QCPP in Practice

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  • Enhancements to cold chain requirements

    Jul 16, 2018

    QCPP is pleased to announce greater flexibility to the cold chain requirements:

    • The QCPP Compliant Refrigerator list has been expanded to include refrigerators that have not been Cold Chain Testing Centre (CCTC) approved but have been determined to be QCPP compliant, e.g. those listed on the Australian Register of Therapeutic Goods (ARTG).
    • Pharmacies can now choose to obtain their refrigerator maintenance certification from the CCTC or through another approved service provider.

    QCPP acknowledges that cold chain technology is evolving. We have implemented these enhancements to Element 5 based on an analysis of Remedial Review Requests, as well as feedback received from pharmacies, manufacturers and EY Assessors.

    Element 5, Action 4 – QCPP Compliant Dispensary Refrigerator
    QCPP expect that your pharmacy must store temperature sensitive medicines in a purpose-built refrigeration unit that is designed and constructed specifically for therapeutic goods. This includes purpose-built refrigeration units that are integrated within an automated dispensing system.

    In addition to CCTC approved refrigerators, the QCPP Compliant Refrigerator list has been expanded to include refrigerators that have been approved to be QCPP compliant, e.g. refrigerators that are ARTG listed.

    Element 5, Action 6 – Certification of the dispensary refrigerator from the Cold Chain Testing Centre
    The current mandatory QCPP requirement is that the pharmacy must have certification of the dispensary refrigerator from the Cold Chain Testing Centre (NSW).

    Since implementation of the revised fees from 1 July 2017, which included removal of the subsidy for the Cold Chain Testing Centre, QCPP committed to providing pharmacies with a choice of which provider confirms the accuracy of the refrigerator temperature. Since 1 July 2017 this has been managed through the Remedial Review Request process and the Interpretations and Rulings Panel.

    Effective immediately (Monday 16 July 2018), QCPP will apply concessions on-site during assessment if the pharmacy choose to use a service provider other than CCTC and can confirm the accuracy of the refrigerator temperature through either:

    • Evidence that accuracy has been confirmed through a service provided by the refrigerator manufacturer OR
    • Evidence that accuracy has been confirmed through a service provided by an Australian Refrigeration Council (ARC) licenced refrigerator technician.
    QCPP has worked closely with EY to ensure EY assessors are aware of this update. QCPP understands that the Cold Chain Testing Centre (NSW) will continue to offer fee-for-service dispensary refrigerator testing services.

    The Knowledge Hub has also been updated to include this interpretation.

    Strive for 5 Guidelines – best practice is twice daily manual monitoring

    QCPP currently accredits pharmacies against the AS85000:2011 Standard which stipulates once daily monitoring. However, QCPP understands that, consistent with the Australian Government’s Strive for 5 Guidelines, best practice is twice daily manual monitoring.

    Moreover, QCPP is aware that in most states and territories, if your pharmacy is providing a vaccination service, you are expected to adhere to Strive for 5 Guidelines. QCPP recommends that you refer to your state or territory health department policy to understand your full requirements.

    Use of data loggers
    QCPP understands that technology for cold chain refrigeration is evolving, including the use of in-built or add-on automated continuous temperature monitoring systems, e.g. data loggers. Consistent with Strive for 5 Guidelines, pharmacies must continue to record minimum and maximum temperatures daily, regardless if a data logger is being used (please refer to the Strive for 5 Guidelines).

    For further information on QCPP cold chain requirements, please visit the QCPP Knowledge Hub or call the QCPP Helpline on 1300 363 340.
     
    Update on QCPP revised requirements
    • The revised requirements are currently undergoing a revision process that will ensure they are relevant and meet your pharmacy's business needs.
    • All pharmacies due for assessment in 2018 will be administered under the current QCPP requirements
    • More information on the revised requirements is available on the QCPP website.


    June 2018 QCPP statistics
    Number of QCPP assessments completed in June:
    NSW:84  VIC:35  QLD:41  SA:10  ACT:6  WA:11  TAS:10  NT:2  Australia-wide: 193

    Percentage of pharmacies currently QCPP accredited:
    NSW:94.58%  VIC:91.3%  QLD:94.46%  SA:97.53%  ACT:98.68%  WA:94.98%  TAS:95.95%  NT:94.87%  Australia-wide:94.15% 

    QCPP Terms and Conditions
    Effective from today (16 July 2018), payment of QCPP annual accreditation invoices will be determined as a declaration of intent by the pharmacy owner to engage QCPP to provide Accreditation Services and comply with QCPP's terms and conditions. A short message on the email accompanying your next invoice will explain this further. QCPP's
    Service Agreement: Terms and Conditions are available on our website.


  • Are all EY QCPP assessors accountants?

    May 30, 2018
    A common question we receive from pharmacies is whether the QCPP assessors from EY are all accountants. It's a fair question as EY (Ernst & Young) has a traditional background in the accounting field.

    Nowadays, EY Australia provides a variety of professional services and employs people from a wide range of backgrounds. Several EY assessors are registered pharmacists, while others are scientists, engineers, and economists, as well as some accountants.

    We thought we'd introduce you to two of EY's assessors (if you haven't met one of them already at your on-site assessment!)

    Brett Muller is a registered pharmacist with a pharmacy degree from the University of Queensland. Based in Brisbane, Brett has been an assessor with the QCPP program from the beginning (assessing our second ever pharmacy registered in 1998) and has now completed over 2,000 QCPP assessments throughout Australia.

    As well as being a lead assessor for QCPP, Brett has been a pharmacy owner and manager, director of a training organisation, and a professional mentor for the Pharmacy Board of Australia.

    Brett's top tip for pharmacies: The better prepared you are the smoother the assessment day will be! If you're part of a pharmacy group that doesn't keep certain records on site, make sure you have a copy of them on the day. Also, don’t put the QCPP materials in the cupboard after your assessment, allocate time each month to reviewing part of the program, so when you're next assessment rolls around you're ready to go.

    Joshua Sutcliffe started his professional life as a solicitor in New Zealand. After discovering that life as a solicitor wasn't his calling, Joshua returned to university and completed a Masters in Business Management.  

    Joshua then worked as a health, safety, environment & quality manager before joining EY. Joshua's background as a solicitor, and his deep interest in legal and policy compliance, led him to join EY as an assessor. 

    Joshua's top tip for pharmacies: Don't stress out. We're not there to catch you out - we are reasonable and want to help! 

    Fee credit to pharmacies identified as being negatively impacted due to implementation of revised flat fees
     
    On 1 July 2017 QCPP implemented a $2,200 (ex GST) flat fee payment structure for all pharmacies, which includes one two-yearly on-site assessment.
     
    Since implementation, QCPP were made aware that, as the accreditation cycle is for two years, certain pharmacies may have been financially disadvantaged by the implementation of the flat fee mid-way through their two year cycle.
     
    As per the robust QCPP feedback framework, inclusive of oversight by the QCPP Impartiality Committee, QCPP has determined that the implementation of the flat fee model should only apply to pharmacies on and from their re-accreditation date. Therefore, QCPP will be applying a one-off fee credit to the 2018/19 invoice of affected pharmacies. A fee credit will automatically be applied to the next invoice of affected pharmacies. No further action is required by pharmacies.
     
    QCPP will be notifying all affected pharmacies by email over the next week.
     
    QCPP openly acknowledges and apologises for any inconvenience caused. We are appreciative to the pharmacies that alerted us to this issue.

    Following a thorough review process, QCPP has been able to implement a solution to simply and fairly resolve the identified issue. This is indicative of QCPP’s commitment to continuous quality improvement.
     
    QCPP is pleased to have implemented the simplified fee structure. Moreover, through our continuous quality improvement, we have implemented internal efficiencies and have passed on the benefits of this to you through a reduction in fees.
      
    More information on the fee credit, including eligibility criteria and Frequently Asked Questions, is available on the QCPP website.
     
    If you have any questions regarding the fee credit, please contact the QCPP Helpline on 1300 363 340 or email help@qcpp.com

     


  • Can I do a MedsCheck with only one pharmacist on duty?

    May 10, 2018

    Providing in-pharmacy medicine reviews, like MedsChecks, is an important service that many pharmacies offer their patients.

    A question pharmacies often ask is whether it is mandatory to have at least two pharmacists on duty during MedsChecks in order to meet QCPP requirements. The answer to this depends on your pharmacy’s operational needs.

    Whilst it is not mandatory for more than one pharmacist to be on duty during a MedsCheck, you must be able to demonstrate that the pharmacist providing the MedsCheck is not dispensing or undertaking other professional duties at the same time. The intent of the requirement is to ensure that the pharmacist and the patient have an uninterrupted consultation.

    In order to adhere to QCPP requirements, your assessor must be confident that if only one pharmacist is on duty whilst a MedsCheck is being conducted, you can demonstrate that they have a system or process in place to ensure their responsibilities for dispensing and the provision of professional services are met.

    During your QCPP assessment your assessor will ask for an explanation, with evidence, of how you manage your personnel resources during in-pharmacy medicine reviews, such as MedsChecks.

    Examples of evidence may include a documented procedure in place to ensure dispensing and professional duties do not occur whilst a MedsCheck is being conducted, a staff roster showing multiple pharmacists on duty, script volume demonstrating peaks and troughs or evidence of performing in-pharmacy medicine reviews outside of your normal operating hours.

    Pharmacies should remain aware of their obligations described in Program Rules for in-pharmacy medicine review services, such as MedsChecks, as QCPP assessment does not specifically assess compliance with these requirements. However, these guidelines may be used to help determine if pharmacist resources for a specific service are adequate.

    Find out more in the QCPP Knowledge Hub


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