BILL ANALYSIS                                                                                                                                                                                                    �







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        |Hearing Date:August 11, 2014       |Bill No:AB                         |
        |                                   |2757                               |
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                      SENATE COMMITTEE ON BUSINESS, PROFESSIONS 
                               AND ECONOMIC DEVELOPMENT
                              Senator Ted W. Lieu, Chair
                                           

                        Bill No:        AB 2757Author:Bocanegra
                   As Amended:August 4, 2014          Fiscal:  Yes 

        
        SUBJECT:    Centralized hospital packaging pharmacies: medication  
        labels.
        
        SUMMARY:  Provides that certain information located in a medication's  
        barcode now be displayed on a human readable label or be retrievable  
        using a lot number or control number. Requires a medication's barcode  
        be machine readable using a medication administration software  
        (software) and that the software cross reference the information  
        contained in the barcode to the electronic medical record of the  
        patient in order to verify the correct medication, dosage, and route  
        of administration for the patient.  This is an urgency measure. 

        Existing law:

        1)Provides for the practice of pharmacy and licensing and regulation  
          of pharmacies and pharmacists by the Board of Pharmacy (Board) and  
          within the Department of Consumer Affairs (DCA). 

        2)Provides that a centralized hospital packaging pharmacy may prepare  
          medications, by performing specialized functions, for administration  
          only to inpatients within its own general acute care hospital and  
          one or more general acute care hospitals if the hospitals are under  
          common ownership and located within a 75-mile radius of each other.  
          (Business and Professions Code (BPC) � 4128)

        3)Defines "hospital pharmacy" as a pharmacy licensed by the Board,  
          located within any licensed hospital, institution, or establishment  
          that maintains and operates organized facilities for the diagnosis,  
          care, and treatment of human illnesses to which persons may be  
          admitted for overnight stay. (BPC � 4029)





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        4)Provides that "hospital pharmacy" also includes a pharmacy that may  
          be located outside of the hospital, in another physical plant that  
          is regulated under a hospital's consolidated license issued by the  
          California Department of Corrections or California Department of  
          Youth Authority.  Specifies that the pharmacy in another physical  
          plant shall provide pharmaceutical services only to registered  
          hospital patients who are on the premises of the same physical plant  
          in which the hospital is located.  Specifies that the pharmacy  
          services provided shall be directly related to the services or  
          treatment plan administered in the physical plant.  (Id.)
         


        5)Requires any unit dose medication produced by a central hospital  
          packaging pharmacy to display a readable barcode at the inpatients  
          bedside. The readable barcode will display the following  
          information:  (BPC � 4128.4)

          a)     The date the medication was prepared.

          b)     The components used in the drug product.

          c)     The lot number or control number.

          d)     The expiration date.

          e)     The National Drug Code Directory number.

          f)     The name of the centralized hospital packaging pharmacy. 

        1)Requires the label for each unit dose medication produced by a  
          centralized hospital packaging pharmacy contain the following  
          information:  (BPC � 4128.5)

          a)     The expiration date.

          b)     The established name of the drug.

          c)     The quantity of the active ingredient. 

          d)     Special storage of handling requirements. 

        This bill:

        1)Defines "barcode medication administration software" as a  





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          computerized system designed to prevent medication errors in health  
          care settings.
         
        2)Permits a barcode medication administration software to cross  
          reference a health care practitioner to ensure that, before a  
          medication is administered to an inpatient, it is the right  
          medication, for the right patient, in the right dose, and via the  
          right route of administration.  

        3)Permits the software to verify that the medication satisfies these  
          criteria by reading the barcode on the medication and comparing the  
          information retrieved to the electronic medical record of the  
          patient. 

        4)Requires any unit dose medication produced by a central hospital  
          packaging pharmacy to display a human-readable label.

        5)Specifies that the human readable label include:

           a)   The date that the medication was prepared.

           b)   The beyond-use date.

           c)   The established name of the drug.

           d)   The quantity of the active ingredient. 

           e)   Special storage or handling requirements.

           f)   The lot number or control number assigned by the centralized  
             hospital packaging pharmacy.

           g)   The name of the centralized hospital packaging pharmacy.

        1)Provides that for quality control and investigative purposes, a  
          pharmacist shall be able to retrieve all of the following  
          information using the lot number or control number as described  
          above:

           a)   The components used in the drug product.

           b)   The expiration date of each of the drugs components.
         
           c)   The National Drug Code Directory number by the lot number or  
             control number. 






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        1)Makes other technical and conforming changes. 

        2)Specifies that this is an urgency measure for the purpose of  
          eliminating, at the earliest possible time, requirements that exceed  
          the current technological capabilities of hospitals and that create  
          overly burdensome administrative costs for the California State  
          Board of Pharmacy. 
        

        FISCAL EFFECT: This bill is keyed fiscal by Legislative Counsel.

        
        COMMENTS:
        
        1.Purpose.  The  Author  is the Sponsor of this measure.  According to  
          the Author, "this bill would permit hospitals to comply with  
          provisions specified in  AB 377  (Solorio, Chapter 687, Statutes of  
          2012) by allowing the necessary information elements required for a  
          centralized hospital packaging pharmacy license to be displayed on a  
          human-readable label (containing the lot number or control number),  
          rather than the barcode.  The Author states that "In order to verify  
          that the medication to be given is the correct medication, dosage,  
          and route of administration for that patient, the bill would require  
          that a medication's barcode be machine readable using software that  
          compares the information contained in the barcode to the electronic  
          medical record of the inpatient."
        
        2.Background.  The Board of Pharmacy was a strong proponent of AB 377,  
          as it makes it easier for hospitals to set up and invest in  
          high-tech central pharmacies utilizing the latest in technological  
          innovations (such as robotics), effectively lowering rates of  
          medication errors and reducing unnecessary costs.

          Language contained in Section 4128.4 of the Business and Professions  
          Code, specifically the word "retrievable," has caused confusion and  
          different interpretations between the Board and hospital chains.   
          The intent of the word "retrievable" by the bill's Author was not  
          that the elements be immediately readable on the label, but instead  
          AB 377 was to link the data elements on the barcode to a database  
          where the elements would be present and retrievable.  

          Recently, hospitals such as Loma Linda University Medical Center,  
          Scripps Health San Diego, and Sharp Health Care have come to the  
          Board of Pharmacy and highlighted limitations in their software that  
          would prohibit full compliance with the barcode requirements  
          specified in Section 4128.4.  According to the hospitals, hospital  





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          IT vendors will have to reconfigure their systems to make all the  
          elements listed in Section 4128.4 immediately readable upon scan.   
          These medical groups requested that the board interpret the meaning  
          of the provisions more broadly to allow for ample time following  
          licensure to fully comply with the requirements. 
          The Board ultimately approved five-year waivers to organizations who  
          have fallen out of compliance - allowing the requisite information  
          elements to be physically listed on the label rather than having  
          them in electronic, barcode format.
        
        3.Prior Related Legislation.   AB 377  (Solario, Chapter 687, Statutes  
          of 2012) authorized a centralized hospital packaging pharmacy to  
          prepare medications, by performing specified functions for  
          administration only to inpatients within its own general acute care  
          hospital, or one or more general acute care hospitals under the same  
          ownership and located within 75 miles of each other.
          
           AB 2077  (Solario) of 2010, in its final version, was virtually  
          identical to AB 377 (Solario). The bill was vetoed by the Governor.   
          In his veto message, the Governor expressed concern that the bill  
          could result in "a greater likelihood of product mix-up, loss of  
          product identity, contamination and cross-contamination, and lack of  
          adequate control systems."    
           
          AB 1370  (Solario) of 2009 was similar to AB 377 bill but created a  
          separate licensing category for centralized hospital pharmacies.   
          (  Status:   The bill was held in the Assembly Committee on Business  
          and Professions.)
           
          SCR 49  (Speier, Chapter 123, Statutes of 2005) created a panel to  
          study the causes of medication errors and recommend changes in the  
          health care system that reduces errors associated with the delivery  
          of prescription and over the counter medication to consumers. 
           
          SB 1875  (Speier, Chapter 816, Statutes of 2000) required hospitals  
          to adopt a formal plan to eliminate or substantially reduce  
          medication-related errors.  
        

        SUPPORT AND OPPOSITION:
        
         Support:  

        California Council for the Advancement of Pharmacy 
        California State Board of Pharmacy 
        California Hospital Association 





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        California Society of Health-System Pharmacists 
        Providence Health & Services, Southern California
         Opposition:  None received as of August 6, 2014.



        Consultant: Mark Mendoza