Virginia Board of Pharmacy Discusses Frequently Cited Deficiencies During Routine Pharmacy Inspections

Frequently Cited Deficiencies During
Routine Pharmacy Inspections
The deficiencies referenced below may be reviewed in
Guidance Document 110-9, available at www.dhp.virginia
.gov/pharmacy/pharmacy_guidelines.htm.
Perpetual Inventory (Major Deficiency 15): Failure
to maintain the perpetual inventory as required is the most
frequently cited deficiency. Board Regulation 18VAC110-
20-240 states each pharmacy shall maintain a perpetual
inventory of all Schedule II drugs received and dispensed,
with reconciliation at least monthly. This includes slow
moving and expired drugs. The perpetual inventory record
must accurately indicate the physical count of each Schedule
II drug “on hand” at the time of performing the inventory.
Furthermore, to comply with the requirement to perform
the required reconciliation of the perpetual inventory, an
explanation for any difference between the physical count
and the theoretical count must be noted (refer to Guidance
Document 110-16).
Partial Filling (Minor Deficiency 19): For each partial
filling or dispensing, a dispensing record must exist that
includes the dates of filling, quantities of drug dispensed, and
the initials of the dispensing pharmacist(s). If the pharmacy
uses an alternative record as described in Board regulation
18VAC110-20-255, such as a combination of an electronic
and manual record, to record the dispensing or partial filling,
the pharmacy must maintain a current policy and procedure
manual documenting the procedures for using the record,
how the record is integrated into the total dispensing record
system, and how the data included in the record shall be
interpreted (refer to Guidance Document 110-22).
Labeling of Prescriptions (Minor Deficiency 24): Although
a requirement for many years, inspectors continue to
identify prescriptions that do not include the generic name
on the label when a drug product possessing a single active
ingredient is dispensed. Additionally, prescription labels
are often found that do not contain the phrase “generic for”
followed by the brand name of the drug prescribed when
a generic drug is dispensed for a prescription written for a
brand-name drug. Terms such as “sub for” or “substitute
for” are not compliant with the Board regulation.

quoted from Virginia Board of Pharmacy August 2013 Newsletter