A PLAN FOR PHARMACIST-MANAGERS TO FOLLOW IN
CASE OF A NATURAL DISASTER
Michael Jackson, BPharm, Executive Vice President and CEO
One of the worst storms to hit the Gulf Coast was hurricane Katrina which devastated the New Orleans area including many communities in and around the southern states. Florida was the recipient of displaced citizens from affected areas. That disaster caused many to reflect on Hurricane Andrew that ravaged through South Florida in August of 1992. We can never predict when the next disaster will be upon us whether it be an act of God or man made. In any case pharmacies and pharmacy providers have to take on the role of first responders and demonstrate the provider status roles that we have been preaching about over the years. The best way to get through a disaster is to have a comprehensive plan in place “BEFORE” the disaster strikes. That plan should be rehearsed and tested frequently to work through any glitches that may occur. Here are some tips that you may want to consider for your pharmacy and your staff.
Prepare Ahead of Time
Assemble a list of all employees with contact information including cell phone, home phone and e-mail addresses. Consider turning your list into a call tree where you contact several employees who will be charged with the responsibility of calling others within your organization. Make sure that the employee at the bottom of the call tree contacts the originator of the message so that you can evaluate whether the messaging changed in the hand off from employee to employee.
Assemble a broadcast fax or email list of local radio and television stations with their news phone number.
Assemble a broadcast fax or e-mail list of physician offices and hospitals.
Obtain from the County Manager’s office a contact at the County Emergency Management Headquarters.
Make list of contact information for wholesalers and delivery services such as UPS and FedEx.
Obtain waterproof covering material for later use.
If controlled substances are lost in a disaster the pharmacist-manager needs to contact the Regional DEA offices for Florida at the following locations:
2100 North Commerce Parkway
Weston, FL 33326
Diversion Number: (954) 306-4650
Diversion Fax: (954) 306-5351
Diversion Program Manager Fax: (954) 306-5352
Diversion Program Manager - Susan C. Langston, (954) 306-4651
GS Gayle W. Lane, (954) 306-4654
TDS ASAC Kevin L. Stanfill, (954) 660-4611
TDS GS Jeannette G. Moran, (954) 660-4654
Jurisdiction: Broward, Charlotte, Collier, Glades, Hendry, Lee, Miami-Dade, and Monroe
JACKSONVILLE DISTRICT OFFICE (reports to Tallahassee RO)
4077 Woodcock Drive, Suite 210
Jacksonville, FL 32207
Diversion Number: (904) 348-7415
Diversion Fax: (904) 348-7433
GS Steve Utt, (850) 350-7355
Jurisdiction: Baker, Clay, Duval, Flager, Nassau, Putnam, and Saint Johns
ORLANDO DISTRICT OFFICE
Heathrow Business Center
300 International Parkway, Suite 424
Heathrow, FL 32746
Diversion Number: (407) 333-7046
Diversion Fax: (407) 333-7056
GS Linda A. Stocum, (407) 333-7006
TDS ASAC Jeffrey T. Walsh, (407) 333-7096
TDS GS Jae W. Chung, (407) 333-7007
Jurisdiction: Alachua, Bradford, Brevard, Columbia, Dixie, Gilchrist, Hamilton, Lafayette, Lake, Levy, Marion, Orange, Osceola, Seminole, Sumter, Suwannee, Union, and Volusia
TALLAHASSEE RESIDENT OFFICE
1510 Commonwealth Business Drive
Tallahassee, FL 32303-3170
Diversion Number: (850) 350-7350
Diversion Fax: (850) 575-0724
GS Stephen L. Utt, (850) 350-7355
Jurisdiction: Bay, Calhoun, Escambia, Franklin, Gadsden, Gulf, Holmes, Jackson, Jefferson, Leon, Liberty, Madison, Okaloosa, Santa Rosa, Taylor, Wakulla, Walton, and Washington
TAMPA DISTRICT OFFICE
4950 W. Kennedy Blvd, Suite 400
Tampa, FL 33609
Diversion Number: (813) 287-5160
Diversion Fax: (813) 287-4766
GS Roberta E. Goralczyk, (813) 287-4767
TDS ASAC James F. DiCaprio, (813) 287-4777
Acting TDS GS Steven Genevish, (813) 282-4462
Jurisdiction: Citrus, DeSoto, Hardee, Hernando, Hillsborough, Manatee, Pasco, Pinellas, Polk, and Sarasota
WEST PALM BEACH RESIDENT OFFICE
444 West Railroad Avenue, Suite 500
West Palm Beach, FL 33401
Diversion Number: (561) 653-4050
Diversion Fax: (561) 832-9016
GS Heather A. McMurry, (561) 656-5809
TDS Number: (561) 656-5842
TDS Fax: (561) 656-5802
TDS ASAC John J. McKenna, (954) 489-1995
TDS GS Thomas Redpath, (561) 656-5851
Jurisdiction: Highlands, Indian River, Martin, Okeechobee, Palm Beach and St. Lucie Counties
It may be necessary to complete a loss form – DEA 106 and/or disposal form DEA 41. Pharmacies are also required to report within one business day the theft or significant loss of controlled substances to the Board of Pharmacy according to 465.022 (11) (b). The mailing address for the Board of Pharmacy is 4052 Bald Cypress Way, Bin C-04, Tallahassee, FL 32399-3258. The fax number is (850) 413-6982. It is recommended that anything sent to the Board include a confirmation of receipt.
If the pharmacy is to be closed and/or evacuated the appropriate supervisory personnel should be notified.
Anticipate power outages. In some cases a portable generator may be advisable.
Ice and coolers should be available to store refrigerated products.
Store flammable materials appropriately.
Check the Board’s website homepage at http://floridaspharmacy.gov/ or the Florida Pharmacy Association’s web site at www.pharmview.com for guidance in the case of hurricanes.
If the pharmacy computer is down prescriptions can be dispensed manually. Labels can be typed or handwritten using a waterproof pen if possible. Printed drug information may not be available but patient counseling still needs to occur.
Refill authorizations may be difficult or impossible to obtain.
Pharmacists can then utilize the Emergency Refill Statute 465.0275. That statute reads as follows:
465.0275 Emergency prescription refill.—In the event a pharmacist receives a request for a prescription refill and the pharmacist is unable to readily obtain refill authorization from the prescriber, the pharmacist may dispense a one-time emergency refill of up to a 72-hour supply of the prescribed medication, with the exception of those areas or counties included in an emergency order or proclamation of a state of emergency declared by the Governor, in which the executive order may authorize the pharmacist to dispense up to a 30-day supply, providing that:
(1) The prescription is not for a medicinal drug listed in Schedule II appearing in chapter 893.
(2) The medication is essential to the maintenance of life or to the continuation of therapy in a chronic condition.
(3) In the pharmacist’s professional judgment, the interruption of therapy might reasonably produce undesirable health consequences or may cause physical or mental discomfort.
(4) The dispensing pharmacist creates a written order containing all of the prescription information required by this chapter and chapters 499 and 893 and signs that order.
(5) The dispensing pharmacist notifies the prescriber of the emergency dispensing within a reasonable time after such dispensing.
There is also similar language authorizing refills to paid for by health plans when the governor declares a state of emergency. That statute reads as follows:
252.358 Emergency-preparedness prescription medication refills.—All health insurers, managed care organizations, and other entities that are licensed by the Office of Insurance Regulation and provide prescription medication coverage as part of a policy or contract shall waive time restrictions on prescription medication refills, which include suspension of electronic “refill too soon” edits to pharmacies, to enable insureds or subscribers to refill prescriptions in advance, if there are authorized refills remaining, and shall authorize payment to pharmacies for at least a 30-day supply of any prescription medication, regardless of the date upon which the prescription had most recently been filled by a pharmacist, when the following conditions occur:
(1) The person seeking the prescription medication refill resides in a county that:
(a) Is under a hurricane warning issued by the National Weather Service;
(b) Is declared to be under a state of emergency in an executive order issued by the Governor; or
(c) Has activated its emergency operations center and its emergency management plan.
(2) The prescription medication refill is requested within 30 days after the origination date of the conditions stated in this section or until such conditions are terminated by the issuing authority or no longer exist. The time period for the waiver of prescription medication refills may be extended in 15- or 30-day increments by emergency orders issued by the Office of Insurance Regulation.
This section does not excuse or exempt an insured or subscriber from compliance with all other terms of the policy or contract providing prescription medication coverage.
Support by institutional pharmacies during a declared state of emergency
465.019 (2) (b) “Class II institutional pharmacies” are those institutional pharmacies which employ the services of a registered pharmacist or pharmacists who, in practicing institutional pharmacy, shall provide dispensing and consulting services on the premises to patients of that institution, for use on the premises of that institution. However, an institutional pharmacy located in an area or county included in an emergency order or proclamation of a state of emergency declared by the Governor may provide dispensing and consulting services to individuals who are not patients of the institution. However, a single dose of a medicinal drug may be obtained and administered to a patient on a valid physician’s drug order under the supervision of a physician or charge nurse, consistent with good institutional practice procedures. The obtaining and administering of such single dose of a medicinal drug shall be pursuant to drug-handling procedures established by a consultant pharmacist. Medicinal drugs may be dispensed in a Class II institutional pharmacy, but only in accordance with the provisions of this section.
(4) Medicinal drugs shall be dispensed in an institutional pharmacy to outpatients only when that institution has secured a community pharmacy permit from the department. However, an individual licensed to prescribe medicinal drugs in this state may dispense up to a 24-hour supply of a medicinal drug to any patient of an emergency department of a hospital that operates a Class II institutional pharmacy, provided that the physician treating the patient in such hospital’s emergency department determines that the medicinal drug is warranted and that community pharmacy services are not readily accessible, geographically or otherwise, to the patient. Such dispensing from the emergency department must be in accordance with the procedures of the hospital. For any such patient for whom a medicinal drug is warranted for a period to exceed 24 hours, an individual licensed to prescribe such drug must dispense a 24-hour supply of such drug to the patient and must provide the patient with a prescription for such drug for use after the initial 24-hour period. The board may adopt rules necessary to carry out the provisions of this subsection.
If the pharmacy is to be closed and evacuation is warranted the pharmacist-manager should produce 2 sets of backup tapes or disks of all drug inventory and all prescription information. One set of information could be kept in a safe place and another kept off-site in the possession of the pharmacist-manager. Any media that contains confidential patient health information should be kept securely and accounted for to prevent any breech of confidential information.
Prior to evacuation, computers should be shut down and covered with waterproof material. If flooding is expected the computer should be disconnected from the terminals and moved to a safe area.
Schedule II drugs should be moved to a locked, secure place. A safe may be used but is not required. Other products such as prescription drugs should be moved, if possible, above the floor level and covered with waterproof materials.
Notify all personnel if the pharmacy is to be closed.
Notify local radio and television media if the pharmacy is to be closed. The FPA has within our legislative action center a listing of print media centers that you may use to send your messaging. Enter this link to see the available listing.
Notify local physicians and/or hospitals of pharmacy closing by broadcast fax or e-mail if necessary.
Notify the emergency management contacts for the county in your affected area. County Emergency Management Contacts can be located as this link: http://www.floridadisaster.org/fl_county_em.asp
When the pharmacy reopens notify all pharmacy personnel; physicians and hospitals; local radio and television media; emergency management and emergency management contacts for your county.
When the situation is stabilized the pharmacy personnel should be notified to take steps to restore the integrity of the pharmacy setting.
If prescriptions have been dispensed while the computer is disconnected please note that the code of federal regulations for controlled substances has policy on what needs to happen. That policy defined in CFR 1306.22 states as follows:
“In the event that a pharmacy which employs such a computerized application experiences system down-time, the pharmacy must have an auxiliary procedure which will be used for documentation of refills of Schedule III and IV controlled substance prescription orders. This auxiliary procedure must ensure that refills are authorized by the original prescription order, that the maximum number of refills has not been exceeded, and that all of the appropriate data are retained for online data entry as soon as the computer system is available for use again.”
Pharmacies may want to apply this standard to all prescriptions and not just for controlled substances.