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Greeley Reflections

Accreditation Connection, August 2, 2010

Medication Management and pharmacist first-dose review

Part 2 of 7

The Hospital Requirements

In the standards for medication management, The Joint Commission requires that prior to dispensing, a pharmacist reviews all newly ordered medications except in areas controlled by a Licensed Independent Practitioner (LIP) (e.g. Emergency Department) or in an urgent situation in which a delay would adversely affect the patient. It also requires that medications be dispensed in accordance with professional standards of practice.

CMS’s Interpretive Guidelines (§482.25(b) requires a pharmacist review of medications prior to dispensing except in emergencies as well. CMS also requires that guidelines, protocols, policies and procedures be developed for the appropriate control and distribution of medications. Aside from federal and state law, CMS is very clear that pharmacy services must be in implemented utilizing standards and guidelines promoted by professional organizations such as the FDA, NIH and the American Society of Heath-System Pharmacists (ASHP) and that these principles be maintained in the process you implement. Although ASHP Guidelines recommend that medications be reviewed by a pharmacist before patient administration, they also allow for exceptions when an established procedure exists for medications used in specific treatment circumstances. So if a standardized, approved process is implemented, setting or circumstance-specific exclusions to the pharmacy first-dose review can occur.

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