Directly Speaking - Let Common Sense Prevail

by Scott A. Meyers, Executive Vice President
June 10, 2011

Let Common Sense Prevail

Raise your hand if your institution suffered staffing issues during “Snowmageddon 2011”.  Keep it up if some staff members were required to spend the night at your facility in order to maintain patient care or because they just couldn’t get home.  Finally, anyone who had an employee ask your department (I’m assuming you all work in the Pharmacy Department) for a dose or two of medications because they didn’t bring theirs from home, leave your hand up.  

I know that there are hands in the air as this article is being read.  I know because of discussions I’ve had with some of you, and I’d guess it anyway because it happened almost every time we experienced some sort of natural disaster when I was still practicing in the hospital.  

People fail to plan.  This year’s massive blizzard was predicted for several days in advance and was accurate almost to the minute when the heavy snow began to fall.  But floods, tornados, fires, earthquakes and all kinds of other natural and man-made disasters don’t give nearly that much warning.  So having staff spending the night or nights to keep the hospital functioning is something that every institution should plan for.

For the purpose of this issue of KeePosted, I intend to focus on the issue of providing employees with necessary medications while they spend extended time on the job - what’s legal and what’s not and what makes sense.  

If your pharmacy department (assuming you work in a hospital setting) has an outpatient pharmacy or provides employee prescriptions, you are steps ahead right away.  Encourage your employees to fill all their prescriptions in your facility because then you have a legal prescription on hand should “Snollapalooza 2012” hit next January!  You can check any employee profile and provide a partial fill (providing the medication is not a CII or does not have refills) and be completely within the law!  Whether you decide to charge or not is your decision, but I suggest you record whatever you dispense so that it may be counted against the prescription total.  I won’t make a recommendation on labeling, placing in a prescription vial, etc. because you need to do what makes sense to you.  And remember, these are my recommendations, not the staff of the Department of Financial and Professional Regulation.  They will tell you to follow the law to the letter.  That’s their job.

If you don’t fill employee prescriptions, then you have some tough decisions to make.  If you want to stay 100% within the Pharmacy Practice Act, you will need to require a new prescription for each medication for each patient, you will need to insure that the medications are labeled properly (although you can ask your employees to waive the child-proof container requirement if you don’t have them in stock) and you will need to provide counseling for each and every prescription if the employee requests it.  That probably means tying up one of your ED physicians or a hospitalist for a significant amount of time and placing them at risk for rapid work-ups and diagnosing patients with limited information and tests when all of that has been done by the patient’s own physician.  You can also try to reach each personal physician for each patient but depending on the disaster, finding an open line or open office is probably going to be a challenge.

If you want to be practical, here’s what I would do.  Provide chronic disease medications like those used for diabetes, hypertension, hyperlipidemia, asthma, immunosuppressants, and etc. one dose at a time if the employee can give you an accurate medication name, strength and directions.  This may also mean drawing up individual doses of insulin for your Type I diabetic employees.  If you or they use an insulin pen, let’s hope they have it with them.  Medications used for behavioral or psychiatric disorders (e.g., antidepressants, antipsychotics, anxiolytics) would only be dispensed with a new prescription from a physician on premises or a call from the employee’s own physician.  Pain meds could be switched to OTCs like acetaminophen or ibuprofen and again, one dose at a time.  Sedatives, muscle relaxants and controlled substances should not be dispensed without a valid prescription.  Birth control would probably be a cost issue and hormone replacement, steroids and other miscellaneous medications might have to be a case-by-case basis.  But always err on the side of common sense.

Would I label them? Nope!  Once I was certain the employee needed the medication, I would provide it and ask them to take it right there.  Provide the water and let it go!  I certainly wouldn’t charge the patient because I probably wouldn’t have a mechanism; plus at one dose at a time, why bother?  However, I would keep track of what my department dispensed and to whom it was dispensed for a couple of reasons.  The list of medications dispensed can be used to show how you kept the hospital running in a crisis.  The list of names of employees could be kept for liability purposes.  I would probably ask each employee to sign for each medication they received to verify that they were requesting it, based on their word of a valid prescription they have filled elsewhere.  The log may also help the next time you face staff overnights and similar requests.

There is of course something else every institution should do annually.  When reviewing the hospital and department disaster response policies and procedures (which I assume is done at least annually), remind employees that having a day or two of medication at work might not be a bad idea if you have a locker or can keep it in a purse or desk drawer.  Not everybody has this luxury, so this may only work for some.  I certainly don’t recommend establishing a departmental medicine cabinet!  Can you imagine how that would work?!  But reminding employees each time bad weather is predicted to think ahead about what they might need if they are stranded at work for a couple days, or anywhere else for that fact just makes good sense!  When I travel, which I do more and more these days, I always take a couple of extra day’s worth of medications with me.  Ask anyone who was on the road on Sept. 11, 2001 or during Hurricane Katrina about that!

If “Snowmaggedon 2011” didn’t produce this scenario for you, outstanding!  You dodged a bullet and didn’t have to agonize about how to handle the problem of “I don’t have my meds!”  Now’s a great time, especially considering we are in the middle of flood and tornado season, to consider what your plan will be for taking care of your caregivers as they care for your patients when your institution is in crisis.  Whatever you decide, let common sense prevail!  If you’re not sure you’ve used the best possible common sense, ask someone from another facility in your area.  They can share their plan, you can both build off each other, or in the worst case scenario, they will steal yours!  Regardless of the option, two facilities will have plans that probably weren’t in place this winter!  Whether you follow the letter of the law or bend the rules just a touch, your goal should always be to maintain access to care for those who need it.  In my opinion, bending the law to prevent harm sometimes makes the most sense. ΓΆβ€"Β 

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