that are added into automated dispensing machines.  Most hospitals that have this system have an automated control tower, and reconciliation of dispensing is part of the job; this reconciliation step ensures that the correct amount gets to the correct place; if the correct amount is NOT added to the correct cabinet, the transaction stands out for the pharmacist to review. 

I am for the petition is to allow Pharmacy to restock an AcuDose with narcotics WITHOUT a nurse having to sign for them.  This practice is pulling nurses away form patient care for a poor quality measure. The practice shows little, i.e., what is the nurse truly signing?It simply shows that those narcotics numbers were present, but it does not verify the placement of them in the acudose. From a narcotic control perspective this shows nothing. 

The count is independently and blindly verified for each and every entry for narcotics into the acudose, any discrepency is addressed with a miscount. If the narcotics were not placed in correct number by pharmacy, that would be addressed at the very next entry into that medication. The computer log would display who and what count was completed when.

The process of narcotic counts is important, but the current nurse signature effort doea not validate a correct count and is using valuable time for nurses...that could be spent in patient care.

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.

As a technician who works the night shift, I know first hand how frustrating it is to have to take the time to find a nurse  and pull her/him away from patient care when staffing is a shortage to sign the controlled substance form.  I'm always asked why it must be signed ,since I'm the one stocking and a Pharmacist has already checked the amount dispensed.

I feel with the automated systems now installed and computerized reports that adequate records are available without having this extra sheet - which shows only that a nurse has signed - not the process.

Thank you for considering this change - which I feel will greatly improve the workflow.

I

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I would like to state that I would like to see the rule that states a nurse must sign a for narcotics

when being put in a automated dispensing unit disolved.  It takes away time that the nurse

can spend with patients and it takes up technician time that can be used in other ways.

Ive worked as a Pharmacy Technician in a hospital setting for years.  As a day shift and a night shift position. I agree with the comments that have been made so far that state that obtaining a nursing signature when filling narcotics into a automated dispensing systems serves no real purpose. It holds up nurses from providing patient care and prevents technicians from moving to other machines on other units that need medications as well or from returning to the pharmacy to continue other important tasks. There are numerous reports that are kept by the systems that show every transaction. These reports show far more than a RN signature.  I would love to see this step removed from the process.

I am absolutely for this petition as a technician who works the night shift solo with one pharmacist.  It is very time comsuming and combersome to track a nurse down to sign for narcotics especially when they have no idea what you are going to do with them once they sign for them.  The medication is signed out of NarcStation, which is accounting for the vault count, as well as stating where the drugs are going.  The medication, as well as the count, is then verified by a pharmacist before delivery. Once the medication reaches the floor, we have to find a nurse willing to sign for the narcotics, then the count is added to the AccuDose/Pyxis, making for easy catch of a mistake, as it would be caught with the next AccuDose or Pyxis transaction.  I feel with all the automation that we have in place, this paper trail is just a waste of paper, Pharmacy Technicians time, as well as Nurses time.  I am constantly being asked "what exactly am I signing for", with a lot of hesitation and disgruntlement.". This makes the process even longer because then I have to explain that is a state law, not a federal law, and that I absolutely agree with them that it is a waste of their time, as well as mine.

 What they are verifying is that the count is correct, but is this really necessary? Isn't all of this easily tracked by NarcStation, the pharmacist signature, as well as the AccuDose/Pyxis machine?  If there is a problem, it can always be solved with a transaction report.  Why do the nurses need  to be pulled away from their patients, when they are scarce and extremely busy,  for this?  I think this whole process should be reconsidered for everyone involved. It would greatly improve patient care, as well as allow the pharmacy technician to deliver something to the floor in a timely manner.

Thank you for considering this change.

As a Pharmacy Technician I would like to say I think  having the nurses sign for narcotics before restocking acu dose is a complete waste of time.  I have NEVER  had a nurse watch me restock. Some nurses don't even check the sheet they sign against the drugs I have, they just sign.  IF I don't get something into the acu dose, who do you think will be held responsible? The Nurse? We restock many other drugs that could be abused in some way, not just narcotics, and the nurses don't sign for them. Our Pharmacy is in the process of removing more Pharmacists from the Pharmacy to working on the floors. In short this means we will need our Techs in the Pharmacy more than ever.  Thanks for your consideration, helen

I agree that it serves no purpose to pull nursing staff away from the bedside to sign for controlled substances that are being loaded into automated dispensing cabinets. They do not witness the transaction. The transaction is documented electronically by pass-coded entry into the automated dispensing cabinets. Additionally, the Board has requirements for auditing these processes. It is wasteful of both the technician's and nurse's time to continue this practice!

As a Pharmacy Technician,  I feel that having the nurses sign for our narcotics is something that is not necessary. The nurses are busy taking care of patients, and patient care is much more important.  Our narcotics are checked by a pharmacist before we deliver and we have to deliver into our acudose. I feel there is enough paper trail and computer trail that if a narcotic is not placed it will be caught with the next acudose transaction for that drug. I feel with this change we as technicians and the nurses can be much more efficient in our jobs.

I support this change.  It serves little purpose to require the signature and takes time away from clinical care.

THERE IS ALREADY A PAPER TRAIL STARTED WHEN THE PHARMACIST PULLS FROM

THE ACUDOSE NARCOTIC CABINET. THEN THE TECHNICIAN FILLS THE NARCOTIC

IN THE CORRECT ACUDOSE ON THE NURSING UNIT. THESE ACTIONS ARE REVIEWED

EACH STEP OF THE WAY BY PAPER REPORTS PRINTED EVERY MORNING ,OR WHEN EVER

A QUESTION OR DISCREPANCY MAY ARISE.THE NURSES TAKING TIME AWAY FROM PATIENT'S

TO SIGN ANOTHER SHEET OF PAPER THAT IS NOT REALLY NEEDED IS UNFAIR TO THE

CARE SHE SHOULD GIVE HER PATIENTS.

ITS BEING VERIFIED BY THE TECHNICIAN AND THE PHARM. THAT DESPENCES IT FROM THE NARC STATION. THERE ARE NARC REPORTS PULLED DAILY TO VERIFY THE DESPENCING AND THE FILLING OF THE ACCUDOSE MACHINE SO NO I FEEL THAT THE NURSE DOESNT NEED TO SIGN FOR SOMETHING THEY ARE NOT WATCHING BEING PUT INTO THE ACCUDOSE MACHINE..

Please allow Pharmacy to restock acudose machines with narcotics without a signature from a registered nurse.  The time it takes to hunt one down and then they run from you because they don't want to sign it really annoing.  The electronic trail leaves it hard for people in the pharmacy to divert.

This step is a redundant & unnecessary step that pulls the nurses, pharmacists, & technicians away from patient care.  Also, this signature collection forces the technician to basically stand in the way if the nurse's station is busy, which further detracts from patient care.  Currently, there is a sufficient paper trail between the withdrawl of narcotics out of the vault to the individual Pyxis/Acudose machine on the floors.  And, these reports are reviewed daily already.  Why continue to add to the unnecessary pile of papers for our pharmacists to review?  The pharmacists have more pressing items, like patient care, to look at. Plus, we could be saving a lot of money by not having to buy this paper & by just eliminating this step.

I agree with the proposed rule change.  Having nurses sign for narcotics takes nurses away from there main duty which is patient care.  Their has been numerous occasions where a nurse has had to come from a patients room just to sign for the narcotics so I could put them in the accudose. 

There is still a checks and balance system that is in place to insure that diversion of narcotics will not happen.  The computers will know if you didnt put in the correct amount.  When then next person goes to take out a narcotic to give a patient the nurse will count prior and will see that there is a discrepency. 

I think that the proposed rule change would make nurses jobs better and easier as well as the pharmacy staff.

Tracy Phillips

I suppport this proposal because the drugs being restocked in accudose or pyxis have already been checked by a pharmacist and the restocking can be verified through accudose and pyxis reporting.  This would free up the nurses to spend more time on patient care and make the technicians more efficient because they would not waste time trying to track down a nurse to sign.

I beleive that nurses should not have to sign for controlled substances that are being placed in automated dispensing devices in hospitals such as acudose, because not only does it take the nurses away from there patients it also holds up the pharmacy when a technician has to wait around a unit for a signature when other units are also waiting for narcotics to be loaded into their machines. As a technician who uses the Acudose machines on a regular basis the controlled substances get checked numerous times when the order is placed into the narcotic vault, when the technician pull narcotics from the vault, then when the technician signs for them, and then again when the pharmacist checks and signs for them before being dispenced into an acudose machine. In my experience nurses are frustrated at having to be pulled away from work and often do not even check what they are signing for and on evening and night shifts it is very difficult to even find a nurse who has a free hand and is not turning a patiend or busy elsewhere. Nurses also do not whitness the medications being put into the acudose machine to even ensure proper placement although the machine only allows the proper drawer and door to open for the narcotic that has been selected earlier to be dispenced from the narcotic vault located in the pharmacy. There are already so many checks to ensure that the proper drugs are dispenced it is unnecessary to have a nurse sign especially when it slows down the process of delivering medications that are needed right away.

I do not feel it is necessary to have a nurse sign for narcotics.  All it basically says is taht the drug made it up to the floor.  It does not assure anyone that the correct count was entered into the acudose machine. 

In my opinion, it wastes the nurses's time and the pharmacy technician's time to have to track down a nurse and take them  away from patient care.

I fully support this amendment.  I feel this task is very time consuming for nurses and pharmacy technicians alike.  By taking away this mundane task our nurses have more time for patient care, which is top priority.

Not only does it pull nurses away from patients, it also takes more time for pharmacy techinicians to find a nurse to sign for the controls.  It is a hassle for both pharmacy and nurses.  The controls are regulated enough to be accounted for if there was a discrepency.

HAVING NURSES SIGN FOR NARCOTICS AFTER IS REDUNDANT WORK THAT TAKES TIME AWAY FROM THE NURSES AND THE PHARMACY PERSONEL .

i support the change to regulations that would omit the requirement of a nursing signature for narcotics which are delivered to an automated dispensing system, because the quantities dispensed and delivered are trackable thru the automated system,  Thank you

I am in favor of this change

I agree with the petition that pharmacy should be able to re-stock narcotics WITHOUT a nurses

signature. 

I am writing to support the petition to allow pharmacy to restock an AcuDose with controlled substances WITHOUT a nurse signature. The controlled substance is signed out of stock in the pharmacy, verified by a pharmacist, and loaded into the AcuDose. Checks and balances exist to ensure that what was signed from the pharmacy is loaded into AcuDose. Requiring a nurse to sign for the controlled substance does nothing more than pull the nurse away from patient care and create a delay in delivery by the pharmacy. There are also many nursing units that are closed on weekends or midnight shifts whereby obtaining a nurse signature requires shifting technician staffing to ensure nurse availability for signatures or create a delay in delivery until a nurse is scheduled to work.

The count for controlled substance is independently and blindly verified for each and every entry for controlled substances into the AcuDose, any discrepancy is addressed within the shift. Audit trails exists for all AcuDose transactions. AcuDose access is limited to authorized users with confidential and unique user id and passwords. 

The control of scheduled medications is important but the current requirement for nurse signatures does not validate a correct count and is spending valuable time for nurses that should be spent in patient care.   

This amendment would allow technicians to deliver narcotics to the ER, ICU, etc in a timely manner and not have to pull nurses away from caring for their patients.  Technicians are a key role in the pharmacy and having them return to the pharmacy in a timely manner instead of trying to search down a nurse to check their narcotics would allow them to come back and assist the pharmacist(s).  This would be benificial to all!  The narcotics are double check by a pharmacist before leaving the pharmacy and the acudose machines also have reports to assure the proper amount of narcotics were loaded.