John Lowe Associate Chief Consultant PBM Why Are We Here? Slide
2 Objectives Discuss findings of internal and external reviews
Review VAs response and action plan to reviews Provide training to
staff and supervisors on the front line Establish network of
co-workers Slide 3 Internal and External Reviews Office of
Inspector General Combined Assessment Program (OIG CAP) Government
Accountability Office (GAO) Joint Commission (JC) System-wide
Ongoing Assessment & Review Strategy (SOARS) Drug Enforcement
Agency (DEA) Slide 4 Reviews of Pharmacy Inventory OIG Audit of
Pharmacy Inventory 2000 OIG Audit OF VA CMOP Inventory Management
2002 GAO Review of Pharmacy Inventory 2004 OIG Audit of VA CMOP
Inventory Accountability 2009 OIG Audit of VHAs Management of Non-
Controlled Drugs 2009 Slide 5 OIG Audit of Pharmacy Inventory 2000
Findings (from sample of 4 facilities): Inventories reduced
compared to previous system under supply depot system Inventories
at all 4 centers exceeded 10 day supply None of the facilities had
determined stock levels or reorder points based on use None of the
facilities conducted physical inventories End of year purchases
contributed to excess stock Slide 6 OIG Audit of Pharmacy Inventory
2000 Recommendations VHA issue guidance for inventory reduction VHA
monitor progress in reducing inventories Provide staff training for
inventory management Discourage using end of year funds for large
purchases of stock Slide 7 OIG Audit of VA CMOP Inventory
Management 2002 Findings Supply on hand exceeded benchmarks for
59.9% of items in inventory CMOP did not effectively monitor stock
levels or management item demand Maintained cushions of excess
stock Inventory included items with little or no demand Estimated
$28.8 million in excess inventory Slide 8 OIG Audit of VA CMOP
Inventory Management 2002 Recommendations Require CMOPs to
eliminate excess inventory and use automated information to manage
inventory Improve CMOP automated inventory management and control
reports Develop minimum demand for adding new items Train CMOP
staff on inventory management techniques and use of automation
Slide 9 OIG Audit of VA CMOP Inventory Management 2002
Recommendations Ensure CMOPs implement internal controls and
security requirements for controlled substances Monitor CMOP
progress in reducing inventories and improving inventory control
Slide 10 GAO Review of Pharmacy Inventory 2004 Focused on drugs for
return Findings (6 medical centers): 5 of 6 did not inventory drugs
for return No analytical review of credits Returned drugs stored in
unsecured open bins in 4 of 6 facilities VA uses an honor system,
relying on contractors VA not aware of company requirements
regarding returns (exp dates, etc) Pharmacy staff claimed not cost
effective to monitor (without data to support claim) Slide 11 GAO
Review of Pharmacy Inventory 2004 VA Response to GAO Facilities
will maintain a list of drugs held for credit (VISTA Patch
PSA*3*51) Non-controlled drugs for return will be secured
Facilities will periodically test to see if credits received is
correct Network PBM will monitor facility returns Data will be
analyzed for trends National directive will be published Slide 12
OIG Audit of VA CMOP Inventory Accountability 2009 Findings:
Inadequate wall to wall inventories Inadequate tracking of
dispensing by software Significant differences between actual and
projected on hand inventory Inadequate control of inventory balance
adjustments Lack of control for drugs held for return Inadequate
separation of duties over critical system functions Inadequate
Econolink system access controls (everyone used same password)
Slide 13 OIG Audit of VA CMOP Inventory Accountability 2009 VHA
Response Wall to wall inventories completed quarterly Each CMOP
Director certified compliance with policy for returned drugs
Developed a statement of work to rewrite software to ensure
complete tracking of inventory Developed management policy to
review inventory adjustments monthly Established procedures to
restrict one person from ordering, receiving and adjusting
inventory Generic password for Econolink was disabled Slide 14 OIG
Audit of VHA Management of Non-Controlled Drugs 2009 Findings
(Review of 31 facilities): Drug dispensing not accurately and
consistently recorded (transfer and returns to stock) State home
dispensing Automatic replenishment/ward stock Label reprint
function used inappropriately to dispense drugs Drugs returned to
stock not accurately captured Lack of policy to monitor high risk
non-controlled drugs Wall to wall inventory data not used to
improve accountability Slide 15 OIG Audit of VHA Management of
Non-Controlled Drugs 2009 VHA Response VHA will identify high risk
drugs to monitor PBM will re-emphasize the importance of tracking
all dispensing activity and survey results PBM will remind staff
that drugs that leave pharmacy cannot be returned to stock
Inventory balances must be adjusted for drugs that dont leave
pharmacy and are returned to stock Access to label reprint will be
limited PBM will develop standardized electronic formats for
inventory and hold managers accountable for accuracy Slide 16 SOARS
Program Provide assessment and educational consultation to VA
facilities Support a continuous readiness culture Help provide
quality health services Assist medical centers with meeting
standards of care Identify and share strong practices Slide 17
SOARS Program Site visit to each facility every 3 years ~250
trained SOARS consultants Training films completed for SPD, Mental
Health and Pharmacy Strong focus on pharmacy and medication
management Slide 18 SOARS Trends Report Inventory Related Findings
Based on 136 reviews Identification, management and security of
high cost, look alike-sound alike, high risk and other sensitive
drugs (40 sites, 29%) Pre-labeling, accurate labeling, segregation
and security of drugs throughout organization (63 sites, 45%)
Management of controlled substance inventories (13 sites, 9%) Slide
19 Annual Inventory Results YEARInventory Turns 201011.97 20099.15
20089.99 200710.8 200611.07 Slide 20 In Summary Inventory
management opportunities cited in numerous internal and external
reviews Reviews identified a lack of training for staff involved in
inventory management and drug accountability Need to improve
management of dollars involved in inventory as a tax payer funded
organization Reduce opportunity for theft and diversion Improve
services to veterans Slide 21 Questions Slide 22 Welcome! PBM Drug
Accountability Conference
