Directly Speaking - Tech-Check-Tech - Are We There Yet?
by Scott A. Meyers, Executive Vice President
April 21, 2011
Tech-Check-Tech - Are We There Yet?
Last month we reported on the Board of Pharmacy presentation by three
energetic first-year pharmacy residents from Northwestern Memorial
Hospital on their project to demonstrate the safety and effectiveness of
a Tech-Check-Tech pilot project.
We also reported that SB1305 had been introduced to provide a vehicle
for a potential pharmacy practice act change to allow for this practice
in institutional settings. Sara McEnany, Clinical Specialist at Rush
University Medical Center and former resident at Froedert Memorial Hospital in
Milwaukee also reported on the implementation of their Tech-Check-Tech
last year during her residency in last month’s issue. So we have set
the stage and have been receiving a number of eager inquiries since as
to when and how Tech-Check-Tech will become a reality in Illinois.
Since the last issue of KeePosted
we haven’t sat still. The Government Affairs Director-elect and I met
via conference call with Department of Financial and Professional
Regulation attorneys, Daniel Kelber and Scott Golden, and Pharmacy
Coordinator, Dr. Yash Amin, to determine if a Pharmacy Practice Act or
Practice Act Rules change would make Tech-Check-Tech happen and whether
the Department would work with or against our efforts.
Here’s the great news, the Department is willing to work with us to make
this happen. The best news from the call is that a rules change should
be sufficient to make Tech-Check-Tech a reality. That’s the easiest
option of the two and is very encouraging. But now the real work
The ICHP Division of Government Affairs has agreed to create the first
draft of the proposed rules and provide them to the Department staff for
their review later this spring. The Department staff asked us to wait
until after the end of the regular legislative session before pressing
to work on these rules, and we have agreed. We will provide a first
draft prior to the end of session but will wait to hear from the
Department once the General Assembly adjourns.
In our discussion, we agreed that the proposed rules will be
incorporated into Section 1330.530 On-site Institutional Pharmacy
Practice only to begin with. Eventually, there may be expansion into
Off-site Institutional Pharmacy Practice but not with the initial
change. Use of Tech-Check-Tech in Community Practice is not anticipated
because medications dispensed in that setting do not normally have
another registrant or licensee of the Department involved with the
administration of the medications. Until automation becomes broadly
used and consistently has a high safety rating, it is not anticipated
that the Department will allow movement in that direction.
I want to recognize that the Department staff has one responsibility in
this process – to protect the citizens of Illinois. They are not
concerned with advancing the profession of pharmacy unless it provides
improved safety and effectiveness of medication therapy. I
whole-heartedly agree with that mission. It should be our profession’s
mission, too. We should never advance a practice that does not improve
or enhance patient care. We should support efforts that move the
pharmacist closer to the patients to provide the kind of care we are
trained to provide.
In the first draft that is being studied by the Division of Government
Affairs, pharmacies may only implement Tech-Check-Tech if they have an
on-going clinical pharmacy program with the goal of maintaining or
expanding that program by moving distributive pharmacists into clinical
roles. The first draft is based on rules developed from California and
recognizes that this type of program can only work if pharmacists are on
the floors and in the patients’ rooms.
There’s no guarantee that we will be able to begin implementation of
Tech-Check-Tech by this fall, but there was certainly less of a chance
that we would be able to do it if a legislative change was needed. We
thank the Department of Financial and Professional Regulation staff for
working with us to begin this process, and we look forward to their
efforts this summer as we roll up our sleeves and really dig in. I
encourage anyone interested in implementing a Tech-Check-Tech program to
get involved with Government Affairs’ work in this area, so that when
these rules are finalized, you will know what is expected in order to
implement a compliant program. We’re not there yet, but we are
definitely on our way! ΓΆβ€"Β
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