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BOP Hospital Advisory Committee (HAC) Update

18 Sep 2017 8:49 AM | Anonymous

Author: Bert McClary, RPh

The HAC met in Jefferson City on August 7




  • Class J Shared Services Rule.  An emergency amendment became effective August 7 that will allow a licensed pharmacy to deliver a filled and labeled prescription to another licensed pharmacy without being licensed under Class J if the medication is to be administered on the same premises as the receiving pharmacy.  This amendment was based on current problems caused when specialty pharmacies could not deliver medications to a pharmacy/clinic for administration to the patient at the clinic because it was not possible obtain a Class J permit between the two pharmacies. 
  • The Board is working with DHSS, the Department of Mental Health and others to implement provisions of new legislation related to opioid abuse and misuse, including a standing order for naloxone, MoHealthNet billing, patient education, insurance and distribution of free supplies from DMH.
  • New legislation allows hospitals to be licensed if they are in compliance with CMS Conditions of Participation, and places restrictions on DHSS hospital licensing rules.  The definition of licensed premises is unclear under the new requirements and is significant to BOP licensing regarding certain practice sites.  DHSS and MHA are working together to interpret the law and DHSS will make proposals for rule changes.  HAC will review the previously proposed changes to the DHSS pharmacy services and medication management rule and make a recommendation to DHSS regarding sections that should be implemented.
  • Suggestions were made regarding proposed pharmacy practice advancement legislation, to be forwarded to the task force that is preparing the language.
  • Proposed technician legislation was reviewed and concerns were expressed regarding the effect of sterile compounding being placed in the advanced technician category.  The potential for DHSS and BOP to propose a joint rule regarding technician activities was discussed, to be considered if the proposed legislation is not successful or if the final language is not satisfactory.
  • Greg Teale was elected to serve as Chairman.
  • Strategic review of committee operations was deferred to the next meeting, to include a more complete review of previous activities, membership, scope of authority and future topics.

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