckler, RPh,

Esq., vice president of policy and communications
and staff counsel for the American Pharmacists
Association in Washington, DC.
They might not only make an elegant product but
an elegant label as well, Winckler says.
Check your labels

The secondary marketwhen drugs are in a

wholesalers possessionis often where the
counterfeit problem originates, Winckler says.

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Hospital Pharmacy Regulation ReportOctober 2003

Drugs frequently move around from one wholesaler

to another before reaching the hospital or pharmacy,
usually to move a product to a certain area more
quickly, she says.
That presents the opportunity for counterfeit drugs
to enter the market. Government officials in Florida
noticed problems with counterfeit products moving
into the state in 2000, says Gregg Jones, pharmaceutical program manager at the Bureau of Statewide
Pharmaceutical Services, division of the Florida Department of Health in Tallahassee,
The state began noticing labels
with adhesivesa red flag for
counterfeit drugsand fake pedigree papers, which help verify
the drugs authenticity.

and pharmacies to wholesale drugs without a

license, Jones says.
In the past, some physicians would receive drugs
such as Lupron or Zoladex at a reduced price and
sell it back to wholesalers for a profit, he says.
Floridas new prescription drug protection law has a
maximum penalty of life in prison if a counterfeit
drug caused serious injury or death. Drug counterfeiting carried a five-year maximum prison sentence
in the past.

Physically examine
the drug. If it looks
different from what is
normally used, notify
the manufacturer.

The label adhesives and missing

package inserts typically show the
drugs have already been used, while the fake pedigrees are usually associated with counterfeit drugs in
the wholesale market, Jones says.
The state passed a new law in May that requires
each drug to have a pedigree paper that passes
from the manufacturer through the wholesaler to the
hospital or pharmacy. Florida has required pedigree
papers since 1992, but the requirements were difficult to enforce because the federal government did
not have strict regulations, Jones says.
Hospitals and pharmacies will now be able to see
the source of the medication and its travels through
the wholesale process, Jones says. They can decide
whether or not to purchase a drug based on where
it has been.
Not many states currently require a pedigree paper
to accompany a drug through the wholesale process,
Jones says. Florida will phase in the pedigree requirement until 2006, when it will take full effect.
New penalties for unlawful resales

The new law also makes it more difficult for doctors

TIP: Physically examine the drug. If

it looks different than normal,
notify the manufacturer.

Also, remind patients to speak up

if they notice anything unusual
during their treatments. Hospitals
and the FDA noticed some counterfeit injections when patients
said they burned or stung, Winckler says.
Know your wholesalers reputation

Wholesale oversight is not as extensive as it should

be, Winckler says. Although wholesalers must maintain their facilities and adhere to certain standards,
laws vary from state to state and not enough regulators exist to verify a distributors integrity.
Some manufacturers allow hospitals and pharmacies to purchase direct and cut out the wholesale
process, but it would usually cost the organization
more, Winckler says.
With wholesalers, manufacturers only have to deal
with five or six distribution outlets instead of 70,000
or more if they sold direct to hospitals or pharmacies, she says.
Hospitals and pharmacies need to be able to rely
on their distributors integrity. Industry leaders have
discussed using electronic tracking technology to
help verify a drugs authenticity, but uniform standards would need to be in place nationwide, Jones

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Page 9



Prescription drug plan update

Large budget deficit could impede pharmacy benefit
During the Congressional recess
in August, the conference on
prescription drug benefits continued and both sides made substantial progress on numerous
drug-related issues.
However, not much changed
with the prescription package,
says Bill Sarraille, a partner at
the Washington, DC-based law
firm Sidley, Austin, Brown, & Wood LLP.
There is tremendous political pressure to develop a
pharmaceutical benefit for Medicare, says Sarraille.
That has been a major goal of the presidents domestic agenda. He doesnt want to repeat his fathers
mistake and be accused of focusing on foreign policy to the exclusion of domestic policy.
One problem holding up the prescription benefit is
the amount of money needs to be set aside for rural
health provisions. Focusing on rural health needs is
important to the Senate but causes problems with
representatives from the House who are less
focused on rural health care, says Sarraille.
Rural health care is a point of contention. Both
sides will have to get beyond this issue to implement a pharmaceutical benefit, says Sarraille.

better than either under consideration, says

In related Medicare news, the Minnesota attorney
general filed a civil lawsuit against two pharmaceutical companies for allegedly significantly inflating the price of their inhalant drugs. Inflating
the prices meant pharmacists and physicians received more reimbursement from Medicare and
Dey, Inc., and Warrick Pharmaceuticals Corp. cost
the state and its senior citizens millions of dollars
since the early 1990s, said Attorney General Mike
Hatch in a press statement.
Similar suits have been filed against companies in
Texas, West Virginia, Montana, Nevada, and Connecticut. The drugs in question, including albuterol
sulfate, typically treat asthma, chronic bronchitis,
and emphysema.
Hatch charged the companies with consumer
fraud, Medicaid fraud, fraud on seniors and the
disabled, false advertisement, and unjust enrichment, said Hatch. The drug company determines
the average price with no regulatory oversight,
said Hatch.

Over the August recess, Congress revealed that the

federal budget deficit was higher than anticipated.
That will make it even more difficult to agree on a
pharmaceutical benefit, says Sarraille.

The Minnesota complaint alleges that the manufacturers inflated the average wholesale price of the
drugs in reports to the government. By law, Medicaid and Medicare payments are based on the
average wholesale price, which the government
uses to determine how much to pay doctors and

The pharmaceutical benefit will entail a significant cost over a significant period of time. This
news strengthens the hand of conservatives who
dont like either the House bill or the Senate bill.
Some conservatives have suggested that no bill is

A spokesperson for Schering-Plough Corp, which

owns Warrick, says the government has known for
years that the average wholesale price doesnt
reflect actual prices, but it still uses those numbers
as guidelines.

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2003 HCPro, Inc.

Hospital Pharmacy Regulation ReportOctober 2003

Editors note: As noted on p. 2, you must create a process that allows a pharmacist to review emergency and
after-hours orders. Heres a sample policy to help with compliance at your facility, taken from the just published The Compliance Guide to the JCAHOs Medication Management Standards, 2003, HCPro, Inc., in
Marblehead, MA. Visit to order the book or call Customer Service
at 800/650-6787.

After-hours access to pharmacy

Policy: After the hospital pharmacy is closed, access to medications for new written orders will be available via the pharmacys night automated medication station.
The drugs in the pharmacy night station shall be removed by the nursing supervisor and only in
the amount sufficient for immediate therapeutic need.

The nursing units will fax their orders immediately to the pharmacy. Pharmacist review is needed
for non-urgent drug administration per the policy and procedure on pharmacist review of medication orders. The order also needs to be faxed to the sister hospital.


Once the hospital pharmacy has reopened, the pharmacist will review and enter medication orders
into the pharmacy system.


The pharmacist will ensure that orders are received for all medications taken from the night


If an unusual problem arises and the medication is not in the pharmacy night station or must be
compounded, the nursing supervisor may telephone the on-call pharmacist at home.


A list of on-call pharmacists will be maintained by the telephone operator, and a copy will be forwarded to the nursing office.


After receiving approval from the on-call pharmacist to access the pharmacy, both the night supervisor
and security officer must enter into the pharmacy. The night supervisors keycard accesses the pharmacys main lock, but the security officer must be contacted for the key that opens the dead bolt.


The night supervisor will complete a pharmacy access form (Figure 4.2, p. 88) and document
every medication that was taken from inventory. Both the security officer and the night supervisor
will sign the form. The night supervisor will leave the form and an identical dose of each medication retrieved for the pharmacist opening in the morning (except for refrigerated medications).


The pharmacy director/assistant director will review and sign the pharmacy access forms and
make recommendations to reduce access to the pharmacy (e.g., add drugs to the night station or
contact the night supervisor to recommend alternatives).

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Page 11

HIPAA quick tip: Dont display patient

information on medication charts

Always remember to keep items

printed with patient information out
of sight of people who dont need to see them,
says Phil Klein, a senior consultant with the San
Diegobased Pharmacy Healthcare Solutions.
For example, in some facilities, staff carry medication cassettes that prominently display patient names
throughout the hospital, which would be a violation of the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
Try to find a way to identify patients without compromising privacy rights, says Klein.
In other facilities, staff use the patients first initial,
last name, and room number on medication cart
drawers that are kept locked in the hallways. According to HIPAA, this is not an acceptable form of

Hospital Pharmacy Regulation Report

Editorial Advisory Board
Robert Marder, MD
Quality and Patient Safety
The Greeley Company
Marblehead, MA
William Sarraille, Esq.
Sidley Austin Brown & Wood LLP
Washington, DC

Donna Soflin, PharmD

Director of Pharmacy
Tri-County Hospital
Lexington, NE
Douglas Wong, PharmD
Pharmacy Healthcare Solutions
AmerisourceBergen Corporation
Fort Washington, PA

patient identification.
Some organizations write patient names on file
cards placed on the front of the carts drawers.
These organizations are not doing enough to protect patients privacy, says Klein.
TIP: Rotate the carts to shield patient names from
the public.
Use a patients first name only or make an effort to
cover the names. A simple cloth can do the trick.
You should also check that a certain measure of
privacy is taken once youve delivered the cart to
the nursing station. Encourage nursing staff to get
into the habit of checking the cart to make sure
that the public cant easily see patient names.

We want to hear from you . . .

For news and story ideas:
Contact Executive Editor Julia Fairclough
Phone: 781/639-1872, ext. 3273
Mail: 200 Hoods Lane, Marblehead, MA 01945
Fax: 781/639-2982
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Executive Editor: Julia Fairclough
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Hospital Pharmacy Regulation Report is published monthly by HCPro, Inc., 200 Hoods Lane, P.O. Box 1168, Marblehead, MA 01945. Subscription rate:
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2003 HCPro, Inc.

Hospital Pharmacy Regulation ReportOctober 2003