The accountable officer must ensure that the use of CDs is monitored through routine processes such as data analysis, audit and clinical governance, all of which should form an integral part of the organisation’s normal governance systems.
Routine monitoring and auditing
The accountable
officer must ensure that the use of CDs is monitored through routine processes
such as data analysis, audit and clinical governance, all of which should form
an integral part of the organisation’s normal governance systems.
Hospital pharmacists
are key members of the multidisciplinary team sup-porting accountable officers
in their monitoring role. Different models and approaches to routine monitoring
and auditing exist across hospitals but it is generally recommended that the
security of CDs is checked, by pharmacy staff, at least every 3 months.
The process of
monitoring should include aspects of both audit and rec-onciliation, and should
occur in all locations where CDs are stored. This independent assessment of
local CD management supported by knowledge and data can help assess and detect
discrepancies between amounts supplied and amounts prescribed and used. Even
simple acts such as roughly correlat-ing supply and prescription can act as
indictors to trigger more in-depth investigations and help eliminate error,
misuse or misdirection. E-prescribing, electronic data collection and automated
data analysis tools have been devel-oped within some organisations to provide
reports which can be used to support the audit and reconciliation processes.
The same principles
of having an independent approach to the monitoring of CD stock held within
hospital pharmacies should be considered best prac-tice. It is recommended that
organisations arrange for periodic checks of pharmacy-held CDs by appropriate personnel
who do not routinely work in the particular pharmacy service.
The focus of
clinical area– including pharmacy checks is often solely on schedule 2 CDs for
which a register or record book is required. However, it should be remembered
that all drugs classified in the misuse of drugs legisla-tion are known to have
the potential for misuse. Therefore, hospital phar-macies should develop
systems to assess periodically the local management and use of other medicines
with the potential for misuse, including medicines in schedules 3 to 5.
Currently, primary
care trust accountable officers are required to monitor all prescriptions for
CDs dispensed in the community through the Electronic Prescribing Analysis and
Costs (ePACT) data analysis tools available from the Prescription Pricing
Division of the NHS Business Services Authority. Hospitals who issue FP10 (HNC)
prescriptions, which are dispensed in the community, should ensure that their
hospital CD ePACT reports form part of their local CD prescription monitoring
processes.
Systems were
introduced in 2006 to control and collect data on all private prescriptions for
schedule 2 and 3 CDs dispensed by community pharma-cies. Non-NHS prescribing of
schedule 2 and 3 CDs, which are to be dispensed by a community pharmacist, must
be on a dedicated prescription form (FP10PCD) and each prescriber must be
allocated a unique six-digit private CD prescriber’s code. Private
prescriptions issued and dispensed within the same hospital are not currently
subject to the same requirements; this is one area where the hospital
accountable officer may require additional specific and comprehensive
monitoring arrangements if such a service is provided.
The Care Quality
Commission (CQC) is required to produce an annual report on the safer
management of CDs. This provides data and an overview against which certain
aspects of hospital prescribing and medicines use can be further analysed.
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