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Kaiser discipline and Guild members

The Guild is informing all members of the harsh disciplinary Kaiser is currently administering, especially for Drug Furnishing Incidents (DFIs). This is contrary to past practice, and we believe it is excessive and inappropriate. The Guild has requested a meeting with Kaiser to address this change, but the Employer has refused to meet with the Guild to address this issue. The Guild has an obligation to its members and advises each pharmacist, independent of your classification, length of employment or employment status, to double check individual work as it relates to ALL aspects of daily tasks performed. A pharmacist who has 1 or 2 DFIs in one year may be terminated depending on the severity of the DFIs. Recently, the Employer has gone as far as administering a suspension for a "Near Miss" event. (Note that the Guild is challenging this).

It is vital that each of you complete one task at a time to avoid increasing your chance of making mistakes. The Guild advises against the following common practices listed below as some have resulted in DFIs and/or disciplinary cases in the past year. The Guild is presenting Outpatient issues listed below as examples. However, this same concept in accurately performing your work applies to ALL Inpatient and AmCare Guild members.

For example, the Guild advises against entering biometrics prior to checking the FULL content of all bottles or packages for accuracy at Product Verification (PV). Be sure to check for correct quantity, correct imprint, mixed tablets, sensible directions, etc. For example if ONE wrong tablet is commingled in a vial of 300 tablets, Employer may attempt to administer discipline to address this situation as a DFI. You may opt to pour out the full contents (not just some tablets in the cap of the vial in your hand) of the amber vial to look for tablet uniformity. Similarly, the wrong quantity (especially for any Controlled substances) is also considered a DFI. Ensure that the product you are verifying is 100% correct prior to allowing product to hit Will Call status to minimize the pressure of meeting metrics.

The Guild advises against participating in any Visual Checks. Visual checks usually occur as a result of the 3 common following scenarios listed.

  1. It can occur when front line staff cannot locate a medication in Will Call status to sell to a patient and another user will just re-print the label to place on the bottle. The pharmacist who is visually checking the “lost” medication is usually not the same pharmacist who initially entered his/her biometrics at PV previously.

  2. Another example of a visual check is when an insufficient quantity is discovered after the pharmacist enters biometrics at PV. A User at Fill will then add in the remaining tablets in the vial. The additional tablets added may contain different strengths of the same medicine or a different medicine altogether.

  3. The third example is when some pharmacies choose not to affix the label directly onto Special Order medicines. Pharmacy will wait for the patient to arrive and then have staff label and count medicine that is already in Will Call status. The intent of this practice is to allow pharmacy to return the Special Order product back to Bergen for credit if patient does not pick up. The second pharmacist will visually verify or “Eyeball” that the medicine is labeled correctly.

All these situations put both first and second pharmacists in a precarious position if the second pharmacist did not perform the visual check correctly. Accountability is lacking for the second pharmacist and the risk for DFI rests solely on the first pharmacist whose biometric was initially entered. Some DFIs are not discovered until many months after the prescription is sold.

The Guild advises against pre-documenting or pre-signing any forms such as invoices, End of page audit for Controlled Substances, Compounds, Controlled substance entries in perpetual log sheets, etc., with the intent of reviewing it later. When physically placing Controlled Substances into the inventory upon daily delivery, it must be performed in an uninterrupted manner per regional policy. As for verifying compounded medicines, ensure the correct ingredients are used, has correct expiration date, contains all required auxiliary labels, etc. For End of page Controlled Substance audit, hand count all partial bottles. We advise you to follow regional policy by immediately affixing an entry into perpetual log sheets upon dispensing Schedule II Controlled Substances and verifying back count prior to placing biometrics at PV. Any back count discrepancy warrants immediate remediation. If the discrepancy cannot be resolved, notify your supervisor as soon as practicable.

Given the current workload coupled with the pressure to meet metrics, it is in your best interest to ensure that each task you perform is 100% correct, even if it means having to double or triple check yourself. These tasks include but are not limited to Order Entry, Data Entry, Data Verification, Fill, Product verification, Consultation, Documentation of Controlled Substance audits, proper Documentation of all work as required, accurate Coupling of meds especially CII substances, and the uninterrupted process of Controlled substances Check In process. Accuracy is paramount.

Attached is the Letter of Agreement between NCAL KP and Guild for Professional Pharmacists for the conversion of Legacy PIMS to ePIMS. This agreement specifically states “It is not the intent of the Employer to initiate discipline against Guild members based on ePIMS biometrics (DV, PV, other ePIMS tasks...)." If the Employer wants to meet with you regarding ePIMS biometrics, please let the Guild know and have a Guild representative present at the meeting. This includes all staff and lead pharmacists. Remember, you have the right to Guild representation before any hearing, meeting, or discussion with management related to your work performance if it is not your annual evaluation. Please ask in advance if this meeting is related to allegations about your performance, which will or could lead to discipline, and assert your right to representation.

The Guild for Professional Pharmacists is in disagreement with the Employer's current disciplinary practice regarding DFIs, Controlled Substance inventory logging and auditing errors, and all other errors which occur as part of the overall pharmacy workflow. The message above is not any sort of admission that what the Employer is currently doing is acceptable, rather it is a warning that while we challenge the Employer’s actions, you should be extra vigilant. The Guild is actively representing Guild members against Employer discipline for allegations against Guild members through the Grievance process.

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