Guidance for Prescription Security in Primary Care€¦ · prescription log sheet (Appendix 1) 6....
Transcript of Guidance for Prescription Security in Primary Care€¦ · prescription log sheet (Appendix 1) 6....
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Pharmacy and Medicines Management Team October 2017
Guidance for Prescription
Security in Primary Care
Information for General Dental Practices
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Contents
1. Introduction…………………………………………………................3
2. Prescription Security Procedures and Protocols…………………...4
3. Register of Prescriptions Forms…………………………………….. 4
4. Ordering New Prescription Forms ................................................ 5
5. Receipt of Prescription Forms ...................................................... 5
6. Issue of prescription Forms .......................................................... 5
7. Storage of Prescription Forms ……………………………………….6
8 Stolen /missing prescriptions………………………………………… 7
9. Preventing the alteration of written prescriptions……………….......8
10. Disposing of obsolete prescription forms…………………………...8
11. Audit of prescription security…………………………………………9
12. Appendix 1……………………………………………………………10
13. Appendix 2 …………………………………………………………..11
14. Appendix 3 …………………………………………………………..12
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1. Introduction
Theft and misuse of blank or legitimately completed HS21D prescriptions signed by an authorized practitioner is an area for concern as these forms can be used to obtain drugs, often controlled drugs, illegally for recreational use, unsupervised treatment of an illness or health condition, or for onward sale. Given current problems with drug misuse across Northern Ireland and potential adverse effects on the prescribing budget, it is essential that all prescribers and other staff who handle prescription forms are vigilant in adhering to procedures that reduce the risk of prescription theft and misuse. There are already a number of security measures that have been built into HS21D prescription forms to prevent theft and fraudulent use such as ultraviolet markings, coloured backgrounds and serial numbers. These are less effective if poor security measures allow theft of the forms in the first instance. The effective management of prescription forms e.g. how they are stored and accessed by authorized prescribing and non-prescribing staff is very important and there should be appropriate security policies, procedures and systems in place in each practice. This guidance has been designed to assist dental practices in developing their own procedures and systems to ensure the security of HS21D prescription forms held within the practice.
While the detail of this guidance relates to health service
prescriptions, the underlying principles should be considered as best
practice for the security of private prescriptions in primary dental care
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2. Prescription Security Procedures and Protocols
The practice should have a written protocol signed up to by all staff outlining procedures for the management of prescription security. A log should be maintained in the surgery detailing information about prescriptions ordered, received and taken for use
Nominated person(s) should be appointed to take responsibility for prescription security procedures e.g. Practice Manager (PM)
All staff should be made aware of prescription security procedures through training. A list of those staff members trained and date of training must be kept. Processes must be in place to ensure that new staff and deputies are made aware of the procedures.
Only appropriately trained staff should be allowed to generate prescriptions
Passwords should not be shared. Computer generated prescriptions can be identified by an audit trail
An annual review should be carried out to ensure appropriate systems are in place and are being adhered to.
The following issues should be considered when developing procedures for HS21D prescription forms and in the day-to-day management of prescription forms 3. Register of Prescription Forms
A register formally recording the ordering, receipt and issue of prescription forms must be kept. Serial numbers for prescriptions received and issued should be recorded. See Appendix 1
A register should include details of the following for each prescriber /cypher number:
- Date of order and name of person placing the order - Number of prescriptions ordered
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- Name of person who received and stored prescriptions and date received
- Quantity/Serial numbers of prescriptions received - Name of prescriber on the prescription - Date, quantity and serial numbers issued for use - Person who removed the pads from store
4. Ordering New Prescription Forms All NHS prescriptions should be ordered from DLRS (NI) Ltd. Order forms can be downloaded from the Business Services website www.hscbusiness.hscni.net/services/1944.htm A copy of the order form should be kept in a designated file. If a delivery is not received, DLRS (NI) Ltd should be contacted via their helpdesk (Tel: 028 92622999). 5. Receipt of Prescription Forms Deliveries should be signed for by a nominated and trained member of practice staff. As this signature is obtained electronically by the courier and there is no paper delivery note, it is imperative that a check is carried out on each pack to ensure the delivery is for the correct practice and practitioner. The person signing for the delivery should ensure the person who placed the order is informed. Entries should be made on the prescription log sheet (Appendix 1)
6. Issue of prescription forms When a new supply of prescriptions is issued for use to a prescriber, entries should be made on the appropriate section of the prescription log sheet (Appendix 1).
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Unused forms must be returned at the end of any employment period (e.g. day or week). The returned formed should be returned to secure storage and a record made in the prescription log sheet (Appendix 1). The prescription log for each pad should not be stored with unused forms/pads Deputies - only one working pad should be kept for use by deputies. When prescriptions are issued, all the details should be recorded on the locum prescription log sheet (Appendix 2) 7. Storage of Prescription Forms
Unused forms should be kept in a secure locked area to which access is kept to a minimum number of nominated people
A named person (e.g. practice manager) should be responsible for checking prescription storage and registers at regular intervals. This should include obtaining assurances from all practitioners working in the practice including deputies (locums) that unused forms in their possession are still secure.
Forms should be stored in chronological order of delivery to facilitate audit/review
It is good practice for only one working pad per practitioner to be in use at any one time
Forms should not be left visible, unattended or unsecured at any time in the practice. All forms should be kept in a locked drawer/cabinet in the practice when not in use. Prescription forms should be secured when a practitioner leaves the room regardless of the reason or length of time.
Domiciliary visits - When carrying out domiciliary visits, practitioners should only use an appropriate number of prescription forms for the visit. Serial numbers should be pre-recorded in the prescription log before departure and re-checked on arrival back at the practice.
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8. Stolen/ Missing Prescriptions Theft of prescriptions can occur with either blank and/or completed prescriptions and as such prescription security requires constant vigilance. If a stolen prescription is presented for dispensing, this is a false representation and will become a fraud investigation. If prescriptions are stolen or missing, the practice should notify:
Contact PSNI – Call local police service on 101
Contact BSO Counter Fraud and Probity Services (CFPS) – Contact via HSC Fraud Hotline 0800 096 3396 or online at https://cfps.hscni.net/report/
Contact HSCB – Relevant Assistant Business Support Manager for your area:
Belfast & South East – Denise Taylor [email protected] or Seán Woods [email protected] 028 95 363926 North – Marlene Drummond [email protected] or 02895 362823
South – Andy Gregg [email protected] or 02895 362084 West – Tom Coyle [email protected] or 02895 361052
Missing/Stolen prescriptions for Controlled Drugs must always be reported to the HSCB Accountable Officer by contacting your local medicines management office. Assume “lost” prescriptions are stolen until evidence is available to the contrary. There is an obligation on each prescriber to check if the volume of their pad is going down unexpectedly. The risk of forms being stolen or going missing can be reduced if they are taken out of store only a few at a time.
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9. Preventing the alteration of written prescriptions Prescriptions obtained in good faith by members of the public can be fraudulently altered in two ways,
the number associated with the medication to be dispensed is altered to increase the quantity or strength
extra medication is added to the prescription.
The patient may either be obtaining the medication to consume themselves or to sell onto others. In order to prevent the unauthorised addition of medication it is recommended that the unused section of the prescription form is endorsed with a large X.
10. Disposing of obsolete prescription forms In some circumstances, blank prescription forms will become obsolete and must be destroyed, for example:
The prescriber leaves or retires from the practice
Obsolete prescription forms should be destroyed according to the practice’s confidential waste policy and records kept of the destruction. A record should be kept of forms destroyed (including start and end serial numbers), date and method of destruction, signature of authorising GDP and signature of person doing the destroying.
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11. Audit of prescription security
A nominated individual (e.g. Practice Manager) should carry out a monthly reconciliation of the prescription register. An annual audit of prescription security using the HSCB Audit Tool is also recommended (Appendix 3 Dental Prescription Security Audit Tool July 2017)
Any adverse incident should be reviewed promptly by relevant members of the practice team and appropriate actions taken, including notification of other agencies as required (see section 8). A record of the adverse incident should be made and submitted to the HSCB to allow learning from incidents to be shared.
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Appendix 1 Prescription Log Sheet Prescriber ________ Cypher No. __________
Date
ordered
Ordered
by
Method
of order
Date
received
Serial numbers Stored
by
Date taken
for use
Taken by Given
to(dentist
name)
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Appendix 2 PRESCRIPTION LOG SHEET DEPUTY (LOCUM) PRESCRIPTIONS
Date
taken for
use
Taken by Given to:
(Locum
name)
Session
details
Name of
practitioner
on form
Number
of scripts
Serial
numbers
issued
Serial
numbers
returned
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APPENDIX 3
Dental Prescription Security Audit
July 17
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PRESCRIPTION SECURITY AUDIT
INTRODUCTION
Theft and misuse of blank or legitimately completed prescriptions
signed by an authorized practitioner is an area for concern as these
forms can be used to obtain drugs, often controlled drugs, illegally for
recreational use, unsupervised treatment of an illness or health
condition, or for onward sale. It is essential that all prescribers and
other staff who handle prescription forms are vigilant in adhering to
procedures that reduce the risk of prescription theft and misuse.
AIMS OF THE AUDIT
To ensure the effective secure management of prescription forms
within the dental practice.
CRITERIA
The criteria questions have been divided up in to sections addressing
various issues.
1. Procedures
Criteria Method Comments/
Examples
Does the practice have a written
protocol for the management of
prescription security?
Y/N
Is it signed up to by all staff? Y/N
Documentation
Question staff
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Is there a nominated person(s)
appointed to take responsibility for
prescription security procedures?
Y/N
Documentation
Question staff
Does regular training on prescription
security procedures occur with all staff
members?
Y/N
Question staff
Are registers recording the ordering,
receipt and use of prescription forms
kept? Y/N
Do the registers include details of the
following:
Date, method and name of person
placing the order?
Y/N
Number of prescriptions ordered?
Y/N
Quantity/Serial numbers of
prescriptions received?
Y/N
Person who received and stored?
Y/N
Name of practitioner on the
prescription Y/N
Date and quantity/serial numbers
issued for use?
Y/N
Documentation
Documentation
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Person who removed from store?
Y/N
Practitioner they will be used by?
Y/N
2. Ordering
Criteria Method Comments/
Examples
When ordering new prescription forms
are the following records kept,
The name of the person who places
the order?
Y/N
The date of the order?
Y/N
The number of prescriptions ordered?
Y/N
The name of the practitioner whose
prescription pad was ordered?
Y/N
Documentation
Are deliveries signed for by a
nominated trained member of the
practice staff? Y/N
Documentation
Question staff
Are deliveries checked against the
order to ensure it matches the original
order including the correct address for
the practice and practitioner name(s)?
Y/N
Question staff
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3. Storage
Criteria Method Comments/
Examples
Are unused forms kept in a secure
locked area to which access is kept to
a minimum number of nominated
people? Y/N
Documentation
Question staff
Do regular checks occur on
prescription storage and registers at
regular intervals?
Y/N
Question staff
Are forms left unattended or unsecured
at any time in the practice
Y/N
Question staff
4. Missing / stolen prescriptions
Criteria Method Comments/
Examples
Does the practice have a procedure for
dealing with missing prescriptions?
Y/N
Documentation
Does the practice have a procedure for
dealing with stolen prescriptions?
Y/N
Documentation
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5. Disposal of obsolete prescriptions
Criteria Method Comments/
Examples
Does the practice have a procedure for
dealing with disposing of obsolete
prescription forms?
Y/N
Documentation
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STANDARDS
100% for each criteria
METHOD
This audit should be carried out by the practice manager or clinical
governance lead for the practice. The questions should be asked in
relation to existing practice policies and procedures concerning all
aspects of dealing with prescription forms including ordering and
security.
RESULTS
When recording the results,
Yes equates to 100%
No equates to 0%
For questions that have multiple parts then each part equates to a
percentage
e.g. for the question, ‘Do the registers include the following details’:
Date, method and name of person placing the order?
Number of prescriptions ordered?
Quantity/Serial numbers of prescriptions received?
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Person who received and stored?
Name of practitioner on the prescription?
Date and quantity/serial numbers issued for use?
Person who removed from store?
Practitioner they will be used by?
Each yes / no answer is equivalent to 12.5%
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RESULTS SUMMARY SHEET
Five Audit criteria Y/N Percentage Standard
set
1.Procedures
Does the practice have a written protocol for
the management of prescription security?
Is it signed up to by all staff?
%
%
Total
%
50%
50%
Total
100%
Is there a nominated person(s) appointed to
take responsibility for prescription security
procedures?
%
100%
Does regular training on prescription security
procedures occur with all staff members?
%
100%
Are registers recording the ordering, receipt
and use of prescription forms kept?
%
100%
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Do the registers include the following details
Date, method and name of person placing
the order?
Number of prescriptions ordered?
Quantity/Serial numbers of prescriptions
received?
Person who received and stored?
Name of practitioner on the prescription?
Date and quantity/serial numbers issued for
use?
Person who removed from store?
Practitioner they will be used by?
%
%
%
%
%
%
%
%
Total
%
12.5%
12.5%
12.5%
12.5%
12.5%
12.5%
12.5%
12.5%
Total
100%
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2. Ordering
When ordering new prescription forms are
the following records kept,
The name of the person who places the
order?
The date of the order?
The number of prescriptions ordered?
The name of the practitioner whose
prescription pad was ordered?
%
%
%
%
Total
%
25%
25%
25%
25%
Total
100%
Are deliveries signed for by a nominated and
trained member of the practice staff?
%
100%
Are deliveries checked against the order to
ensure it matches the original order
including the correct address for the practice
and practitioner name(s)?
%
100%
3. Storage
Are unused forms kept in a secure locked
area to which access is kept to a minimum
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number of nominated people? % 100%
Do checks occur on prescription storage and
registers at regular intervals?
%
100%
Are forms left unattended or unsecured at
any time in the practice?
%
100%
4. Missing /stolen Prescriptions
Does the practice have a procedure for
dealing with missing prescriptions?
Does the practice have a procedure for
dealing with stolen prescriptions?
%
%
Total
%
50%
50%
Total
100%
5. Disposal of obsolete prescriptions
Does the practice have a procedure for
disposing of obsolete prescription forms?
%
100%
TOTAL
%
100%
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Grading System
>90% achieved per section. LOW RISK Current system working well.
Very minor changes / additions to existing security protocol
70%- 90% achieved per section MEDIUM RISK Standards
broadly achieved but some sections need to be reviewed
< 70% achieved per section HIGH RISK Standards not
addressed, need for complete review of section
ACTION PLAN What steps should you take to improve prescription
security?
Formulate a plan to modify the areas where current practice does not meet the standards set.
Consider how to address all missing factors.
Set a timescale for implementing change and reviewing your actions.
Agree and document what needs to be done, by whom, and by when