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Unlicensed staff-processing medication refills

  • 1.  Unlicensed staff-processing medication refills

    Posted 12-04-2023 11:40

    I have found several old discussion on this topic. Looking for updated thoughts. If you are in PA that is even better. 

    We currently have MA's and Pharm Techs who pend medication refills to the provider in Epic. The provider then signs and routes to the pharmacy. 

    We use several protocols in Epic to help us speed up the time it takes to pend medications for chronic conditions such as HTN, high cholesterol, acid reflux, etc. 

    It has been proposed that we should consider having the MA's and Pharm Techs route these medications directly to the pharmacy and have the provider co-sign after. 

    We do use this process with RN's on a limited basis for urgent after hours chronic refill needs (no controls). 

    Looking for thoughts from those who use a process like this and give your pros and cons. 

    Thank you

    Nicole



    ------------------------------
    Nicole Holmes RN
    Ambulatory Director, Clinical Call Services
    UPMC Central PA
    New Bloomfld PA
    (717)988-9666
    ------------------------------


  • 2.  RE: Unlicensed staff-processing medication refills

    Posted 12-05-2023 07:30
      |   view attached

    I have done a lot of work around MA scope of practice. It is considered ordering medications if it goes directly to the pharmacy and thus out of scope for unlicensed, even with protocols. However, if the provider has written in the note to continue the medication beyond the current prescription, then yes, the unlicensed staff can transpose from the note to the order page and send it.

     

    The reference I have is from AAMA (see attached).

     

    Regards,

    Leslie

    Leslie Hazle, MSN, RN, CPHQ (she/her)

    Director, Patient Safety & Clinical Risk

    McLaren Medical Group - Our Guiding Principle is to provide healthcare as we expect for our own family.

    G-3235 Beecher Rd.

    Flint, MI 48532

    PH: 810-342-1051

    Mobile: 703-980-0651

    "Safety brings first aid to the uninjured." - F. S. Hughes

    MMG_DWB Horizontal rgb

    This is a confidential professional/peer review and quality assurance document of the medical center. It is collected as patient safety work product  It is protected from disclosure pursuant to the provisions of MCL 333.20175, MCL 333.21513, MCL 333.21515, MCL 331.531, MCL 331.532, MCL 331.533, MCL 330.1143 and all other State and Federal law providing protection for facility professional review and/or peer review functions.  Unauthorized disclosure or duplication prohibited.

     

    McLaren confidentiality statement: "The information contained in this communication, including attachments, is confidential, may be privileged, and is intended only for the use of the named recipient(s). Unauthorized use, disclosure, forwarding or copying is strictly prohibited and may be unlawful. If you have received this communication in error, please notify me IMMEDIATELY at the phone number or pager listed above."



    Attachment(s)



  • 3.  RE: Unlicensed staff-processing medication refills

    Posted 12-05-2023 09:17

    Hello all, in some states MA may order medications using standing orders/protocols. In Maine, a MA scope of practice is defined by an organizations policy- so the organization determines what a MA may or may not do.

     

    Tracy Colburn, DNP, MSN, RN

    Provider Practice Support Team

    York Hospital

    207-351-3572

    York Hospital Logo

     






  • 4.  RE: Unlicensed staff-processing medication refills

    Posted 12-05-2023 08:18

    We also use the Pend/Send feature in Epic for medication refills.  The State of Ohio is very clear, if a medical assistant/nurse/etc. send a medication refill directly to a pharmacy and the provider provides retrospective signature that is considered 'Practicing Medicine' and not allowable by State code.

     

    Hope that helps!

     

    Erin

     

    Erin Slay, DNP, MHA, RN

    System Director, Ambulatory/UHPS Nursing

    University Hospitals

    216.789.2131 cell

    Erin.Slay@UHhospitals.org

     

     


    Visit us at www.UHhospitals.org.

    The enclosed information is STRICTLY CONFIDENTIAL and is intended for the
    use of the addressee only. University Hospitals and its affiliates disclaim
    any responsibility for unauthorized disclosure of this information to anyone
    other than the addressee.

    Federal and Ohio law protect patient medical information, including
    psychiatric_disorders, (H.I.V) test results, A.I.Ds-related conditions,
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    by law.





  • 5.  RE: Unlicensed staff-processing medication refills

    Posted 12-06-2023 08:43

    Hi, 

    In NYS, probably most stringent. MAs and techs can pend meds but must be authorized / signed by provider prior to going to the pharmacy.

    Agree with other comments, that would be considered prescribing, and could not be covered by a 'protocol.' We would consider that equal to reading the provider note, as that is still not a direct order. Our allowable protocols for ambulatory around medication are only for vaccine administration, associated treatment of anaphylaxis, and some select testing. Only an RN can use those orders. In some situations, the RN can also enter a 'verbal' order that requires co-sign  after the fact, however requires actual conversation, readback, documentation and is reserved for emergent situation.

    From a safety perspective, I am always concerned with non-nursing personnel even pending medication orders because they lack the professional education, responsibility and accountability to do a 'due diligence' clinical check to make sure the refill is appropriate. However, that is my personal/professional opinion and in practice, refills (but not new meds or changes) are pended by MAs.

    Lastly, there are many functionalities in EPIC that allow for non-provider prescribing by choosing option for protocol without provider signature, so staff need to know that just because they have access and can do something, doesn't mean they should do it!

    Regards,

    Jaclyn



    ------------------------------
    Jaclyn Schindler, MPH, PMC, FNP-BC
    Senior Director, Nursing and Clinical Operations
    Faculty Group Practice
    NYU Langone Health
    1 Park Avenue
    New York, NY 10016
    Jaclyn.Schindler@nyulangone.org
    (646) 276-3005
    ------------------------------



  • 6.  RE: Unlicensed staff-processing medication refills

    Posted 12-07-2023 20:37

    Unfortunately, I am in an academic medical center where we use EPIC and the cma is allowed to "load" or pend medications for refills. I accept the policy , but I find it annoying. There is one cma whom I can trust and scan what she has pended; there is "rarely" an error waiting to happen. Depending on the education and experience of the cma, many get the names of the meds confused, such as loading trazodone for the patient who requested tizanidine. If medication reconciliations are not up to date, they may load an expired or incorrectly dosed medication that was already changed. They may pend an expired Rx, or they do not read the last progress note the way an RN would which sometimes indicates a plan to change the dose on the next refill. 


    I encourage all of my patients to make their requests directly through EPIC's MyChart, so I don't have to deal with possible  cma interpretation. 


    Most of my medication refills are for opioid analgesics, which I do not think the cma should be allowed to touch (my opinion). One helpful cma took it upon themself to load hydrocodone 40 mg ER tab every 12 hours because the patient called and said that the insurance no longer covered their OxyContin 40 mg every 12 hours. The on-call provider signed it.  The only problem is that 80 mg a day of hydrocodone = 80 MME: while 80 mg of oxycodone = 120 MME. Big mistake and not helpful.  After that one, the cma's were only allowed to pend an order that had been previously filled (not make up their own 'helpful' orders). They also load refills for me on patients that I have not seen in the past 3 months because my name was on the original script, or they believe I will manage the issue sooner than another provider. I have to waste time re-routing it either back the cma or to the past provider who last evaluated the patient. 


    EPIC does have a lot of ways to increase productivity by implementing the five fingers found on any hand; but any errors remain the responsibility of the licensed provider and any negative consequence are suffered by the patient.


    Having the meds routed to the pharmacy before signing sounds like it would require additional EHR programming and IT costs. Keep in mind, every time you remove a safety step you increase your error rates. These processes are creating an artificial way of allowing the cma to take "verbal orders" without "really" taking a verbal order. Why not insist that providers (typically physicians) get organized and do some of their own work? 


    Giving more skills to cma's who can "type" should not be a replacement for nursing leadership making the argument for why they need an RN in the mix to properly assess, monitor, lead, and/or supervise what the cma does. 


    Aleesa

    ---------------

     

    Aleesa M Mobley PhD APN  (she/her/hers) Why Pronouns Matter

    Assistant Professor - Clerkship Director [Pain Management/Substance Use Disorder]

    Physical Medicine & Rehabilitation - Neuro Musculoskeletal Institute 

    Lippincott Procedures: Subject Matter Expert - Wolters Kluwer Publishing


    Rowan Medicine Bldg., 42 E. Laurel Rd, Ste 1700, Stratford New Jersey 08084 

    T: 856-566-7010 | F: 856-566-6956| C: 856-230-1229 

    mobley@rowan.edu | som.rowan.edu 


    Learning is not attained by chance, it must be sought for with ardor and attended to with diligence [Abigail Adams (1744 - 1818), 1780].





  • 7.  RE: Unlicensed staff-processing medication refills

    Posted 12-08-2023 10:01
    Well stated. Safety first.







  • 8.  RE: Unlicensed staff-processing medication refills

    Posted 12-08-2023 15:23
    Our institutional process is to have all requests come from the patient pharmacy to a centralized team that works on behalf of multiple primary care clnics.  The non-licensed staff pend renewal requests that exactly match what is on the patient's med list.  If they don't match they go to a team of LPNs who resolve the discrepancy.  This depends on good med reconciliation, but using this centralized process allows the team to track the number of meds requested that don't match the list and work with teams to improve med rec processes.  The centralized teams' skills get pretty well honed in this model and they don't have the urgency of other tasks or interruptions that they would have it was decentralized to the provider/team level.
    Stephanie

    Stephanie G Witwer, Ph.D., RN, NEA-BC, FAAN
    Department of Nursing
    Emeritus Staff





  • 9.  RE: Unlicensed staff-processing medication refills

    Posted 12-19-2023 18:11
    Hi. We use EPIC. I am curious to know how other organizations do Results calls. I'm referring to the documentation workflow in EPIC.

    Thank you, Karen Hunter, BSN, RN, AMB-BC







  • 10.  RE: Unlicensed staff-processing medication refills

    Posted 02-15-2024 12:43
    Hello everyone.

    I am curious how results calls are documented in your organizations if you use EPIC. 

    There is a discrepancy where I work.

    TIA for any responses.






  • 11.  RE: Unlicensed staff-processing medication refills

    Posted 02-16-2024 07:35

    My practice just implemented the use of kiosks for patient check in. We have 3. They are literally right next to each other. I'm wondering about HIPAA compliance and privacy. Any thoughts out there?

    TY, Karen Hunter, R. N.






  • 12.  RE: Unlicensed staff-processing medication refills

    Posted 02-16-2024 09:05

    Hello Karen,

    I personally do not think this is a HIPAA issue. When the front checks in patients, they are asking them for their name and date of birth, and the patients are verbalizing this, and other people checking in, or waiting to be checked in are hearing this information. Having used kiosks like this before, I prefer them as I'm not having to answer questions out loud. On a side note, if HIPAA is a concern, is there the possibility to put up a divider around the kiosk, or at least around the monitor?



    ------------------------------
    Sharon Peacock, MSN-Ed., RN, AMB-BC
    Nursing Professional Development Generalist
    Sentara Ambulatory Services Division
    Charlottesville, VA
    sjpeacoc@sentara.com
    ------------------------------



  • 13.  RE: Unlicensed staff-processing medication refills

    Posted 03-07-2024 10:24
    Hi I work in a family practice and I was wondering if anyone out there has Stop the Bleed kits and/or training. 






  • 14.  RE: Unlicensed staff-processing medication refills

    Posted 06-10-2024 08:12
    I am looking for opinions and comments on a recent situation that occurred where I work.

    A staff person became suddenly dizzy with a headache and nausea. One of the physicians was notified to assess the ill staff member. The physician had an RN medicate the ill staff person with Zofran. The staff person is not a patient at our practice and is not in our system as a patient either. I'm wondering about the possible legal ramifications or liability, for the physician, RN and the practice. I'm not saying that the ill person shouldn't have been tended to, but how far are we allowed to go? I'm assuming my manager wrote up an incident report. 







  • 15.  RE: Unlicensed staff-processing medication refills

    Posted 06-10-2024 21:03
    [Opinion] 

    I am not an attorney, but I try to make a point of understanding how the law works. 
     
    [[A staff person became suddenly dizzy with a headache and nausea. One of the physicians was notified to assess the ill staff member. The physician had an RN medicate the ill staff person with Zofran. The staff person is not a patient at our practice and is not in our system as a patient either.]]

    Possible legal ramifications or liability for the physician, RN and the practice are "unlikely," but very real. If this was not your "patient," I must assume you did not do the administrative intake paperwork to obtain informed consent. You had the time to do so, and/or you had the ability to contact 9-1-1. 

    You medicated a person without documenting whether you knew the history of allergies and other medications. If you did obtain this information, the person should have had a chart started and made to be a legal patient. If you did not obtain this information, it could be construed as a form of negligent practice particularly if the person developed an allergic or adverse reaction to the medication provided. The physician implicated the nurse in the potential "assault" if no documented consent obtained. Nursing is much like the military, you should know better than to follow inappropriate or invisible (no documentation) orders. The physician could have provided the medication themself.

    There is also the liability of using business assets (medication) without reimbursement. Who owns the office; are you allowed to give away medications for free? Keep in mind, people have been known to lose their jobs for taking home gloves from the workplace. Reallocation without authorization might be akin to theft. An incident report (if written) would at least explain the missing meds/supplies. 

    Now that the physician has created a provider-patient relationship, do they plan to follow up? Has the office created a delay in this person's care by treating symptoms instead of having the patient properly assessed for potential "Migraine, TIA, vertigo, vestibular syndrome, sinusitis, "hyperemesis" secondary to pregnancy, marijuana use, gastroparesis, or other GI condition". 

    I hope someone checked the blood pressure and heart rate. Was the patient sent home sick or made comfortable so they could continue to work for the rest of the day?  If the person continued to work, there is a risk of a human resource error that could be interpreted as denying sick time. The denial may not be "real," but it could be inferred from the power difference between the staff person and the provider. 

    Again, all of these issues are possible risks, but unlikely if the staff person has positive outcomes. Keep in mind, doing the NICE thing is not always doing the RIGHT thing. 


    Aleesa  
    ---------------

     

    Aleesa M Mobley PhD APN  (she/her/hers) Why Pronouns Matter

    Assistant Professor - Clerkship Director [Pain Management/Substance Use Disorder]

    Physical Medicine & Rehabilitation - Neuro Musculoskeletal Institute 

    Lippincott Procedures: Subject Matter Expert - Wolters Kluwer Publishing


    Rowan Medicine Bldg., 42 E. Laurel Rd, Ste 1700, Stratford New Jersey 08084 

    T: 856-566-7010 | F: 856-566-6956| C: 856-230-1229 

    mobley@rowan.edu | som.rowan.edu 


    Learning is not attained by chance, it must be sought for with ardor and attended to with diligence [Abigail Adams (1744 - 1818), 1780].






  • 16.  RE: Unlicensed staff-processing medication refills

    Posted 06-11-2024 06:25
    Thank you Aleesa. You touched on a lot of the issues I was concerned about.

    I was not the RN who medicated the ill staff member. But when I questioned that action my manager (not an RN) reprimanded me and stated, " We have to treat her. I'll take care of it ". 

    I was not even aware at first that an ill staff member was being tended to. Another RN ( much younger and way less experienced) was brought into the situation. I happened to "stumble across " the scenario. I'm 65 years old and an RN since 1981 ( yes you can do the math, lol) with a ton of hospital experience so I tend to question things. When I started to get involved and started asking the ill co-worker questions I was told by my manager " we don't need two nurses in here ".

    I do know that vital signs were checked and an EKG was done. An ambulance was offered but the ill staff person declined. Eventually a family member came and picked her up. 

    I do not know if all of this was included in the employee incident report by my manager or if an incident report was even done.

    BTW the employee came back to work and stated she is feeling better. I didn't ask her any details as I didn't want to get reprimanded again by my manager.





  • 17.  RE: Unlicensed staff-processing medication refills

    Posted 12-20-2023 07:50

    Hi. In PA, working on AthenaOne with HealthCatalyst to support medication refills. 

    We at our CHC do not allow CMAs to refill meds; that is by protocol and only RNs work on refills of particular meds- the rest are sent directly to clinician. If request does not meet specific protocols set by CMO then those also go back to clinician or patient is asked to come in for requisite visit. In Athena you can set petmissions that would allow CMA to do the task, just not in their scope per our interpretation ( not that the clinicians didn't try). 

    Hope this helps. 

    Melissa Miranda,  RN CEO

    Neighborhood Health Centers of the Lehigh Valley 

    610-936-9090



    ------------------------------
    Melissa Miranda CEO
    Neighborhood Hlth Ctrs of the Lehigh Valley
    Bethlehem PA
    (610)820-7605 (2302)
    ------------------------------