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Audit of the State Office of Pharmacy Services Overview of Audited Entity

This section describes the makeup and responsibilities of the State Office of Pharmacy Services.

Table of Contents

Overview

The State Office of Pharmacy Services (SOPS) was established in 1992 through a study commissioned by the Department of Health, the Department of Developmental Services, and the Department of Public Health to address the concerns of rising costs in pharmacy services.

According to SOPS’s 2023 Policies and Procedures, its mission is as follows:

[SOPS’s mission] is to provide state of the art pharmaceutical care through clinically appropriate and operationally efficient drug therapy management in a safe and effective manner. Through this process optimal patient outcomes will be achieved. Our goal is to always be prepared and to service the needs of the Commonwealth.

According to SOPS, in fiscal years 2022 and 2023, SOPS spent $38,404,485 and $43,505,989 on medications, respectively. These purchases are made by SOPS’s pharmacy vendor, Cardinal Health, and are purchased through the statewide pharmaceutical provider. If medications are unavailable through the state pharmaceutical provider, SOPS acquires the medications from an appropriate supplier. SOPS pharmaceutical purchases are made using net pricing that includes discounts and rebates for the medication. In addition to purchases through the state wholesaler and appropriate suppliers, SOPS also uses a group purchasing organization and Managed Health Care Associates to secure additional price reductions based on the group purchasing organization’s leveraged contract prices. SOPS was able to receive $26,698 in rebates for fiscal year 2022 and $10,373 for fiscal year 2023 through purchases with the group purchasing organization. By using multiple sources to obtain pharmaceuticals, SOPS seeks the lowest price for the agencies it supports.

As of the end of the audit period, SOPS provided pharmaceutical services to the following facilities across the Commonwealth:

Massachusetts Department of Mental Health
Worcester Recovery Center and HospitalSolomon Carter Fuller Mental Health Center (Boston)
Taunton State HospitalCorrigan Mental Health Center (Fall River)
Women’s Recovery from Addiction Program (Taunton)Cape Cod and the Islands Mental Health Center (Pocasset)
Men’s Recovery from Addiction Program (Taunton) 
Massachusetts Department of Developmental Services
Hogan Regional Center (Danvers)Wrentham Developmental Center
Massachusetts Department of Public Health
Lemuel Shattuck Hospital (Jamaica Plain)Tewksbury Hospital
Western Massachusetts Hospital (Westfield)Pappas Rehabilitation Health Center for Children (Canton)
Veterans Homes
Veterans Home at HolyokeVeterans Home at Chelsea
Massachusetts Department of Correction
Bay State Correctional Center (Norfolk)Massachusetts Alcohol and Substance Abuse Center (Bridgewater)Bridgewater State Hospital
Massachusetts Treatment Center (Bridgewater)Massachusetts Correctional Institution (MCI) Cedar Junction (Walpole)MCI Concord
MCI FraminghamMCI NorfolkMCI Plymouth
MCI Shirley Medium/MinimumNorth Central Correctional Center (Gardner)Northeastern Correctional Center (Concord)
Old Colony Correctional Center (Bridgewater)Old Colony Minimum (Bridgewater)Pondville Correctional Center
South Middlesex Correctional Center (Framingham)Sousa-Baranowski Correctional Center (Shirley) 
Sheriffs’ Departments
Barnstable House of CorrectionHampden House of Correction (three locations)
Berkshire House of CorrectionHampshire House of Correction
Bristol House of Correction (two locations)Middlesex House of Correction
Dukes County Sheriff’s DepartmentNorfolk House of Correction
Essex House of Correction (three locations)Plymouth House of Correction
Franklin House of CorrectionSuffolk House of Correction (two locations)

Standardization and Monitoring of Prescription Functions

SOPS fulfills its responsibilities to the agencies to which it provides pharmaceutical services through a contract with Cardinal Health for pharmacy management and staffing services. SOPS oversees the process to ensure that medication orders are prepared with a high rate of accuracy. An order that is filled incorrectly and identified before or after it is delivered to the patient is considered a medication error. SOPS and Cardinal Health identify and track these errors to determine the cause of the error and whether any harm came to the patient.

SOPS requires its vendor to have a prescription medication error rate below 0.25% for each fiscal year. Prescription medication errors are documented in a Medication Event Report, which provides the total number of medication errors and calculates the error rate for the month. If a month’s medication error rate is greater than 0.15%, a corrective action plan is implemented and documented in Cardinal Health’s Medication Event Report.

According to SOPS, Cardinal Health can earn monetary bonuses from SOPS by achieving a medication error rate of less than 0.20%, which provides an additional incentive for medication orders to be filled with a high rate of accuracy.

Vendor Contract Overhead Fees

Cardinal Health can make purchases of up to $250,000 per fiscal year for products or services in order to achieve its objective of providing pharmacy management services for SOPS using funding designated in its contract. These are known as overhead fees. Items purchased may include medication carts, office supplies, office equipment, and database services.

For Cardinal Health to make an overhead fee purchase, it must submit a proposal for approval to SOPS’s chief of pharmacy. SOPS’s chief of pharmacy, along with SOPS’s fiscal director, ensures that all contract fees are used within the scope of their proposed use.

General Chapter 797 from the United States Pharmacopeia Safety Standards

Within the Pharmacy Distribution Center, SOPS has a compounding room where pharmacy technicians prepare compounded pharmaceuticals under clean and sterile conditions for the patients it serves across the Commonwealth.

To ensure the sterility and integrity of compounded sterile preparations, SOPS has policies and procedures in place that comply with General Chapter 797 from the United States Pharmacopeia safety standards. SOPS’s internal policies and procedures require that an accredited environmental company complete an external review of surface and air testing in its compounding room to ensure that SOPS adheres to General Chapter 797 from the United States Pharmacopeia safety standards.

To maintain competency with compounding procedures, employees who use the compounding room to prepare compounded pharmaceuticals are required to complete at least five hours of training in the area of sterile compounding and pass competency evaluations for media fill and cleaning procedures. They also must display competency in garbing and gloving procedures in order to prepare compounded pharmaceuticals.

Reports to the Legislature

Under Chapter 24 of the Acts of 2021 and Chapter 126 of the Acts of 2022, SOPS was responsible for sending reports to the House and Senate Committees on Ways and Means by April 15, 2022 and April 14, 2023, respectively. These reports were to detail SOPS’s recommendations for other entities that may benefit from the cost savings SOPS provides.

Date published: March 20, 2025

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