The Most Important Audit in Pharmacy

What is the most important Audit in Pharmacy?

Our ManageRx team thinks the single most important audit is the Controlled Substance Invoice Audit.

In fact, we think that if you are not conducting an audit like this, we would argue that you are neglecting your responsibilities.

Why?

Why is the Controlled Substance Invoice Audit so important?  It is critical to stop drug diversion in your pharmacy, surgery center, or any location using controlled drugs.  One of the most common problems we encounter when we are called in to manage a problem pharmacy is internal controlled substance theft. There are two places where controlled substance inventory is most vulnerable.  The first, and today’s topic, is at the point of receipt from the supplier. In many instances, a supplier will ship multiple drug totes, and the controlled drugs are almost always separate from the regular stock.  Further, the controlled substances may be spread across multiple totes.  What can happen is that a controlled drug can end up alone in a tote and be the sole item on an invoice.

In so many understaffed pharmacies, it is easy for the ‘bad guy’ to immediately unpack the controlled substance, slip it away into a coat pocket, backpack, etc. before anyone notes it arrived.  What makes this difficult to detect is the theft of the medication AND the invoice.  In most pharmacies, the controlled drugs will be unpacked, matched with the invoice, and handed to the pharmacist for review and signature.  

Consequences

I am a strong believer that the ‘bad guys’ are fully responsible for their dishonest and unlawful ways. But there are people in law enforcement, such as the DEA in this situation, who like to make sure that registrants are responsible and take reasonable precautions against the real bad guys who are the thieves. Therefore, be aware that there can be significant financial penalties assessed to the registrant who are the victims of theft. In one such case, the fine was nearly $20,000 per occurrence for a theft occurring nearly daily for well over a year. Yes, that is a multi-million dollar fine.

Actions

To combat this type of theft, there are some basic policies that should be followed:

·         Separate staff should order the drugs than those responsible for receiving them.

·         Receiving practices should be evaluated for where they happen.  While they are not the most exciting aspect of practice, having an area that is not isolated from the rest of the team for receiving is a plus.

·         Record the invoice number and date for your most likely abused medications in your perpetual inventory system if one is being used.

·         As per law, sign, and date all the controlled substance invoices and file them by month.

·         At the end of a month, compare all of the signed invoices from your files to the list of invoices from your wholesaler’s system. Most wholesalers will send a hard copy of the controlled substances purchased in the previous month, specifically to address this type of problem.

o   If this report never comes to the Pharmacist in Charge, it could be another indication of a problem, or perhaps you should check with the wholesaler.

o   If the report is not available, most wholesalers now have on-line accounts with invoice listings and even bill paying. An audit of those invoices should be a good alternative.

The good news is that this procedure is very simple and effective as a part of your controlled substance accountability procedures.

 is the Pharmacy Management program from Indispensable Health.  We help organizations facing pharmacy issues.