April 15th is not just the deadline for your taxes April 15th is not just the deadline for your taxes!!! Is your documentation complete for Pharmacist to Registered Technician Ratios? Policies and Procedures, Education Plan, Competencies – Demonstration, Job Descriptions – Delegable Tasks addressed, Task Protocols, Signed by the Registered Technician and Pharmacist certifying competency. Deborah Brown, MS, PharmD, FASHP FSHP Legal and Regulatory Consultant www.fshp.org

Responsibilities of the Pharmacist 64B16-27.430 The delegation of any duties, tasks or functions to registered pharmacy interns and registered pharmacy technicians must be performed subject to a continuing review and ultimate supervision of the pharmacist who instigated the specific task, so that a continuity of supervised activity is present between 1 pharmacist and 1 registered pharmacy technician. The licensed pharmacist shall retain the professional and personal responsibility for any delegated act performed by registered pharmacy interns and registered pharmacy technicians in his employ and under his supervision.

Registered Pharmacy Technician to Pharmacist Ratio – 64B16-27.410 A pharmacist shall not supervise greater than one registered pharmacy technician nor shall a pharmacy allow a supervision of greater than one registered pharmacy technician to one pharmacist, unless specifically authorized to do so pursuant to the provisions of the rule. 3:1 – Registered technician assisting with delegable tasks involving sterile compounding 4:1 – Any pharmacist or any pharmacy may allow as long as delegable tasks do not include sterile compounding 6:1 – A pharmacy which does not dispense medicinal drug as long as delegable tasks do not include sterile compounding Any ratios outside the 3:1, 4:1, or 6:1 would have to be approved by the Board of Pharmacy.

Policy and Procedure Manual 64B16-27 Policy and Procedure Manual 64B16-27.410 Registered Pharmacy Technician to Pharmacist Ratio Number of registered pharmacy technician positions and their utilization, scope of delegable tasks, job descriptions, and task protocols. Policies shall address: Supervision by a pharmacist Minimum qualifications as established by statute and rule In-service education or on-going education training and demonstration of competency specific to the practice site and job function General duties and responsibilities

Policy and Procedure Manual 64B16-27 Policy and Procedure Manual 64B16-27.410 Registered Pharmacy Technician to Pharmacist Ratio All functions related to prescription processing. All functions related to prescription legend drug and controlled substance ordering and inventory control, documentation and record keeping All functions relating to retrieval of prescription files, patient files, patient profile information and other records pertaining to the practice of pharmacy All delegable tasks and non-delegable tasks Confidentially and privacy laws and rules Prescription refill and renewal authorization

Policy and Procedure Manual Functions related to automated pharmacy systems Continuous Quality Improvement System Must be maintained on-site where the pharmacy technician will perform the delegable tasks Must be available during a Department inspection or at the request of the Board of Pharmacy

Pharmacy Technician- Delegable Tasks 64B16-27.420 Performed pursuant to a pharmacist’s direction, without the exercise of the pharmacy technician’s discretion, and do not require the pharmacy technician to exercise professional judgment Delegable tasks Data entry Labeling of preparations and prescriptions Retrieval of prescription files, patient files and profiles Counting, weighing, measuring, and pouring of prescription or stock legend drugs and controlled substances, including the filling of automated medication system

Delegable Tasks- Registered Pharmacy Technicians The acceptance of an authorization to dispense medications pursuant to a prescribing practitioner’s authorization to fill an existing prescription that has no refills remaining The receiving, in a permitted nuclear pharmacy, of diagnostic orders only Assisting in preparing parenteral and bulk solutions or assisting in any act involving sterile compounding must comply with Rule 64B16-27.1001 Organizing of or participating in continuous quality improvement related events, meetings, or presentations

Non-Delegable Tasks Prepare a copy of a prescription or read a prescription to any person for purpose of providing reference concerning treatment of the person or animal for whom the prescription was written Engage in patient counseling Receive therapy or blood products procedures in a permitted nuclear pharmacy Engage in any other act that requires the exercise of a pharmacist’s professional judgment.

Required Documentation Acknowledgement signed by the registered pharmacy technician that they have reviewed the Policy and Procedure Manual – must be complete by April 15th All registered pharmacy technicians hired subsequent to this rule’s effective date shall have 90 days from the date of hire. Establish and maintain documentation that demonstrates the registered pharmacy technician is knowledgeable in the established job description, delegable tasks, task protocols, and policy and procedures in the specific pharmacy setting where the delegable tasks will be performed.

Documentation 64B16-27.410 paragraphs 1(b) and(c) Any and all the documentation required must be maintained and must be provided to the board of Pharmacy or a Department inspector within 72 hours of a request.