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News Coronavirus Disease 2019 (COVID-19) Frequently Asked Questions

4/02/2020
  • Board of Registration in Pharmacy

                                                        Board of Registration in Pharmacy

                                                   Coronavirus Disease 2019 (COVID-19)

                                                          Frequently Asked Questions

1. Will the Board waive the live CE requirement since so many live programs have been canceled?

Although we will continue to monitor the situation and its impact on live CE availability, bear in mind that there are several online CE offerings that meet the requirement of 5 live CE credit hours per year.

ACPE approved courses are considered “live” as long as the activity provides direct interaction between presenter and learner, including lectures, live teleconferences, workshops, etc. An online course (i.e. webinar) that is approved for live CE credits would be designated with an “L” in its ACPE number.

Please see following link for details: http://elearning.ashp.org/acpe-designations

2. Can a pharmacist work more than 12 hours?

During the emergency period, a pharmacist, pharmacy intern, or pharmacy technician may remain on duty for more than 12 hours per day in order to act in the best interest of patients, provided that the time in excess of 12 hours is minimized (to the extent possible) and licensees are able to accurately and safely dispense prescriptions.

3. What about supervisory ratios for interns and technicians?

During the emergency period, the Board of Pharmacy does not intend to take any enforcement action against pharmacies that may be temporarily out of compliance with required supervisory ratios (247 CMR 8.06) provided that there is at least one licensed pharmacist in the pharmacy and the pharmacy is able to accurately and safely dispense prescriptions.

4. Can I still accept oral prescriptions?                                                        

As always, pharmacies should continue to accept oral prescriptions for any Schedule III - V medication as long as a follow-up prescription (written or e-prescribed) is requested to be sent within 7 business days. The prescription should indicate: "Issued to document an Oral Prescription". 

The Massachusetts DPH has indicated that the current state of public health emergency qualifies for Schedule II emergency exceptions. The prescriber must dictate the needed quantity, up to a 30 day supply. The prescriber should notate "Authorization for Emergency Dispensing” on the follow-up prescription (written or e-prescribed) to be provided within 7 business days.

Oral Schedule VI prescriptions are acceptable and do not require follow-up written or electronic prescriptions.

It is the prescriber’s responsibility to ensure that the follow up prescription is sent.

Patient prescriptions should not be denied if a prescriber continually fails to send follow up prescriptions.

Pharmacists need only document on the prescription that a hard copy or e-prescription was requested.

5. Can I dispense an “emergency supply” on a prescription with no remaining refills?

Yes. See the following link for details: 

https://www.mass.gov/news/covid-19-order-of-the-commissioner-of-public-health-related-to-pharmacy-practice

6. Can I refill clozapine without lab results?

In accordance with current practice, pharmacies may refill clozapine prescriptions if current lab results cannot be obtained in a timely manner provided that the pharmacist uses professional judgment after consulting the prescriber. Required lab results must be obtained as soon as possible and the pharmacist must document all pertinent details.

See the FDA guidance regarding REMS drug requirements during the COVID-19 emergency:

https://www.fda.gov/media/136317/download

7. Can I still immunize if my CPR certification expires?

During the emergency period, the Board of Pharmacy does not intend to take any enforcement action against pharmacists who continue to provide immunizations after their CPR certification has expired. Refresh your knowledge using online resources until classes become available.

8. Can I provide curbside delivery so patients do not have to come into the pharmacy?

Pharmacies may certainly provide this service if designated personnel provide the medication to the patient or his/her agent and offer counseling to be provided by a pharmacist. Counseling may be provided by phone. Provisions should be established for the security and accountability of medications.

9. Do I still have to get identification when a customer receives a prescription for a federally controlled substance or gabapentin?

No. See link to the PMP guidance document:

https://www.mass.gov/news/covid-19-waiver-of-requirement-for-pharmacies-to-collect-and-submit-customer-id-information-to

10. Can you waive the signature for pickup and delivery to limit the amount of surface touching?

Board regulations do not require any signature at pick up to document either acceptance or refusal of counseling. Additionally, the Drug Control Program is waiving the requirement in 105 CMR 700.012(A) for pharmacies to collect and report a patient ID and signature in association with dispensing a controlled substance or gabapentin.

Although the Board does not require a signature for delivery, it recommends that some method of acceptance confirmation should be established upon delivery.

If there are 3rd party insurer requirements for a signature at pickup or delivery, please contact the insurer for guidance.

11. Do I still have to do perpetual inventory every 10 days during the emergency?

During the emergency period, the Board of Pharmacy does not intend to take any enforcement action against pharmacies that perform and reconcile perpetual inventory counts as least every 30 days. Back counts are strongly recommended.

12. Can you address insurance issues such as early refills and signature requirements?

The Division of Insurance has issued this bulletin that addresses these concerns:

https://www.mass.gov/doc/bulletin-2020-06-administration-of-precription-drug-benefits-during-covid-19-coronavirus-public/download

13. Can I change my hours of operation during the emergency period?

Yes. Use the following form at any time to change store hours:

https://www.mass.gov/doc/pharmacy-store-hours/download

14. Can we request permission to close a pharmacy for more than 1 day, directing patients to other locations and transferring to other pharmacies as needed?

If your organization makes a decision to temporarily close, the Board would require notification via email prior to this occurring with all pertinent details such as the effective date, estimated duration, continuity of care plan, communication plan, etc. Current patients must also be notified of the continuity of care plan.

15. What if I need to open late, close early, or temporarily close during the day?

To the extent possible, provide methods to notify patients such as signage and emergency contact information. Pharmacies must ensure patient needs are met in a timely manner. Notify the Board as soon as possible via email.

16. Due to illness and quarantine, I’m not sure how long my MOR will be out. Do I have to let the Board know?

The Board must always know which pharmacist is currently responsible for a pharmacy and should be notified of these incidents by email.

17. Can pharmacists and technicians from other states practice in Massachusetts during the emergency period?

Yes. Technicians licensed in other states may work inside a Massachusetts pharmacy only after an application has been received and approved by the Board.

For authorization to practice in Massachusetts please submit "Application for Emergency Authorization for Out-of-State Pharmacists and Pharmacy Technicians to Practice During the COVID-19 State of Emergency" form as well as sign up for NABP Passport in your e-Profile account. If you do not have an e-Profile account please sign up through the NABP website.

See the following link for the application and details:  https://www.mass.gov/news/covid-19-order-of-the-commissioner-of-public-health-related-to-pharmacy-practice

18. Can support personnel (e.g. pharmacy technicians) work remotely?

Yes. See the following link for details: 

https://www.mass.gov/news/covid-19-order-of-the-commissioner-of-public-health-related-to-pharmacy-practice

 **Pharmacy technicians who are not licensed by Massachusetts and are working in other states may process patient-specific prescriptions for a Massachusetts licensed pharmacy as long as the prescription processing activities are reviewed and verified by a Massachusetts licensed pharmacist.

19. Is it possible to conduct a central fill process for compounded medications during this state of emergency? 

Yes. See the following link for details: 

https://www.mass.gov/news/covid-19-order-of-the-commissioner-of-public-health-related-to-pharmacy-practice

20. Is there guidance for how to handle compounding garb shortages?

Yes. See the following link for details: 

https://www.mass.gov/news/covid-19-order-of-the-commissioner-of-public-health-related-to-pharmacy-practice

21. My certification for the sterile compounding facility has expired and I am unable to get a certifier at this time. Can I still compound sterile preparations?

During the emergency period, the Board of Pharmacy does not intend to take any enforcement action against sterile compounding pharmacies for expired certifications provided that environmental monitoring for air and surface has been performed within the previous 30 days and results are within USP action levels.

22. Can pharmacies compound hand sanitizer?

Yes. See requirements here:

https://www.mass.gov/news/covid-19-hand-sanitizer-guidance

23. Can I compound products that are essentially copies of commercially available products in the event of shortages of the commercially available products?

In accordance with Board Policy 2020-02 (https://www.mass.gov/doc/policy-2020-02-compounding-of-commercially-available-drugs/download), the compounding of products that are essentially copies of commercially available products may not occur unless:

• a compound would meet the unique medical need of an individual patient by producing a significant difference between the compounded drug preparation and a comparable commercially available drug; or

• there is a shortage of the commercially available product, as determined by the FDA.

If these conditions do not exist, during the emergency period a pharmacy may compound a product that is essentially a copy of a commercially available product only if it can document that it has attempted and failed to obtain the commercially available product.

Additional resources:

CDC:

https://www.cdc.gov/coronavirus/2019-ncov/cases-in-us.html

Massachusetts DPH:

https://www.mass.gov/resource/information-on-the-outbreak-of-coronavirus-disease-2019-covid-19

MassHealth:

https://www.mass.gov/doc/pharmacy-facts-141-march-12-2020-0/download

https://www.mass.gov/files/documents/2020/03/25/pharmacy-facts-143.pdf

DEA:

https://www.deadiversion.usdoj.gov/coronavirus.html

FDA:

https://www.fda.gov/emergency-preparedness-and-response/mcm-issues/coronavirus-disease-2019-covid-19

WHO:

https://www.who.int/health-topics/coronavirus#tab=tab_1

NABP:

https://nabp.pharmacy/coronavirus-updates/

APhA:

https://www.pharmacist.com/coronavirus

ASHP:

https://www.ashp.org/Pharmacy-Practice/Resource-Centers/Coronavirus

Please direct any questions and communications to: Pharmacy.Admin@MassMail.State.MA.US

 

 

Coronavirus Disease 2019 (COVID-19) Frequently Asked Questions

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