Flex Program Request
by Shruti Patel, Pharm. D.
Ensure proper disposition of controlled substances is an essential function of the consultant pharmacist. In California, this is done with a registered pharmacist and a registered nurse with proper documentation of name, strength, and number of doses being disposed. Complex records are maintained by the medical records department to ensure proper compliance. With the COVID-19 outbreak many pharmacists are being requested to stay out of the facility. Many traditional tasks such as chart review maybe done off site with EHR review. If a facility has decided not to have a consultant pharmacist visit for medication disposition or secure storage space for the controlled substances is limited, the facility can request program flexibility by using form CDPH 5000-A (3/2020).
The facility must define how drug destruction can be done with consultant pharmacist being present virtually. California Department of Health will respond with a waiver. Medical directors, directors of nursing and consultant pharmacists should be aware of the response and expectations before proceeding with disposition.