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 begins.
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