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In light of many recent inquiries to the Colorado Board of Pharmacy about the impact of COVID-19 on licensure and operations, the Division of Professions and Occupations (“Division”) has compiled a list of up-to-date information about the virus and the state of Colorado’s response. Additionally, after a thorough review of Title 12 governing pharmaceutical licensure and the Pharmacy Practice Act, we have determined some additional measures that may be taken to help boost the workforce as we face the rising number of infections.
Please note: Additional emergency measures around remote practice, notification and application requirements, and restrictions on screening practice are forthcoming in a separate email.
Due to the fluid nature of this situation, please continue to check your email and the DORA COVID-19 Updates for Licensees and Consumers site in the coming days.
Frequently asked questions for the Colorado Pharmacy Board and answers from the Division of Professions and Occupations:
1. DOES THE DIVISION HAVE ANY RECOMMENDATIONS FOR PHARMACIES AT THIS TIME?
Disinfecting and Cleanliness Guidance
- As always, pharmacy services must be safely and properly provided at all times. Pharmacies should take proactive steps to prevent the spread of germs and to protect Colorado patients. Proper cleaning, sanitizing and disinfection procedures must be in place. See CDC’s guidance for healthcare facilities for useful tips.
- The United States Environmental Protection Agency (EPA) has published an online listing of disinfectant products approved for use against SARS-COV-2, the coronavirus that causes COVID-19.
- Pharmacy staff should be trained on how to recognize symptoms of potential illness and what to do if they develop symptoms or come in close contact with a person known to have COVID-19. Free educational materials the CDC on identifying COVID-19 symptoms are available online.
- The Division recommends establishing procedures for staff to report potential symptoms or COVID-19 exposure to pharmacy management/the pharmacist-in-charge. Pharmacy management should be trained on appropriate response measures, including, any isolation and quarantine requirements. The CDPHE recommends that workers stay home if they are feeling sick.
- Make sure pharmacy staff are trained on and use proper hand-washing techniques. CDC hand-washing recommendations are available online.
2. WHAT IF A PHARMACY DECIDES TO TEMPORARILY CLOSE?
- The Division recognizes that situations could occur that may require the pharmacy to temporarily close. Planning is key! The Division encourages licensees to take proactive steps to adopt emergency response plans before an actual emergency occurs.
- In the event a pharmacy has to temporarily close, licensees should take proactive steps to assist patients and avoid interruptions in patient care:
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Provide patients as much advance notification as possible. The Division recommends posting signs/notifications in a publicly visible location such as on main entry doors, near the pharmacy area and on the pharmacy’s website. Other direct patient notification options should also be considered (e.g., HIPAA compliant texts/emails).
- Patients should be provided instructions and contact information for contacting the pharmacy/speaking with a pharmacist (phone number/e-mail). To avoid medication interruptions, the Division recommends providing directions for transferring prescriptions, if necessary.
- Once again, licensees should take reasonable measures to assist patients and prevent interruptions in care if the pharmacy is unable to provide a transfer due to illness, quarantine or a closure related to COVID-19.
3. CAN PHARMACY STAFF WORK FROM HOME?
- Please refer to Board of Pharmacy Rule 26 which outlines Remote Pharmacy Practice, including but not limited to the following provisions for remote practice:
- A registered prescription drug outlet or other outlet may employ or contract with one or more pharmacists for the purpose of conducting Remote Pharmacy Practice provided that all requirements, including those of confidentiality, privacy, and security are met, as required in the Rule;
- All pharmacists employed or contracted with to conduct Remote Pharmacy Practice must be Colorado licensed pharmacists, holding active, unrestricted licenses with the Board;
- No drug inventory shall be stocked or maintained at any Remote Pharmacy Practice location;
- Pharmacists engaged in Remote Pharmacy Practice are not considered in the computation of the technician to pharmacist ratio;
- All records of Remote Pharmacy Practice must be maintained at the prescription drug outlet or other outlet in accordance with applicable record keeping rules;
- Remote Pharmacy Practice shall have adequate security and be conducted in a setting sufficient to maintain patient privacy and confidentiality.
FOR PHARMACISTS: Rule 26 allows pharmacists to perform non-dispensing activities outside of a licensed pharmacy. Authorized non-dispensing activities include, but are not limited to:
- Patient counseling/education
- Obtaining patient history/information
- Reviewing patient records/medical histories
- Consulting with prescribers and other healthcare professionals
- Verifying prescription/medication order (data)
- Clarifying prescription/medication order information
- Patient assessment/evaluation, as authorized by Colorado law
- Medication therapy management
- Billing and insurance claim submissions/ review
- Drug utilization review
- Assessing payer eligibility/coverage
- Peer review/peer consultations
- Reviewing, selecting, and developing formulates or plan/practice guidelines
- Reviewing compliance with benefit guidelines
- Managing inventory, including purchasing and ordering
- Managing/reviewing information systems
- Patient medication review
- Patient referrals
- Drug therapy management as provided under Board Rule 6.00.00
- Prescription order entry/review, provided that a pharmacist may only accept a prescription on the premises of a Colorado licensed pharmacy (see question #4)
4. CAN PHARMACISTS TAKE VERBAL PRESCRIPTIONS/MEDICATION ORDERS OR CALL THE PRESCRIBER TO CLARIFY A PRESCRIPTION/MEDICATION ORDER FROM HOME?
- According to Rule 26, if Remote Pharmacy Practice includes conducting the final evaluation of prescriptions for a prescription drug outlet or other outlet, the following requirements apply:
- The pharmacist must have a visual connection with the prescription drug outlet or other outlet for the pharmacist to review the finished product prior to delivery to the patient; and
- The prescription drug outlet or other outlet shall maintain records of final evaluation in accordance with all other applicable record keeping requirements.
5. CAN STERILE COMPOUNDING PHARMACIES REUSE GARB IN THE EVENT OF A SHORTAGE?
- Licensees have expressed concerns with potential shortages of gowns, face masks and shoe covers. The Division recommends talking with your supplier. If a shortage is anticipated, pharmacies should first consider measures to conserve supplies they have on hand. Potential measures could include limiting the number of personnel entering the buffer room/controlled area and modifying staging activities to minimize trips into the buffer room/controlled area.
- If you are experiencing a shortage of garb and need to modify your procedures to allow for reuse, appropriate aseptic processes must be followed to maintain the compounding environment and to ensure the proper state of microbial control is preserved. The pharmacy’s written policies and procedures must be revised to incorporate modifications and staff should be properly trained on new requirements. To ensure compliance, staff garbing should be assessed to ensure staff can successfully carry out any modified garbing procedures.
- CriticalPoint® LLC has released a webinar entitled “COVID-19: Downstream Implications for Sterile Compounding” which contains information on the reuse of garb due to a shortage. The free Peer Network Silver subscription will give you access to the recording. Note: CriticalPoint® information is being provided for informational purposes only. The webinar was conducted by a private entity and is not officially endorsed or sponsored by the Division or Board.
- If your facility is regulated by other agencies (e.g., the Colorado Department of Public Health and Environment), please consult those agencies for guidance as well.
6. WHAT ABOUT SHORTAGES OF OTHER PHARMACY SUPPLIES?
- It is difficult to determine what shortages may occur in the future (if any). However, the Division will review issues as they arise and may issue additional guidance if needed. In the interim, pharmacists should use their professional judgment to avoid interruptions in patient care and to ensure pharmacy services are safely and properly provided.
ADDITIONAL INFORMATION ABOUT COVID-19 IN COLORADO
HOTLINE:
CDPHE has also established statewide public hotlines for both citizens and providers needing guidance regarding COVID-19.
- Citizen Hotline: 303-389-1687 or 1-877-462-2911, with answers in many languages
- Provider Hotline: From Monday thru Friday, 8:30 a.m.- 5:00 p.m., please call 303-692-2700. For after-hours, holidays, and weekends, please call 303-370-9395.
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