journal article
LitStream Collection
ASHP professional policy recommendations—Invitation to comment
doi: 10.1093/ajhp/72.8.e37pmid: 25825192
All ASHP members are encouraged to review and comment on professional policy proposals scheduled for consideration by the House of Delegates in June 2015. By taking advantage of this opportunity, any member can influence the stance ASHP takes on issues of importance to the public and the profession. The proposed policies crafted by ASHP’s policy committees in September and approved by the Board of Directors in January are published here. In response to a recommendation from the Task Force on Organizational Structure to develop a more responsive and timely policy process, ASHP councils met in February to consider new policy recommendations, which were duly considered by the Board of Directors in early April and so were unavailable when this edition went to press. Complete reports on policy issues considered by ASHP councils over the past year, including at their February meetings, have been made available via the ASHP website (www.ashp.org/hod) and the ASHP Connect House of Delegates Community (http://connect.ashp.org). The Board of Directors Reports on Councils include background information on all the proposed policies. All current ASHP professional policies may be found at www.ashp.org/policypositions. How to comment The best way to comment on specific policy proposals is through ASHP Connect, where members can also view comments by others. Members can also contact state delegates (listed on the House of Delegates web-page), the ASHP President, the Chair of the House of Delegates, or other members of the Board (telephone numbers are in each issue of AJHP). Regional conferences for delegates to the House are scheduled for May 2–5, 2015, and comments received from members before then are especially useful in the policymaking process. The business scheduled for the House is reviewed in detail at the regional delegate conferences (RDCs). Delegates who receive comments from members can share them with other state delegates at the RDCs. ASHP policymaking process The councils are the foundation of the ASHP process for developing professional policies. (The executive committees of sections and forums may also recommend professional policies.) Periodically throughout the year, ASHP issues a call for agenda items to be considered by its policymaking bodies. Ideas for policy development come from ASHP members, members of the Board of Directors, policy committee members, and the ASHP staff. Further, the Board of Directors often refers Resolutions, Recommendations, and New Business items from the previous House of Delegates sessions to the appropriate policy-initiating group for consideration. Each idea is researched by staff with respect to existing ASHP policy; appropriate background information on the issue is collected. The final agenda for meetings is formulated by the chair and staff secretary of the group. Actions taken during meetings of a policy committee are recorded in minutes. The Board of Directors then acts on the policy recommendations, and the Board’s decisions are reflected in the reports provided to delegates and published on the ASHP website. The ASHP policy-development process allows thorough exploration of an issue and careful crafting of language that expresses clearly the intent of ASHP members. Council on Public Policy The Council on Public Policy is concerned with ASHP professional policies related to laws and regulations that have a bearing on pharmacy practice in hospitals and health systems. Within the Council’s purview are (1) federal laws and regulations, (2) state laws and regulations, (3) analysis of public policy proposals that are designed to address important health issues, (4) professional liability as defined by the courts, and (5) related matters. 1. Pharmacist Participation in Health Policy Development To urge pharmacists to participate with policymakers and stakeholders in the development of medication-related health policies at the national, state, and community levels; further, To develop tools and resources to assist pharmacists in fully participating in health policy development at all levels. 2. Pharmacist Recognition as a Healthcare Provider To advocate for changes in federal (e.g., Social Security Act), state, and third-party payment programs to define pharmacists as healthcare providers; further, To affirm that pharmacists, as medication-use experts, provide safe, accessible, high-quality care that is cost effective, resulting in improved patient outcomes; further, To recognize that pharmacists, as healthcare providers, improve access to patient care and bridge existing gaps in healthcare; further, To collaborate with key stakeholders to describe the covered direct patient-care services provided by pharmacists; further, To advocate for compensation for pharmacist services by any available payment program. (Note: This policy would supersede ASHP policy 1307.) 3. Compassionate Use of Unapproved Experimental Drugs* To advocate that the Food and Drug Administration (FDA) Expanded Access (Compassionate Use) Program be the sole mechanism for patient access to unapproved experimental drugs, in order to preserve the integrity of the drug approval process and assure patient safety; further, To advocate for broader patient access to unapproved experimental medications under the FDA Expanded Access Program; further, To advocate that the applicant for an investigational new drug or a new drug application expedite review and release of drugs for patients who qualify for the program; further, To advocate that the experimental drug therapy be recommended by a physician and reviewed and monitored by a pharmacist to assure safe patient care; further, To advocate for the patient’s right to be informed of the potential benefits and risks via an informed consent process, and the responsibility of an institutional review board to review and approve the informed consent and the drug therapy protocol. 4. Pharmaceutical Product and Supply Chain Integrity To encourage the Food and Drug Administration (FDA) and relevant state authorities to take the steps necessary to ensure that (1) all drug products entering the supply chain are thoroughly inspected and tested to establish that they have not been adulterated or misbranded and (2) patients will not receive improperly labeled and packaged, deteriorated, outdated, counterfeit, adulterated, or unapproved drug products; further, To encourage FDA and relevant state authorities to develop and implement regulations to (1) restrict or prohibit licensed drug distributors (drug wholesalers, repackagers, and manufacturers) from purchasing legend drugs from unlicensed entities and (2) ensure accurate documentation at any point in the distribution chain of the original source of drug products and chain of custody from the manufacturer to the pharmacy; further, To advocate for the establishment of meaningful penalties for companies that violate current good manufacturing practices (cGMPs) intended to ensure the quality, identity, strength, and purity of their marketed drug product(s) and raw materials; further, To advocate that drug product labeling include a readily available means to retrieve the location of the facility that manufactured the specific lot of the product; further, To advocate that this readily retrievable manufacturing information be available prospectively to aid purchasers in determining the quality of a drug product; further, To urge Congress and state legislatures to provide adequate funding, or authority to impose user fees, to accomplish these objectives. (Note: This policy would supersede ASHP policy 0907.) 5. Patient Adherence Programs as Part of Health Insurance Coverage To advocate for the pharmacist’s role in patient medication adherence programs that are part of health insurance plans; further, To advocate those programs that (1) maintain the direct patient-pharmacist relationship; (2) are based on the pharmacist’s knowledge of the patient’s medical history, indication for the prescribed medication, and expected therapeutic outcome; (3) use a communication method desired by the patient; (4) are consistent with federal and state regulations for patient confidentiality; and (5) permit dispensing of partial fills or overfills of prescription medications in order to synchronize medication refills and aid in medication adherence. (Note: This policy would supersede ASHP policy 0116.) 6. Statutory Protection for Medication-Error Reporting To collaborate with other healthcare providers, professions, and stakeholders to advocate and support state and federal legislative and regulatory initiatives that provide liability protection for the reporting of actual and potential medication errors by individuals and healthcare providers; further, To seek state and federal liability protection for medication-error reporting that is similar in concept to that which applies to reporting safety incidents and accidents in the aviation industry. (Note: This policy would supersede ASHP policy 0011.) 7. Premarketing Comparative Clinical Studies To advocate that the Food and Drug Administration have the flexibility to decrease the requirement for placebo-controlled studies and correspondingly impose a requirement for comparative clinical trials. (Note: This policy would supersede ASHP policy 0514.) 8. Funding, Expertise, and Oversight of State Boards of Pharmacy To advocate appropriate oversight of pharmacy practice and the pharmaceutical supply chain through coordination and cooperation of state boards of pharmacy and other state and federal agencies whose mission it is to protect the public health; further, To advocate adequate representation on state boards of pharmacy and related agencies by pharmacists who are knowledgeable about all areas of pharmacy practice (e.g., hospitals, health systems, clinics, and nontraditional settings) to ensure appropriate oversight; further, To advocate for dedicated funds for the exclusive use by state boards of pharmacy and related agencies including funding for the training of state board of pharmacy inspectors and the implementation of adequate inspection schedules to ensure the effective oversight and regulation of pharmacy practice, the integrity of the pharmaceutical supply chain, and protection of the public; further, To advocate that inspections be performed only by pharmacists competent about the applicable area of practice. (Note: This policy would supersede ASHP policy 0518.) Council on Therapeutics The Council on Therapeutics is concerned with ASHP professional policies related to the safe and appropriate use of medicines. Within the Council’s purview are: (1) the benefits and risks of drug products, (2) evidence-based use of medicines, (3) the application of drug information in practice, and (4) related matters. 1. Naloxone Availability To recognize the potential public health benefits of broader use of naloxone for opioid reversal by properly trained individuals; further, To support efforts to safely expand access to naloxone; further, To advocate that individuals other than licensed healthcare professionals be permitted access to naloxone only after counseling by a healthcare professional on proper administration, safe use, and appropriate follow-up care; further, To foster education on the role of naloxone in opioid reversal. 2. Complementary and Alternative Medicine in Patient Care To promote awareness of the impacts of complementary and alternative (CAM) products on patient care, particularly regarding drug interactions and medication safety; further, To advocate for the documentation of CAM products in the electronic health record to improve patient safety; further, To advocate for the inclusion of information about CAM products and their characteristics in medication-related databases; further, To provide education on the impacts of CAM products on patient care in healthcare organizations; further, To foster the development of up-to-date and readily available resources about CAM products, with special consideration to drug interactions and medication safety. 3. Development of Abuse-Resistant Narcotics To advocate that the Food and Drug Administration investigate the efficacy of abuse-resistant formulations in preventing prescription drug abuse. 4. Quality Patient Medication Information To support efforts by the Food and Drug Administration (FDA) and other stakeholders to improve the quality, consistency, and simplicity of written patient medication information (PMI); further, To encourage the FDA to work in collaboration with patient advocates and other stakeholders to create evidence-based models and standards, including establishment of a universal literacy level, for PMI; further, To advocate that research be conducted to validate these models in actual-use studies in pertinent patient populations; further, To advocate that FDA explore alternative models of PMI content development and maintenance that will ensure the highest level of accuracy, consistency, and currency; further, To advocate that the FDA engage a single third-party author to provide editorial control of a highly structured, publicly accessible central repository of PMI in a format that is suitable for ready export; further, To advocate for laws and regulations that would require all dispensers of medications to comply with FDA-established standards for unalterable content, format, and distribution of PMI. (Note: This policy would supersede ASHP policy 1012.) 5. Safety and Effectiveness of Ethanol Treatment for Alcohol Withdrawal Syndrome To oppose the use of oral or intravenous ethanol for the prevention or treatment of alcohol withdrawal syndrome (AWS) because of its poor effectiveness and safety profile; further, To support hospital and health-system efforts that prohibit the use of oral or intravenous ethanol therapies to treat AWS; further, To educate clinicians about the availability of alternative therapies for AWS. (Note: This policy would supersede ASHP policy 1010.) 6. Research on Drug Use in Obese Patients To encourage drug product manufacturers to conduct pharmacokinetic and pharmacodynamic research in obese patients to facilitate safe and effective dosing of medications in this patient population, especially for medications most likely to be affected by obesity; further, To encourage manufacturers to include in the Food and Drug Administration (FDA)–approved labeling detailed information on characteristics of individuals enrolled in drug dosing studies; further, To advocate that the FDA develop guidance for the design and reporting of studies that support dosing recommendations in obese patients; further, To advocate for increased enrollment and outcomes reporting of obese patients in clinical trials of medications; further, To encourage independent research on the clinical significance of obesity on drug use, as well as the reporting and dissemination of this information via published literature, patient registries, and other mechanisms. (Note: This policy would supersede ASHP policy 1013.) Council on Education and Workforce Development The Council on Education and Workforce Development is concerned with ASHP professional policies related to the quality and quantity of pharmacy practitioners in hospitals and health systems. Within the Council’s purview are (1) student education, (2) postgraduate education and training, (3) specialization, (4) assessment and maintenance of competence, (5) credentialing, (6) balance between workforce supply and demand, (7) development of technicians, and (8) related matters. 1. Developing Leadership Competencies To work with healthcare organization leadership to foster opportunities for pharmacy practitioners to move into leadership roles; further, To encourage leaders to seek out and mentor pharmacy practitioners in developing administrative, managerial, and leadership skills; further, To encourage pharmacy practitioners to obtain the skills necessary to pursue administrative, managerial, and leadership roles; further, To encourage colleges of pharmacy and ASHP state affiliates to collaborate in fostering student leadership skills through development of co-curricular leadership opportunities, leadership conferences, and other leadership promotion programs; further, To reaffirm that residency programs should develop leadership skills through mentoring, training, and leadership opportunities; further, To foster leadership skills for pharmacists to use on a daily basis in their roles as leaders in patient care. 2. Pharmacy Technician Training and Certification To advocate that pharmacy technicians be required to have completed a pharmacy technician training program accredited by the Pharmacy Technician Accreditation Commission (PTAC) and to obtain and maintain Pharmacy Technician Certification Board certification; further, To foster expansion of PTAC-accredited pharmacy technician training programs. (Note: This policy would supersede ASHP policies 1015 and 0702.) Council on Pharmacy Management The Council on Pharmacy Management is concerned with ASHP professional policies related to the process of leading and directing the pharmacy department in hospitals and health systems. Within the Council’s purview are (1) development and deployment of resources, (2) fostering cost-effective use of medicines, (3) payment for services and products, (4) applications of technology in the medication-use process, (5) efficiency and safety of medication-use systems, (6) continuity of care, and (7) related matters. 1. Impact of Insurance Coverage Design on Patient Care Decision To advocate that all health insurance policies be designed and coverage decisions made in a way that preserves the patient– practitioner relationship; further, To oppose provisions in health insurance policies that interfere with established drug distribution and clinical services designed to ensure patient safety, quality, and continuity of care; further, To advocate for the inclusion of hospital and health-system outpatient and ambulatory care services in health insurance coverage determinations for their patients. (Note: This policy would supersede ASHP policy 1017.) 2. Identification of Prescription Drug Coverage and Eligibility for Patient Assistance Programs To advocate that pharmacists ensure that the use of patient assistance programs is optimized and documented to promote continuity of care and patient access to needed medications; further, To support the principle that medications provided through manufacturer patient assistance programs should be stored, packaged, labeled, dispensed, and recorded using systems that ensure the same level of safety as prescription-based programs that incorporate a pharmacist-patient relationship. (Note: This policy would supersede ASHP policy 0603.) 3. Disposition of Illicit Substances To encourage healthcare organizations to develop procedures for the disposition of illicit substances brought into a facility by patients that ensure compliance with applicable laws and accreditation standards; further, To encourage healthcare organizations to include pharmacy leaders in formulating such procedures. 4. Pharmacist’s Role in Population Health Management To recognize the importance of medication management in patient-care outcomes and the vital role of pharmacists in population health management; further, To encourage healthcare organizations to engage pharmacy leaders in identifying appropriate patient cohorts, anticipating their healthcare needs, and implementing the models of care that optimize outcomes for patients and the healthcare organization; further, To encourage the development of complexity index tools and resources to support the identification of high-risk, high-cost, and other patient cohorts to facilitate patient-care provider panel determinations and workload balancing; further, To promote collaboration among members of the interprofessional healthcare team to develop meaningful measures of individual patient and population care outcomes. Council on Pharmacy Practice The Council on Pharmacy Practice is concerned with ASHP professional policies related to the responsibilities of pharmacy practitioners in hospitals and health systems. Within the Council’s purview are (1) practitioner care for individual patients, (2) practitioner activities in public health, (3) pharmacy practice standards and quality, (4) professional ethics, (5) interprofessional and public relations, and (6) related matters. 1. Support for the Second Victim of Medical Errors To acknowledge that healthcare personnel may become second victims of medical errors; further, To recognize that a just culture environment must include a support system for second victims; further, To encourage healthcare organizations to establish programs to support second victims; further, To educate healthcare professionals about the second-victim effect and available resources. 2. Standardization of Doses To recognize that standardization of medication doses within healthcare organizations reduces medication errors and improves information technology interoperability, operational efficiency, and transitions of care; further, To encourage healthcare organizations to develop standardized doses specific to their patient populations; further, To promote publication and education about best practices in standardizing medication doses. 3. Prescription Drug Abuse To affirm that pharmacists have leadership roles in recognition, prevention, and treatment of prescription drug abuse; further, To promote education on prescription drug abuse, misuse, and diversion-prevention strategies. 4. Pharmacist’s Role in Urgent and Emergency Situations To affirm that pharmacists should participate in planning and providing emergency treatment team services; further, To advocate that pharmacists participate in decision-making about the contents of code carts, emergency medication kits and trays, and the role of pharmacists in medical emergencies; further, To advocate that pharmacists serve on cardiopulmonary resuscitation and rapid response teams, and that those pharmacists receive appropriate training and maintain appropriate certifications. 5. Excipients in Drug Products To advocate that manufacturers remove unnecessary, potentially allergenic excipients from all drug products; further, To advocate that manufacturers declare the name and derivative source of all excipients in drug products on the official label; further, To advocate that vendors of medication-related databases incorporate information about excipients; further, To foster education on the allergenicity of excipients and documentation in the patient medical record of allergic reactions to excipients. (Note: This policy would supersede ASHP policy 0808.) 6. Online Pharmacy and Internet Prescribing To support efforts to regulate prescribing and dispensing of medications via the Internet; further, To support legislation or regulation that requires online pharmacies to list the states in which the pharmacy and pharmacists are licensed, and, if prescribing services are offered, requires that the sites (1) ensure that a legitimate patient-prescriber relationship exists (consistent with professional practice standards) and (2) list the states in which the prescribers are licensed; further, To support mandatory accreditation of online pharmacies by the National Association of Boards of Pharmacy Verified Internet Pharmacy Practice Sites or Veterinary-Verified Internet Pharmacy Practice Sites; further, To support appropriate consumer education about the risks and benefits of using online pharmacies; further, To support the principle that any medication distribution or drug therapy management system must provide timely access to, and interaction with, appropriate professional pharmacist patient-care services. (Note: This policy would supersede ASHP policy 0523.) 7. Standardization of Small-Bore Connectors To Avoid Wrong-Route Errors To advocate for use of medication administration device connectors and fittings that are designed to prevent misconnections and wrong-route errors; further, To encourage healthcare organizations to prepare for safe transition to use of medication delivery device connectors and adapters that meet International Organization for Standardization standards; further, To oppose the use of syringes with Luer fittings for other than intravascular or hypodermic routes of administration; further, To identify and promote the implementation of best practices for preventing wrong-route errors. (Note: This policy would supersede ASHP policy 1018.) 8. Medication Safety Officers Role To discontinue ASHP policy 1019, which reads: To advocate that accountability for development and maintenance of a medication safety program in hospitals and health systems be assigned to a qualified individual (i.e., a medication safety officer or leader of a medication safety team); further, To advocate that individuals in these roles have the authority and autonomy to establish priorities for medication-use safety and make the necessary changes as authorized by the medical staff committee responsible for medication-use policy; further, To affirm that pharmacists are uniquely prepared by education, experience, and knowledge to assume the role of medication safety officer or other leadership role in all activities that ensure the safety, effectiveness, and efficiency of the medication-use process; further, To support all pharmacists in their leadership roles in organizational medication-use safety, reflecting their authority over and accountability for the performance of the medication-use process. Section of Pharmacy Informatics and Technology A. ASHP Statement on the Pharmacist’s Role in Clinical Informatics To approve the ASHP Statement on the Pharmacist’s Role in Clinical Informatics (available at: www.ashp.org/hod). Footnotes * At its February meeting, the Council on Public Policy recommended changes to the wording of this policy recommendation. The revised policy recommendation, and additional policy recommendations from other council meetings in February, are available on the ASHP website at www/ashp.org/hod. Copyright © 2015 by the American Society of Health-System Pharmacists, Inc. All rights reserved.