13.2 Centralized Prescription Processing, Telepharmacy & Remote Dispensing Pharmacies

13.2 Centralized Prescription Processing, Telepharmacy & Remote Dispensing Pharmacies

Blueprint item 4.6 covers "centralized prescription processing or central-fill pharmacy dispensing." Utah's rules also cover telepharmacy-supported remote dispensing pharmacies.

Centralized prescription processing

Definition (§ 58-17b-102(9)): a pharmacy processes a request from another pharmacy to fill or refill a prescription, or to perform processing functions such as dispensing, DUR, claims adjudication, refill authorizations, and therapeutic interventions.

Conditions (R156-17b-614f(1)): the parties must:

• have common ownership or common administrative control, or a written contract setting out the services and each party's responsibilities; and
• share a common electronic file, or have technology that gives each party enough information to fill or refill the prescription.

Policies and procedures (R156-17b-614f(2)). Both parties keep a manual, available to DOPL, that covers:

1. how they comply with federal and state law;
2. records identifying the responsible pharmacists and the dispensing and counseling process;
3. a way to track each prescription through every step of dispensing;
4. security protecting PHI; and
5. a continuous quality improvement program that monitors and evaluates care and resolves problems.

Licensing (R156-17b-614f(3)). A central processing pharmacy that does not handle drugs or devices (for example, a remote DUR and data-entry center) is a Class E pharmacy. One that fills and ships (central fill) is licensed in its appropriate class, such as A, B, or D. For controlled substances, DEA's central-fill rules also apply. DEA registration categories expressly let a retail pharmacy perform central fill activities.

Telepharmacy

• Definitions: the "practice of telepharmacy" is pharmacy practice through telecommunications and information technology. Telepharmacy across state lines occurs when the patient is in one jurisdiction and the pharmacist in another (§ 58-17b-102(59)–(60)).
• Remote supervision (§ 58-17b-612(1)(b)–(d)): normally a Utah pharmacist must supervise a pharmacy. The supervising pharmacist need not be physically present, and may be available by telepharmacy for immediate contact with the technician or intern, if:
  • the pharmacy is in an area of need;
  • the supervising pharmacist is not otherwise available;
  • the system keeps records and files quarterly reports; and
  • DOPL approves the arrangement with the board. For a hospital pharmacy, this applies only if a local board owning no more than two hospitals controls the hospital. A pharmacist may supervise no more than two pharmacies at once this way.
• Area of need (R156-17b-102(4)): a remote-rural hospital, a county of the fourth, fifth, or sixth class, or an area DOPL and the board approve based on access to pharmacy services.
• Patient counseling may be given by telepharmacy (R156-17b-610(1)(b)).

Remote dispensing pharmacies (R156-17b-614g)

Violating these standards is unprofessional conduct (R156-17b-502(26)). Pharmacy dispensing normally requires a pharmacist physically present. Remote dispensing pharmacies are the exception, supervised through the telepharmacy system (R156-17b-614a(6)).

Scenario

A chain opens a remote dispensing pharmacy in a sixth-class county, supervised by its Class A store 60 miles away. Two technicians with 700 and 450 hours of experience are scheduled. The 450-hour technician does not meet the 500-hour minimum. If the video link fails at 2 PM and no pharmacist is on site, the pharmacy must close to the public until the link is restored.