Directly Speaking - Tech-Check-Tech: A Dream That Will Soon Come True!
by Scott A. Meyers, Executive Vice President
August 9, 2013
I think we formed the first Tech-Check-Tech (don’t try to say that fast three times…you will fail) task force within ICHP back in the early 1990s. We even had a bill introduced in the General Assembly in 2011! It looks like hospital and health-system pharmacists will finally have our dream come true this fall!
The Illinois Department of Financial and Professional Regulation staff have undertaken a massive rewrite of the Illinois Pharmacy Practice Act Rules. As you will read in The GAS From Springfield, they took up the issue of sterile compounding and expanded it to all compounding, moving to a national standard from the USP-NF (yes that means 797 compliance will be forthcoming for all). They also revised the Multi-Med Pack rules, automated dispensing and storage system regulations and much, much more.
But let’s get back to my initial point, Tech-Check-Tech. The initial draft is incorporated into the On-site Institutional Pharmacy Services Section of the Rules or Section 1330.530 to be precise. This means that Tech-Check-Tech can only be used in institutions with on-site pharmacies. The practice cannot be used for community pharmacy practice, nuclear pharmacy services or in institutions where there is no pharmacy on-site.
Here are the Tech-Check-Tech rules as initially drafted, Section 1330.530 3) h):
h) An on-site institutional pharmacy practice that has an ongoing clinical pharmacy program may allow certified pharmacy technicians to check the work of other pharmacy technicians (“tech-check-tech program”) in connection with the filling of floor and ward stock, automated dispensing and storage systems, and unit dose distribution systems for patients admitted to the hospital whose orders have previously been reviewed and approved by a licensed pharmacist. The pharmacy shall have on file and available for review, a description of the clinical pharmacy program prior to initiating a tech-check-tech program.
(1) This subsection shall only apply to acute care inpatient hospital pharmacy settings.
(2) Hospital pharmacies that have a tech-check-tech program shall deploy pharmacists to the inpatient care setting to provide clinical services.
(3) Products compounded or repackaged in the pharmacy must have been previously checked by a pharmacist and then may be used by the technician to fill unit dose distribution systems, and floor and ward stock.
(4) To ensure quality patient care and reduce medication errors, programs that use a tech-check-tech program pursuant to this subsection must include the following components:
(A) The overall operation of the program shall be the responsibility of the pharmacist-in-charge.
(B) The program shall be under the direct supervision of a pharmacist and the parameters for the direct supervision shall be specified in the facility’s policies and procedures manual.
(C) The certified pharmacy technician who performs the checking function has received specialized and advanced training as prescribed in the policies and procedures of the facility.
(D) The tech-check-tech program shall be operated only with an ongoing evaluation system in place.
These rules not only include Tech-Check-Tech for floor stock and automated dispensing and storage systems but also unit dose distribution systems. For departments that continue to use unit dose cart fills, this can drastically help increase efficiency and productivity.
You will note that deployment of a Tech-Check-Tech program requires the implementation or continuation of a clinical pharmacy program in the institution. It also requires deployment of pharmacists to the patient care units to provide those clinical services. The rules are not specific as to how much time on the patient care units, but the intent is to prevent implementation of Tech-Check-Tech at the expense of pharmacist positions. Pharmacists are not prohibited from working in the pharmacy for the purposes of checking IV admixtures and first doses, or verifying orders in the computer system although the latter may also be done on the patient care units.
In addition, these rules require that only certified pharmacy technicians may provide the checking in a Tech-Check-Tech program and only after receiving appropriate specialized training. An ongoing evaluation system such as a quality assurance program or audit of a specific percentage of doses per day or week to ensure safe medication distribution is also required.
While the above rules are a first draft, it is hoped that the final rule will provide similar if not the same opportunity for pharmacy departments to design their own training and quality assurance systems. Being too prescriptive can often hinder innovation. However, making sure new programs ensure patient safety is paramount! The new Tech-Check-Tech system can help Illinois health-system pharmacies improve productivity, increase distribution accuracy (we’ve all seen the studies that show that specially trained techs do a better job of checking fills than most pharmacists) and enhance job satisfaction for both certified pharmacy technicians and pharmacists.
ICHP is very excited and pleased that this section has been added to the Illinois Pharmacy Practice Act Rules, and we thank the staff at IDFPR for their open minds and collaboration on this important issue.
If you haven’t read The GAS From Springfield
yet, I’m guessing you’ll be headed there next to see what other changes are in your future!
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