Policy Statement  Use of Pharmacy Technician Trainees to Stock Automated Dispensing Devices

Date:	06/01/2023
Organization:	Drug Control Program Board of Registration in Pharmacy
Referenced Sources:	Policy 2023-08: Pharmacy Technician Stocking of Automated Dispensing Devices (ADD)

Joint Policy of the Board of Registration in Pharmacy, Drug Control Program, Bureau of Healthcare Safety and Quality

Joint Policy

1. Purpose and Scope

The Massachusetts Board of Registration in Pharmacy (“Board”), Drug Control Program (“DCP”), and Bureau of Healthcare Safety and Quality (“BHCSQ”) have established this policy permitting Board-licensed pharmacy technicians to perform certain medication inventory / stocking functions related to Automated Dispensing Devices (“ADD”).

2. General Requirements
   1. The activities permitted by this policy may only occur within Massachusetts-licensed health care facilities (e.g., hospitals) that:
      1. have on-site pharmacies; and
      2. have the ADDs located at the same physical address as listed on the facility’s Massachusetts Controlled Substances Registration (“MCSR”).
   2. The pharmacy must determine if any approvals or other notices are required by the licensing authority of the health care facility (e.g., BHCSQ, etc.).
   3. The pharmacy must have policies and procedures in place with respect to the permitted activities specified in this policy, including training requirements.
   4. The general ADD requirements as outlined in Policy 2019-02: Automated Dispensing Device Use must be followed.
   5. A licensed health care professional must use an electronic device with bar code scanning or other electronic validation for product verification upon removal from an ADD and / or upon patient administration.
   6. For quality assurance purposes, a designated Board-licensed individual must:
   7. verify all ADD transactions to account for the inventory that was sent from the pharmacy or expected to be received by the pharmacy (e.g., expired medications); 
   8. monitor all ADD access;
   9. track and trend data for accuracy and compliance; and
   10. random audits must be conducted at various points in the inventory / stocking process. For instance, audits of the ADD’s physical contents.
3. Without direct pharmacist supervision, a pharmacy technician trainee (“PTT”) may:
   1. transport and load pharmacist-verified Schedule III through VI stock medications into an ADD that is located in a patient care area using barcode scanning or other electronic validation; and
   2. verify expiration dates and remove expired Schedule III through VI stock medications (using barcode scanning or other electronic validation) from an ADD that is located in a patient care area.

Note: Although the above activities may be performed without direct pharmacist supervision, any activities performed by PTTs must be under the direction and supervision of a pharmacist.

4. Under pharmacist supervision, all licensed pharmacy technicians (EXCEPT PTTs) may:
   1. transport and load pharmacist-verified Schedule II through VI stock medications into an ADD that is located in a patient care area using barcode scanning or other electronic validation; and
   2. verify expiration dates and remove expired Schedule II through VI stock medications (using barcode scanning or other electronic validation) from an ADD that is located in a patient care area.
5. Without prior verification by a pharmacist, a licensed technician that is nationally certified (i.e., CPhT) may:
   1. remove non-patient specific Schedule VI medications (excluding PMP drugs such as gabapentin) from an electronic inventory management system using barcode scanning or other electronic validation without further manipulation (e.g., manufacturer's sealed, original packaging, etc.); and
   2. transfer and load these medications into an ADD in a patient care area using barcode scanning or other electronic validation.

Please direct any questions to: [e-mail]