2 Remote Processing Questions for Pharmacies Responding to COVID-19
March 19, 2020
As restrictions and HIPAA regulations related to telehealth loosen in response to the COVID-19 pandemic, healthcare facilities - especially pharmacies - will have many questions regarding how to best handle new modifications to regulations on processing requests and providing services remotely. We've provided guidance on two of the most significant of these questions:
What do I need to know in order to leverage telehealth effectively (and legally) for my pharmacy?
In some cases, remote processing of a medication order or prescription may allow for a pharmacy to treat patients when face-to-face encounters are not possible. The limitations placed on face-to-face encounters in response to the COVID-19 outbreak are requiring administrative agencies to modify remote processing regulations and pharmacies to review and modify existing policies to provide remote processing services.
Generally, an Ohio-licensed pharmacy delivering remote processing services must remain in compliance with all state and federal regulations. There are a few key requirements pharmacies must keep in mind when operating remotely:
Written agreements and policies are mandatory. In Ohio, a pharmacy seeking to deliver remote processing services to patients must have a written agreement or documented policies and procedures outlining the services to be provided and establishing the expectations and responsibilities of all parties involved. It should cover:
- positive identification by remote pharmacists;
- personal or direct supervision of pharmacy interns and pharmacy technicians conducting remote processing;
- compliance with record keeping requirements; and
- methods to adequately safeguard and maintain patient confidentiality.
Conducting the required training. All pharmacists, pharmacy interns, and pharmacy technicians providing remote processing services must be trained on the items provided in the agreement or policy.
Keeping effective records. The pharmacy must maintain records including the names, active license numbers, and location where remote processing will be performed by pharmacists, pharmacy interns, and pharmacy technicians. All records, including end-of-day reports capturing positive identification of orders processed remotely, must be available for inspection or furnished to the board upon request within three business days.
What actions are administrative agencies taking to ensure hospitals and pharmacies are properly staffed to provide health care services to patients during the workforce shortage?
The State of Ohio Board of Pharmacy, State Medical Board of Ohio, and the Ohio Board of Nursing have each responded to the need for emergency licensure. Please see the response from each agency below:
The State of Ohio Board of Pharmacy has expanded the ability for out-of-state pharmacists and technicians to work in Ohio under certain conditions:
Pharmacists and pharmacy technicians licensed and in good standing in other states can work in Ohio if
- their license and good standing are verified by the out-of-state terminal distributor;
- verification documentation is maintained by the terminal distributor and easily retrievable for three years;
- training in Ohio compliance, including compounding training by USP 795 and 797, is provided to the pharmacist by the out-of-state terminal distributor; and
- the terminal distributor provides the Board with an “out-of-state notification form” prior to employment.
Additionally, pharmacy technicians are only permitted to work as a registered pharmacy technician unless they hold a certification from ExCPT or PTCB.
The State Medical Board of Ohio voted on three key items to better allow licensees to meet the extraordinary needs caused by COVID-19:
- The Board is suspending enforcement of any regulations requiring in-person visits between providers and patients beginning March 9
- Continuing education requirements for the renewal of licenses are suspended for renewals due by March 1, 2021
- Board staff will work with the State Emergency Management Agency and others to effectuate Ohio licensure eligibility for out-of-state doctors.
The Ohio Board of Nursing outlined key nursing regulations to help support an adequate and safe nursing workforce:
- During the emergency, Ohio law authorizes nursing without an Ohio nursing license, including the deployment of out-of-state nurses to Ohio and the deployment of Ohio nurses to other states;
- The Board is expediting temporary permits, which authorize nurses to begin practicing in Ohio within 3 days of the Board’s receipt of an application for reciprocity; and
- Long-term care facilities may utilize an individual who is not listed on the Nurse Aid Registry for up to four months.