The third chapter of the Joint Commission
on Accreditation of Healthcare Organizations'
Standards for Behavioral Health Programs
is entitled, "Medication Management
(MM)." The goal for this function is
to assure that MM systems support client
safety while improving clients' quality
of care. The standards apply to programs
that provide the full range of pharmacy
services as well as those that contract
with external pharmacies for their medications.
In such cases, only those standards that
are applicable to the medication processes
managed by the program will be surveyed
for compliance. This chapter includes the
following six areas of focus: 1) selection
and procurement of medications; 2) storage
of medications; 3) ordering and transcribing
of medications; 4) preparing and dispensing
of medications; 5) administration of medications;
and 6) monitoring of the effects of medications.
If the opioid treatment program (OTP) only
stores and dispenses medications and clients
self-administer them, then those standards
for storing, dispensing, self-administering,
and monitoring of the effects of medications
would apply. An additional focus of this
section relates to the management of high-risk
medications. Patient safety issues related
to the storage of look-alike, sound-alike
drugs and the use of high-risk abbreviations
in documentation of medication orders are
addressed.
Accreditation Requirement(s)
To conform to the MM standards, the program
must show evidence of the following:
Ongoing efforts at reducing
practice variation, errors, and misuse
in MM
Monitoring of MM processes to assure
efficiency, quality, and safety
Standardization of equipment and processes
for MM throughout
the program
Use of evidence-based practices in
the development of MM
policies
Promotion of safe MM
practices by addressing critical processes
and assuring that they are managed appropriately
throughout the program
Consistency in handling of all medications,
including sample drugs
The term "medications" includes
prescription medications, samples, over-the-counter
drugs, vitamins, nutraceuticals, and
herbal remedies. The standards in this
chapter apply to all of these categories.
OTPs are often located in facilities
that are part of a larger organization,
and utilize the pharmacy services
of the parent organization or may contract
with a community pharmacy unrelated
to the management of the program.
In
these instances, the standards that
specifically apply to the pharmacy
operations would not be applicable
to the program. However:
Contract should specify that the
pharmacy will comply with the
standards and what the performance
expectations
are for these responsibilities
Program should monitor its pharmacy
services to assure that they
are in compliance with the stated
performance
expectations
Contracted pharmacy must
be able to provide after-hour
and emergency
services when needed by the
client population
Be able to speak to your
processes for the coordination
of the OTP medication
regimen with other psychosocial,
therapeutic, or behavioral interventions.
Side effects and responses
to the levels and
dosing of opioid maintenance therapy
must
be
well documented
and individualized
for each client. You should be
able to demonstrate
how
each client is able
to participate in activities
of daily living
and have the ability to
respond to other therapeutic
interventions while
participating in the program.
Since medication-related
adverse events are the
highest occurring error
category nationally,
client safety issues related
to MM
will be a primary
focus for the survey. Make sure you collect
data on key medication-related
processes and have
conducted
a proactive risk analysis
of at least one medication
process.
Stay abreast of JCAHO's
National Patient
Safety Goals (NPSGs) related to prohibited
abbreviations.
This lists the
abbreviations
that are
not to be used
in clinical documentation. Be aware that
the list has been expanded
and may continue
to
evolve. The NPSGs are updated
and published
each July
for implementation
the following January.
Also reference the Institute for
Safe Medication
Practices (ISMP) and the U.S. Pharmacopeia
(USP) for their
lists of dangerous
abbreviations. You may wish to add
some that are not on
the current NPSG
list.
After educating
clinical staff
(including
contracted licensed independent
practitioners
[LIPs]) on
the prohibited abbreviations
on the list,
conduct "spot" audits to
assure compliance.
Give 1:1 feedback
to those who
do not comply.
Incorporate
the prohibited
abbreviations
list into
new orientation
for all clinical
staff and
contracted LIPs.
Revise
any pre-printed
medication
or therapy
order sheets
that
contain
items on the prohibited
list.
Security of methadone
and LAAM products and
storage of sound-alike,
look-alike drugs
should be
addressed
in a proactive manner.
Assure that your system
for drug
recalls is effective. The surveyor
may "test"
your
process
to see how it works. It would
be
a good idea to test it yourself
first.
