Virginia Regulatory Town Hall
Department of Health Professions
Board of Pharmacy
Regulations Governing the Practice of Pharmacy [18 VAC 110 ‑ 20]
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4/15/09  4:51 am
Commenter: Brad Ferguson, CPhT Henrico Doctors' Hospital Forest Campus

Nursing signatures for narcotic delivery to automated dispensing systems

I absolutely agree with the proposed change that has been submitted regarding the requirement of a nurse's signature upon delivery of a narcotic by pharmacy staff. It is unnecessary to pull a nurse away from patient care in order to verify the count of narcotics that are being stocked into an automated dispensing system such as Pyxis or Acudose.

As previously stated by other participants of this petition, the signature of a nurse does not necessarily prove that the narcotics that were accounted for by that nurse made it to the dispensing mechanism. The pharmacy technician or pharmacist could theoretically get the signature from a nurse stating that the correct amount of drug was present, only to either mistakenly or purposely stock the machine incorrectly or not at all. Should a discrepancy arise, the only thing this requirement would do is complicate the situation by involving more employees in the problem. Also as before mentioned, if this does happen, the reports that are printed automatically for these systems will provide all pertinent information necessary to investigate the situation. The users who have previously accessed the drug in the dispensing unit will be the points of interest anyway, not the nurse who signed off on the dispensing sheet.

I know from personal experience that this additional step of acquiring a nurse's signature before restocking an Acudose or Pyxis machine is nothing more than an inconvenience to the nurses and potentially to the patients. With the nursing shortage that is at hand, I believe that many would agree that this is not a necessary state law, especially when the nursing staff is already stretched far too thin. 

I have had many nurses posing the question to me, "Why do we have to sign off on these narcotics. You will be the last one with the drug. How do I know that you are going to put the right amount in the machine?" And I always agree with them. The only answer I can provide to them is that it is a Virginia state law. I don't think that answer is sufficient. This law does not make sense because it only delegates potentially great liability unto others unjustly. It does not seem to be beneficial in any way. I do not know of any situation in which the signature of a nurse for a narcotic being delivered to an automated dispensing machine has ever been used to determine the findings of a narcotic discrepancy. Yes, records for those signing out and delivering narcotics need to be maintained , but there is no need for records of a completely unassociated party when automation reports are more than sufficient.

This would be a great amendment if passed. I think it would be very beneficial to the healthcare professionals for whom this law affects, and more importantly, our patients. Thank you for presenting this issue for us to comment on. This is a great tool for resolving problems such as this that affect the healthcare community.

CommentID: 6959