Pushing to protect pharmacies and patients from the spread of COVID-19
OPA has been working around the clock maintaining your membership services, fielding calls and questions from members, rescheduling our Annual Conference, and engaging media and state officials in an effort to help deploy strategies to protect Ohioans from the spread of COVID-19.
As we field feedback from our member pharmacists on the ground, we are assessing all suggestions, opportunities, and concerns, and we are pushing them to officials at the governor's office, board of pharmacy, department of health, health plans, and other state leaders.
We are pleased to report that much of our feedback and recommendations are being embraced, and much of it is in the process of being implemented, if not already. And we are continuing to refine and build our strategies for success — much like all of you are doing back at your practices and in your homes.
First, this week we have launched a special section of our website dedicated to COVID-19 news and resources. We plan to update with any and all relevant information. In the interest of serving the profession and the public, we have made this open to all members and non-members alike. Please bookmark it and check it often.
The Ohio Department of Health has created a special checklist of the top 10 things pharmacies can do prepare for and protect from COVID-19. They also created a general guide for businesses and employers.
Second, we have been pushing state officials for emergency guidance and policy changes to help better equip pharmacists and pharmacy staff with they tools they need to protect themselves and the public. Here is a rundown of the latest:
- March 13: Pharmacies empowered to perform remote prescription processing
This ensures that workflow can be better managed by off-site personnel for pharmacies, keeping administrative functions outside of the pharmacy area.
- March 14: Pharmacists empowered to compound hand sanitizer
As hand sanitizer supplies are diminished, many pharmacies struggled to keep their pharmacies clean and to offer needed supplies to their patients. Recognizing that pharmacists can compound sanitizer from scratch, OPA worked with the board to create a temporary allowance for pharmacists to compound their own alcohol-based sanitizer for their own use and distribution to the public.
- March 14: Allowing reuse of Personal Protective Equipment (PPE) for compounding activities
Recognizing the diminished supply of PPE, and the need to conserve needed supplies, the board has created new allowances for sterile compounders to reuse certain types of PPE.
- March 16: Extending and expanding pharmacists' authority to dispense emergency refills
With many patients and pharmacists having difficulties obtaining reauthorizations of current drug therapy from prescribers, OPA worked with the board to expand emergency dispensing authority. Specifically, the guidance allows the following:
- Extends the emergency refill of schedule III-V controlled substances to not exceed a thirty-day supply or the days’ supply as indicated in the pharmacy’s records, whichever is less (as opposed to a 72-hour supply limitation).
- Permits a pharmacist to authorize emergency refills for a particular drug up-to three times
in any twelve-month period (as opposed to once in any twelve-month period). This applies to both schedule III-V controlled substances and non-controlled substances.
- In lieu of three 30-day emergency refills, a pharmacist may dispense a one-time emergency refill of a 90-day supply for a particular non-controlled substance medication.
- The board also authorized the use of oral prescriptions for schedule II controlled substances as
permitted in 21 CFR 1306.11(d).
- March 16: Empowering compounding pharmacists to step in to address drug shortages
As the drug shortages mount, the need for pharmacists to get pragmatic with drug supply grows. Recognizing this, OPA worked with the board to unleash the expertise and skills of Ohio's compounding pharmacists to help fill the void of drugs that are in shortage.
- March 17: Easing hiring and onboarding of pharmacy personnel to maintain adequate staffing
As pharmacies see increased levels of demand, constrained staffing levels due to sickness and family responsibilities, and the need to add services, OPA has worked with the board of pharmacy to ease some of the hiring and onboarding requirements for new pharmacy personnel. The board's recent barrier erosions include:
- Authorization for pharmacists and pharmacy technicians licensed in other states to work in Ohio
Pharmacists and pharmacy technicians not licensed or registered in Ohio, but currently licensed and in good standing in another state, may practice pharmacy in this state under a limited set of conditions.
- Expedited onboarding of pharmacy technician trainees
Upon the submission and processing of a trainee license, including payment of the registration fee and any other requirements specified by the Executive Director or the Director’s designee, the applicant will be granted a status of “In-Review - Conditional Approval.” This status will permit the technician trainee to practice as a trainee in accordance with rule 4729:3-3-01 of the Administrative Code for the duration of this resolution, unless otherwise notified in a Notice for Opportunity for Hearing or until the licensing status has been made “Active.”
- Extension of registered pharmacy technician renewal and technician trainee extensions
The registered pharmacy technician renewal date is being extended by 120 days. Pharmacy technician registrations are now valid until July 29, 2020. This means that registered pharmacy technicians have until July 29, 2020 to renew as well as complete the required continuing education requirements. Technician trainees who are set to have their registrations expire any time between 3/16/2020 through 5/31/2020 will be provided an automatic six-month extension to the trainee’s registration.
- Authorization for pharmacists and pharmacy technicians licensed in other states to work in Ohio
- March 18: Expansion of the maximum days’ supply for multiple drugs in single-dose containers in long-term care facilities
To address patient access to medication, the Board of Pharmacy has adopted guidance allowing for the temporary expansion of the authorized maximum days’ supply permitted under rule 4729-9-23 of the Administrative Code from 31 days to 60 days. This extension only applies to prescriptions dispensed to patients residing in long-term care facilities.
- March 18: Temporary extension of basic life support requirements
To ensure that pharmacists aren't being held back by having to renew basic life-support training requirements, the Board has delayed expiration dates to July 16, 2020.
- March 19: New guidance aimed at protecting the safety of pharmacy staff and the patients they serve
After days of OPA fielding phone calls and messages from pharmacists and pharmacy technicians concerning some instances of poor protective measures at pharmacies and absurd prohibitions placed on pharmacy staff to protect themselves and their patients, OPA worked with the Board of Pharmacy to ensure the the risks of transmission and spread are minimized. Their new guidance ensures that at-risk pharmacy staff members are permitted to wear personal protective equipment (PPE). The guidance also ensures safe distances are kept and that proper equipment must be worn in giving immunizations. The guidance also suggests developing special procedures for caring for high-risk patients and requires adequate breaks for staff to maintain cleanliness.
- March 20: Expanded administrative roles for pharmacy technicians to alleviate workload issues
In order to mitigate possible staffing shortages, the Board of Pharmacy has adopted guidance to permit registered pharmacy technicians to stock automated drug storage systems and send and receive copies of non-controlled prescriptions, under certain conditions. Additionally, this guidance provides clarification
on the positive identification requirements for technicians transferring prescriptions. This guidance is being issued in accordance with a Board resolution adopted on March 2, 2020 and shall remain in effect until rescinded by the Board.
- March 20: Central compounding for compounded sterile products
In order to mitigate reported shortages of personal protective equipment (PPE) and address staffing concerns, the State of Ohio Board of Pharmacy has adopted the following guidance to permit licensees to perform sterile compounding for another licensee, referred to as central compounding. This guidance is being issued in accordance with a Board resolution adopted on March 2, 2020.
- March 20: Moratorium placed on PBM audits in Ohio
OPA has spoken with several pharmacies who were continuing to be pursued by PBMs and insurers for audits during the height of the COVID-19 pandemic. These were unnecessarily wasting the time and resources of already-constrained pharmacies that were scrambling to provide care. In response to our requests, the Ohio Department of Insurance graciously ordered for all pharmacy audits to be suspended during the declared emergency period.
- March 22: Curbing the stockpiling and inappropriate prescribing of chloroquine and hydroxychloroquine
In OPA's work to assess what is happening on the ground in pharmacies, we were alarmed in mid-March as pharmacies started to report shortages of hydroxychloroquine. The shortages coincided with some premature hype over the drug's possible use as a treatment for COVID-19. Regardless of its possible utility, the attention on the drug created a massive push for prescriptions - many of which pharmacists reported as being likely inappropriate prescribing. As such, OPA worked with the board of pharmacy and Governor DeWine's office to create appropriate guardrails as supply dwindled. Effective March 22, all new hydroxychloroquine prescriptions must be accompanied with a diagnosis code, with COVID-19 diagnoses being limited to a 14-day supply. For more on the problem and the board's solution, see this Columbus Dispatch feature on the move that is now catching on in states across the country.
- March 24: Sale and shipment of non-reportable drugs from unlicensed out-of-state facilities
In order to address any drug shortages during the COVID-19 outbreak, the Board of Pharmacy issued guidance on the sale and shipment of non-reportable dangerous drugs that are in shortage by unlicensed, out-of-state facilities. The guidance allows Ohio pharmacies to receive non-reportable dangerous drugs from an unlicensed pharmacy, wholesale distributor of dangerous drugs, third-party logistics provider, or manufacturer of dangerous drugs located in another state in order to alleviate a drug shortage if certain criteria are met.
OPA would like to thank Governor DeWine, Board of Pharmacy Executive Director Steve Schierholt, board president Shawn Wilt, and board policy director Cameron McNamee for consistent and thorough communication with OPA, swift reviews and considerations, and an overall proactive approach that is clearing ambiguity and keeping pharmacy staff and patients safe.
Recognizing the need for further reforms, OPA has sent a letter to the governor's office this week to also make requests for the following:
- Securing reasonable amounts of personal protective equipment (PPE) for pharmacies without the ability to maintain safe distances
- Temporarily eliminate insurer/PBM requirements for patient signatures, and to protect pharmacies from audit takebacks due to a lack of signatures
- Eliminating insurer/PBM limits and restrictions on mailing and delivering prescriptions
- Empowering pharmacists to test and treat for flu, strep, and other tests, including COVID-19 as appropriate and as it becomes available, and if adequate PPE is made available for testing
- Ending restrictive insurer/PBM networks and single-source contracts that are restricting patient access to needed medications and supplies
- Allowing pharmacists to dispense emergency medications without a prescription
- Requiring insurer/PBM coverage of compounded shortage medications
- Creating a formal assessment and referral process for pharmacies encountering high-risk patients
- Removing unnecessary prior authorizations and "refill too soon" limits from insurers/PBMs
- Allowing therapeutic substitution for drugs of concern and medications that are out of supply or in shortage
- Implementing Medicaid provider ID numbers for pharmacists
- Allowing insurance coverage for pharmacist-initiated medications and OTC products
- Obtaining reimbursement for pharmacist-rendered services (consult agreement drug therapy management, INRs, etc.) to relieve pressure on health systems and emergency departments
These are just a few of our suggestions, but we are open to hear many more. We are gathering feedback hourly at this point. If you see any opportunities or concerns that you feel need to be addressed, please contact email@example.com.
While we appreciate the Board of Pharmacy's quick action to protect pharmacy staff and patients, you all are instrumental in making sure that pharmacies comply with these requirements. If you feel that your pharmacy is not taking adequate measures to maintain safe distancing between staff and and patients, provide for a clean practice setting, or provide reasonable amounts of protective equipment (recognizing the shortage of PPE), please keep us informed, and let the board of pharmacy know as well.
We have heard from a number of pharmacists that they are documenting safety concerns and sending formal questions, issues, and complaints to managers and leaders at their pharmacies, but instead of receiving a written response, pharmacists are instead receiving phone call responses. Pharmacists have stated that they believe that a lack of written responses are being done as a means to possibly avoid the accountability that documentation provides. We have been advised by the board of pharmacy that if you feel that something nefarious is occurring in this regard, you should file a complaint.
A reminder to all pharmacists: it is your license, and if you feel that someone is unreasonably getting in the way of the safe practice of pharmacy, it is important to speak out. We will be working to make sure your voices are heard.
In closing, we are so incredibly proud of how pharmacists and pharmacy teams are stepping up in this moment of disruption and risk. We have already heard a number of amazing stories of pharmacists being nimble, clever, and resourceful in their efforts to meet the growing and complex needs of their patients and their communities. Please let us know what you are doing, so that we can keep track of how you are innovating, adapting, and succeeding. Fill out this brief survey. If a member of OPA's team reaches out to you to get more information, please take a few minutes to respond. If you are willing and able, we want to share your stories with other pharmacists, media, and state officials. It's time to show the public the value of pharmacists.
Stay tuned, and stay safe. Keep watching the coronavirus section of our website. OPA will continue working for you while you continue working for your patients.