Monday, October 1, 2012

Continuous Quality Improvement Programs Emergency Regulations Finalized - Effective October 1, 2012

Governor McDonnell has approved the emergency regulations requiring the implementation of continuous quality improvement (CQI) programs for all pharmacies.  These emergency regulations went into effect on October 1, 2012.  Of note, there will be a 6 month implementation allowance before enforcement will occur.  Thus, pharmacies will have until March 31, 2013 to come into compliance with the emergency regulations.

Since these are emergency regulations (effective for 1 year), a public comment period will open on October 8th to receive comments on the regulations and if changes are needed, the Board of Pharmacy will review and propose alternate permanent regulations in 2013.  More information on the future public comment period can be found by clicking here.

There are two ways that pharmacies can implement a CQI program.  
  • Reporting dispensing errors to a "Patient safety organization" (PSO).  A complete listing of PSOs can be found at the AHRQ's webpage.  If you are "actively reporting" (reporting all dispensing errors and analyses of such errors to a PSO as soon as practical or at least within 30 days of identifying the error) to a PSO, your pharmacy is in compliance with the regulation
  • Implementation of a CQI program that includes the following:
    • Notification as well as Documentation and record requirements
    • (a detailed list of the requirements can be found on pages 10 and 11 of the emergency regulations document)
Click here for the full text of the emergency regulations.  NOTE: the CQI requirements can be found in all text that is underlined in the document.