Tag Archives: certificate to prescribe

State of Ohio Board of Pharmacy Implements Infection Control Procedures in Face of Corona Virus

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Updated 3/19/2020

The State of Ohio Board of Pharmacy issued new requirements to implement safeguards to allow pharmacy professionals employed by a terminal distributor to practice pharmacy in a safe and effective manner.

The Ohio Pharmacy Board issued the following (emphasis added):

Section 4729.55 of the Revised Code requires a pharmacy to implement adequate safeguards that allow pharmacy professionals employed by a terminal distributor to practice pharmacy in a safe and effective manner. This includes implementing safeguards to protect pharmacy professionals (pharmacists, interns, technician, and support personnel) and patients during a public health emergency.

To comply with the requirements of section 4729.55 of Revised Code, the Board has determined the following steps shall be implemented by all pharmacies located in Ohio starting no later than 5 p.m. on Thursday, March 19, 2020 to ensure the practice of pharmacy can be conducted in a safe and effective manner:

  • For pharmacies open to the public, consider developing a process for older adults (60+), pregnant women, and individuals with chronic health conditions to pick up medications without waiting in line (i.e. post signs directing to drive-thru, offer curb-side delivery, mail delivery, senior hours, etc.).
  • Implement infection control procedures, especially for waiting areas, to include the following:
  • Pharmacies with workspaces that currently allow patients to get closer than the minimum recommended distance of 3 feet should post signage or utilize other methods to ensure patients who are waiting are maintained at a safe distance. NOTE: This does not apply to patients who must interact with pharmacy staff (i.e. for purposes of payment, immunizations, etc.) or pharmacies that are not open to the public.
  • Pharmacists and pharmacy interns shall no longer be permitted to administer immunizations or other injections without standard protective measures, which includes gloves and proper hand hygiene (i.e. routinely washing hands with soap and water for at least 20 seconds). Standard protective measures do not include the use of masks or gowns.
  • Pharmacists and pharmacy interns shall not administer any immunizations or other injections to patients displaying or reporting symptoms of respiratory illness, including any of the following:
    • Fever (NOTE: This does not require mandatory temperature checks);
    • Cough; or
    • Shortness of breath.
  • Pharmacy professionals who are older adults, pregnant women, or individuals with chronic health conditions shall not be prohibited from wearing appropriate PPE to operate within a pharmacy.
  • Regularly clean and disinfect counters, credit/debit card devices, waiting areas, and other spaces where public interaction occurs with an EPA-approved disinfectant. Clean at least every hour or after every 10 patients, whichever is more frequent. If cleaning and disinfecting products are in short supply, the Ohio Department of Health has developed the following guidance. Read here.
  • If available, place alcohol-based hand sanitizer next to the checkout window so people can sanitize their hands after using common items, like the pen used to sign for prescriptions or devices used to process credit/debit card transactions. REMINDER: Manual signatures from patients are not required by Board of Pharmacy rule (see Important COVID-19 Reminders section of this guidance document for more information).
  • Provide regular breaks for staff to engage in proper hand hygiene (i.e. routinely washing hands with soap and water for at least 20 seconds).
  • Monitor pharmacy staff for symptoms of respiratory illness, including any of the following:
    • Fever (NOTE: This does not require mandatory temperature checks. However, the Ohio Department of Health recommends pharmacies take staff temperatures once per shift);
    • Cough; or
    • Shortness of breath.

Staff exhibiting or reporting any of these symptoms must be sent home.

Failure to comply with the requirements set forth in this document may result in administrative discipline for the pharmacy and the pharmacy’s responsible person.

As always, if you have any questions concerning this post, contact Todd Collis or Beth Collis.

ADVANCED PRACTICE REGISTERED NURSES: New Legislation to take Effect on April 4, 2017

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On January 4, 2017, Governor Kasich signed Ohio Substitute House Bill 216 into law.

Effective April 4, 2017, there will be new licensing criteria for advanced practice registered nurses (APRNs).  A new APRN license will replace the current “Certificate  of  Authority” and “Certificate  to Prescribe”.

The APRN license will also authorize a Certified Nurse-Midwife (CNM), a Certified Nurse Practitioner (CNP), and a Certified Nurse Specialist (CNS) to prescribe.  In order to obtain the new APRN license, CNPs, CNSs, and CNMs must have either a current Certificate to Prescribe or Certificate to Prescribe Externship, or have completed a 45-hour course in advanced pharmacology within five years of the application date.

Additional information is available from the Ohio Association of Advanced Practice Nurses here: http://c.ymcdn.com/sites/www.oaapn.org/resource/resmgr/hb_216/HB_216_Signed_Revised_-_Effe.pdf

A FAQ from the Ohio Association of Advanced Practice Nurses is here: https://oaapn.site-ym.com/page/HBFAQ

As always, if you have any questions about this post or the Ohio Board of Nursing, contact one of the attorneys at the Collis Law Group LLC at 614-486-3909 or go to our website at http://www.collislaw.com for more information.

Ohio nurses: Watch when your Certificate to Prescribe Externship (CTP-E) and CTP expire!

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As a registered nurse in Ohio, it has become routine to timely submit a complete RN renewal application at the same time every two years. However, a CTP-E is issued for one year and expires one year from the date of issuance, NOT one year after you start working as a nurse. In addition, once a CTP is issued, the renewal date may be different from the date the nurse renews their license. It is imperative that you know when you need to renew your license, CTP-E and CTP.  You will not receive a letter or notification from the Nursing Board to remind you to renew your certificate to prescribe.  It is illegal to continue to prescribe on a lapsed CTP-E or CTP!

The Ohio Board of Nursing requires advanced practice nurses who have had no prior experience prescribing medications or therapeutic devices to obtain a Certificate to Prescribe-Externship (“CTP-E”).  The purpose of the externship is to create a period during which the nurse’s prescribing activities are reviewed and evaluated by a supervising professional for the purpose of ongoing improvement of the nurse’s competence, knowledge, and skill in pharmacokinetic principles and the application of these principles to the nurse’s area of practice.

In order to apply for a CTP-E, the applicant must hold a valid Ohio R.N. license as well as a current Certificate of Authority to practice as a certified nurse midwife, nurse practitioner or nurse specialist.  In addition, the applicant must have completed required coursework on advanced pharmacology.  Once all materials have been submitted and reviewed by the Board of Nursing, the CTP-E will be issued for one year.  The year begins on the date the CTP-E is issued by the Board.  It is critical to remember this date.

During this year, the advanced practice nurse is required to complete 1,500 hours of supervised prescribing (500 hours under the direct supervision of a supervising professional).  Direct supervision means that the supervising professional is on-site when the nurse is prescribing.  300 of the 500 direct supervision hours must be supervised by a physician; the remaining 200 hours may, with the collaborating physician’s permission, be supervised by an advanced practice nurse with prescriptive authority, not a CTP-E.  The remaining 1,000 hours may be indirectly supervised.  This means that a physician, in accordance with a schedule documented in the standard care arrangement, regularly and timely reviews the nurse’s prescriptions and prescribing practices.

Once the advanced practice nurse has completed the required supervision hours through the CTP-E, the supervision must be documented by the collaborating physician and submitted directly to the Board of Nursing on Form B.  PLEASE NOTE that Form B must be submitted well prior to the end of the expiration date on the CTP-E to allow the Board time to review it and issue the advanced practice nurse applicant a Certificate to Prescribe.  Even if Form B is submitted timely, it is illegal to continue to prescribe after the year for the CTP-E has expired unless the nurse has received the Certificate to Prescribe.  Advanced practice nurses may face discipline if they continue to prescribe once the CTP-E has expired if they have not been issued a Certificate to Prescribe.

A CTP-E cannot be renewed.  It can be extended for a one-time period of 2 years, if a request to extend is timely received by the Board before the CTP-E expires.

As always, if you have any questions about his post or about the Ohio Board of Nursing in general, please contact one of the attorneys at the Collis Law Group LLC at 614-486-3909 or email beth@collislaw.com.