Six New Medication Reconciliation Requirements for 2009
     Establishing Best Management Practices...

Six New Medication Reconciliation
Requirements for 2009
By Kurt A. Patton, MS, RPh of Patton Healthcare Consulting, LLC
  1. An explicit requirement newly added by the Joint Commission concerns analysis of the medication list during admission and states that any ”discrepancies, omissions, duplications, adjustments, deletions or additions are reconciled and documented.” Thus if a patient reports taking five medications and only four are continued during the inpatient stay, this decision must be documented to indicate that it was intentional and not an oversight.
  2. In hospital-to-hospital or other care setting transfers, not only must the list of medications be sent on, but also contact information must be included in the event that the next care setting has a question about the medication regimen.
  3. The facility must ensure that the medication regimen is a component of all patient-care handoffs within the organization, although specific documentation is not required.
  4. At discharge, the patient must be provided not only with the medication list, but also with an explanation of the list and this interaction must be documented. The patient must also be educated at this point to discard any older versions of their medication reconciliation listing. Printing the advice on each form and being sure to date the form is the simplest way to accomplish this.
  5. A new standards tagging process has begun wherein elements of performance are tagged with a ”D”, indicating that the Joint Commission is specifically looking for documentation of effort for that EP. However, there are many EPs that do not have a D tag, but do say ”record and document” in the body of the text. Be sure to read all EPs carefully.
  6. The most significant change for 2009 is the creation of an approved definition of, and set of simpler requirements for, settings that use medications minimally. As with all patients that will receive medications, a medication list must be gathered. However, in the minimal use setting, if the patient’s chronic medications are not changed and no long-term drug is prescribed, there is no need to provide copies of the medication list either to the patient or the next provider of care. Should changes be made to the chronic medications or something long-term be prescribed, the full medication reconciliation process must then be instituted.
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Establishing Best Management Practices
for Pharmaceutical Waste Management
By Charlotte Smith, RPh, MS, HEM of PharmEcology Associates, LLC
  1. Identify those drugs that are considered hazardous waste under RCRA rules. The same must be done for those states with additional hazardous waste regulations.
  2. Designate a second category for particularly hazardous drugs such as chemotherapy, endocrine disrupters and other highly toxic drugs, which are not listed under RCRA, and then manage these drugs as hazardous waste as well.
  3. Avoid disposing of drugs via the drain wherever possible. All chemical entities used as drugs should be segregated and disposed of through either regulated medical waste incineration or municipal incineration. Exceptions can be made for innocuous products (for instance, bran flakes and Metamucil), which should be sent to a landfill to avoid the unnecessary cost of incineration; and drugs that are not synthetic chemical entities (such as saline or dextrose), which should be designated for potential sewer or landfill disposal.
  4. Approach your local wastewater treatment plant with a list of potentially sewerable items, such as saline or electrolytes, to determine if these products will be permitted in the sewer.
  5. Ensure that trace chemotherapy is put into a container, generally yellow, to be incinerated at a regulated medical waste incinerator.
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  Did You Know...
  …Only 21% of hospitals nationwide report having a line item in their operating budget for managing pharmaceutical waste, however 59% of hospitals without a budget for pharmaceutical waste management expect to establish one in the next two years. For more information on annual pharmaceutical waste expenditures, click here.

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