Over View on the Over View on the implementation of implementation of Repackaging Training.Repackaging Training.

By: Jennifer Phelps, LPN/QMHPBy: Jennifer Phelps, LPN/QMHP

Central Virginia Community Central Virginia Community ServicesServices

Review ObjectivesReview Objectives

• BOP GuidelinesBOP Guidelines• Re-Packaging LogRe-Packaging Log• Labeling of pillboxesLabeling of pillboxes• Location where re-packaging can be Location where re-packaging can be

donedone• Facilitate DiscussionFacilitate Discussion

Who has started the Who has started the Repackaging process?Repackaging process?

How many CSB’s or BHA’s How many CSB’s or BHA’s have implemented this have implemented this process?process?

BOP GuidelinesBOP Guidelines

• Repackaging to assist the client to self Repackaging to assist the client to self administer drugs.administer drugs.

• The program is NOT intended to teach or The program is NOT intended to teach or authorize an individual to administer authorize an individual to administer medication.medication.

• Assisting with self-administration is Assisting with self-administration is different from administering the drug to different from administering the drug to the client.the client.

BOP GuidelinesBOP Guidelines

• Delivery ProcessDelivery Process• ““Deliver” – Handing or delivering the Deliver” – Handing or delivering the

already – dispensed medication to the already – dispensed medication to the patient or patient;s agent. Delivery may patient or patient;s agent. Delivery may be delegated by the person dispensing be delegated by the person dispensing to other staff, including un-licensed to other staff, including un-licensed staff. Completion of the Medication staff. Completion of the Medication Administration training approved by the Administration training approved by the Board of Nursing is NOT required for Board of Nursing is NOT required for staff who deliver medications.staff who deliver medications.

Guidance on this point Guidance on this point includes:includes:

• Generally, taking pills out of the Generally, taking pills out of the consumer’s bottle or blister pack consumer’s bottle or blister pack and handing them to the consumer and handing them to the consumer for on-the-spot ingestion is for on-the-spot ingestion is considered “administration” and is considered “administration” and is NOT permitted.NOT permitted.

Guidance on this point Guidance on this point includes:includes:

• Handing the bottle or blister pack to the Handing the bottle or blister pack to the consumer, instructing or verbally consumer, instructing or verbally prompting the consumer to take (I.e. prompting the consumer to take (I.e. self-administer) the medication, self-administer) the medication, coaching the consumer through the coaching the consumer through the steps to ensure compliance, and closely steps to ensure compliance, and closely observing the consumer self-administer observing the consumer self-administer the medication all fall short of the medication all fall short of “administer” and are therefore “administer” and are therefore permitted.permitted.

Guidance on this point Guidance on this point includes:includes:

• Reading / reviewing written Reading / reviewing written materials about medication effects materials about medication effects and side effects, or asking and side effects, or asking questions to monitor possible side questions to monitor possible side effects, are also NOT considered effects, are also NOT considered “administration”, hence are “administration”, hence are permitted. From permitted. From Guidance for Guidance for Community Service BoardsCommunity Service Boards

Repackaging of MedicationRepackaging of Medication

• Repackaging ProcessRepackaging Process• Repackaging involves taking a Repackaging involves taking a

previously dispensed medication previously dispensed medication and transferring it to another and transferring it to another container while maintaining container while maintaining specific items in the labeling of the specific items in the labeling of the new container.new container.

The following must be The following must be labeled on the container.labeled on the container.

• The client’s first and last nameThe client’s first and last name• The name and 24 – hour contact The name and 24 – hour contact

information for the CSB or BHA.information for the CSB or BHA.

• Ex: Jane DoeEx: Jane Doe• CVCSB –555-555-1212CVCSB –555-555-1212

Repackaging of MedicationRepackaging of Medication

• Repackaging ProcessRepackaging Process• Because dispensed drugs are packaged Because dispensed drugs are packaged

in blister packages, vials, or unit dose in blister packages, vials, or unit dose containers labeled with drug name, drug containers labeled with drug name, drug dose, frequency and client’s name, dose, frequency and client’s name, moving the medication from one moving the medication from one container to another is considered container to another is considered repackaging and not dispensing.repackaging and not dispensing.

Repackaging ProcessRepackaging Process

• Medication can be repackaged in a Medication can be repackaged in a CSB or BHA program by individuals CSB or BHA program by individuals who have passed an approved who have passed an approved medication repackaging training medication repackaging training program. program.

Repackaging Repackaging RequirementsRequirements

• The repackaging of a dispensed prescription drug The repackaging of a dispensed prescription drug order pursuant to § 54.1-3420.2 shall only be done order pursuant to § 54.1-3420.2 shall only be done at a CSB or BHA. at a CSB or BHA.

• Repackaging should be under good lighting and Repackaging should be under good lighting and the use magnifying lenses and or keep the the use magnifying lenses and or keep the medication bottles at eye level to improve the medication bottles at eye level to improve the likelihood of proper interpretation of look-alike likelihood of proper interpretation of look-alike medication names. medication names.

RecordkeepingRecordkeeping

• A record of repackaging shall be made and A record of repackaging shall be made and maintained for one year from the date of maintained for one year from the date of repackaging and shall include the following:repackaging and shall include the following:

• a. Date of repackaging;a. Date of repackaging;

• b. Name of client;b. Name of client;

• c. Prescription number of the originally c. Prescription number of the originally dispensed prescription drug order;dispensed prescription drug order;

RecordkeepingRecordkeeping

• d. Pharmacy name;d. Pharmacy name;

• e. Drug name and strength;e. Drug name and strength;

• f. Quantity of drug repackaged; andf. Quantity of drug repackaged; and

• g. Initials of the person performing the g. Initials of the person performing the repackaging and verifying the accuracy of repackaging and verifying the accuracy of the repackaged drug container.the repackaged drug container.

RecordkeepingRecordkeeping

• Any time a repackaged drug is initially Any time a repackaged drug is initially given to a client, and upon any subsequent given to a client, and upon any subsequent change in medication order, the client shall change in medication order, the client shall be provided written information about the be provided written information about the name and strength of the medication and the name and strength of the medication and the direction for use. Such written information direction for use. Such written information shall have been prepared by a pharmacy or shall have been prepared by a pharmacy or by a nurse at the CSB or BHA. by a nurse at the CSB or BHA.

Repackaging LogRepackaging LogDateDate Client Client

NameNamePharmacyPharmacy Rx Rx

NumberNumberDrug Drug Name and Name and StrengthStrength

Qty.Qty. Staff Staff InitialsInitials

Client Client

InitialsInitials

Received Received

Repackaging Repackaging RequirementsRequirements

• The repackaging of dispensed prescription drugs The repackaging of dispensed prescription drugs shall be restricted to solid oral dosage forms and a shall be restricted to solid oral dosage forms and a maximum of a 14-day supply of drugs. maximum of a 14-day supply of drugs.

• The drug container used for repackaging pursuant The drug container used for repackaging pursuant to this section shall bear a label containing the to this section shall bear a label containing the client’s first and last name, and name and 24-hour client’s first and last name, and name and 24-hour contact information for the CSB or BHA. contact information for the CSB or BHA.

  

Repackaging Repackaging RequirementsRequirements

• A clean, well-closed container that assists A clean, well-closed container that assists the client with self-administration shall be the client with self-administration shall be used when multiple doses of a repackaged used when multiple doses of a repackaged drug are provided to the client at one time.  drug are provided to the client at one time.  Medication pill boxes must be wiped with Medication pill boxes must be wiped with alcohol pads when reusing containers. See alcohol pads when reusing containers. See “Infection Control”“Infection Control”

Retention and storageRetention and storage

• Any portion of a client’s prescription drug order Any portion of a client’s prescription drug order not placed into a container intended to assist with not placed into a container intended to assist with self-administration may be either given to the self-administration may be either given to the client or retained by the CSB or BHA for client or retained by the CSB or BHA for subsequent repackaging. If retained by the CSB or subsequent repackaging. If retained by the CSB or BHA, the remaining portion shall be stored within BHA, the remaining portion shall be stored within the board-approved drug storage location in the the board-approved drug storage location in the original labeled container, and shall only be used original labeled container, and shall only be used for the client for whom the drug was originally for the client for whom the drug was originally dispensed.dispensed.

Retention and storageRetention and storage

• Any portion of a prescription drug order remaining at the Any portion of a prescription drug order remaining at the CSB or BHA that has exceeded any labeled expiration date CSB or BHA that has exceeded any labeled expiration date or one year from the original pharmacy dispensing date on or one year from the original pharmacy dispensing date on the label shall be separated from unexpired drugs, stored the label shall be separated from unexpired drugs, stored within a designated area of the board-approved drug within a designated area of the board-approved drug storage location, and destroyed within 30 days of expiration storage location, and destroyed within 30 days of expiration with the written agreement of the client.  Remaining with the written agreement of the client.  Remaining portions of discontinued prescription drug orders retained portions of discontinued prescription drug orders retained by the CSB or BHA shall also be separated from active by the CSB or BHA shall also be separated from active stock and either returned to the client or destroyed within stock and either returned to the client or destroyed within 30 days of discontinuance with the written agreement of the 30 days of discontinuance with the written agreement of the client.client.

DisclaimerDisclaimer

• All of the information presented today All of the information presented today can be found in the can be found in the Medication Medication Repackaging GuidanceRepackaging Guidance Document given Document given out by the Virginia Association of out by the Virginia Association of Community Services Boards.Community Services Boards.

• This is This is NOTNOT a Training on Repackaging a Training on Repackaging but an overview on how our program but an overview on how our program implemented this process. implemented this process.

Positive Points from this….Positive Points from this….

• Our clients have taken a more active Our clients have taken a more active role in self-administering their role in self-administering their medications.medications.

• Clients have commented they feel more Clients have commented they feel more pride in taking ownership in being more pride in taking ownership in being more responsible for their medications.responsible for their medications.

• We have more clients than ever now We have more clients than ever now handling their medications and filling handling their medications and filling their weekly pillboxes.their weekly pillboxes.

Negative points…Negative points…

• Not all clients have adapted to the system.Not all clients have adapted to the system.• Keeping pill boxes labeled properly is an on-Keeping pill boxes labeled properly is an on-

going issue.going issue.• Clients normally do not have money for a Clients normally do not have money for a

pillbox, and have lost a few of them.pillbox, and have lost a few of them.• Not having meds when needed for filling the Not having meds when needed for filling the

pillbox d/t nurses not having more direct pillbox d/t nurses not having more direct involvement in the re-order process. involvement in the re-order process.

DiscussionDiscussion

• Joyce let me tell Joyce let me tell you what they you what they have us doing have us doing NOW!NOW!

• (insert comic (insert comic relief!)relief!)

Resources used for this Resources used for this presentation.presentation.

More information can be More information can be found on the Virginia Board of found on the Virginia Board of Pharmacy Website, at Pharmacy Website, at http://www.dhp.state.va.us/phhttp://www.dhp.state.va.us/pharmacy/.armacy/.