QCPP in Practice

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  • Can I Provide Vaccinations With Only One Pharmacist On Duty?

    Sep 17, 2018

    Pharmacist-administered vaccination is one of the many ways community pharmacy improves public health and is a growing and continually evolving service.

    Most recently, approved community pharmacies in Tasmania can now vaccinate children 10 years and over with the ACWY strain meningococcal vaccine so it’s important that you understand your QCPP requirements.  
     
    To help keep you up to speed, we’ve compiled a few important points and answers to common questions around vaccination and QCPP accreditation.

    Can I provide a pharmacist-administered vaccination service with only one pharmacist on duty?
    The QCPP requirements for providing a vaccination with a sole pharmacist rostered on are similar to those around MedsChecks, which we covered in a QIP newsletter in May.
     
    You can provide a pharmacist-administered vaccination service with only one pharmacist on duty, so long as:

    • the pharmacist providing the vaccination service is not responsible for dispensing or undertaking other professional services at the same time
    • you have a system or process in place to ensure that the pharmacist providing the vaccination service is not undertaking dispensing or professional duties whilst the service is being conducted.

    During your QCPP assessment, your assessor will ask for an explanation, with evidence, of how you ensure that the pharmacist and the patient have an uninterrupted vaccination service. Evidence may include:

    • a documented procedure which ensures that dispensing or other professional services do not occur during a vaccination service
    • a staff roster showing multiple pharmacists on duty
    • script volume, demonstrating peaks and troughs
    • records showing provision of a vaccination service outside of your normal operating hours.

    Does QCPP require my pharmacy to have a consultation room to provide vaccinations?
    QCPP requires that you have a dedicated area to enable the vaccination service to be provided. Mandatory requirements include:

    • a screened area to ensure consumer privacy is maintained, and to lie down if required
    • that access to the vaccination area is safe and appropriate and does not put your pharmacy or the patient at risk (e.g. the patient should not be required to walk through or past the dispensary or S4 medicines)
    • an area that it is free from interruptions
    • access to a hand hygiene procedure and to hand hygiene facilities
    • an appropriate area to for the patient to sit and allow for observations for a minimum of 15 minutes following administration of the vaccine

    Please log into the Knowledge Hub and download the T3M – Vaccination Services in the Pharmacy Checklist to understand all your QCPP requirements. 
     
    It is your responsibility to ensure that your vaccination area complies with your jurisdictional legislation, as well as QCPP requirements. For example, in some states a dedicated consultation room is mandatory, or you may be required to provide reports to your health department.

    Can I expand the scope of accreditation to include vaccinations? 
    Absolutely. If you would like to provide an additional service or program during your two-year accreditation cycle, simply complete and submit an application for Expansion of Professional Service including supporting documentation and evidence.

    QCPP celebrates two years of partnership with EY
    July 2018 marked two years of EY working with us to provide QCPP on-site assessments in pharmacies throughout Australia.

    We’re very proud of the strong and successful working relationship that QCPP and EY have developed. Over the last two years EY assessors have completed 5,762 QCPP on-site assessments!

    The integration and continuous improvement that has been applied over the last two years will see us to continue to build on the strong relationship and program into the future. Based on EY’s positive performance and success of the relationship, we are pleased to have extended our contract with EY to June 2022.


    August 2018 QCPP statistics
    Number of QCPP assessments completed in August:
    NSW:45  VIC:43  QLD:46  SA:11 ACT:4  WA:25  TAS:5  NT:0  Australia-wide:179

    Percentage of pharmacies currently QCPP accredited:
    NSW:95.5%  VIC:92.3%  QLD:95.2%  SA:97.8%  ACT:97.4%  WA:96%  TAS:96%  NT:97.5%  Australia-wide:95%



  • 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

     


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