MOM Chapter
03. MANAGEMENT OF MEDICATIONS
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03. MANAGEMENT OF MEDICATIONS
Dr. Grace Mary John
Mr. Biju Thomas
Ms. Linda Jacob
1. Introduction
* NABH 6th Edition: Overview of the accreditation body and edition.
* Accreditation Standards for Hospitals: Context of the training - focusing on hospital standards.
* Chapter 3: Management of Medication (MOM): Specific chapter focus - Medication Management.
* CAHO - Committed to Safer Patient Care: Highlighting the commitment to patient safety.
2. Intent of MOM
* Core Purpose: Ensuring a safe and organized medication process within the hospital.
* Key Intent Points:
* Safe and organized medication process.
* Pharmacy oversight of medications outside pharmacy.
* Standardized, readily available, and timely replenished emergency medications.
* Safe use of high-risk medications.
* Monitoring patients post-medication administration.
* Procedure for reporting and analyzing medication safety events (near misses, errors, ADRs).
* Availability of medical supplies and consumables.
3. MOM - Summary of Standards
* Overview of Standards: 11 Key Standards in MOM.
* Comparison (6th vs 5th Edition): Highlighting that standards themselves are largely unchanged.
* Focus on Objective Elements (OEs).
* Total No. of OEs: 68 (Consistent across editions).
* List of Standards (MOM 1-11):
* 1. Pharmacy services and usage of medication
* 2. Hospital formulary
* 3. Storage of medication
* 4. Prescription of medication
* 5. Medication order
* 6. Dispensing of medication
* 7. Medication administration
* 8. Patient monitoring
* 9. Narcotic drugs and psychotropic agents
* 10. Implants, prosthesis and medical device
* 11. Medical supplies
4. Colour Coding
* Understanding Levels of Compliance: Explanation of the colour-coding system.
* Level & Colour & Icon:
* Commitment level (Blue) - Icon: C
* Commitment level (Core OE) (Blue) - Icon: CO
* Achievement level (Magenta) - Icon: A
* Excellence level (Green) - Icon: E
* Note on Asterisk (*): Mandatory system documentation requirement.
5. Summary of Changes - Intent & MOM 1
* Overall Intent Changes:
* Modified to include:
* Medication safety officer role.
* Reconciliation of medication at transition points and patient care areas.
* MOM 1: Pharmacy services and medication management is done safely:
* Summary of Changes: Language of the standard modified.
* Objective Elements Changes:
* MOM 1a: Interpretation is modified.
* MOM 1c: Changed from excellence to achievement level.
6. MOM 1: Detailed Breakdown
* MOM 1a: Written Guidance:
* Requirement: Pharmacy services and medication usage implemented following written guidance. (C)
* Areas of Written Guidance: Formulary, Procurement, Storage, Prescription, Dispensing, Administration, Monitoring, Usage.
* Note: Medication Management Manual - Clubbing all procedures.
* MOM 1b: Multidisciplinary Committee:
* Requirement: Committee guides formulation and implementation. (C)
* Staff in-charge: Composition of the multidisciplinary committee (Representatives from clinical departments, administration, pharmacy, nursing, quality).
* Responsibilities: Developing processes, formulary, evaluating use, monitoring safety incidents.
* Documentation: Objectives, Composition, Frequency, Quorum, Minutes.
* Note: Committee meeting frequency - once in three months.
* MOM 1c: Multidisciplinary Committee - Update Processes:
* Requirement: Committee updates medication management processes. (A)
* Monitor: Literature reviews and best practice information.
* Use Information: To update medication management process.
* Examples for Update: Rational use, Medication errors, Medication management, ADRs, Patient safety (high-risk medications).
* Objective Element Change: Excellence to Achievement.
* MOM 1d: Procedure for Medication When Pharmacy Closed:
* Requirement: Procedure to obtain medication when pharmacy is closed. (C)
* Flowchart: Is pharmacy closed? -> Follow SOP -> Procure drugs from outside.
* Note: Preference for 24-hour pharmacy.
* MOM 1e: Mechanism to Inform Staff of Changes:
* Requirement: Mechanism to inform staff of key changes in pharmacy services. (C)
* Points to Remember:
* Pharmacy-in-charge/designated authority communication.
* Process should be documented.
* Examples of Key Changes: Medication shortages (stockouts), Drug recalls (within 24 hours), Serious adverse medication events.
7. MOM 2: Hospital Formulary
* MOM 2: Develop, Update, Implement Formulary:
* Summary of Changes: No change in standard.
* Objective Element Changes:
* MOM 2a: Interpretation modified.
* MOM 2d: Changed from excellence to commitment level.
* MOM 2f: Interpretation modified.
* MOM 2a: Collaborative Formulary Development:
* Requirement: List of medications developed collaboratively by multidisciplinary committee. (CO)
* Develop based on: Organisation's mission, Patient's need, Scope of services.
* Include: Name of molecule, Formulation, Strength(s).
* Consider: Harm potential, Interactions, Likelihood of patient safety incidents.
* Limit: Number of drug concentrations.
* Points to Remember: System/Speciality wise formulary, Implants/devices as drugs.
* MOM 2b: Annual Review and Update:
* Requirement: List reviewed and updated at least annually. (C)
* Review and update: All medications or certain categories.
* Include in revised list: Non-formulary drugs procured previous year.
* Discuss: Patient safety aspects (ADRs, disease pattern, resistance), Cost.
* Note: Annual review and update frequency.
* MOM 2c: Formulary Availability:
* Requirement: Current formulary available for clinicians. (C)
* Who should have access: Treating doctors and clinicians.
* How to make available: Physical or electronic form.
* MOM 2d: Clinician Adherence to Formulary:
* Requirement: Clinicians adhere to current formulary. (A)
* Clinician Action: Prescribe as per formulary.
* Organisation Action: Monitor prescription rejections/local purchases due to non-formulary drugs.
* Objective Element Change: Excellence to Achievement.
* MOM 2e: Acquisition of Formulary Medications:
* Requirement: Adherence to procedure for acquisition of formulary medications. (C)
* Key Steps: Vendor selection, Vendor evaluation, Reorder levels, Indenting process, Purchase order generation, Receipt of goods, Stock-outs management.
* MOM 2f: Acquisition of Non-Formulary Medications:
* Requirement: Adherence to procedure for non-formulary medications. (C)
* Flowchart: Local purchase -> Evaluate -> Authorise -> Ratify -> Decide subsequent inclusion.
8. MOM 3: Storage of Medication
* MOM 3: Appropriate Storage and Availability:
* Summary of Changes: No change in standard.
* Objective Element Changes: MOM 3a, 3b, 3c - Interpretation modified.
* MOM 3a: Clean, Safe, Secure Environment:
* Requirement: Medications stored in clean, safe, secure environment, incorporating manufacturer's recommendations. (CO)
* Storage space: Clean, safe, secure, organized.
* Storage requirements: Adhere to manufacturer’s instructions/guidelines.
* Beyond expiry drugs: Separate storage.
* Points to Remember: Protect from loss/theft - Access control, Locking carts, Staffed area, Periodic audits.
* Vaccine Storage Guidelines: Separate box, Vaccine refrigerators (ice-lined), Temperature monitoring (daily).
* MOM 3b: Inventory Control Practices:
* Requirement: Sound inventory control practices guide storage. (C)
* Inventory Methods: ABC (cost), VED (criticality), FSN (movement), FEFO (expiry), Lead time analysis.
* Points to Remember: Inventory medicines - alphabetical order (generic), Non-inventory medicines - mechanism required (e.g., physician samples).
* MOM 3c: List of High-Risk Medications:
* Requirement: Organisation defines a list of high-risk medications. (CO)
* High-Risk Medication Definition: Heightened risk for adverse outcomes, catastrophic harm in error.
* Points to Remember/Examples: Low therapeutic window, Controlled substances, Psychotherapeutic, LASA, Concentrated electrolytes.
* MOM 3d: Storage Areas for High-Risk Medications:
* Requirement: High-risk medications stored in clinically necessary areas. (A)
* Actions: Store in pre-determined areas, Determine availability based on clinical needs, Adhere to regulations (narcotics), Adopt safety measures (inadvertent administration prevention).
* MOM 3e: Physical Separation of High-Risk Medications:
* Requirement: LASA and different concentrations of same medication stored physically apart. (CO)
* LASA Medications: Make a list, Place list in storage units.
* Different Concentrations: Develop list from formulary, Revise list regularly (formulary/packaging changes).
* Points to Remember: Separate LASA drugs and different concentrations far apart (pharmacy ends), Storage practices in patient care areas as well.
* MOM 3f: Emergency Medication List and Uniform Storage:
* Requirement: List of emergency medications defined and stored uniformly. (C)
* Actions: Prepare a list, Use crash cart for standardized storage.
* Point to Remember: Do not store other drugs with emergency medications.
* MOM 3g: Availability and Replenishment of Emergency Medications:
* Requirement: Emergency medications available and replenished promptly. (CO)
* Actions: Stock adequate quantity, Perform inventory check daily.
* Note: Emergency cart sealing system - check after each use/once a month.
9. MOM 4: Prescription of Medication
* MOM 4: Safe and Rational Prescription:
* Summary of Changes: No change in standard.
* Objective Elements: MOM 4b, 4c, 4f - Interpretation modified; MOM 4e, 4g, 4h - No change.
* Objective Elements: List of OEs with changes noted.
* MOM 4a: Rational Prescription Guidelines:
* Requirement: Medication prescription in consonance with good practices/guidelines for rational prescription. (C)
* Actions: Follow good practice, Adhere to guidelines.
* WHO Definition of Rational Use: Appropriate medications, correct doses, individual needs, adequate duration, lowest cost.
* Points to Remember: Written guidance (OP & IP prescriptions), Clinician training/sensitization.
* MOM 4b: Minimum Requirements of a Prescription:
* Requirement: Adherence to determined minimum requirements of a prescription. (CO)
* Actions: Adhere to national/international guidelines, Write in capital letters, Initialise errors/illegible prescriptions, Avoid error-prone abbreviations.
* Note: Reference to 'Drugs and Cosmetics Act' and 'Code of Medical Ethics'.
* Points to Remember: Minimum requirements of a prescription (IPD, OPD, Emergency): Name of patient, Unique hospital number, Name of drug, Strength, Dosage instruction, Duration, Total quantity, Doctor's details.
* MOM 4c: Drug Allergies and ADRs Ascertained Before Prescribing:
* Requirement: Drug allergies and previous ADRs ascertained before prescribing. (C)
* Timing: During initial consultation, At any point in time during care.
* Note: Documentation of allergies in medical record (OP & IP).
* MOM 4d: Mechanism to Assist Clinician in Prescribing:
* Requirement: Organisation has a mechanism to assist clinician. (E)
* Mechanisms to Identify: Drug interactions, Food-drug interactions, Therapeutic duplication, Dose adjustments.
* Note: Electronic or physical form.
* MOM 4e: Reconciliation of Medications at Transition Points:
* Requirement: Reconciliation of medications occurs at transition points. (CO)
* Purpose: Complete and up-to-date medication list.
* When to do: Transition points (Admission, Transfer, Discharge), After cross-consultation, During handover.
* Note: Process should be documented.
* MOM 4f: Verbal Orders - Safe Medication Management Practices:
* Requirement: Verbal orders implemented by ensuring safe practices. (CO)
* Written Guidance Areas: Who can give, When can it be given, How to authenticate.
* Points to Remember: Verbal Orders: Limit to urgent situations, Approved formulary drug list (inclusion/exclusion), Repeat back/read back, Doctor countersign (within 24 hours).
* MOM 4fg: Audit of Medication Orders/Prescriptions:
* Requirement: Audit to check for safe and rational prescription. (A)
* Audit Points: Legibility/capital letters, Appropriateness (drug, dose, frequency, route), Therapeutic duplication, Drug/food interactions, Standard requirements.
* Points to Remember: Perform audit monthly, Representative sample size, Staff in-charge (Clinical pharmacologist/pharmacist/multidisciplinary committee).
* MOM 4h: Corrective/Preventive Actions based on Audit:
* Requirement: Corrective/preventive action(s) taken based on audit. (A)
* Process: Perform root-cause analysis -> Take CAPA -> Maintain records of action(s).
10. MOM 5: Medication Orders - Uniform Manner
* MOM 5: Uniform Medication Orders:
* Summary of Changes: No change in standard.
* Objective Element: MOM 5c - Interpretation modified.
* MOM 5a: Authorised Personnel to Write Orders:
* Requirement: Only authorised personnel write orders. (C)
* Medication Order Card: Only Doctor (MBBS) to write (including verbal/consultant orders, OP record/admission note).
* Electronic Medical Record (EMR): Doctor to enter prescription (HIS login), Assistant entry verified/authorised by doctor.
* Note: Medication orders by other authorised staff backed by legislation/government order.
* MOM 5b: Uniform Location and Patient Identification:
* Requirement: Orders in uniform location, reflecting patient name and unique ID. (C)
* Actions: Write in uniform location, Administer only from this location, Transcribe orders from different locations, Include patient details, Same sheet for prescription/administration or use "Drug Kardex", Fresh order for change.
* Note: Electronic orders to follow principles.
* Points to Remember: Avoid phrases like "CST"/"continue same treatment"/"repeat all"/"repeat 1,4,5,8", No strike-through or over-writing.
* MOM 5c: Legible, Dated, Timed, Signed Orders:
* Requirement: Medication orders are legible, dated, timed, and signed. (C)
* Actions: Write in capital letters, Use approved abbreviations, Avoid error-prone abbreviations, Ensure traceability (name/employee code/master signature list).
* Note: Reference to 'Institution for Safe Medication Practices' guidelines.
* MOM 5d: Content of Medication Orders:
* Requirement: Orders contain medicine name, route, strength, frequency/time. (C)
* Actions: Write all required information.
* Actions: Write strength of individual drugs (tablet/capsule/injection).
* Actions: Record separately if strength differs for each administration time.
* Points to Remember: Strength not needed for vitamin/mineral combinations, Mechanism for incomplete orders.
11. MOM 6: Dispensing of Medication
* MOM 6: Safe Dispensing:
* Summary of Changes: No change in standard.
* Objective Elements: MOM 6b, 6f - Interpretation modified.
* MOM 6a: Dispensing Safely:
* Requirement: Dispensing of medications is done safely. (C)
* Written Guidance: Dispense against valid prescription (except OTC), Check medication before dispensing (generic, formulation, expiry, strength), Do not sell physician’s samples.
* Note: Safe dispensing for bulk and retail pharmacy.
* MOM 6b: Medication Recalls Handled Effectively:
* Requirement: Medication recalls are handled effectively. (C)
* Based on: Communication from regulatory authorities, manufacturer, or internal feedback (contaminant).
* Inform: Appropriate regulatory authority for internal feedback recalls.
* MOM 6c: Near-Expiry Medications Handled Effectively:
* Requirement: Near-expiry medications are handled effectively. (C)
* Actions: Define near-expiry, Withdraw near-expiry drugs, Ensure non-availability of beyond expiry medication.
* Note: Near-expiry definition - may be three months before expiry.
* MOM 6d: Dispensed Medications are Labelled:
* Requirement: Dispensed medications are labelled. (CO)
* All medications (For OP): Write dosage instructions.
* Cut strips/bulk containers (For IP, OP, reconstituted): Write drug name, strength, dosage instruction, expiry date.
* MOM 6e: High-Risk Medication Order Verification:
* Requirement: High-risk medication orders are verified before dispensing. (CO)
* Actions: Verify written order before dispensing, Adhere to statutory requirements.
* MOM 6f: Return of Medications to Pharmacy:
* Requirement: Return of medications to pharmacy is addressed. (C)
* Written Guidance: Make list of medications accepted for return, Define minimum conditions. Ensure non-return of specific temperature drugs.
* Points to Remember: Minimum conditions for return: Drug name, Strength, Batch number, Expiry date matching bill, No visible damage. Create awareness about medication return.
12. MOM 7: Medication Administration
* MOM 7: Safe Medication Administration:
* Summary of Changes: No change in standard.
* Objective Elements: MOM 7c, 7d, 7i, 7j - Interpretation modified.
* MOM 7a: Administration by Permitted Personnel:
* Requirement: Medications administered by those permitted by law. (C)
* Permitted Personnel: Registered nurse OR Doctor with minimum MBBS qualification.
* Note: Other authorized staff administration backed by legislation/government order.
* MOM 7b: Labelled Prepared Medication:
* Requirement: Prepared medication labelled before preparing second drug. (C)
* Steps: Prepare first medication -> Attach label -> Prepare second drug.
* Points to Remember/Examples: Anaesthetic drug preparation in OTs, Chemotherapy drugs.
* MOM 7c: Patient Identification Before Administration:
* Requirement: Patient identified before administration. (C)
* Minimum Two Identifiers: Check unique identification number, Check patient's name.
* MOM 7d: Medication Verification Before Administration:
* Requirement: Medication verified from order and physically inspected. (CO)
* Actions: Verify medication order, Check general appearance (melting, clumping), Check expiry dates, Defer administration if missing/incomplete parameters (Name, strength, route, frequency/time).
* Points to Remember: Verbal confirmation - adhere to procedure, High-risk medications - two staff verification (nurse-nurse/nurse-doctor), Empower nurses to highlight prescription errors.
* MOM 7e: Strength Verification:
* Requirement: Strength verified from order before administration. (C)
* Actions: Verify strength from medication order, Defer administration in case of discrepancy.
* MOM 7f: Route Verification:
* Requirement: Route verified from order before administration. (C)
* Action: Check route and site of administration with medication order.
* MOM 7g: Timing Verification:
* Requirement: Timing verified from order before administration. (C)
* Scheduled Timing: Verify with medication order.
* Suggested Timing: Document actual timing if not written in order.
* Points to Remember: ISMP Acute Care Guidelines for Timely Administration of Scheduled Medications - Guidance on scheduled medication, Time-critical/non-time-critical classification, Organisation can adopt/adapt.
* MOM 7h: Measures to Avoid Catheter/Tubing Misconnections:
* Requirement: Measures to avoid misconnections implemented. (CO)
* Actions to Avoid Inadvertent Administration: Use design features to prevent misconnections, Prompt user to take correct action, Avoid IV extension tubes for epidurals/irrigation/drains/central/enteric feeding tubes, Position dissimilar tubes apart, Trace all lines from origin to connection port.
* MOM 7i: Medication Administration Documentation:
* Requirement: Medication administration is documented. (C)
* Documentation Elements: Name of medication, Strength, Route, Timing, Name/employee ID, Infusions (start time, rate, end time).
* Points to Remember: Document in uniform location, Document each dose separately, Record actual administration, Examples (brand substitution, strength variation), Document patient refusal.
* MOM 7j: Measures to Govern Patient Self-Administration:
* Requirement: Measures to govern patient’s self-administration implemented. (C)
* Organisation Definition: Define if self-administration is permitted.
* Written Guidance: If permitted - list of self-administered medications, Method to remind patient (before each dose), Document relevant information.
* MOM 7k: Measures to Govern Patient's Outside Medications:
* Requirement: Measures to govern patient’s medications brought from outside implemented. (C)
* Organisation Definition: Define if patient can bring medications.
* Written Guidance: If permitted - prerequisites for medication (Clear label).
* Points to Remember: Content of medication label: Name, Strength, Expiry date, Batch number.
13. MOM 8: Patient Monitoring After Medication Administration
* MOM 8: Patient Monitoring:
* Summary of Changes: No change in standard.
* Objective Elements: MOM 8a, 8b, 8c - Interpretation modified.
* Objective Elements: List of OEs with changes noted.
* MOM 8a: Monitoring After Administration:
* Requirement: Patients are monitored after medication administration. (C)
* Monitoring Actions: Verify intended effect, Monitor effects via lab results (beneficial/adverse), Identify near misses, medication errors, ADRs.
* Note: Define situations for more frequent monitoring (e.g., high-risk medicines).
* MOM 8b: Medication Changes Based on Monitoring:
* Requirement: Medications changed where appropriate based on monitoring. (C)
* Monitoring Parameters: Clinical response, Adverse drug reactions (if any).
* Definitions:
* Adverse Drug Event (ADE): Harm from medical intervention related to a drug (IOM). Includes medication errors, ADRs, allergic reactions, overdoses. Statistics on ADEs.
* Adverse Drug Reaction (ADR): Drug-induced harm with appropriate use. Noxious and unintended response at normal doses. Subtype of ADE.
* Medication Errors: Mistakes during prescribing, transcribing, dispensing, administering, adherence, monitoring. Near misses. Harm less than 1% of time.
* Adverse Drug Events and Medication Errors Relationship: ~50% ADEs due to medication errors (preventable AE). Medication errors without harm (potential AE). ADRs/side effects (non-preventable AE).
* MOM 8c: Capture of Near Miss, Medication Error, ADR:
* Requirement: Organisation captures near miss, medication error, and ADR. (CO)
* Written Guidance (Near miss, medication errors, ADR): Identify -> Document -> Report -> Analyse -> Act.
* Note: Define near miss, medication errors, ADR based on best practices.
* MOM 8d: Reporting Timeframe:
* Requirement: Near miss, medication error, ADR reported within a specified timeframe. (C)
* Actions: Define timeframe, Adhere to timeframe.
* MOM 8e: Collection and Analysis:
* Requirement: Near miss, medication error, ADR collected and analysed. (C)
* Who is responsible: Multidisciplinary committee (clinical pharmacologist/pharmacist can be part).
* When to do: Within a defined timeframe.
* MOM 8f: Corrective/Preventive Actions Based on Analysis:
* Requirement: Corrective/preventive action(s) taken based on analysis. (C)
* Process: Perform root cause analysis -> Take CAPA -> Maintain records of action taken.
14. MOM 9: Narcotic Drugs and Psychotropic Substances, Chemotherapeutic Agents and Radio-Pharmaceuticals
* MOM 9: Safe Use of Controlled and Specialized Medications:
* Summary of Changes: Radioactive agent replaced by radio-pharmaceuticals.
* Objective Elements: MOM 9a, 9b, 9c, 9d - Radioactive agent replaced; MOM 9e - Interpretation modified.
* MOM 9a: Safe Use - Written Guidance:
* Requirement: Narcotic drugs, psychotropic substances, chemotherapeutic agents, radio-pharmaceuticals used safely. (C)
* Written Guidance: Develop in consonance with local/national regulations/guidelines, Address all objective elements of this standard.
* Point to Remember: Regulations/Guidelines: Narcotic Drugs and Psychotropic Substances Act, AERB guidelines.
* MOM 9b: Prescribed by Appropriate Caregivers:
* Requirement: Prescribed by appropriate caregivers. (C)
* Type of Drug & Who Should Prescribe:
* Narcotic drugs: Designated medical officer(s).
* Chemotherapy: Medical oncologist/doctor with chemotherapy adverse effect management knowledge.
* Radioactive agents: Caregiver authorized by statutory body.
* MOM 9c: Secure Storage:
* Requirement: Drugs shall be stored securely. (C)
* Type of Drug & How to Store:
* Narcotic drugs: Securely (security requirements), Security measures to prevent diversion/abuse.
* Chemotherapeutic agents: Accessible only to authorised personnel.
* Radioactive agents: Store as per AERB guidelines.
* Note: Separate storage from other medications.
* MOM 9d: Preparation and Administration of Chemo and Radio-pharmaceuticals:
* Requirement: Prepared properly and safely and administered by qualified personnel. (C)
* Chemotherapy agents: Staff in-charge (specially trained), Area (bio-safety cabinet class II, preferably IIA), Safety measures (appropriate PPE).
* Radioactive agents: Staff in-charge (Caregiver authorized by statutory body).
* MOM 9e: Proper Record of Usage, Administration, Disposal:
* Requirement: Proper record kept. (C)
* Narcotic Drugs: Record usage, Adhere to statutory requirements, Dispose as per statutory requirements (Narcotic Drugs and Psychotropic Substances Act, AERB rules, biomedical waste rules) and manufacturer's recommendation.
* Points to Remember: Strict Inventory Control for: Narcotic drugs, Psychotropic substances, Chemotherapeutic agents, Radioactive agents.
15. MOM 10: Implantable Prosthesis and Medical Devices
* MOM 10: Usage in Accordance with Laid Down Criteria:
* Summary of Changes: No change in standard.
* Objective Elements: MOM 10c, 10e - Interpretation modified.
* Objective Elements: List of OEs with changes noted.
* MOM 10a: Usage Guided by Scientific Criteria:
* Requirement: Usage guided by scientific criteria and national/international guidelines/approvals. (C)
* Before Selection: Relevant and sufficient scientific data available.
* For Product Approval: International or national notification.
* Points to Remember: International Notification: US-FDA, National Notification: Central Drugs Standard Control Organisation notification (Drugs and Cosmetics Act).
* Note: Multidisciplinary committee responsible for approving implant use.
* MOM 10b: Mechanism for Usage:
* Requirement: Organisation implements a mechanism for usage. (C)
* Written Guidance Areas: Procurement, Storage/Stocking, Issuance, Usage.
* Note: Written guidance should address statutory regulations/guidelines and manufacturer's recommendations.
* MOM 10c: Patient and Family Counselling:
* Requirement: Patient and family counselled for usage, including precautions. (C)
* Counselling Points: Usage (implantable prosthesis and medical devices), Precautions (non-usage of specific drugs), Reporting (to hospital if symptom occurs).
* MOM 10d: Batch and Serial Number Recording:
* Requirement: Batch and serial number recorded in medical record, master logbook, discharge summary. (C)
* Flowchart: Does implant have pre-labelled sticker? -> YES: Record batch and serial number. -> NO: Use mechanism to identify implant (manufacturer, type, size, batch number, serial number, other detail).
* Note: Implant details recorded in medical record, master logbook, discharge summary.
* MOM 10e: Recall Process:
* Requirement: Process of recall handled effectively. (A)
* Based on: Communication from regulatory authorities, manufacturer, or internal feedback.
* Inform: Appropriate regulatory authority and manufacturer in case of internal feedback recall.
16. MOM 11: Medical Supplies and Consumables
* MOM 11: Appropriate Storage and Availability:
* Summary of Changes: No change in standard.
* MOM 11a: Acquisition Process:
* Requirement: Adherence to defined process for acquisition. (C)
* Key Steps: Vendor selection, Vendor evaluation, Indenting process, Purchase order generation, Receipt of goods.
* Points to Remember: Medical supplies and consumables are items used in patient care (excluding medications and implants).
* MOM 11b: Safe Use:
* Requirement: Used in a safe manner, where appropriate. (C)
* Actions: Take relevant precautions, Maintain sterility and integrity of items.
* MOM 11c: Clean, Safe, Secure Environment for Storage:
* Requirement: Stored in clean, safe, secure environment, incorporating manufacturer's recommendations. (C)
* Storage Requirements: Follow manufacturer's guidelines in all areas (including wards).
* Storage Area: Should be clean.
* Points to Remember: Protect items from loss/theft, Identify and store hazardous materials safely.
* MOM 11d: Inventory Control Practices:
* Requirement: Sound inventory control practices guide storage. (C)
* Inventory Methods: ABC (cost), VED (criticality), FSN (movement), First expiry, first out, Lead time analysis.
* MOM 11e: Mechanism to Verify Condition:
* Requirement: Mechanism to verify condition. (C)
* Action: Ensure item is in good condition for safe dispensing and usage.
* Check the following: Package opened, Cotton roll damp, Physical damage, Unwanted discoloration.
17. Definitions
* Recap of key definitions: ADE, ADR, Medication Errors, and their interrelationship for a comprehensive understanding of medication safety.
18. Q&A and Thank You
* Any Questions?: Opportunity for clarification and engagement.
* Thank You!: Conclusion of the training session.
This outline provides a structured approach to understanding the NABH 6th Edition MOM chapter, suitable for professional training and note-taking, without page number references. It breaks down each standard and objective element into key learning points for effective comprehension and implementation.
Understanding the Introduction Components:
The initial slides of the presentation serve as the introduction to the entire MOM chapter training. They establish the context and purpose of the information being presented. Let's break down each component:
NABH 6th Edition:
NABH (National Accreditation Board for Hospitals & Healthcare Providers): NABH is the leading accreditation body for healthcare organizations in India. It sets standards for quality and patient safety. It's crucial to understand that this training is based on NABH standards, meaning the content is driven by the requirements of this accreditation body.
6th Edition: This explicitly states that the training is based on the latest edition of the NABH standards, the 6th Edition. This is important because NABH standards are periodically updated to reflect advancements in healthcare, evolving best practices, and lessons learned from implementation. Mentioning the 6th Edition right at the start signals that this is current and up-to-date information for hospitals aiming for NABH accreditation.
ACCREDITATION STANDARDS FOR HOSPITALS:
Focus on Hospitals: This clarifies the target audience and scope of the standards being discussed. NABH has different accreditation programs for various types of healthcare organizations (e.g., small healthcare organizations, blood banks, etc.). This introduction specifically points to the standards designed for hospitals. This is important for professionals in hospitals as it directly relates to their work environment and accreditation goals.
Accreditation Standards: These are not just suggestions or guidelines, but rather standards that hospitals are assessed against during the accreditation process. Meeting these standards is a requirement for achieving and maintaining NABH accreditation, which has implications for a hospital's reputation, patient trust, and potentially payer contracts.
CHAPTER 3: MANAGEMENT OF MEDICATION (MOM):
Chapter 3: This places the topic within the broader structure of the NABH standards document. The standards are organized into chapters covering different functional areas of a hospital. Knowing it's Chapter 3 helps orient individuals familiar with the NABH manual and quickly locate this section within the larger document.
MANAGEMENT OF MEDICATION (MOM): This clearly defines the specific topic of this chapter and training. "Management of Medication" is a critical function in any hospital. It encompasses all processes related to medications, from procurement and storage to prescription, dispensing, administration, and monitoring. The acronym "MOM" is introduced, which is used consistently throughout the presentation for brevity. This immediately signals that the training will be centered around medication safety and effective medication management practices.
Changes from 5th to 6th Edition in the Introduction Context:
Looking specifically at the slides and OCR text provided, there are no explicit changes mentioned for the introduction itself between the 5th and 6th Editions. The titles, headings, and overall components (NABH, Accreditation Standards, MOM chapter, CAHO) remain consistent.
However, the presentation does highlight general changes within the MOM chapter for the 6th Edition compared to the 5th. These changes, while not direct alterations to the introductory text, are crucial to understand as they set the stage for the entire chapter's update:
"Summary of Changes (6th edition Vs. 5th edition)" slides are presented early. This signifies that the 6th Edition is not just a minor revision, but incorporates important updates. The fact that changes are being summarized right after the introduction indicates their significance and that the training will specifically address these updates.
Intent of MOM is elaborated in a new slide. This could be seen as an enhancement of the introduction. While the core intent of MOM likely remained consistent between editions, explicitly outlining the "Intent of MOM" at the beginning of the training (as shown on Page 2 of the OCR) is a notable improvement in the 6th edition training material. It provides a clearer and more structured starting point for understanding the chapter's objectives. This helps participants grasp the why behind the MOM standards before diving into the specifics of what the standards are.
Modifications to Intent specifically mention new elements for the 6th edition: "Modified to include: Medication safety officer, Reconciliation of medication at transition points and patient care areas." These modifications, while related to the "Intent," are highlighted immediately after the introduction. This implicitly signals that the 6th Edition has broadened or emphasized these specific aspects of medication management that were potentially less prominent or newly added compared to the 5th edition.
In Summary Regarding Introduction Changes:
The basic introductory elements (NABH, Accreditation Standards, MOM, CAHO) remain largely the same in terms of structure and focus.
No explicit textual changes to the initial introductory headings are mentioned or apparent.
The key change in the "introductory context" is the emphasis on the updates for the 6th Edition right from the start. This is achieved through:
Clearly labeling the training for the 6th Edition.
Presenting "Summary of Changes" slides early on.
Elaborating the "Intent of MOM" explicitly, including new elements for the 6th edition like the Medication Safety Officer and Medication Reconciliation at transition points.
Therefore, while the basic introductory components are consistent, the 6th Edition introduction in the training material is enhanced by immediately highlighting the updates and the core purpose of the MOM chapter in a more structured manner. The emphasis is on the evolution and improvement reflected in the 6th Edition standards, particularly in areas like medication safety officers and reconciliation, which are introduced as key updates early in the presentation.
This overarching standard is the cornerstone of medication safety in the NABH framework. It’s not just a statement of intent; it's a guiding principle that should permeate every aspect of how a hospital handles medications. The core idea is to minimize the risk of medication-related harm to patients. Let's break down each sub-element to see how this overarching goal is achieved.
Rationale: Imagine a hospital where medication procedures are passed down verbally, change based on individual preferences, or are inconsistently applied across departments. Chaos and errors are inevitable. Written guidance brings consistency, predictability, and accountability to medication processes. It acts as a standardized playbook, ensuring everyone is on the same page and follows established best practices.
Practical Implementation Examples:
Formulary Guidance: The written guideline wouldn't just list the formulary drugs, but also detail how the formulary is created and maintained. For example, it could specify:
The process for adding new drugs to the formulary (including criteria for selection, review process, committee approval).
How often the formulary is reviewed and updated (at least annually, as per MOM 2b).
How clinicians are informed of formulary changes.
Procurement Guidance: This guidance would outline:
Vendor qualification and selection criteria (ensuring reliable and reputable suppliers).
The process for placing medication orders (who is authorized, how orders are documented).
Receipt and inspection procedures (checking for damage, expiry, batch numbers).
Managing medication shortages and backorders.
Storage Guidance: This is crucial for maintaining drug integrity and safety. Examples in the written guidance would include:
Temperature requirements for different medications (including specifics for refrigerated drugs and vaccines).
Guidelines for storage security (preventing unauthorized access, theft, diversion).
Protocols for managing expired medications (segregation, proper disposal).
Arrangements for storing medications outside the central pharmacy (ward stock, crash carts - ensuring pharmacy oversight, as per Intent of MOM).
Prescription Guidance: This focuses on promoting rational and safe prescribing habits, addressing:
Hospital policy on using generic names where appropriate to promote cost-effectiveness.
Guidelines on restricted medications or those requiring specialist authorization.
Processes for medication reconciliation at admission, transfer, and discharge (as updated in 6th edition intent).
Strategies for minimizing polypharmacy and drug interactions.
Dispensing Guidance: Ensuring accurate medication provision to patients:
Steps for prescription verification by a pharmacist before dispensing.
Double-checking processes to prevent dispensing errors (right drug, right strength, right patient).
Labeling requirements for dispensed medications (patient information, dosage instructions, expiry).
Procedure for handling medication recalls (as per MOM 6b).
Administration Guidance: The cornerstone of the "5 Rights" (Right Patient, Right Drug, Right Dose, Right Route, Right Time) and beyond:
Patient identification procedures before administration (using at least two identifiers, as per MOM 7c).
Verification processes at the point of administration (checking against the medication order, physical inspection - MOM 7d).
Techniques for different routes of administration (IV, oral, IM etc.), ensuring safety and efficacy.
Protocols for administering high-risk medications (independent double-checks, as per MOM 7d).
Guidelines for documentation of medication administration (MOM 7i).
Monitoring Guidance: Ensuring patient safety post-administration:
Protocols for routine monitoring after medication administration (assessing therapeutic effect, observing for side effects).
Specific monitoring guidelines for high-risk medications or those with narrow therapeutic indices.
Procedures for reporting and managing adverse drug reactions (ADRs – as per MOM 8c onwards).
Usage Guidance: Overall framework for responsible medication use:
Hospital's commitment to antimicrobial stewardship and responsible antibiotic use.
Policies on self-administration of medications (MOM 7j) and patient-brought medications (MOM 7k).
Guidelines for managing medication samples (prohibition of selling, appropriate handling).
Rationale: Medication management is complex, crossing departmental lines and involving diverse professional expertise. A multidisciplinary committee ensures that decisions are well-rounded, consider various perspectives, and are not solely driven by one department. This collaborative approach is vital for creating a system that is safe, efficient, and patient-centered.
Importance of Committee Composition:
Clinical Department Representatives: Physicians from key specialties (Internal Medicine, Surgery, Pediatrics, etc.) bring clinical insights into medication needs, prescribing patterns, and therapeutic issues specific to their patient populations.
Administration: Management representatives ensure that medication management initiatives are aligned with overall hospital goals, are financially sustainable, and are practically implementable within the hospital's resources and infrastructure.
Pharmacist/Clinical Pharmacologist: Pharmacy professionals provide specialized knowledge about pharmacology, drug interactions, formulary management, dispensing systems, and medication safety. Clinical pharmacologists bring expertise in the rational use of drugs and optimizing medication therapy.
Nurses: Nurses are at the front line of medication administration and patient monitoring. Their input is crucial for practical considerations in medication administration workflows, identifying potential error-prone areas, and ensuring patient-centered care.
Quality Department: Quality personnel ensure that medication management processes are aligned with quality improvement principles, are regularly audited, and contribute to overall patient safety goals and accreditation standards.
Benefits of the Committee's Responsibilities:
Developing Processes: The committee's collaborative nature ensures processes are practical, clinically sound, and address the needs of all stakeholders.
Formulary Management: The multidisciplinary input leads to a formulary that is evidence-based, considers cost-effectiveness, and meets the diverse therapeutic needs of the hospital's patient population, avoiding being driven purely by cost or single-specialty preferences.
Evaluating Medication Use: The committee can analyze medication usage data from different perspectives (clinical, pharmacy, cost) to identify patterns, areas for improvement in prescribing practices, and potential cost savings opportunities, while always prioritizing patient safety and outcomes.
Monitoring Safety Incidents: The committee can collectively analyze medication errors and ADRs from different viewpoints to identify root causes that might be missed by a single department and develop more effective system-wide corrective actions.
Rationale: Healthcare is not static. New medications, guidelines, technologies, and safety concerns constantly emerge. A stagnant medication management system will become outdated and potentially unsafe. Continuous improvement through regular updates is essential to maintain a safe and contemporary system.
Importance of "Monitor and Use Information":
Monitor Literature Reviews and Best Practices: This is proactive learning. The committee doesn't just react to problems; it actively seeks out new knowledge to prevent problems and improve proactively. This could involve:
Subscribing to pharmacy journals and safety newsletters.
Attending conferences and webinars on medication safety and best practices.
Reviewing alerts and guidelines from organizations like ISMP (Institute for Safe Medication Practices), FDA, WHO, and relevant national bodies.
Benchmarking against best-performing hospitals or healthcare systems in medication safety.
Use Information to Update Processes: The gathered information isn't just for knowledge; it's for action. This step involves:
Translating new guidelines or best practices into concrete revisions of hospital policies, procedures, and protocols.
Disseminating updated information to relevant staff through training, memos, or electronic communication.
Implementing changes in workflows or systems based on new safety recommendations or technological advancements.
Real-World Update Examples:
Example 1: Look-Alike Sound-Alike (LASA) Medications: If new LASA drug pairs are identified nationally or internationally, the committee should update the hospital's LASA drug list, review storage strategies (as per MOM 3e), and update staff training to emphasize awareness of these new pairs.
Example 2: High-Risk Medication Updates: If national guidelines for safe use of a particular high-risk medication category (like concentrated electrolytes) are updated, the committee should review the hospital's protocols for prescribing, dispensing, administering, and monitoring these medications and make necessary revisions to align with the latest recommendations.
Example 3: Medication Error Trends: If the committee’s medication error analysis (as per MOM 8e) reveals a recurring type of error (e.g., wrong dose calculations in pediatric patients), they should proactively review and update relevant processes, potentially implement double-check systems for pediatric doses, or provide focused training to staff on pediatric medication safety.
Rationale: Patients' medical needs don't adhere to pharmacy opening hours. Emergencies can occur at any time, and inpatients require continuous medication access. Ensuring 24/7 medication availability is a patient safety imperative. A procedure for after-hours access bridges the gap when the regular pharmacy is unavailable.
Components of a Robust After-Hours Procedure:
Clear Trigger: The procedure needs a clear definition of "pharmacy closed" – is it nights only? Weekends? Holidays? This defines when the after-hours procedure kicks in.
Designated Access Points: Are there designated individuals who can access a limited after-hours medication supply? Is there a secure medication cabinet or dispensing system for after-hours access?
Authorized Personnel: Who is authorized to access and dispense medications after hours? Usually, this would be senior nurses, on-call physicians, or a designated on-call pharmacist (if available).
Limited Formulary: After-hours access often involves a limited formulary of essential emergency medications, not the full range of the hospital formulary. This limits risk and complexity while still meeting urgent needs. The procedure should define this limited formulary.
Documentation and Accountability: Every medication dispensed through the after-hours procedure must be carefully documented (patient name, medication, dose, time, person dispensing) to maintain accountability, inventory control, and ensure accurate billing.
SOP Details: The SOP itself should outline step-by-step instructions:
Confirmation of pharmacy closure.
Authorization process for accessing medications (who needs to approve).
Location of after-hours medication stock.
Dispensing and documentation steps.
Procedure for replenishing after-hours stock when the pharmacy reopens.
Why 24-Hour Pharmacy is Preferable: While an after-hours procedure is a minimum requirement, a 24-hour pharmacy offers significant advantages:
Full Pharmacist Oversight: 24/7 pharmacy ensures continuous pharmacist review of prescriptions, dispensing accuracy, and drug information support, minimizing errors and maximizing patient safety at all times.
Wider Medication Availability: A 24-hour pharmacy can maintain a broader range of medications readily available, not just a limited emergency stock.
Improved Efficiency and Workflow: Reduces reliance on complex after-hours procedures and designated personnel, streamlining medication access for staff and patients around the clock.
Rationale: Information is power, especially in a complex system like medication management. If staff are unaware of crucial changes, errors and unsafe practices are more likely. Timely and effective communication is a critical safeguard.
Characteristics of an Effective Communication Mechanism:
Designated Responsible Person/Team: Clearly identify who is responsible for initiating and disseminating these communications (e.g., Pharmacy In-charge, Medication Safety Officer, Pharmacy Committee).
Multiple Communication Channels: Utilize various methods to reach all relevant staff. Examples include:
Email alerts: For broad announcements and updates.
Intranet postings: For detailed information, policies, and procedures.
Department meetings/huddles: For face-to-face communication, discussions, and Q&A, especially for critical or complex changes.
Notice boards/bulletin boards: For visual reminders and quick updates in key areas like pharmacy, nursing stations.
Training sessions/workshops: For more in-depth education on significant changes or new protocols.
Defined Content and Format: Standardize the communication format to ensure clarity and consistency. Information should be concise, accurate, actionable, and easily understandable.
Targeted Communication: Ensure that communication reaches the relevant staff. Not every change needs to be communicated to every single employee. Identify the staff groups who need to be informed about each specific type of change.
Documentation of Communication: Keep records of communications sent (e.g., email logs, meeting minutes) as proof of compliance and for future reference.
Examples of Communication Scenarios:
Medication Shortages: When a drug goes into shortage:
Pharmacy informs prescribers about the shortage and recommends therapeutic alternatives (via email, intranet).
Pharmacy staff updates dispensing system to reflect the shortage and guide substitutions.
Nursing staff is informed about potential changes in medication orders and alternative options.
Drug Recall: For a Class I recall (serious risk):
Pharmacy immediately issues a hospital-wide alert (email, urgent intranet posting).
Pharmacy and nursing staff are tasked with identifying and removing the recalled product from all storage locations (pharmacy, wards, crash carts).
Prescribers are notified to immediately discontinue use of the recalled drug and consider alternatives.
Patients who may have received the recalled drug may need to be identified and contacted (depending on the nature of the recall).
Serious Adverse Medication Event Trends: If analysis reveals a concerning trend in ADRs with a particular drug or drug class:
The Pharmacy Committee/Medication Safety Officer might issue an alert to prescribers about the trend, recommending more cautious prescribing or specific monitoring strategies.
Nursing staff might be alerted to be especially vigilant for signs of ADRs with that drug.
Pharmacy may review dispensing procedures to ensure appropriate patient counseling about potential side effects.
This standard focuses on the crucial role of a hospital formulary in ensuring rational, safe, and cost-effective medication use. A formulary is essentially a list of medications approved for use within a hospital. It's a dynamic document that reflects the hospital's clinical needs, evidence-based practices, and safety considerations.
Let's break down the objective elements (sub-sections) of MOM 2:
Key Phrase: "Developed collaboratively by the multidisciplinary committee" and "appropriate for patients and scope of services."
Requirement: The hospital's formulary isn't just created in isolation by the pharmacy department. It must be a product of collaborative effort by the multidisciplinary committee (as established in MOM 1b). The selection of medications for the formulary must be directly tied to the patient population served by the hospital and the range of clinical services it offers. It's about aligning the available medications with the actual needs of the hospital's patients.
Rationale: A collaboratively developed formulary ensures:
Clinical Relevance: Medications included are those genuinely needed by the hospital's patient population, considering the diseases treated and services offered.
Evidence-Based Practice: Selection can be based on clinical guidelines, efficacy data, and expert consensus, rather than solely on cost or pharmaceutical company promotions.
Multidisciplinary Input: Input from clinicians, pharmacists, and administration ensures a balanced approach, considering clinical needs, pharmacy operations, and cost-effectiveness.
Rational Use: A well-defined formulary promotes more rational prescribing, as clinicians are guided towards a pre-approved list of effective and safe medications.
Practical Implementation - Developing the Formulary:
Develop Based On:
Organisation's mission: The formulary should align with the hospital's overall mission and values. For example, a mission focused on specialized care for cardiac patients would necessitate a strong cardiology section within the formulary.
Patient's need: The formulary should prioritize medications commonly used to treat the conditions prevalent in the hospital's patient population. Consider epidemiological data for the region.
Scope of services: The range of clinical services offered by the hospital directly dictates the required medication categories in the formulary. A hospital with a robust oncology department will need a comprehensive chemotherapy section.
Include: The essential components to be specified for each medication in the formulary list:
Name of the molecule (Generic name): Using generic names promotes consistency and cost-effectiveness. Brand names might be listed alongside for clarity, but generic names should be primary.
Formulation: Specify the available dosage forms (tablets, injections, creams, solutions, etc.). The formulary might list multiple formulations if clinically relevant (e.g., both oral and IV forms of an antibiotic).
Strength(s): Detail the available strengths for each formulation (e.g., amoxicillin 250mg capsules, 500mg tablets). This helps guide prescribing and dispensing and standardizes available options.
Consider: Factors the committee must deliberate upon during formulary development:
Harm potential of a medication: Evaluate the risk-benefit profile. Medications with a higher potential for serious adverse events (high-risk medications – see MOM 3c) might require stricter formulary inclusion criteria, usage guidelines, or even restriction.
Interaction with other medications: Consider common drug interactions, especially if the hospital patient population is likely to be on multiple medications (e.g., elderly patients). The formulary could prioritize medications with fewer interaction concerns or include guidelines on managing interactions.
Likelihood of patient safety incidents: Medications known to be associated with a higher rate of medication errors (e.g., LASA drugs) might require special consideration in formulary inclusion and necessitate extra safety measures.
Limit: A crucial aspect of formulary management:
Number of drug concentrations of a drug: Limiting the number of strengths and formulations of a drug is a key formulary management strategy. Too many options can increase complexity, confusion, and the risk of medication errors. Standardizing to a clinically sufficient but limited range of strengths simplifies processes and reduces errors.
Points to Remember:
Organisation can have system wise/speciality wise formulary: Hospitals can choose to have a hospital-wide formulary or develop specialty-specific formularies (e.g., a cardiology formulary, an oncology formulary) if their services are highly specialized. However, a central, overarching formulary system is usually beneficial for consistency and overall management.
Implants and devices are considered as drugs: For the purpose of NABH MOM standards, implantable prosthesis and medical devices are also considered under the umbrella of "medications" or items to be managed within the medication management system. This is important for MOM 10 specifically.
Key Phrase: "Reviewed and updated collaboratively...at least annually." Emphasizes dynamism and regular review.
Requirement: The formulary is not a static document. It needs to be reviewed and updated at least once a year by the multidisciplinary committee. This ensures it remains current with the latest medical advances, safety information, and changing patient needs. "Collaboratively" is reiterated, emphasizing that updates should also be a committee decision.
Rationale: Regular review and update is critical because:
Medical Advancements: New, more effective, or safer medications are continuously being developed. The formulary needs to incorporate these advancements to provide patients with the best possible care.
Safety Updates: New safety information, drug recalls, or adverse event reports may necessitate changes in formulary inclusion, usage guidelines, or even removal of certain medications.
Changing Disease Patterns: The prevalence of diseases within the hospital's patient population might shift over time, requiring adjustments to the formulary to reflect current needs.
Cost-Effectiveness Considerations: Generic medications become available, or the cost of certain medications might change significantly. Formulary updates can consider these factors to promote cost-effective yet clinically appropriate medication use.
Resistance Patterns: In areas like antibiotics, emerging resistance patterns require formulary updates to ensure the hospital is using the most effective agents while minimizing the development of further resistance.
Practical Implementation - Reviewing and Updating:
Review and update: The scope of the review can be:
All medications: A comprehensive annual review of the entire formulary.
Only certain medication categories: Focused reviews on specific therapeutic areas (e.g., antibiotics, anticoagulants, pain medications) based on emerging issues, new guidelines, or usage data.
Include in revised list: Important source of input for formulary updates:
Non-formulary drugs procured previous year: If there's a pattern of frequently procuring medications that are not on the formulary (through non-formulary drug request processes – see MOM 2f), it indicates a potential gap in the current formulary. The committee should review these non-formulary drugs to assess if some should be added to the regular formulary in the next revision.
Discuss: Key aspects to be discussed during the review and update process:
Aspects of patient safety including adverse drug reactions: Review ADR reports, medication error data, and any safety concerns related to formulary medications. This could lead to removing certain drugs, adding warnings, or tightening usage guidelines.
Changing disease pattern and changing resistance pattern: Analyze hospital epidemiological data, antibiotic resistance trends in the community and within the hospital, and update the formulary to align with these patterns. For instance, if resistance to a certain antibiotic class is rising, the formulary might need to favor alternative classes.
Cost: Consider the cost implications of formulary changes. Evaluate the cost-effectiveness of newer medications versus existing ones, explore generic alternatives, and assess the overall budget impact of formulary decisions.
Note: "The multidisciplinary committee should review and update the list at least annually." Reinforces the minimum frequency. More frequent reviews might be necessary if there are rapid changes in medical practice or significant safety alerts.
Key Phrase: "Available for clinicians to refer to." Emphasis on accessibility and point-of-care use.
Requirement: The formulary is only useful if it is easily accessible to the clinicians who need to prescribe medications. This standard mandates that the current version of the formulary must be readily available for reference by treating doctors and clinicians.
Rationale: If clinicians don't have easy access to the formulary:
They might prescribe medications not on the formulary, leading to increased costs, potential stock-out issues for non-formulary drugs, and deviation from rational prescribing.
They may not be aware of formulary restrictions, preferred agents, or updated guidelines.
The intended benefits of having a formulary (rational prescribing, cost-effectiveness, safety guidance) are diminished if it's not easily used in practice.
Practical Implementation - Ensuring Formulary Availability:
Who should have access to current version of formulary?
Treating doctors and clinicians: Anyone authorized to prescribe medications needs ready access. This includes physicians, residents, and in some settings, authorized advanced practice providers.
How can it be made available? Flexible options for access:
Physical form (Printed formulary): Traditional printed formulary booklets can be placed at key locations like nursing stations, clinics, and pharmacies. However, printed versions can quickly become outdated.
Electronic form (e-Formulary): Electronic access is generally preferred for easier updating and broader availability. Options include:
Hospital Intranet: Hosting the formulary on the hospital's intranet for access from any computer within the network.
Electronic Health Record (EHR) integration: Ideally, the formulary should be integrated into the EHR system, allowing prescribers to easily check formulary status and preferred medications directly within their prescribing workflow. This is the most seamless and effective approach.
Mobile Apps/Web-based Access: Providing web-based or mobile app access for clinicians to check the formulary from hospital devices or even their personal devices (following hospital security policies).
Regular Updates and Communication: Regardless of the format, it's vital to ensure that the formulary is always current and that any updates are promptly communicated to clinicians.
Key Phrase: "Clinicians adhere to the current formulary." Emphasis on compliance and appropriate prescribing.
Requirement: Having a formulary and making it available is not enough. This standard requires that clinicians actively adhere to the current formulary when prescribing medications. The expectation is that clinicians should primarily prescribe medications that are listed in the formulary, promoting rational use and cost-effectiveness.
Rationale: Adherence to the formulary:
Promotes Rational Prescribing: Guides clinicians towards using medications that have been vetted by the multidisciplinary committee, ensuring they are evidence-based and appropriate for the hospital's patient population.
Enhances Patient Safety: Formulary decisions often incorporate safety considerations, promoting the use of safer alternatives or establishing guidelines for medications with higher risk.
Controls Costs: Formularies often prioritize cost-effective medications and generic alternatives, helping to manage hospital medication expenditure.
Streamlines Pharmacy Operations: A well-adhered-to formulary simplifies pharmacy inventory management, procurement, and dispensing processes.
Practical Implementation - Promoting Clinician Adherence:
Clinician Action:
Prescribe drugs as per current formulary: The primary expectation is to prescribe formulary medications unless there is a compelling clinical reason to use a non-formulary drug for a specific patient.
Organisation Action: Monitoring and feedback mechanisms to track adherence:
Monitor frequency of prescription being rejected/local purchase done as it contained non-formulary drugs: Pharmacy systems should track prescriptions that are for non-formulary medications and require manual intervention (rejection or local purchase - meaning buying outside of regular contracts). A high frequency of these can indicate poor formulary adherence or gaps in the formulary.
Feedback and Education: If monitoring reveals low adherence, the multidisciplinary committee should investigate the reasons. It may require:
Education for clinicians: Reinforcing the importance of formulary adherence, explaining formulary policies, and highlighting the availability of the formulary resource.
Addressing Formulary Gaps: If clinicians are frequently requesting non-formulary medications because the formulary is missing essential drugs for specific clinical situations, the committee needs to reconsider formulary inclusions during the next review.
Streamlining Non-Formulary Request Process: While formulary adherence is the goal, there should be a clear and efficient process for clinicians to request non-formulary medications when clinically justified (MOM 2f addresses this). This ensures that patient needs are met while maintaining a degree of control over non-formulary use.
Objective element changed from excellence to achievement: In the 5th edition, this might have been considered an "excellence" level indicator. Shifting it to "achievement" in the 6th edition suggests that demonstrable formulary adherence is now considered a more fundamental expectation for accreditation, highlighting its importance for quality and safety.
Key Phrase: "Procedure for the acquisition of formulary medications." Focus on a structured procurement process.
Requirement: The hospital must have a well-defined procedure and actively adhere to it when acquiring medications that are listed in the formulary. This ensures a reliable, safe, and cost-effective medication supply chain for formulary drugs.
Rationale: A structured acquisition process for formulary drugs is essential for:
Consistent Supply: Ensuring that formulary medications are consistently available when needed, preventing stock-outs that could disrupt patient care.
Quality Assurance: Selecting reliable vendors and following quality control steps during procurement helps ensure the medications purchased are of good quality, authentic, and meet required standards.
Cost Management: A well-defined process can incorporate strategies for vendor negotiation, bulk purchasing, and competitive bidding to optimize medication costs.
Regulatory Compliance: Procurement procedures must comply with relevant regulations and legal requirements for purchasing, storing, and handling pharmaceuticals.
Practical Implementation - Acquisition Procedure Steps:
Vendor selection:
Establish criteria for vendor selection (reputation, reliability, quality certifications, regulatory compliance, price competitiveness, service).
Maintain a list of approved vendors.
Conduct periodic vendor evaluations (MOM 2e itself mentions "Vendor evaluation" again, likely referring to initial selection and ongoing performance monitoring).
Vendor evaluation: Ongoing assessment of vendor performance, including:
Timeliness of deliveries.
Quality of products.
Responsiveness to issues.
Compliance with agreements.
Reorder levels:
Establish appropriate reorder levels for each formulary medication based on usage patterns, lead times from vendors, and desired stock levels. This prevents stock-outs while avoiding excessive inventory.
Indenting process:
Define a clear process for departments to "indent" or request medications from the pharmacy. This might involve electronic requisition systems, standardized order forms, and authorized personnel for placing orders.
Generation of purchase orders:
Outline the steps for generating purchase orders based on indent requests, ensuring proper authorization, budget approvals, and documentation of orders placed with vendors.
Receipt of goods:
Establish procedures for receiving medication deliveries:
Verifying quantities against purchase orders.
Inspecting for damage, expiry dates, and batch numbers.
Properly documenting receipt of goods.
Stock-outs management:
Have a plan to manage medication stock-outs if they occur despite good procurement practices. This might involve:
Identifying therapeutic alternatives.
Expedited procurement from alternative vendors if possible.
Communicating stock-out situations to prescribers and relevant clinical staff.
Key Phrase: "Procedure to obtain medications not listed in the formulary" - Balancing formulary adherence with patient needs.
Requirement: While formulary adherence is important (MOM 2d), there will be legitimate clinical situations where a clinician needs to prescribe a medication that is not on the formulary. This standard requires a clear procedure for obtaining these non-formulary medications. The procedure should ensure that non-formulary use is justified, controlled, and potentially informs future formulary updates.
Rationale: A non-formulary drug request procedure:
Balances Formulary Adherence with Patient Needs: A rigid formulary could hinder optimal patient care in specific circumstances. A mechanism to access non-formulary drugs ensures flexibility for unique clinical scenarios.
Controls Non-Formulary Use: The procedure should have built-in checks to ensure non-formulary drug requests are clinically justified and not simply due to clinician preference or lack of formulary awareness.
Informs Formulary Updates: Tracking non-formulary requests provides valuable data to the formulary committee. Frequent requests for certain drugs may indicate a need to reconsider their inclusion in the regular formulary in future revisions (MOM 2b).
Maintains Documentation and Accountability: Properly documenting non-formulary requests provides a record of why these drugs were used, ensuring accountability and enabling review for appropriateness.
Practical Implementation - Non-Formulary Drug Request Procedure:
Flowchart of Steps (as shown in the slide):
Local purchase outside the formulary (Trigger): A clinician identifies a need for a non-formulary medication for a specific patient.
Evaluate: The request is evaluated. Who evaluates it? This is crucial. It could be:
Pharmacist review: Pharmacist can review for drug interactions, appropriateness, formulary alternatives, and potential safety issues.
Peer review (e.g., by a senior clinician or departmental head): For high-cost or unusual requests, peer review can add another layer of clinical justification.
Authorise: Authorization step. Who authorizes?
Pharmacy authorization: Pharmacy can authorize based on clinical justification from the prescriber and their own review.
Designated authority authorization: For very expensive or restricted non-formulary drugs, a designated authority (e.g., Head of Department, Pharmacy Committee chair, or a senior administrator) might be required to authorize.
Ratify: Ratification step. This might involve:
Pharmacy documentation: Pharmacy documents the non-formulary drug dispensing, cost, and reason.
Committee review (periodic): The formulary committee periodically reviews a summary of non-formulary drug use (perhaps quarterly or annually) to identify trends and inform formulary updates.
Decide subsequent inclusion in formulary: Based on the pattern and justification for non-formulary drug use, the formulary committee decides whether to include the medication in the regular formulary during the next review cycle (MOM 2b). If a particular drug is frequently requested and clinically justified, it's a strong indicator for potential formulary inclusion.
MOM Standard 2 is all about establishing and managing a robust hospital formulary system. It highlights the importance of:
Collaborative Development and Updating (MOM 2a & 2b): Ensuring the formulary is clinically relevant, evidence-based, and continuously improved through multidisciplinary input.
Accessibility (MOM 2c): Making the formulary a practical tool for clinicians at the point of care.
Adherence and Monitoring (MOM 2d): Promoting formulary compliance and tracking non-formulary use to inform improvements.
Structured Acquisition (MOM 2e & 2f): Having defined procedures for both formulary and non-formulary drug procurement to ensure supply, quality, cost-effectiveness, and appropriate usage.
This standard emphasizes two crucial aspects of medication management:
Appropriate Storage: Medications must be stored under conditions that maintain their quality, safety, and efficacy throughout their shelf life. This includes considerations for temperature, light, humidity, security, and organization.
Availability Where Required: Medications must be accessible at the right locations (pharmacy, wards, emergency areas) and in sufficient quantities to meet patient needs promptly.
Now, let's dissect each objective element within MOM 3:
Key Phrases: "Clean, safe and secure environment" and "manufacturer's recommendation(s)."
Requirement: This objective element mandates that medication storage environments within the hospital must meet stringent criteria:
Clean: Storage areas must be clean and hygienic to prevent contamination of medications.
Safe: Storage must be safe for both the medications themselves (protecting their integrity) and for the personnel handling them.
Secure: Storage must be secure to prevent unauthorized access, diversion, theft, and loss of medications, especially controlled substances and high-value drugs.
Manufacturer's Recommendation(s): Hospitals must adhere to the storage instructions provided by the medication manufacturers. These recommendations are based on scientific stability studies and are critical for maintaining drug quality.
Rationale: Proper storage is paramount to:
Maintain Medication Efficacy: Incorrect storage (e.g., temperature excursions) can degrade active pharmaceutical ingredients, reducing the drug's intended therapeutic effect, potentially leading to treatment failure.
Ensure Patient Safety: Degraded medications can not only be ineffective but also potentially produce harmful byproducts, posing a direct risk to patient safety.
Prevent Contamination: Unclean storage areas can harbor microorganisms or contaminants that could compromise medication sterility and safety, particularly for injectables and sterile preparations.
Control Diversion and Abuse: Secure storage, especially for controlled substances like narcotics and psychotropics, is legally mandated and ethically essential to prevent diversion, misuse, and abuse.
Meet Regulatory Requirements: Accreditation standards (like NABH) and regulatory bodies mandate proper medication storage practices as a fundamental aspect of patient safety and pharmaceutical quality assurance.
Practical Implementation - Creating a Compliant Storage Environment:
Storage Space: Clean, Safe, Secure and Organised:
Cleanliness: Implement regular cleaning schedules for medication storage areas, shelves, and refrigerators. Use appropriate cleaning agents that are compatible with pharmaceutical environments.
Safety:
Ensure adequate ventilation and appropriate temperature and humidity control in storage areas.
Provide adequate lighting for visibility and accurate medication selection.
Storage areas should be free from pests, rodents, and other potential contaminants.
Implement measures to prevent spills and breakages.
Secure:
Restrict access to medication storage areas to authorized personnel only (pharmacy staff, designated nurses, etc.).
Use locked cabinets, rooms, or automated dispensing systems, especially for controlled substances and high-value medications.
Implement inventory tracking systems and regular audits to detect and prevent medication diversion.
Organised:
Implement a systematic storage arrangement (e.g., alphabetical order by generic name, therapeutic category).
Use clear labeling and signage for shelves, bins, and drawers to facilitate easy medication identification and retrieval.
Separate different dosage forms and strengths of medications to minimize mix-ups.
Storage requirements: Adhere to manufacturer's instructions/develop and implement guidelines:
Manufacturer's Instructions are Key: The first and most important step is to always consult the medication's packaging insert or manufacturer's prescribing information for specific storage instructions (temperature range, light sensitivity, humidity, etc.).
Develop Hospital Guidelines: Translate manufacturer's recommendations into practical hospital-wide guidelines and Standard Operating Procedures (SOPs). These guidelines should specify:
Temperature monitoring frequency and documentation in medication storage areas, especially refrigerators and temperature-controlled rooms.
Actions to take in case of temperature excursions (out-of-range readings).
Procedures for handling light-sensitive medications (storage in light-protective containers or areas).
Humidity control measures, if relevant (especially in areas with high humidity).
Protocols for managing power outages that could affect temperature-controlled storage.
Storage of beyond expiry date drugs (before disposal): Store these drugs away from drugs intended for patient use:
Expired medications pose a risk of being inadvertently dispensed or administered. Therefore, expired drugs must be:
Immediately removed from active medication stock upon expiry.
Segregated and stored in a separate, clearly marked area that is physically distinct from medications intended for patient use.
Stored in a designated "quarantine" area pending proper disposal according to hospital policy and regulatory requirements.
Key Phrase: "Sound inventory control practices." Focus on organized and efficient storage management.
Requirement: Effective inventory control practices must guide how medications are stored throughout the hospital – not just in the central pharmacy, but also in wards, clinics, and other areas where medications are stored. This is about organized storage that supports efficient stock management and minimizes waste and errors.
Rationale: Sound inventory control in medication storage is crucial for:
Preventing Stock-Outs: Effective inventory management ensures that essential medications are consistently available when patients need them, avoiding treatment delays or interruptions.
Minimizing Expiry and Waste: Proper inventory control, especially using "First-Expiry, First-Out" (FEFO) principles, reduces the risk of medications expiring before use, minimizing drug waste and associated costs.
Optimizing Stock Levels: Sound practices help maintain appropriate stock levels – neither too high (leading to expiry and storage space issues) nor too low (leading to stock-outs).
Improving Efficiency: Organized storage facilitated by inventory control makes it easier and faster for pharmacy staff and nurses to locate and retrieve medications, improving workflow efficiency.
Practical Implementation - Inventory Control Methods for Storage:
Always, better and control (ABC) (Based on cost):
ABC analysis categorizes inventory items based on their annual consumption value (cost).
"A" items: High-value medications (typically 70-80% of total drug expenditure) - require tight control, frequent monitoring, and precise inventory management. Examples: expensive biologics, specialized cancer drugs.
"B" items: Medium-value medications (around 15-20% of expenditure) - moderate level of control and monitoring. Examples: commonly used antibiotics, antihypertensives.
"C" items: Low-value medications (around 5-10% of expenditure) - simpler inventory control methods, less frequent monitoring. Examples: common analgesics, multivitamins.
Storage strategies can be tailored based on ABC category. "A" items might have more secure, closely tracked storage, while "C" items might have simpler stock management.
Vital, essential and desirable (VED) (Based on criticality):
VED analysis classifies medications based on their clinical criticality.
"Vital" drugs: Life-saving medications, absolutely essential for patient survival in critical conditions (e.g., epinephrine, emergency cardiac drugs). Must always be in stock.
"Essential" drugs: Medications needed for managing common conditions, important for routine patient care (e.g., commonly used antibiotics, analgesics). Should be readily available.
"Desirable" drugs: Supportive medications or those used for less critical conditions or as adjunct therapy. Stocking levels can be more flexible, and temporary stock-outs are less critical.
"Vital" medications, by their nature, should have robust storage and inventory control to guarantee constant availability.
Fast moving, slow moving and non-moving (FSN):
FSN analysis categorizes medications based on their rate of consumption.
"Fast-moving" drugs: High consumption, frequently used medications. Require larger stock levels and frequent replenishment. Should be stored in easily accessible locations for quick retrieval.
"Slow-moving" drugs: Lower consumption rate. Smaller stock levels, less frequent ordering. Can be stored in less prime storage locations.
"Non-moving" drugs: Very low or no consumption over a defined period. Need careful review. May indicate overstocking, formulary changes, or potential expiry. Need to minimize stocking to prevent waste.
FSN analysis helps optimize storage layout. Fast-moving drugs should be readily accessible, while slow-moving or non-moving items can be stored in less convenient locations.
First expiry, first out (FEFO):
FEFO is a fundamental principle of medication storage and dispensing. Medications with the earliest expiry dates should always be stored in front and dispensed first to minimize expiry and waste.
Implement FEFO by:
Organizing shelves so that earlier expiry medications are placed in the front and are easily accessible.
Training pharmacy and nursing staff to always check expiry dates and pick the medications with the soonest expiry first.
Lead time analysis:
"Lead time" is the time interval between placing an order for a medication and receiving it from the vendor.
Lead time analysis involves:
Tracking the typical lead times for different medications from various vendors.
Incorporating lead time information into inventory management systems and reorder point calculations.
Accurate lead time data helps in setting appropriate reorder levels to prevent stock-outs while minimizing overstocking.
Key Phrase: "Defines a list of high-risk medication(s)." Proactive identification of dangerous medications.
Requirement: Hospitals must proactively define and maintain a list of "high-risk" or "high-alert" medications. These are medications that have a heightened risk of causing significant patient harm if used in error. This list is the basis for implementing enhanced safety strategies throughout the medication use process.
Rationale: Identifying high-risk medications is a cornerstone of medication safety because:
Prioritization of Safety Efforts: Focuses resources and attention on the medications that pose the greatest potential for harm, allowing hospitals to implement targeted safety strategies.
Error Prevention: Knowing which medications are high-risk allows hospitals to implement extra layers of safety measures at each step of the medication use process (prescribing, dispensing, administration, monitoring) to minimize the chance of errors.
Standardization and Awareness: A defined high-risk medication list promotes staff awareness and consistent application of enhanced safety protocols across the hospital.
Practical Implementation - Defining the High-Risk Medication List:
High-risk/high alert medications carry heightened risk for adverse outcomes: The definition of high-risk medications is based on their inherent properties and potential for harm.
Cause catastrophic harm in case of error: Errors with these medications can have severe, even life-threatening consequences for patients.
Examples (Points to Remember): The slide provides examples of common high-risk medication categories, but each hospital needs to develop its own list based on its patient population, services, and medication usage patterns. Common categories include:
Medications with low therapeutic window: Drugs where the difference between a therapeutic dose and a toxic dose is small, increasing the risk of toxicity if dosage errors occur. Examples: digoxin, warfarin, lithium, theophylline.
Controlled substances (Narcotics and psychotropic agents): High potential for abuse, diversion, and respiratory depression if misused or overdosed. Examples: opioids (morphine, fentanyl, hydromorphone), benzodiazepines.
Psychotherapeutic medications: Medications used for psychiatric conditions that can have significant side effects, drug interactions, and require careful monitoring. Examples: antipsychotics, antidepressants, mood stabilizers.
Look-alike, sound alike (LASA) medications: Drug names or packaging that are easily confused with each other, leading to medication mix-ups. Hospitals should develop their own LASA lists specific to their formulary.
Concentrated electrolytes: Highly concentrated solutions of electrolytes (potassium chloride, sodium chloride, magnesium sulfate, etc.) which can cause severe electrolyte imbalances and cardiac arrest if administered undiluted or incorrectly.
Chemotherapeutic agents: Potent cytotoxic drugs used in cancer treatment with narrow therapeutic windows and significant toxicity.
Insulin: Crucial for diabetes management but dosage errors can lead to hypo- or hyperglycemia, both of which can be dangerous.
Anticoagulants: Medications that prevent blood clotting (warfarin, heparin, enoxaparin, etc.). Over-anticoagulation can lead to bleeding complications; under-anticoagulation can increase the risk of thromboembolism.
Process for Developing the List: The multidisciplinary committee (MOM 1b) should be responsible for creating and regularly reviewing the high-risk medication list. The process should involve:
Reviewing national and international lists of high-alert medications (e.g., ISMP High-Alert Medication List).
Analyzing the hospital's own medication error data and ADR reports to identify medications frequently involved in errors or causing harm.
Considering the hospital's formulary, patient population, and services offered.
Regularly reviewing and updating the list (at least annually or more frequently as needed) to reflect new safety information and changes in medication usage.
Key Phrase: "Stored in areas...where it is clinically necessary." Controlled and targeted availability.
Requirement: While high-risk medications must be available for legitimate clinical needs, their storage should be controlled and targeted to areas where they are truly needed for patient care. This element aims to balance accessibility with enhanced security and control.
Rationale: Controlled storage of high-risk medications:
Enhances Security: Limiting storage locations reduces the number of places where these potent drugs are accessible, making it easier to implement enhanced security measures and inventory control, especially for controlled substances prone to diversion.
Focuses Safety Efforts: Concentrating high-risk medication storage in specific areas allows for more focused implementation of error prevention strategies and specialized storage conditions in those locations.
Minimizes Unnecessary Distribution: Prevents the widespread distribution of high-risk medications throughout the hospital, reducing potential exposure and the risk of errors in areas where they are less frequently needed and staff might be less familiar with their specific handling requirements.
Practical Implementation - Controlled Storage Areas:
Store high-risk medications in pre-determined areas: Identify specific locations within the hospital where high-risk medications will be routinely stored. Examples could be:
Central pharmacy: For bulk stock and controlled dispensing.
Intensive Care Units (ICUs): For critical care medications, including concentrated electrolytes and vasoactive drugs, often stored in automated dispensing cabinets with restricted access.
Operating Rooms (ORs): For anaesthetic agents and emergency medications.
Designated areas in wards (with secure access): If high-risk medications are routinely used on certain wards (e.g., oncology, cardiology), consider designated, secure storage (locked medication carts, automated dispensing units) within those wards rather than scattered throughout general ward stock.
Determine their availability in these areas based on clinical needs: The quantity and type of high-risk medications stored in each designated area should be based on a clinical need assessment:
ICUs would require a broader range and larger quantities of certain high-risk medications (e.g., vasoactive drugs, concentrated electrolytes) compared to general medical wards.
Ward stock of high-risk medications should be minimized and only include those routinely required on that specific ward, with most high-risk drugs dispensed from the pharmacy on a patient-specific basis.
Adhere to regulations, where applicable (storing narcotics): For controlled substances (narcotics and psychotropics), storage must strictly comply with all applicable legal and regulatory requirements, which often mandate:
Securely locked, substantially constructed cabinets or rooms.
Double-locked storage for Schedule II controlled substances in some regions.
Strict inventory records, dispensing logs, and perpetual inventory tracking.
Specific personnel authorized to access controlled substance storage.
Adopt safety measures to prevent inadvertent administration: In designated storage areas, implement additional safety measures, such as:
Visual cues and warning labels to clearly identify high-risk medications within storage.
Segregation strategies (e.g., storing concentrated electrolytes separately from other IV solutions).
Restricting access to automated dispensing cabinets using multi-factor authentication for high-risk drug drawers.
Regular audits of high-risk medication storage areas to ensure compliance and identify any potential security vulnerabilities.
Key Phrase: "Stored physically apart from each other" and specific examples of medication types needing separation.
Requirement: To minimize medication errors, especially mix-ups involving high-risk medications, hospitals must store specific categories of high-risk drugs physically separate from one another. The slide highlights two key categories needing separation:
Look-alike, sound alike (LASA) medications: Medications with similar names or packaging.
Different concentrations of the same medication: Different strengths of the same drug (e.g., heparin 1000 units/mL vs. heparin 10,000 units/mL).
Rationale: Physical separation is a powerful error-prevention strategy because:
Reduces Confusion: Separation visually cues staff to the distinct nature of these medications, reducing the chance of picking the wrong one due to name or package confusion.
Minimizes Proximity Errors: If LASA drugs or different concentrations are stored right next to each other, the chance of grabbing the incorrect one increases significantly. Physical distance reduces this proximity-related risk.
Reinforces Awareness: Purposeful physical separation serves as a constant visual reminder to staff to be extra vigilant when handling these specific medication categories.
Practical Implementation - Physical Separation Strategies:
LASA medications:
Make a list: Develop a hospital-specific LASA medication list (MOM 3c).
Place the list in all drug storage units: Display the LASA list prominently in pharmacies, nursing stations, automated dispensing cabinets, and any location where medications are stored or dispensed. This serves as a constant visual reminder for staff.
Physical Separation in Storage: Implement significant physical separation in storage locations:
Store LASA pairs on different shelves or in different drawers.
Ideally, store them in different areas of the pharmacy or ward (e.g., opposite ends of a shelf, different sections of a medication cart).
Use visual aids like color-coded bins or labels to further distinguish LASA pairs in storage.
Different concentration of same medication:
Develop a list from hospital formulary: Identify medications that come in multiple concentrations in the formulary. Examples: heparin, insulin, concentrated electrolytes.
Revise the list at regular intervals (Changes in formulary and changes in packaging): The list of different concentrations needs periodic review as formularies change and manufacturers may alter packaging.
Physical Separation in Storage: Implement physical separation for different concentrations:
Store different strengths of the same medication on different shelves or in distinctly labeled bins.
Use auxiliary warning labels on packaging to highlight different strengths (e.g., "1000 units/mL - LOW DOSE," "10,000 units/mL - HIGH DOSE").
In automated dispensing cabinets, ensure different strengths are in completely separate pockets/drawers that are clearly labelled.
Points to Remember:
Keep the two identified LASA drugs and different concentrations of same drug far apart (such as in opposite ends of the pharmacy): Emphasize that "physical separation" is not just putting them on adjacent shelves; it means creating meaningful spatial distance to truly minimize the risk of proximity errors.
In addition to pharmacy, follow storage practices in patient care areas as well: These separation strategies should be implemented in all medication storage locations within the hospital, not just the central pharmacy. This includes ward medication rooms, nursing stations, automated dispensing cabinets in patient care areas, and procedure areas where medications are stored.
Key Phrases: "List of emergency medications is defined" and "stored uniformly." Standardization for rapid access in emergencies.
Requirement: Hospitals must have a defined list of "emergency medications" (drugs used in life-threatening situations) and ensure these medications are stored in a standardized and easily identifiable manner in designated emergency locations (e.g., crash carts). Uniformity is key for rapid and error-free access during emergencies.
Rationale: Standardized emergency medication storage is critical for:
Rapid Access in Emergencies: In critical situations, time is of the essence. Standardized storage ensures that staff can quickly locate and retrieve needed emergency drugs without delay or confusion.
Error Reduction under Stress: Emergency situations are high-stress. Uniformity in storage and presentation reduces the cognitive load on staff and minimizes the chance of errors when selecting medications under pressure.
Efficiency and Teamwork: Standardized crash carts and emergency medication sets enable all trained personnel to quickly and effectively respond to emergencies, regardless of their specific department or usual work area, fostering better teamwork in crisis situations.
Practical Implementation - Standardizing Emergency Medication Storage:
Prepare a list: The multidisciplinary committee (MOM 1b) should define a standard list of emergency medications to be included in crash carts and other emergency medication sets. This list should be:
Based on hospital's patient population and common emergencies: Tailored to the specific needs of the hospital's patient mix and the types of emergencies typically encountered.
Developed with input from relevant specialists (ER physicians, intensivists, cardiologists, pharmacists, nurses): Ensures the list is clinically appropriate and reflects the medications most likely to be needed in emergencies.
Regularly reviewed and updated: To reflect changes in emergency medicine guidelines and best practices.
Use crash cart to store medications in a standardised manner: Crash carts (emergency carts) should be used as the primary standardized storage system for emergency medications:
Uniform Cart Design and Contents: Use the same type of crash cart throughout the hospital. Standardize the layout of drawers, compartments, and the location of specific medication categories within the cart across all carts.
Consistent Labeling and Color-Coding: Use standardized labeling (drug names, concentrations) and color-coding for medication containers and drawer labels within all crash carts. This visual uniformity helps rapid identification.
Standardized Medication Boxes/Trays: Consider using standardized medication boxes or trays within the crash cart drawers to further organize medications into categories (cardiac drugs, vasopressors, anticonvulsants, etc.) and maintain uniformity.
Point to Remember:
Do not store other drugs with emergency medications: Crash carts and designated emergency medication sets should only contain the defined list of emergency medications and related supplies (syringes, needles, IV sets, etc.). Avoid cluttering them with routine medications or non-emergency items as this can cause confusion and delay in emergencies.
Key Phrases: "Available all the time" and "replenished promptly when used." Ensuring constant readiness of emergency drugs.
Requirement: Emergency medications must be consistently available whenever and wherever they are needed in the hospital. This means both:
Maintaining adequate stock levels at all times.
Having a system for promptly replenishing emergency medications and supplies in crash carts and emergency locations after they are used. Readiness is ongoing, not just initial setup.
Rationale: Consistent availability and prompt replenishment are essential for:
Ensuring Immediate Response in Emergencies: Stock-outs or depleted crash carts render emergency medication protocols useless. Reliable availability ensures that staff can always access critical drugs when seconds count.
Maintaining Readiness: Emergency situations can arise unpredictably. Continuous availability and prompt replenishment ensure that the hospital is always prepared to respond effectively to medical crises.
Preventing Delays and Errors: Delays in finding or retrieving emergency medications due to stock-outs or unreplenished carts can lead to adverse patient outcomes. Prompt replenishment eliminates these delays.
Practical Implementation - Ensuring Constant Availability and Replenishment:
Stock adequate quantity of emergency medicines:
Determine appropriate stock levels for each emergency medication based on:
Hospital size and patient volume.
Frequency of emergencies encountered (historical data, if available).
Recommended stock levels in emergency medicine guidelines.
Lead time for replenishment.
Maintain stock levels that are sufficient to meet anticipated emergency needs, but avoid excessive overstocking that could lead to expiry.
Perform inventory check at least daily: Regular inventory checks of crash carts and emergency medication locations are essential:
Implement a daily checklist for designated staff (pharmacy technicians, nurses, assigned ward personnel) to verify the presence, quantities, and expiry dates of all emergency medications and supplies in each crash cart and emergency medication location.
Document the date, time, and name of the person performing the check.
Promptly address any identified deficiencies (missing medications, expired drugs, low stock levels) through replenishment procedures.
Note: "If the organisation follows a system of sealing the emergency cart, then the emergency cart should be checked after each use/once in a month."
Sealed Crash Carts: Some hospitals use a sealing system for crash carts (using a numbered seal). When a cart is used in an emergency, the seal is broken.
Post-Use Check is Mandatory: If sealed carts are used, a mandatory check and replenishment of the entire cart must be done after each use (when the seal is broken). This ensures that the cart is fully restocked and ready for the next emergency.
Periodic Check if Unused (Monthly): Even if a sealed cart is not used during a month, a periodic check (at least monthly) is still required to verify medication expiry dates, integrity of supplies, and overall readiness of the sealed cart.
Overall Summary of MOM 3:
MOM Standard 3 provides a comprehensive framework for medication storage, emphasizing:
Maintaining a Quality Storage Environment (MOM 3a): Cleanliness, safety, security, and adherence to manufacturer's recommendations.
Sound Inventory Control (MOM 3b): Using methods like ABC, VED, FSN, and FEFO to optimize storage and minimize waste.
Proactive High-Risk Medication Management (MOM 3c & 3d): Identifying, defining, and controlling the storage locations of high-risk medications for enhanced safety and security.
Error Prevention through Physical Separation (MOM 3e): Separating LASA medications and different concentrations to reduce mix-ups.
Standardized Emergency Medication Storage (MOM 3f & 3g): Defining emergency medication lists, ensuring uniform storage in crash carts, and guaranteeing constant availability and prompt replenishment for effective emergency response.
This standard emphasizes that medication prescriptions must be generated in a way that minimizes errors, promotes patient safety, and ensures that medications are used appropriately and effectively. It goes beyond just having a prescription order; it's about the quality and rationality of the prescribing process itself.
Let's dissect each objective element within MOM 4:
Key Phrase: "Rational prescription" and "good practices/guidelines."
Requirement: Medication prescribing within the hospital must align with established principles of "rational medication use." This means prescriptions should be guided by evidence-based guidelines and reflect good clinical practice, ensuring medications are used appropriately and effectively.
Rationale: Rational prescribing is fundamental to:
Patient Benefit: Ensuring patients receive medications that are truly appropriate for their clinical needs, leading to better health outcomes.
Minimizing Harm: Rational prescribing avoids unnecessary medication use, reduces the risk of adverse drug reactions (ADRs), and minimizes drug interactions.
Cost-Effectiveness: Promotes the use of cost-effective medications when clinically appropriate, optimizing resource utilization.
Antimicrobial Stewardship: Rational antibiotic prescribing is crucial in combating antibiotic resistance, ensuring these vital drugs remain effective for future patients.
Practical Implementation - Implementing Rational Prescription Practices:
Follow good practice: This is a broad directive, urging prescribers to embrace sound clinical judgment and evidence-based approaches in their prescribing decisions. It means going beyond just writing a prescription and considering the broader context of patient care.
Adhere to guidelines for rational prescription of medications: Hospitals should actively adopt and promote the use of evidence-based guidelines to guide prescribing practices. These guidelines can come from:
National and international clinical practice guidelines: Guidelines developed by reputable medical societies or organizations for specific diseases or conditions.
Hospital-developed guidelines: The multidisciplinary committee (MOM 1b) can adapt national/international guidelines or develop their own hospital-specific guidelines for common conditions or high-priority areas like antibiotic use.
Formulary guidance: The formulary itself (MOM 2) is a tool for rational prescribing, directing clinicians to use preferred medications.
Therapeutic protocols: Standardized treatment protocols for common conditions can guide rational medication choices.
WHO Definition of Rational Use (Quoted in slide): The slide provides the WHO definition of rational drug use:
"Rational use of medicines requires that patients receive medications appropriate to their clinical needs, in doses that meet their own individual requirements, for an adequate period of time, and at the lowest cost to them and their community."
Deconstruct the WHO Definition:
Appropriate to clinical needs: Medication is truly indicated for the patient's diagnosis and condition, not just for convenience or patient demand.
Doses that meet individual requirements: Dosage is individualized based on patient factors (age, weight, renal function, etc.) and the specific medication, not just a "one-size-fits-all" approach.
Adequate period of time: Duration of treatment is appropriate for the condition being treated; avoiding unnecessarily prolonged or overly short courses.
Lowest cost to them and their community: Considering cost-effectiveness, using generic alternatives where possible, and avoiding expensive medications when equally effective and cheaper options exist.
Points to Remember:
Written guidance should address both OP and IP prescriptions: Rational prescribing guidelines should be applicable to both outpatient (OP) and inpatient (IP) settings. While principles are similar, specific contexts might require nuances.
Clinicians should be trained/sensitized on rational prescription of medications: Education is essential. Hospitals need to provide training to prescribers on rational prescribing principles, relevant guidelines, and the hospital's formulary and therapeutic protocols. This can be through workshops, continuing medical education (CME) sessions, online modules, and regular communication about best practices.
Key Phrase: "Minimum requirements of a prescription." Focus on essential prescription elements.
Requirement: The hospital must define and enforce the minimum information that must be included in every medication prescription. This ensures that prescriptions are complete, legible, and contain all the necessary details for safe dispensing and administration.
Rationale: Incomplete or illegible prescriptions are a significant source of medication errors. Standardizing minimum requirements:
Reduces Ambiguity and Errors: Ensures all crucial information is present, reducing the chance of misinterpretation or omissions that can lead to wrong drug, dose, or patient errors.
Enhances Communication: Provides clear and standardized communication between prescribers, pharmacists, and nurses.
Improves Legibility: Guidelines on writing prescriptions, like using capital letters, enhance legibility and reduce errors due to handwriting.
Facilitates Traceability and Accountability: Requiring prescriber details and signatures makes prescriptions traceable and accountable.
Regulatory Compliance: Meeting minimum prescription requirements often aligns with legal and regulatory mandates for prescription content.
Practical Implementation - Defining and Enforcing Minimum Requirements:
Adhere to national/international guidelines and regulatory bodies: Hospitals should consider national drug regulations, pharmacy practice standards, and guidelines from organizations like ISMP or WHO when defining their minimum prescription requirements.
Write in capital letters: Promoting the use of capital letters for drug names and instructions improves legibility, especially for handwritten prescriptions (though electronic prescribing is preferred – see MOM 5a).
Initialise prescription errors or illegible prescriptions after single strikethrough and rewrite: If an error is made on a paper prescription, the recommended method of correction is a single strikethrough of the incorrect information, initialing the change, and then writing the correct information clearly. Overwriting or using correction fluid should be avoided.
Avoid using error-prone abbreviations: Hospitals must develop a list of prohibited abbreviations and ensure prescribers are trained to avoid using them. Error-prone abbreviations are those that are commonly misinterpreted and lead to medication errors. Organizations like ISMP provide lists of these abbreviations. Use full drug names, units (e.g., "units" not "U"), and dosage terms.
Points to Remember: Minimum requirements of a prescription (IPD, OPD and emergency): The slide lists the essential elements that must be on every prescription, regardless of whether it's for inpatients (IPD), outpatients (OPD), or emergency situations:
Name of the patient: Essential for patient identification.
Unique hospital number: More robust patient identifier than just name, especially for patients with common names.
Name of the drug: Clearly written, preferably using generic name.
Strength: Specify the drug strength (e.g., 250mg, 500 units/mL).
Dosage instruction: Clear directions on how to take or administer the medication (e.g., "Take one tablet twice a day," "IV infusion over 30 minutes").
Duration: Specify the length of treatment or when to stop the medication (e.g., "for 5 days," "until discharge," "continue as per OPD follow-up").
Total quantity of medicine: For outpatient prescriptions, specifying the total amount dispensed (e.g., "dispense 30 tablets").
Name, signature and registration number of prescribing doctor: Identifies the prescriber and makes the prescription accountable and traceable.
Note: "For more information, refer 'Drugs and Cosmetics Act' and 'Code of Medical Ethics'." These Indian legal and ethical frameworks provide further context for prescription requirements in India.
Key Phrase: "Drug allergies and previous adverse drug reactions are ascertained." Proactive allergy assessment.
Requirement: Before prescribing any medication, clinicians must make a reasonable effort to ascertain (find out and document) if the patient has any known drug allergies or a history of previous adverse drug reactions (ADRs). This is a fundamental patient safety step.
Rationale: Drug allergies and previous ADRs are critical patient safety information. Failing to ascertain this information:
Can Lead to Preventable ADRs: Prescribing a drug a patient is allergic to can trigger severe allergic reactions, including anaphylaxis, which can be life-threatening.
Increases Risk of Recurrent ADRs: Patients with a history of ADRs to a specific drug or drug class are at higher risk of experiencing the same or similar ADRs upon re-exposure.
Violates Patient Rights: Patients have a right to be treated safely, and preventing allergic reactions and known ADRs is a core element of safe medication practices.
Practical Implementation - Ascertaining Allergies and ADR History:
Timing of Assessment:
During initial consultation: Allergy history taking should be a routine part of the initial patient assessment, both in outpatient and inpatient settings.
At any point in time during care: Allergy status should be re-verified before prescribing any new medication, even if allergy history was taken earlier, as patient history may change or previous information might have been missed or forgotten.
Methods of Ascertainment:
Direct questioning of the patient (or family/caregiver if patient is unable to communicate effectively): Ask open-ended questions about known allergies to medications, foods, latex, and other relevant allergens. Specifically probe for drug allergies and ask about reactions experienced in the past (e.g., "What happens when you take [drug name]?").
Review of medical records: Check past medical records, allergy lists in EHRs, previous discharge summaries, and allergy bracelets/identification cards if available. However, reliance solely on records without patient confirmation is insufficient.
Documentation: It is essential to document the allergy history (or lack thereof) clearly and prominently in the patient's medical record:
Note: "Both in OP and IP, drug allergies should be documented in the medical record." This applies to both outpatient and inpatient settings.
Document the specific allergen (drug name, class, etc.).
Document the type of reaction experienced (e.g., rash, itching, anaphylaxis).
Date of allergy assessment.
Location of allergy documentation (allergy list in EHR, medication chart, etc.).
Highlight allergies prominently (e.g., use allergy alert stickers in paper charts, electronic allergy flags in EHRs).
Note on "allergy vs. intolerance/side effect": Clinicians should be trained to distinguish between a true drug allergy (immune-mediated reaction) and a drug intolerance or expected side effect. True allergies require strict avoidance, while intolerances or manageable side effects might not always preclude drug use. Accurate documentation of the type of reaction is important.
Key Phrase: "Mechanism to assist the clinician in prescribing." Providing tools for informed prescribing.
Requirement: The hospital must provide clinicians with tools and resources that assist them in making informed prescribing decisions, specifically in areas that are complex and prone to errors, like drug interactions, food-drug interactions, therapeutic duplication, and dose adjustments.
Rationale: Prescribing medications is a complex task. Clinicians need readily available information to:
Avoid Drug Interactions: Prevent harmful interactions between multiple medications a patient is taking, which can reduce drug efficacy or increase ADRs.
Manage Food-Drug Interactions: Inform patients about potential food restrictions or modifications needed while taking certain medications to ensure proper drug absorption and avoid adverse effects.
Prevent Therapeutic Duplication: Avoid prescribing multiple medications from the same therapeutic class or with the same mechanism of action unnecessarily, which increases risk and cost without added benefit.
Ensure Correct Dose Adjustments: Facilitate appropriate dose adjustments based on patient factors like renal or hepatic function, age, weight, and co-morbidities, ensuring safe and effective dosing.
Practical Implementation - Mechanisms to Assist Prescribers:
Provide clinicians with mechanisms to identify: The slide specifically lists types of assistance mechanisms should address:
Drug interactions:
Electronic drug interaction checkers: Integrate drug interaction software into the EHR/CPOE (Computerized Physician Order Entry) system. These systems automatically check for potential interactions when a new medication is prescribed and provide alerts and information.
Pharmacist consultation: Make clinical pharmacists readily available for consultation with prescribers to review medication regimens for potential interactions and provide recommendations.
Drug information resources: Provide clinicians with access to reliable drug information databases (electronic or printed) that include drug interaction information.
Food-drug interactions:
Food-drug interaction databases: Integrate databases into the EHR or make them easily accessible to prescribers to check for food-drug interactions.
Dietary counseling resources: Provide access to registered dietitians or nutrition resources who can provide dietary advice to patients, especially for medications with significant food interactions (e.g., warfarin and vitamin K-rich foods).
Patient education materials: Develop and provide patient-friendly materials on food restrictions or modifications for medications known to have food interactions.
Therapeutic duplication:
Therapeutic duplication alerts in CPOE: Integrate CPOE systems to alert prescribers if they are prescribing a new medication that has the same therapeutic effect as a medication the patient is already on.
Formulary guidance: A well-designed formulary can help minimize therapeutic duplication by preferentially listing one or two agents within a therapeutic class, rather than multiple redundant options.
Pharmacist review: Pharmacists reviewing prescriptions can identify and flag potential therapeutic duplication issues.
Dose adjustments:
Renal/hepatic dose adjustment guides: Provide easily accessible guides (printed charts, electronic resources within EHR) that provide dose adjustment recommendations for medications based on renal function (creatinine clearance) or hepatic impairment.
Pharmacokinetic/pharmacodynamic resources: Provide access to drug information resources that include pharmacokinetic and pharmacodynamic data to help guide dose adjustments in complex cases.
Clinical decision support tools: More advanced EHR systems can incorporate clinical decision support tools that automatically calculate adjusted doses based on patient parameters.
Note: "This could be in electronic or physical form." The assistance mechanisms can be delivered through various means – electronic (EHR integration, online databases, software) is generally preferred for accessibility and ease of updating, but physical resources (printed guides, charts) can also be useful, especially in areas without consistent electronic access.
Compliance Level: (E) - Excellence level. Providing robust mechanisms to assist prescribing is considered an indicator of excellence, signifying a hospital's commitment to going above and beyond basic requirements to promote truly safe and rational medication use.
Key Phrase: "Reconciliation of medications occurs at transition points." Emphasis on continuity of medication information across care settings.
Requirement: Medication reconciliation must be performed at key transition points in a patient's care within the hospital. This means systematically creating a complete and accurate list of the patient's medications, comparing it to the physician's admission, transfer, and/or discharge orders, and resolving any discrepancies.
Rationale: Medication reconciliation at transitions of care is crucial to:
Prevent Medication Errors at Transitions: Transitions are high-risk points for medication errors. Patients often have multiple medications, and changes in care settings can lead to omissions, duplications, drug interactions, or dosing errors if medication lists are not accurately and consistently managed.
Ensure Accurate Medication History: Creating an accurate "best possible medication history" (BPMH) at admission is the foundation for safe medication management throughout the hospital stay.
Improve Communication: Reconciliation improves communication about medications between different healthcare providers involved in a patient's care across different settings.
Reduce ADRs and Readmissions: By minimizing medication errors at transitions, reconciliation contributes to reducing ADRs and potentially preventing medication-related hospital readmissions.
Patient Safety Goal: Medication reconciliation is often a core patient safety goal for hospitals and is emphasized by organizations like The Joint Commission and WHO.
Practical Implementation - Implementing Medication Reconciliation:
What is the purpose of medication reconciliation?
To ensure list of medications is complete and up-to-date with past clinical conditions and current care plan: The goal is to create the most accurate and comprehensive medication list possible, considering all medications the patient is taking (prescription, OTC, herbal, supplements), previous conditions, and current treatment plan.
When should it be done? (Transition points):
At transition points (At the time of admission, transfer of patient or at the time of discharge): Key transition points where reconciliation is most important:
Admission: Creating the BPMH upon hospital admission is crucial.
Transfer of patient (Between units within the hospital, e.g., from ER to ward, ward to ICU): Medication regimens may need to be re-evaluated and reconciled when patients move between care units.
At the time of discharge: Ensuring patients have an accurate and understandable discharge medication list is critical for safe medication management at home and in the outpatient setting.
After cross-consultation: If a patient has a consultation with a specialist, reconciliation might be needed to integrate any new medication recommendations into the overall medication plan.
During handover: During shift changes or when care is handed over between healthcare providers, medication reconciliation can help ensure accurate communication of the medication regimen.
Process for Reconciliation: A typical medication reconciliation process involves:
Collect BPMH: Gather the most complete list of the patient's medications. Sources include:
Patient interview.
Patient's medication containers brought from home.
Outpatient pharmacy records (with patient consent).
Primary care physician records.
Previous hospital records (if available).
Compare BPMH to current orders: Compare the BPMH to the medications prescribed upon admission, transfer, or at discharge by the hospital physician.
Identify discrepancies: Note any differences between the BPMH and the new orders (omissions, additions, changes in dose, route, frequency, etc.).
Resolve discrepancies: Investigate and resolve any discrepancies. This often involves:
Consulting with the prescriber to clarify intended orders and rationale for changes.
Verifying if omissions are intentional or unintended.
Ensuring any unintended discrepancies are corrected.
Communicate and document:
Communicate the reconciled medication list to all relevant healthcare providers (physicians, nurses, pharmacists).
Document the reconciled medication list in the patient's medical record.
Document any changes made or discrepancies resolved during the reconciliation process.
Note: "The process should be documented." The entire medication reconciliation process, including roles and responsibilities, steps involved, documentation procedures, and training should be documented in a hospital policy or procedure.
Key Phrase: "Verbal orders...safe medication management practices." Controlling risks of verbal orders.
Requirement: Verbal medication orders (orders communicated orally, usually by phone) are inherently more error-prone than written or electronic orders. This standard requires that if verbal orders are used (which should ideally be minimized), they must be implemented with stringent safety practices in place to mitigate the associated risks.
Rationale: Verbal orders increase the risk of errors due to:
Mishearing or Misunderstanding: Oral communication is prone to mishearing, especially over the phone or in noisy environments.
Lack of Written Record at the Time of Ordering: No immediate written confirmation of the order increases the chance of forgetting details or discrepancies in what was intended and what was heard.
Potential for Ambiguity and Incompleteness: Verbal orders may be less detailed than written orders, increasing the risk of omissions or ambiguity.
Lack of Verification: Verbal orders might bypass standard verification steps that are built into written or electronic ordering processes.
Practical Implementation - Implementing Safe Verbal Order Practices:
Written guidance: The slide emphasizes the need for written guidelines addressing key aspects of verbal orders:
Who can give verbal orders?: Clearly define who is authorized to give verbal medication orders. Typically, this should be restricted to licensed independent practitioners (physicians, dentists, etc.) and only when direct written or electronic ordering is not immediately possible.
When can it be given?: Define when verbal orders are permissible. Verbal orders should ideally be limited to:
Urgent situations: Emergencies or situations where immediate medication administration is crucial, and waiting for a written or electronic order would cause unacceptable delay in patient care.
Situations where immediate written or electronic communication is not practical: For example, during a code situation, in areas with limited electronic access, or when a prescriber is urgently needed to give an order remotely.
How to authenticate these orders?: Define the procedure for authenticating verbal orders to create a written record and ensure accuracy.
Points to Remember: Verbal orders:
Limit to urgent situations where immediate written or electronic communication is not practical: Stress that verbal orders should be the exception, not the rule. Encourage written or electronic orders as the primary method whenever feasible.
Order only approved list of formulary drugs. This list can be defined either by inclusion/exclusion: Consider limiting verbal orders to a pre-defined, restricted list of medications. This list could be:
Inclusion list: A list of drugs that can be verbally ordered (e.g., emergency medications, frequently used IV medications).
Exclusion list: A list of drugs that cannot be verbally ordered (e.g., high-risk medications, chemotherapy, controlled substances – unless in genuine emergency with stringent safeguards). This approach is more restrictive and generally safer.
Follow repeat back/read back: The "repeat back/read back" (or "hear back and verify") technique is essential for verbal orders. The person receiving the verbal order must:
Write down the order as they hear it.
Read back the entire order verbatim to the prescriber. (e.g., "Doctor, I have written down: [Drug name] [Dose] [Route] [Frequency] for [Patient name]. Is this correct?").
Wait for the prescriber to confirm that the read-back is accurate.
Doctor should countersign (within 24 hours): Crucially, a written and signed (or electronically signed) prescription must be obtained from the prescriber to authenticate the verbal order as soon as practically possible, ideally within 24 hours. This provides a permanent written record and formal authorization.
Documentation of Verbal Order: Document the verbal order in the patient's medical record, including: date, time, drug, dose, route, frequency, prescriber's name, name of person receiving the order, and indication that it was a verbal order. Note when the countersigned written order was obtained.
Key Phrase: "Audit of medication orders/prescription...safe and rational prescription." Proactive monitoring of prescribing quality.
Requirement: The hospital must conduct periodic audits (reviews) of medication orders/prescriptions to proactively assess and ensure that prescribing practices are safe and rational. This is a quality improvement activity to identify areas for improvement in prescribing.
Rationale: Regular prescription audits:
Identifies Potential Prescribing Errors or Issues: Audits can detect patterns of prescribing errors, irrational medication choices, deviations from guidelines, or potential areas of overuse or misuse.
Provides Data for Quality Improvement: Audit findings provide data that the multidisciplinary committee (MOM 1b) can use to identify system weaknesses, educational needs, and areas for process improvement in medication management.
Promotes Adherence to Guidelines and Formulary: Audits can assess the extent to which clinicians are adhering to hospital guidelines, formulary policies, and rational prescribing principles.
Enhances Patient Safety: By identifying and addressing prescribing issues, audits contribute to overall medication safety and better patient outcomes.
Practical Implementation - Conducting Prescription Audits:
Audit Points (What to check): The slide suggests points to consider during an audit, ensuring a focus on safety and rationality:
Legibility and use of capital letters in written orders: Check for compliance with hospital guidelines on prescription legibility (MOM 4b and 5c).
Appropriateness of drug, dose, frequency and route of administration: Assess if the prescribed drug, dose, frequency, and route are clinically appropriate for the patient's diagnosis, condition, and relevant patient factors (age, renal function, etc.). This involves reviewing a sample of patient charts and prescriptions.
Presence of therapeutic duplication: Check for instances of potential therapeutic duplication, where patients are prescribed multiple medications with similar therapeutic actions unnecessarily.
Possibility of drug interaction, food-drug interactions and steps taken to avoid them: Assess if the audit sample reveals prescriptions where potential drug-drug or food-drug interactions are likely and if appropriate steps (dose adjustments, monitoring, patient counseling) are documented.
Requirements of this standard (safe and rational prescription of medications): The audit should generally assess overall compliance with the principles of safe and rational prescribing as outlined in MOM 4 and related standards.
Points to Remember:
Perform an audit once in a month: Regular, at least monthly, audits are recommended to provide ongoing monitoring and feedback.
Use representative sample size: Audits do not need to review every single prescription every month. A representative sample of prescriptions should be selected for audit. The sample size should be large enough to provide meaningful data (e.g., a random sample from different departments or patient populations).
Staff in-charge: Clinical pharmacologist/clinical pharmacist/multi-disciplinary committee: The audit should be overseen or conducted by qualified personnel. This could be:
Clinical Pharmacologist or Clinical Pharmacist: Bring specialized expertise in pharmacology and rational drug use to the audit process.
Multidisciplinary committee (or a subcommittee): The MOM 1b committee can delegate audit activities or review audit findings and recommend actions.
Collaboration between pharmacists, physicians, and nurses in the audit process can provide a more comprehensive assessment.
Key Phrase: "Corrective and/or preventive action(s) is taken based on the audit." Audit is not just data collection, it's for action.
Requirement: The audit process is not complete with just data collection and identification of issues (MOM 4fg). This objective element requires that the hospital must take appropriate corrective actions to address identified prescribing issues and preventive actions to avoid future recurrence of similar issues. The audit findings must drive improvement.
Rationale: Without follow-up action, audits become just exercises in data collection without any real impact on patient safety or quality. Implementing corrective and preventive actions closes the quality improvement loop and ensures that audits lead to tangible improvements in prescribing practices.
Practical Implementation - Action Cycle Based on Audit Findings:
Perform root-cause analysis: If the audit identifies significant or recurrent prescribing issues, perform a root-cause analysis (RCA) to understand the underlying system factors contributing to those issues, rather than just blaming individual prescribers. RCA helps identify systemic weaknesses in processes, training, communication, or systems that need to be addressed.
Take CAPA (Corrective and Preventive Action): Based on the root-cause analysis and audit findings, develop and implement a CAPA plan. This plan should outline:
Corrective actions: Actions taken to fix the immediate problem identified in the audit (e.g., provide feedback to individual prescribers on errors, revise a specific policy, improve a workflow).
Preventive actions: Actions taken to prevent the recurrence of similar problems in the future and improve the overall system (e.g., implement new training programs, update clinical guidelines, modify electronic prescribing system alerts, enhance communication processes).
Assign responsibility: Clearly assign responsibility for implementing each CAPA action item to specific individuals or departments.
Set timelines: Establish realistic timelines for completing CAPA actions.
Maintain records of action(s) taken: Document all corrective and preventive actions taken in response to audit findings. This documentation provides evidence of the hospital's quality improvement efforts and is important for accountability and future review.
Re-audit/Follow-up: After implementing CAPA actions, conduct a re-audit or follow-up review (after a reasonable period) to assess the effectiveness of the actions taken. Did the issues identified in the initial audit improve? Were the corrective and preventive actions successful? This completes the cycle and may lead to further refinements if needed.
MOM Standard 4 emphasizes a holistic and proactive approach to medication prescription, encompassing:
Rationality (MOM 4a): Prescribing guided by evidence-based practices and WHO principles of rational drug use.
Completeness (MOM 4b): Ensuring prescriptions contain all essential information for safe use.
Patient Safety (MOM 4c): Proactively assessing for drug allergies and ADR history.
Decision Support (MOM 4d): Providing tools to assist prescribers in complex prescribing decisions.
Continuity at Transitions (MOM 4e): Implementing medication reconciliation to prevent errors at care transitions.
Controlled Verbal Orders (MOM 4f): Minimizing and safely managing the risks of verbal orders.
Proactive Audit and Improvement (MOM 4fg & 4h): Regularly auditing prescribing practices and taking action based on findings to drive continuous improvement in medication safety and rationality.
This standard aims to ensure consistency and clarity in how medication orders are documented across the hospital. Uniformity in medication orders is a fundamental error prevention strategy, making it easier for all healthcare professionals involved (prescribers, pharmacists, nurses) to interpret and act upon the orders accurately and safely.
Let's break down the objective elements within MOM 5:
Key Phrase: "Only authorised personnel write orders." Controlling who can prescribe.
Requirement: The hospital must have a policy and system in place to ensure that only individuals who are legally and organizationally authorized are allowed to write medication orders. This prevents unauthorized prescribing, which can lead to significant safety risks and legal liabilities.
Rationale: Restricting order writing to authorized personnel is crucial to:
Ensure Competency and Accountability: Authorized prescribers are those who have the necessary medical training, licenses, and hospital-granted privileges to prescribe medications safely and responsibly.
Prevent Unqualified Individuals from Prescribing: Unauthorized individuals (e.g., medical students without supervision, non-physician staff not legally authorized to prescribe) writing orders could lead to clinically inappropriate, unsafe, or even illegal prescriptions.
Maintain Legal and Regulatory Compliance: Prescription writing is a legally defined activity. Hospitals must comply with laws and regulations that dictate who can legally prescribe medications.
Practical Implementation - Ensuring Authorised Personnel Only:
Medication order card (Paper-based systems):
Only Doctor (MBBS) should write the medication order (includes transcribing verbal/consultant orders, OP record/admission note): In traditional paper-based systems, establish a clear policy that only physicians with a recognized medical degree (MBBS or equivalent) are authorized to write medication orders on medication order sheets. This includes:
Initial orders: For new admissions, consultations, and routine prescriptions.
Transcribing verbal orders: If a verbal order is received (MOM 4f), it must be transcribed onto the written order sheet only by an authorized physician and then properly authenticated (countersigned).
Outpatient prescriptions: For patients being discharged or seen in outpatient clinics.
Admission notes and OP records: Medication orders documented within admission notes or outpatient records should also be written by authorized physicians.
Verify credentials: Pharmacy and nursing staff should be trained to recognize and verify that the person writing a paper-based order is indeed an authorized physician (e.g., checking for a physician's stamp, signature and credentials).
Electronic medical record (EMR) (Electronic systems):
Doctor should enter the prescription in the hospital information system (HIS) using his/her unique login: In EMR systems, restrict access to the medication ordering module to authorized prescribers. This is typically achieved through:
Unique login and password: Each authorized prescriber has their individual login credentials to access the EMR and prescribe.
Role-based access control: Within the EMR system, user roles and permissions are configured so that only users with the "physician" or "prescriber" role have access to the medication ordering function.
The entry made by an assistant should be verified and authorised by doctor: In some settings, a physician might delegate the data entry of medication orders into the EMR to an assistant (e.g., a medical scribe, a nurse). However, even if data entry is delegated, the final authorization and prescribing decision must always be made by the authorized physician themselves. The EMR system should have features to:
Clearly distinguish between "entered by" and "authorized by" fields for prescriptions.
Require the physician to log in separately and electronically sign to authorize and finalize the prescription entered by an assistant.
System audits: Regularly audit EMR system access logs to ensure that only authorized personnel are accessing and using the medication ordering module.
Note: "The medication order written by other authorised staff should be backed by a legislation or government order." In very specific circumstances, and only if legally permitted by local legislation or government regulations, other healthcare staff (e.g., advanced practice nurses, physician assistants, specially trained pharmacists under collaborative practice agreements) might be authorized to prescribe medications within a defined scope of practice. If such exceptions exist, the hospital's policy must be strictly aligned with and backed by the relevant legislation or government order. This should be clearly documented and communicated to all staff. However, the general rule is physician-led prescribing.
Key Phrase: "Uniform location" and "reflects patient's name and unique identification number." Standardization for order location and patient ID.
Requirement: Medication orders must always be documented in a consistent and designated location within the patient's medical record, and this location must clearly display the patient's name and unique identification number. This standardization makes it easier to find and manage medication orders and ensures proper patient association.
Rationale: Uniform location and patient identification in medication orders:
Facilitates Easy Location and Review: Standardized location allows all healthcare team members (nurses, pharmacists, physicians) to quickly find and review medication orders in the medical record without searching through different sections or notes.
Reduces Errors from Misidentification: Clearly associating the patient's name and unique ID (medical record number, patient ID band number) directly on the medication order reduces the risk of orders being misinterpreted as belonging to the wrong patient, especially when dealing with patients with similar names.
Improves Organization and Clarity: A designated medication order section keeps medication-related information organized and separate from other clinical notes, enhancing clarity and reducing the chance of overlooking medication orders.
Practical Implementation - Uniform Location and Patient ID:
Write in uniform location of medical record:
Paper-based charts: Designate a specific section within the paper chart solely for medication orders. This could be:
A dedicated medication order sheet or section at a consistent place in every patient chart (e.g., always the first or last section).
Using pre-printed medication order sheets that are consistently inserted into the chart.
Electronic medical record (EMR): In EMR systems:
Designate a specific tab or section within the patient's electronic chart dedicated to medication orders.
Ensure that the medication order section is prominently and easily accessible from the main patient chart view.
Administer only medications that are written in this location: Enforce a strict rule that nursing and pharmacy staff should only administer medications based on orders documented in this designated uniform location for medication orders. Orders written in other parts of the chart (e.g., progress notes, consultation reports, discharge summaries) should not be acted upon directly unless they are officially transcribed into the designated medication order section.
Transcribe orders written in different location to this location: If, for legitimate reasons, a medication order is initially written in a non-standard location (e.g., in an emergency note), it must be promptly transcribed into the designated medication order section of the medical record by authorized personnel. The original note should be referenced for context, but the actionable order must be in the uniform location.
Include patient's name and unique identification number: On every medication order sheet (paper) or in the header of the electronic medication order section, clearly display:
Patient's full name: Legibly written and consistently formatted.
Unique identification number: Medical record number, patient ID band number, or other unique hospital identifier to ensure correct patient association.
Ensure prescription and administration record are written on same sheet or use "Drug Kardex": For efficient workflow and error reduction, consider:
Combined prescription and administration record (paper): Using medication order sheets that are designed to also serve as medication administration records (MARs) on the same sheet. This allows nurses to directly document administration on the same form where the order is written, improving traceability and reducing transcription errors.
"Drug Kardex" (paper or electronic): A "Kardex" is a summarized patient care plan or medication profile. If using a Kardex (paper or electronic summary of medication orders), ensure it accurately reflects the medication orders from the uniform location in the chart and is used for administration documentation.
Electronic MAR integration: In EMRs, ensure that the electronic medication administration record (eMAR) is directly linked to the electronic medication orders, so that nurses administer and document against the electronic orders.
Write fresh order for change in existing order: When there is a change to an existing medication order (change in dose, frequency, route, discontinuation, adding a new medication), a fresh, new medication order should be written. Avoid altering or overwriting previous orders. This maintains a clear audit trail and prevents confusion about current vs. previous orders.
Note: Electronic orders should also follow these principles: Even in fully electronic systems, the principles of uniform location and clear patient identification are still vital. Ensure the EMR system is configured to enforce these principles.
Points to Remember:
Phrases like "CST"/continue same treatment/"repeat all"/"repeat 1,4,5,8" should not be accepted: Avoid using vague or ambiguous phrases like "CST" (continue same treatment), "repeat all," or "repeat 1,4,5,8" in medication orders. These phrases are prone to misinterpretation and errors. Each medication order should be written out completely and specifically. If continuing previous medications, list each one out individually with details.
A strike-through or over-writing the previous order is not acceptable: Altering or overwriting previous medication orders, whether on paper or electronically, should be strictly avoided as it can obscure the original order, create confusion, and compromise the audit trail. Use the "write a fresh order for change" principle instead.
Key Phrase: "Legible, dated, timed and signed." Essential elements for a valid and traceable order.
Requirement: All medication orders, whether paper-based or electronic, must be:
Legible: Easily readable and understandable to prevent misinterpretation.
Dated: Date of when the order was written or issued is essential for tracking order history and ensuring order currency.
Timed: Time of when the order was written is also important, particularly for PRN (as needed) medications or for tracking medication timing in relation to other interventions.
Signed: Identified and authenticated by the prescriber through their signature (or electronic signature in EMRs). This establishes accountability for the order.
Rationale: Legibility, dating, timing, and signing of orders are critical for:
Preventing Misinterpretation and Errors: Legible writing reduces the chance of pharmacy or nursing staff misreading the medication name, dose, or instructions.
Establishing Order Validity and Currency: Dating and timing confirm when the order was issued, allowing staff to determine if it is a current and valid order. Undated or untimed orders are ambiguous.
Ensuring Accountability and Traceability: Prescriber signature (or electronic signature) clearly identifies the person responsible for the order, making the order traceable and accountable. Essential for audit trails and error investigations.
Legal and Regulatory Compliance: Legible, dated, timed, and signed orders are often legally required components of a valid prescription.
Practical Implementation - Enforcing Legibility, Dating, Timing, and Signing:
Write in capital letters: As mentioned in MOM 4b, encouraging the use of capital letters for drug names and instructions improves legibility of handwritten orders.
Use list of approved standardised abbreviations: Hospitals should develop and enforce the use of a standardised list of approved medical abbreviations. This helps promote consistent understanding of common medical terms while prohibiting the use of error-prone abbreviations (MOM 4b). Train staff on the approved abbreviation list.
Avoid using error-prone abbreviations: Strictly prohibit the use of error-prone abbreviations (as identified by organizations like ISMP) on medication orders.
Ensure traceability of identity of person (Write name/state employee code against every order or have master signature list having name of the person against signature.): To ensure traceability and accountability:
Option 1: Write name/state employee code against every order: Require prescribers to legibly write their printed name and employee code/identification number along with their signature on every paper prescription. In electronic systems, the EMR system automatically logs the user (and thus their identity) when an order is created.
Option 2: Have master signature list having name of the person against signature: Maintain a master signature list (paper or electronic) that contains the signatures of all authorized prescribers along with their printed names and employee codes. Pharmacy and nursing staff can refer to this list to verify the signature on a prescription and identify the prescriber. This is more cumbersome than Option 1, so Option 1 is generally preferred.
Note: "For more information, refer ‘Institution for Safe Medication Practices' guidelines." ISMP provides excellent resources and guidelines on improving prescription legibility and reducing errors related to handwriting and abbreviations. Hospitals should consult ISMP guidelines to inform their policies.
Key Phrase: "Name of medicine, route, strength, frequency/time of administration." Core elements of a complete medication order.
Requirement: Every medication order must contain, at minimum, these four essential components:
Name of the medicine: Clear and unambiguous identification of the drug to be administered.
Route of administration: How the medication is to be given (oral, IV, IM, subcutaneous, topical, etc.).
Strength to be administered: The dosage strength (e.g., milligrams, units, micrograms per mL).
Frequency/time of administration: How often and when the medication should be given (e.g., "twice daily," "every 6 hours," "stat," "once a week," "at bedtime," "before meals").
Rationale: These four components are absolutely essential for a complete and actionable medication order. Missing any of these:
Creates Ambiguity and Risk of Errors: Without all four components, there is significant ambiguity and increased risk of administering the wrong drug, wrong dose, wrong route, or at the wrong time.
Makes Order Incomplete and Unactionable: Pharmacy cannot accurately dispense, and nurses cannot safely administer, a medication if the order lacks these fundamental details.
Violates Safe Medication Practices: Administering medication based on incomplete orders is a serious deviation from safe medication practices and can directly harm patients.
Practical Implementation - Ensuring Complete Medication Orders:
Write name of medicine, route of administration, strength to be administered and frequency/time of administration: Prescribers must be trained and expected to include all four of these components in every medication order. Use standardized templates or prompts in paper forms or EMR systems to remind prescribers to include all essential information.
Write strength of individual drugs (tablet/capsule/injection) of same medicine: When ordering a medication that comes in multiple strengths, the specific strength to be administered must be explicitly written in the order (e.g., "Amoxicillin 250mg capsules," not just "Amoxicillin capsules"). This is crucial to avoid dispensing or administering the wrong strength.
Record separately, if the strength differs for each time of administration: If the intended dose or strength of a medication varies at different times of the day (e.g., a tapering dose regimen), each dose and its corresponding strength must be clearly and separately recorded in the order. Avoid using a single order line that attempts to describe varying strengths over time, which can be confusing. Use separate order lines for each distinct dose/strength.
Points to Remember:
Strength of individual drugs need not be written for preparations having combination of vitamins and/or minerals: In cases of fixed-dose combination products, particularly for vitamins and minerals (where strengths are usually standardized within the combination product), it may be acceptable to write just the brand name or combination name, as long as the hospital formulary clearly defines the exact composition and strengths of each ingredient in that combination product. However, if there is any ambiguity or multiple combination product options, specifying the individual component strengths is still safer. For most single-entity drugs, always specify the strength.
Have a mechanism to take actions in case of incomplete medication orders: Pharmacy and nursing staff should be trained and empowered to question and clarify any medication order that is incomplete (missing any of the four essential components). Establish clear procedures for:
Pharmacy to reject incomplete prescriptions: Pharmacists should not dispense medications based on incomplete prescriptions and should contact the prescriber to obtain the missing information.
Nurses to clarify with prescriber before administration: Nurses should not administer any medication if the order is incomplete or ambiguous and should contact the prescriber to get clarification before administering the drug.
Documenting clarification efforts: Document all attempts to clarify incomplete orders and the resolution in the patient's medical record and/or pharmacy system.
Overall Summary of MOM 5:
MOM Standard 5 emphasizes the importance of uniformity and completeness in medication orders as a foundational element of medication safety. It focuses on:
Authorised Prescribing (MOM 5a): Ensuring only qualified and authorized individuals write orders.
Uniform Order Location (MOM 5b): Standardizing where orders are documented and associating them with patient identifiers.
Order Legibility and Traceability (MOM 5c): Requiring orders to be legible, dated, timed, and signed for clarity and accountability.
Essential Order Components (MOM 5d): Mandating that every medication order contains the drug name, route, strength, and frequency/time, ensuring completeness and actionability.
This standard emphasizes that the dispensing process, which is the critical step between a medication order and its administration to the patient, must be conducted with the utmost care and adherence to safety protocols to prevent dispensing errors and ensure patients receive the correct medications.
Let's dissect each objective element within MOM 6:
Key Phrase: "Dispensing of medications is done safely." Overarching emphasis on safety during dispensing.
Requirement: This objective element is the overarching principle for MOM 6. It requires that the entire medication dispensing process, from receiving the prescription to handing the medication to the patient (or nurse), must be conducted with a primary focus on safety and minimizing the risk of dispensing errors.
Rationale: Safe dispensing is crucial because dispensing errors can lead to:
Wrong Medication Errors: Dispensing the wrong drug to a patient, potentially causing harm, lack of therapeutic effect, or adverse reactions.
Wrong Dose Errors: Dispensing the wrong strength or dosage form, leading to under-dosing or over-dosing, with potentially serious consequences.
Wrong Patient Errors: Dispensing medication for one patient to another, leading to treatment errors and potential harm to both patients.
Expired Medication Errors: Dispensing medications that are expired, leading to reduced efficacy or potential degradation products.
Contaminated Medication Errors: Dispensing medications that have been compromised or contaminated due to improper handling or storage during the dispensing process.
Practical Implementation - Ensuring Safe Dispensing Practices:
Written guidance: The slide emphasizes the importance of written guidelines to ensure safe dispensing. These guidelines should cover:
Dispense medication only against valid prescription/medication order (except for over the counter drugs): Establish a strict policy that medications should only be dispensed by the pharmacy upon receipt of a valid medication order (prescription) written by an authorized prescriber (as per MOM 5a). This excludes over-the-counter (OTC) drugs, which are typically self-selected by patients and do not require a prescription for dispensing in retail pharmacies (but hospital pharmacies may still have policies for managing OTC medications within the inpatient setting). "Valid prescription" implies that the prescription meets the minimum requirements as per MOM 4b (patient ID, drug name, dose, route, frequency, prescriber details, etc.).
Check medication before dispensing. For example: Check generic composition, formulation, expiry date and strength of medication: Implement a robust verification process that pharmacists (or trained pharmacy technicians under pharmacist supervision, depending on regulations) must follow before dispensing any medication. This verification process should include, at minimum, checks for:
Generic composition: Verify that the medication being dispensed matches the generic name specified in the prescription and aligns with the hospital formulary (MOM 2).
Formulation: Confirm that the dosage form (tablet, capsule, injection, solution, etc.) being dispensed is the correct formulation as per the prescription (and clinically appropriate).
Expiry date: Always check the expiry date of the medication container before dispensing. Dispense only medications that are well within their expiry date. Apply the FEFO principle (MOM 3b). Do not dispense expired medications.
Strength of medication: Critically verify that the strength (dose concentration) of the medication being dispensed exactly matches the strength prescribed. Errors in strength selection are a common source of medication errors.
Do not sell physician's samples: Establish a policy that strictly prohibits the sale of physician's samples by the hospital pharmacy (if the hospital even receives or manages physician's samples at all). Physician's samples are meant to be provided free of charge to patients for specific purposes (e.g., initial dose, titration pack, patient assistance programs) and should not be sold or commercialized. Selling physician's samples is generally unethical and in some jurisdictions, illegal.
Note: Both bulk and retail pharmacy should ensure safe dispensing of medications: This note emphasizes that the principles of safe dispensing apply to all pharmacy dispensing areas within the hospital, whether it's the main inpatient pharmacy (bulk dispensing to wards) or a retail/outpatient pharmacy serving patients directly. Safety is paramount in all dispensing settings.
Key Phrase: "Medication recalls are handled effectively." Proactive management of drug recalls.
Requirement: The hospital must have a well-defined procedure in place to effectively handle medication recalls, ensuring that recalled medications are promptly identified, removed from use, and appropriate actions are taken to protect patients.
Rationale: Medication recalls are issued by regulatory authorities (like FDA in the US or CDSCO in India) or manufacturers when there are concerns about the safety, quality, or efficacy of a particular batch or product. Effective handling of recalls is essential to:
Prevent Patient Harm: Ensure patients are not exposed to potentially unsafe or ineffective recalled medications.
Maintain Patient Trust and Safety: Demonstrates the hospital's commitment to patient safety and responsiveness to safety alerts.
Legal and Regulatory Compliance: Promptly acting on recalls is often a regulatory requirement for healthcare organizations.
Practical Implementation - Effective Medication Recall Process:
Based on: The trigger for initiating the recall process:
Communication from regulatory authorities: This is the most common trigger. Regulatory bodies (like FDA, CDSCO) issue official recall notices. The hospital pharmacy must have a system to promptly receive, monitor, and act upon these official recall communications (e.g., subscribing to email alerts from regulatory agencies, monitoring agency websites).
Communication from manufacturer's: Pharmaceutical manufacturers may also initiate voluntary recalls. The hospital pharmacy must have channels to receive recall notices directly from manufacturers (e.g., through distributor networks, direct manufacturer communications).
Internal feedback (eg: visible contaminant in IV fluid bottle): In some cases, a recall might be initiated based on internal feedback within the hospital. For example, if pharmacy or nursing staff observe a visible quality defect in a medication batch (e.g., particulate matter in an IV solution, discoloration, or packaging defect), this internal feedback can trigger an investigation and potential recall action, even before an official external recall is issued.
Inform: Actions to take upon receiving recall information:
Appropriate regulatory authority in case of recall due to internal feedback: If a recall action is initiated based on internal feedback, and if the issue appears to be significant or affects a larger batch, it is important to inform the appropriate regulatory authority. This might involve reporting the quality defect to the local drug regulatory agency. This is important for transparency and to contribute to broader drug safety surveillance.
Steps in a Recall Procedure: A comprehensive recall procedure should typically include steps like:
Prompt receipt and verification of recall notice: Ensure recall information is received from reliable sources and is accurately understood.
Immediate cessation of dispensing: Immediately stop dispensing the recalled medication from the pharmacy inventory and inform all dispensing locations within the hospital to do the same.
Identify and quarantine recalled medication: Locate all stocks of the recalled medication throughout the hospital (pharmacy, wards, clinics, crash carts, automated dispensing cabinets). Physically remove the recalled medication and place it in a designated quarantine area to prevent accidental dispensing.
Review dispensing records: If possible, review dispensing records to identify patients who might have already received the recalled medication.
Patient notification (if necessary): Depending on the severity of the recall and the potential harm, consider if patient notification is needed. This is usually directed by the regulatory recall notice and may involve contacting patients, sending letters, or issuing public notices.
Manufacturer communication and return: Contact the manufacturer or distributor to arrange for the return of the recalled medication as per recall instructions.
Documentation: Document all steps taken during the recall process, including receipt of recall notice, inventory removal, quarantine, patient notification (if done), return to manufacturer, and disposal. Maintain records for audit trails and regulatory compliance.
Staff training: Ensure all relevant pharmacy and nursing staff are trained on the hospital's recall procedure and their roles in implementing it.
Key Phrase: "Near-expiry medications are handled effectively." Managing medications approaching their expiry date.
Requirement: The hospital must have a defined procedure for managing "near-expiry" medications to minimize wastage and ensure that medications are dispensed before they expire and lose efficacy.
Rationale: Effective management of near-expiry medications is important for:
Minimizing Medication Waste: Medications expiring on shelves represent a significant financial loss for the hospital. Proactive management can reduce wastage and optimize medication inventory.
Preventing Dispensing of Expired Medications: Ensuring that expired medications are not accidentally dispensed to patients is a patient safety imperative.
Cost-Effectiveness: Reducing wastage contributes to more cost-effective pharmacy operations.
Practical Implementation - Near-Expiry Medication Management Procedure:
Define near-expiry: The first step is to clearly define what "near-expiry" means for the hospital's context. The slide note suggests: "Note: Near-expiry may constitute three months before expiry date." This is a common timeframe, but hospitals can define their own timeframe based on their inventory turnover rates and dispensing practices. Common definitions are 3-6 months before expiry, but it depends on medication type and typical usage patterns.
Withdraw near-expiry drugs: Implement a system to proactively identify and withdraw medications that are approaching their defined "near-expiry" date from the active dispensing stock. This involves:
Regularly monitoring medication expiry dates (e.g., through pharmacy software reports, physical shelf checks using FEFO principles).
Identifying medications that are nearing their near-expiry timeframe.
Physically removing these medications from regular dispensing shelves or automated dispensing cabinets.
Ensure non-availability of beyond expiry date medication: The withdrawn near-expiry medications should be managed to ensure that they do not become "beyond expiry" (expired) and are never dispensed to patients after they expire. Management options for near-expiry drugs (after withdrawal from active dispensing) include:
Prioritized dispensing (if still usable): If the "near-expiry" timeframe is still within a reasonable period before actual expiry, consider implementing strategies to prioritize dispensing these medications first (while still ensuring they are dispensed before they truly expire) to use them before they are wasted. This might involve:
Using pharmacy software to flag near-expiry batches and prioritize them for dispensing for appropriate prescriptions.
Using color-coded labels or physical separation to visually identify near-expiry stock for pharmacy staff to preferentially dispense.
Return to supplier (if applicable): Check if there are agreements with medication suppliers or manufacturers that allow for the return of near-expiry medications for credit or exchange.
Donation (if permitted and appropriate): In some settings, if medications are still usable before expiry and meet quality standards, consider donating them to charitable organizations or healthcare facilities in need, if legally permissible and ethically sound.
Proper disposal (if expiry date passed or no other option): If near-expiry medications cannot be dispensed, returned, or donated before they actually expire, ensure they are disposed of properly according to hospital policy and relevant waste management regulations for pharmaceutical waste.
Key Phrase: "Dispensed medications are labelled." Importance of clear and informative labeling.
Requirement: All medications dispensed by the pharmacy must be appropriately labelled to ensure accurate identification, safe use, and provide necessary information to patients and healthcare staff. The labeling requirements depend on whether it's for outpatient or inpatient use and the dispensing format.
Rationale: Proper labelling of dispensed medications is crucial for:
Patient Safety: Clear labels help patients and nurses correctly identify the medication, dose, and administration instructions, reducing medication errors.
Accurate Administration: Labels provide nurses with essential information needed for safe medication administration (patient name, drug name, dose, route, timing, etc.).
Patient Understanding and Adherence: For outpatients, clear dosage instructions and other label information are crucial for patients to understand how to take their medications correctly at home, improving medication adherence.
Legal and Regulatory Requirements: Labeling requirements for dispensed medications are often mandated by pharmacy laws and regulations.
Practical Implementation - Medication Labelling Standards:
All medications (For OP) -> Write dosage instructions: For all outpatient dispensed medications, at a minimum, the label must include clear and easily understandable dosage instructions for the patient. This should specify:
How much to take (e.g., "Take one tablet").
How often to take it (e.g., "twice a day").
When to take it (e.g., "with meals," "at bedtime").
Route of administration (if not obvious from the dosage form, e.g., "apply to skin," "eye drops").
Any special instructions (e.g., "shake well," "take with plenty of water").
Use simple and non-technical language that patients can easily understand. Consider providing instructions in the patient's preferred language if possible.
Medications dispensed as cut strips or from bulk containers (For IP, OP and reconstituted drugs) -> Write drug name, strength, dosage instruction and expiry date: For medications that are dispensed in formats other than original manufacturer packaging, or for reconstituted medications, the label requirements are more extensive. This applies to:
Cut strips/unit doses (often for inpatients): If tablets or capsules are dispensed in cut strips or unit dose packaging (e.g., from bulk bottles), they need a new label.
Medications dispensed from bulk containers (for both IP and OP): If liquids, ointments, or other medications are dispensed from larger bulk containers into smaller dispensing containers, they must be relabeled.
Reconstituted drugs (e.g., powdered antibiotics reconstituted into solutions): Reconstituted medications always require new labels as they are prepared by the pharmacy.
For these types of dispensed medications, the label must include, at minimum:
Drug name: Generic name (and brand name if relevant and helpful).
Strength: Strength per unit dose or per mL (e.g., "Amoxicillin 250mg," "Potassium Chloride 40mEq/20mL").
Dosage instruction: As described above for outpatient labels.
Expiry date: Crucial for tracking expiry, especially for reconstituted drugs which often have shorter expiry dates after reconstitution. The label should state the reconstituted expiry date if different from the original product expiry. If dispensing from bulk, consider using a shortened "beyond-use date" (BUD) if the stability data for dispensing container is shorter than the original expiry date.
Additional Labeling Considerations (Best Practices): Beyond the minimum requirements, consider adding other elements to dispensed medication labels for improved safety and patient information:
Patient name and medical record number (especially for inpatient labels and often for outpatient as well).
Route of administration (if not oral).
Special warnings or precautions (e.g., "May cause drowsiness," "Take with food").
Hospital name and pharmacy contact information.
Barcode or QR code for medication identification and verification if using technology systems.
Key Phrase: "High-risk medication orders are verified." Extra verification for dangerous drugs.
Requirement: For orders of "high-risk medications" (as defined by the hospital in MOM 3c), a mandatory extra verification step must be implemented before dispensing. This adds a layer of safety to minimize dispensing errors for these particularly dangerous drugs.
Rationale: High-risk medications have a greater potential to cause significant patient harm if errors occur. Therefore, adding a robust verification step before dispensing is a critical safety strategy to:
Catch Potential Prescribing Errors: Pharmacist verification can identify prescribing errors in dose, drug selection, route, or frequency.
Prevent Dispensing Errors: Even with a correct prescription, there's still a chance of dispensing the wrong medication or strength. Verification aims to catch these dispensing errors specifically for high-risk drugs.
Enhance Overall Safety: Adding a verification step for high-risk medications significantly reduces the likelihood of patients receiving these drugs in error.
Practical Implementation - Verification Process for High-Risk Medications:
Verify written order before dispensing: For all orders of medications on the hospital's high-risk medication list (MOM 3c), implement a mandatory verification step before dispensing. This verification step typically involves a pharmacist review (or a trained senior pharmacy technician under pharmacist supervision, depending on local regulations). The verification should include:
Independent review of the original medication order: The pharmacist should review the original prescription or medication order (not just the dispensed medication container) to confirm:
Patient identification (name, MRN).
Drug name, strength, dosage form.
Dose, route, frequency, duration.
Prescriber details.
Clinical appropriateness for the patient (within the pharmacist's scope of practice).
Verification of dispensing process: Pharmacist should also verify that the dispensing process itself was performed correctly by pharmacy technicians, confirming:
Right medication was selected from the shelf.
Correct strength and dosage form was picked.
Labeling is accurate and complete.
Expiry date is checked.
Final dispensed product matches the prescription.
Adhere to statutory requirements: In some jurisdictions, there may be specific legal or regulatory requirements for verifying prescriptions of certain high-risk medication classes (e.g., controlled substances, chemotherapy). Ensure that the hospital's verification procedure is compliant with all applicable regulations.
"Second Check" Approach: Often, verification for high-risk medications involves a "second check" approach – meaning two qualified individuals (e.g., two pharmacists, or a pharmacist and a senior pharmacy technician) independently verify the prescription and dispensing process for extra safety redundancy. This is strongly recommended for high-risk drugs.
Documentation of verification: Document the verification process (who verified, when, that verification was completed) in the pharmacy system or medication record.
Key Phrase: "Return of medications to the pharmacy is addressed." Managing returned medications safely and appropriately.
Requirement: The hospital must have a policy and procedure to address the return of medications to the pharmacy. This is about managing medications that are returned from patient care areas or from patients themselves (e.g., unused medications after discharge, discontinued medications) in a safe, controlled, and compliant manner.
Rationale: Addressing medication returns is important for:
Medication Safety: Preventing the re-dispensing of returned medications that might be compromised or pose a safety risk if re-issued.
Inventory Control: Managing returns properly helps maintain accurate pharmacy inventory records and prevents confusion.
Waste Management: Provides a system for appropriate disposal of returned medications that cannot be reused.
Regulatory Compliance: Regulations may dictate how returned medications should be handled.
Practical Implementation - Medication Return Policy and Procedure:
Written guidance: The slide emphasizes the need for written guidance on medication returns.
Make a list of medications which would be accepted for return: Define which types of medications the pharmacy will accept for return. Common categories for acceptable returns might include:
Unopened, manufacturer-sealed medications: Often, only medications returned in their original, unopened, tamper-evident manufacturer packaging can be considered for potential reuse (after careful pharmacist inspection).
Specific dosage forms: Return policies might be limited to certain dosage forms (e.g., oral solids like tablets and capsules) and exclude others (e.g., injectables, opened liquids, creams).
Exceptions for specific drugs: Controlled substances, refrigerated medications, compounded preparations, and certain other high-risk or temperature-sensitive drugs are often not accepted for return or reuse due to safety and regulatory concerns.
Define minimum conditions for returning medication: Establish minimum conditions that must be met for a returned medication to be considered for potential acceptance and review by the pharmacy. These conditions might include:
Drug name: Clearly identifiable.
Strength: Clearly identifiable.
Batch number: Present and legible (for traceability in case of issues).
Expiry date matching bill: Expiry date must be clearly visible and preferably verified against original dispensing records or invoice.
No visible damage: Packaging must be intact, not damaged, tampered with, or compromised in any way (no tears, openings, discoloration, etc.). Medication inside must appear in good condition (no discoloration, clumping, etc.).
Ensure non-return of drug having specific temperature storage requirement: Strictly prohibit the return or reuse of medications that require specific temperature storage (e.g., refrigerated medications, frozen medications). These medications, once removed from controlled storage, cannot reliably be guaranteed to have maintained their required temperature throughout the return process, potentially compromising their efficacy and safety.
Points to Remember:
Minimum conditions for return of medications: Reiterate the minimum conditions (Drug name, Strength, Batch number, Expiry date matching bill, No visible damage). Emphasize that all conditions must be met for a return to even be considered for review.
Create awareness regarding the return of medication: Communicate the hospital's medication return policy to all relevant staff (nurses, physicians, pharmacists, patients – if outpatient returns are considered in the policy). Educate staff on the types of medications accepted for return, the conditions for return, and the process for returning medications to the pharmacy. This promotes consistent implementation of the policy.
Pharmacist review of returned medications: Even if a medication meets the minimum return conditions, a pharmacist should always inspect the returned medication before it is considered for potential reuse (if policy allows reuse in very specific and limited circumstances for unopened, sealed packages of low-risk drugs - this is generally not recommended practice for most hospitals due to risk). In most cases, and particularly for high-risk hospitals, a safer and more common practice is that returned medications are generally NOT reused or re-dispensed to other patients. Returned medications are typically segregated and disposed of according to pharmaceutical waste disposal procedures. The emphasis is on safe disposal, not reuse, in most modern hospital settings.
MOM Standard 6 is dedicated to ensuring medication dispensing is performed with a primary focus on safety at every step. Key themes include:
Verification and Accuracy (MOM 6a & 6e): Robust checks to confirm prescription validity and prevent dispensing errors, especially for high-risk medications.
Recall Management (MOM 6b): Effective procedures to handle medication recalls promptly and protect patients.
Expiry Date Management (MOM 6c): Proactive handling of near-expiry medications to minimize waste and prevent dispensing of expired drugs.
Clear Labeling (MOM 6d): Mandating informative labeling for dispensed medications to ensure safe use and patient understanding.
Controlled Medication Returns (MOM 6f): Addressing the management of returned medications to prevent unsafe reuse and ensure proper disposal.
This standard is at the very heart of medication safety because it addresses the final step before a medication reaches the patient – administration. It emphasizes that every aspect of the medication administration process must be designed and executed to minimize errors and ensure patient safety during this crucial step.
Let's dissect each objective element within MOM 7:
Key Phrase: "Permitted by law to do so." Focus on legal authorization for administration.
Requirement: Medications must be administered only by healthcare professionals who are legally authorized and competent to perform medication administration within the scope of their practice and according to hospital policy. This prevents unauthorized individuals from administering medications, which could be unsafe and illegal.
Rationale: Restricting medication administration to legally authorized personnel is fundamental for:
Patient Safety: Ensuring medications are administered by trained and qualified individuals who understand medication administration principles, techniques, and potential complications.
Legal Compliance: Medication administration is a legally defined healthcare practice. Hospitals must adhere to laws and regulations that specify who is authorized to administer medications in different healthcare settings.
Professional Accountability: Assigning responsibility to legally authorized personnel ensures accountability for safe medication administration.
Practical Implementation - Defining and Ensuring Authorized Personnel:
Registered nurse: In most hospital settings and jurisdictions, Registered Nurses (RNs) are legally authorized and trained to administer a wide range of medications across various routes of administration. The slide explicitly lists "Registered nurse" as authorized personnel. This assumes the RN has the required education, licensure, and hospital-granted competencies for medication administration.
Doctor with minimum MBBS qualification: Physicians (Doctors with MBBS or equivalent degrees) are also legally authorized to administer medications and often do so in specific situations (e.g., IV push medications, emergency medications, procedural sedation). The slide lists "Doctor with minimum MBBS qualification" as authorized personnel.
Note: "Medication administration by other authorised staff should be backed by a legislation or government order." In very specific circumstances, and only if permitted by law and regulations, other healthcare staff beyond RNs and MBBS doctors might be authorized to administer certain limited categories of medications (e.g., in some regions, trained Licensed Practical Nurses (LPNs) or Licensed Vocational Nurses (LVNs) may administer specific oral medications under RN supervision). However, such authorization must be explicitly backed by relevant legislation, government orders, or specific regulatory frameworks, and should be clearly defined in hospital policy and scope of practice documents. This should be an exception, not the rule, and carefully controlled. The core expectation is RNs and MBBS-qualified physicians as primary medication administrators in most hospital settings.
Hospital policy and scope of practice: Hospital policies should clearly define:
Who is authorized to administer medications in different roles (RN, physician, and any other legally permitted categories).
Scope of practice for each authorized category (types of medications, routes of administration they are competent and permitted to administer).
Competency assessment and training requirements for medication administration.
Supervision requirements, if any (e.g., for less experienced staff or in specific clinical areas).
Verification and education: Nursing and pharmacy leadership should ensure that all staff involved in medication administration are:
Aware of the hospital's policy on authorized personnel for medication administration.
Properly trained and competent in medication administration techniques and safety procedures.
Regularly assessed for competency maintenance.
Supervised and mentored appropriately, especially newly hired or less experienced staff.
2. MOM 7b: Prepared medication is labelled before preparation of a second drug. (C)
Key Phrase: "Prepared medication is labelled before preparation of a second drug." Immediate labelling to prevent mix-ups.
Requirement: When preparing medications, especially in settings where multiple medications might be prepared sequentially (e.g., operating rooms, procedure areas, compounding areas), the first medication prepared must be fully labelled before the preparation of a second, different medication is started. This sequential preparation and immediate labelling reduces the risk of medication mix-ups and unlabeled syringes.
Rationale: Sequential preparation and labelling:
Prevents Mix-Ups of Prepared Medications: In busy clinical settings, it's easy to get distracted or misidentify unlabeled syringes or prepared medications if multiple preparations are done at once. Labelling immediately after preparing each medication minimizes this risk of confusion.
Ensures Correct Identification: Immediate labelling prevents the risk of forgetting what medication is in an unlabeled syringe or container, especially if preparations are interrupted or staff is called away.
Maintains Order and Organization: Sequential preparation and labelling promotes a more organized and controlled medication preparation workflow, reducing potential for errors and interruptions.
Practical Implementation - Sequential Preparation and Labelling:
Prepare and load first medication: When preparing a medication for administration (e.g., drawing up a medication into a syringe, reconstituting a powder, preparing an IV admixture), focus only on that one medication at a time.
Attach label: Immediately after preparing the first medication (e.g., once the syringe is filled or the admixture is compounded), apply a complete and accurate label to the prepared medication container (syringe, IV bag, etc.). The label should include all essential information (drug name, strength, concentration, patient name, date/time of preparation, preparer's initials – hospital policy will specify required elements).
Then, prepare second drug: Only after the first prepared medication is fully labelled, start the process of preparing a second, different medication, if needed. Do not prepare multiple medications simultaneously without labelling each one sequentially.
Points to Remember/Examples:
Anaesthetic drug preparation in OTs: This is a prime example. In operating rooms, anaesthesia personnel often prepare multiple medications for induction, maintenance, and emergencies. Following sequential preparation and labelling is crucial in the fast-paced OT environment to avoid mix-ups of potent anaesthetic agents.
Chemotherapy drugs: Compounding of chemotherapy drugs requires meticulous accuracy and labelling. Sequential preparation and labelling is essential in compounding areas to prevent errors and cross-contamination between different chemotherapy agents.
General principle for all medication preparation: This principle should ideally be applied to all medication preparation in all clinical settings, not just in specialized areas. Any time a medication is prepared (drawing from a vial, reconstituting, etc.) it should be labelled immediately before moving on to prepare another, different medication.
Key Phrase: "Patient is identified before administration." Fundamental step of patient identification.
Requirement: Before administering any medication to a patient, the healthcare professional administering the medication must positively and reliably identify the intended recipient. This is the cornerstone of the "Right Patient" principle and a critical step to prevent wrong-patient medication errors.
Rationale: Patient identification is the single most important step to prevent wrong-patient medication errors. Failure to properly identify the patient:
Leads to Wrong-Patient Errors: Administering medication to the wrong patient can have severe consequences, including allergic reactions, adverse drug reactions, lack of therapeutic effect, and incorrect treatment for the actual intended patient.
Undermines All Other Safety Steps: Even if all other aspects of medication management are correct (right drug, dose, route, time), if the medication is given to the wrong patient, it is a serious and preventable error.
Violates Basic Patient Safety Principles: Correct patient identification is a fundamental patient right and a core expectation in healthcare.
Practical Implementation - Patient Identification Protocol:
At a minimum, two identifiers shall be used: The standard of care for patient identification requires using at least two different, acceptable patient identifiers to reliably verify patient identity. Relying on just one identifier is not considered sufficiently robust and increases the risk of errors (e.g., two patients with the same last name in the same ward).
Check unique identification number: One of the two identifiers must be a unique identification number that is specific to the patient and their medical record. Acceptable unique identifiers include:
Medical record number (MRN): The hospital-assigned unique MRN is an excellent identifier.
Patient ID band number: The unique number printed on the patient's wristband. Visual check of the ID band against the medication order/MAR is essential.
Check patient's name: The patient's name should be used as a second identifier. However, name alone is not a sufficient identifier because multiple patients can have the same or similar names. It must always be used in conjunction with a unique identifier. Verify the name by:
Asking the patient to state their full name: If the patient is conscious and able to communicate, ask them to state their full name.
Comparing the name on the patient's ID band to the medication order/MAR: Visually confirm that the name on the ID band matches the name on the medication order/MAR.
Acceptable Patient Identifiers (Hospital Policy should define): Hospital policy should specify the approved two patient identifiers that must be used for medication administration. Commonly accepted identifiers (beyond name and MRN/ID band number, if needed) could include:
Date of birth (DOB).
Another patient-specific identifier (e.g., unique visit number).
Unacceptable Identifiers (to be avoided as sole identifiers):
Room number or bed number (patients can be moved, rooms can be misidentified).
Patient's medical condition or diagnosis (can be shared by multiple patients).
Patient Unable to Respond: If the patient is unconscious, confused, or unable to communicate, the identification process must still be performed using the patient's ID band and verifying with a second qualified staff member if possible.
Document patient identification: In some settings (e.g., for high-risk medications, or per hospital policy), documentation of patient identification verification may be required in the medication administration record.
Key Phrase: "Verified from medication order" and "physically inspected." Two-pronged verification before administration.
Requirement: Immediately before administering a medication to a patient, the healthcare professional must perform a "double-check" process, involving both:
Verification against the medication order (or Medication Administration Record - MAR): Confirming that the medication being prepared is consistent with the prescribed order.
Physical inspection of the medication: Visually examining the medication itself for any signs of issues or discrepancies before administering it.
Rationale: Two-pronged verification:
Catches Prescription Errors: Verification against the medication order ensures that the medication being administered is actually what was prescribed. It acts as a final check for potential prescribing errors in drug, dose, route, or frequency.
Catches Dispensing Errors: Verifying against the order also helps catch any dispensing errors – if the wrong medication or strength was dispensed by the pharmacy, this verification step can identify the discrepancy before it reaches the patient.
Detects Medication Quality Issues: Physical inspection can reveal obvious medication quality problems (e.g., discoloration, precipitation, particulate matter, damaged packaging, expiry).
Ensures "5 Rights" Compliance: This verification process helps confirm key elements of the "5 Rights of Medication Administration" (Right Drug, Right Dose, Right Route, Right Time, Right Patient).
Practical Implementation - Verification and Physical Inspection:
Verify medication order: Compare the prepared medication against the information in the medication order (or MAR). The comparison should include verifying:
Right drug: Confirm that the name of the medication being prepared matches the name on the order. Check both generic and brand names.
Right dose: Verify that the dose (strength and quantity) being prepared is exactly what is prescribed. Pay close attention to units of measurement.
Right route: Confirm that the route of administration (oral, IV, etc.) is consistent with the order and is appropriate for the medication and patient.
Right time (for scheduled medications): Verify that it is the correct time to administer the medication based on the frequency and timing in the order.
Check general appearance of medication (melting and clumping): Physically inspect the medication itself before administration for any signs of quality issues:
Visual appearance: Check for any unusual discoloration, cloudiness (for solutions), precipitation, or presence of particulate matter (especially in injectables).
Physical integrity: Check for damage to tablets or capsules (crushing, breaking, melting, clumping).
Package integrity: Inspect the packaging for any tears, leaks, or signs of tampering.
Check expiry dates: Always re-verify the expiry date of the medication container immediately before administration, even if it was checked at dispensing. Expiry dates can sometimes be missed earlier in the process. Do not administer expired medications.
Defer administration in case of missing/incomplete parameters (Name, strength, route or frequency/time): If any of the essential information is missing or incomplete on the medication order, or if there's any ambiguity or discrepancy during verification or physical inspection, do not administer the medication.
Defer administration: Hold the medication administration.
Clarify with prescriber: Contact the prescriber to clarify any ambiguities, get missing information, or resolve discrepancies.
Document clarification efforts: Document the reason for deferring administration and the steps taken to clarify the order in the patient's medical record and/or medication administration record.
Points to Remember:
Verbal confirmation: "Adhere procedure for verbal order." If the medication order is based on a verbal order (MOM 4f - which should be minimized), it is even more critical to follow a rigorous "repeat back/read back" process and perform careful verification before administration.
High-risk medication(s): "At least two staff (nurse-nurse or nurse-doctor) should verify independently and document the process." For high-risk medications (MOM 3c), implement a double-check or independent verification process. This usually requires two qualified healthcare professionals (e.g., two nurses, or a nurse and a physician) to independently:
Verify the medication order.
Verify the prepared medication against the order.
Physically inspect the medication.
Document both of their verifications in the medication administration record.
Empower nurses to highlight prescription errors: Create a culture where nurses are empowered and encouraged to question prescriptions, highlight potential errors, and defer administration if they have any concerns about the order or the medication, without fear of reprisal. Nurses are often the last line of defense in catching medication errors before they reach the patient.
Key Phrase: "Strength is verified from the order." Specific focus on verifying medication strength.
Requirement: Specifically and explicitly, the strength of the medication to be administered must be verified against the medication order before administration. This is a focused subset of the broader verification in MOM 7d, highlighting the critical importance of dose and strength accuracy.
Rationale: Strength errors are a frequent and potentially serious type of medication error. Highlighting strength verification as a separate objective element underscores its significance:
Dose Errors are Common: Errors involving incorrect medication strength or concentration are a significant portion of medication errors reported.
Strength Errors Can Have Major Impact: Wrong strength administration can easily lead to under-dosing (treatment failure) or over-dosing (toxicity, ADRs), especially for medications with narrow therapeutic indices.
Multiple Strengths Available: Many medications are available in multiple strengths and concentrations. It's crucial to verify that the correct strength is being administered as per the order.
Practical Implementation - Strength Verification:
Verify strength from medication order: When performing verification before administration, place particular emphasis on confirming that the strength written on the medication order exactly matches the strength of the medication being prepared and is ready for administration. This should be a conscious and deliberate step in the verification process.
Defer medication administration in case of discrepancy: If there is any discrepancy identified between the ordered strength and the strength of the prepared medication, defer administration immediately. Do not administer the medication until the discrepancy is fully investigated and resolved by clarifying with the prescriber and/or pharmacy.
Key Phrase: "Route is verified from the order." Specific focus on verifying administration route.
Requirement: Specifically and explicitly, the route of administration (oral, IV, IM, subcutaneous, topical, etc.) must be verified against the medication order before administration. This is another focused element highlighting the importance of correct route selection.
Rationale: Route errors are also a serious type of medication error, and selecting the wrong route can have significant clinical consequences:
Wrong Route Can Lead to Ineffectiveness: Administering a medication via the wrong route can render it ineffective (e.g., giving an IV medication orally).
Wrong Route Can Cause Serious Harm: Administering a medication via the wrong route can cause severe tissue damage, systemic toxicity, or even death (e.g., giving an IV medication intended for IM use, giving intrathecal medication intravenously).
Route Errors Can Be Subtle but Dangerous: Mix-ups between IV and subcutaneous routes, or between different types of topical preparations, can occur if route verification is not meticulous.
Practical Implementation - Route Verification:
Check route and site of administration with medication order: When performing verification before administration, explicitly check and confirm that the intended route of administration written in the medication order (e.g., "IV," "oral," "IM," "topical") matches the route you are about to use for administration and is appropriate for the medication and patient. Also, for certain routes (e.g., IM, subcutaneous, topical), verify the intended site of administration (e.g., "deltoid muscle," "left thigh," "affected area of skin") as specified in the order or standard protocol.
Clarify any ambiguity: If the route of administration is unclear, ambiguous, or seems inappropriate based on the medication, patient, or clinical situation, always clarify with the prescriber or pharmacy before administering the medication. Do not assume or guess the intended route.
Key Phrase: "Timing is verified from the order." Specific focus on verifying correct administration time.
Requirement: Specifically and explicitly, the timing of medication administration (when the medication is due to be given) must be verified against the medication order (or MAR) before administration. Administering medications at the correct time is crucial for therapeutic effectiveness and patient safety.
Rationale: Correct timing of medication administration:
Maintains Therapeutic Blood Levels: For many medications, especially those given multiple times a day, maintaining consistent blood levels within the therapeutic range is important for efficacy. Giving doses too early or too late can disrupt these levels and reduce effectiveness.
Optimizes Drug Action: For some medications, timing is critical for optimal drug action (e.g., medications given before meals for better absorption, medications given at bedtime to minimize daytime sedation).
Prevents Errors Related to Frequency: Verifying timing helps ensure that medications are given at the correct intervals (e.g., every 6 hours vs. twice daily) as prescribed, avoiding over or under dosing due to incorrect frequency interpretation.
Minimizes Interactions: Proper timing can be important in managing drug interactions, e.g., separating administration times of medications known to interact.
Practical Implementation - Timing Verification:
Scheduled timing: "Verify with medication order." For medications with scheduled administration times (e.g., "every 6 hours," "twice daily," "morning," "evening"), verify that it is the correct time window to administer the dose based on the prescribed schedule and the hospital's medication administration timing policies. Check the MAR to see when the last dose was given and when the next dose is due.
Suggested timing: "Documentation of actual timing should be available when timing is not written in the medication order." For medications prescribed "PRN" (as needed) or with less specific timing instructions, document the actual time of administration in the medication administration record. This provides a record of when PRN medications were given and helps track frequency and effectiveness.
Points to Remember:
ISMP Acute Care Guidelines for Timely Administration of Scheduled Medications: The slide references ISMP guidelines, highlighting their importance. ISMP provides excellent resources on medication timing, including:
Provides guidance on scheduled medication: ISMP guidelines offer practical guidance on establishing hospital policies for medication administration timing windows, defining "on-time," "early," and "late" administration.
Classifies them into time-critical and non-time-critical: ISMP categorizes scheduled medications into "time-critical" (where even small delays in administration can be harmful – e.g., insulin, anticonvulsants) and "non-time-critical" medications. This categorization helps hospitals prioritize timing for different medication categories.
The organisation can adopt/adapt the same: Hospitals are encouraged to review and adopt or adapt ISMP guidelines for timely medication administration to develop their own timing policies that best suit their setting and patient needs.
Key Phrase: "Avoid catheter and tubing mis-connections." Preventing dangerous misconnections.
Requirement: Hospitals must implement specific measures to prevent dangerous misconnections between different types of catheters and tubing used for medication administration and other medical purposes (e.g., IV lines, feeding tubes, epidural catheters). Misconnections can lead to administering medications or fluids into the wrong route, with potentially catastrophic consequences.
Rationale: Catheter and tubing misconnections can result in severe and often preventable patient harm, including:
Intravenous administration into non-IV lines: Accidental IV infusion into feeding tubes, epidural catheters, or other non-vascular lines can cause severe tissue damage, infection, or systemic complications.
Enteral administration into IV lines: Accidental enteral feeding into IV lines can lead to serious systemic infections (sepsis) and death.
Medication administration into wrong route (e.g., IV medication into epidural space): This is extremely dangerous and can cause paralysis, neurological damage, or death.
Under-treatment or over-treatment: If fluids or medications are delivered to the wrong system, the intended therapeutic effect will be missed, and the patient may be under-treated. Conversely, if high-concentration medications are misconnected to a wrong route, it can cause overdose.
Practical Implementation - Measures to Prevent Misconnections:
Avoid inadvertent administration of a drug through a wrong route: The overarching goal of these measures is to eliminate or minimize the possibility of accidentally administering a medication or fluid into the wrong catheter or tubing route.
Use design features to prevent misconnections: Utilize specialized connectors and tubing designs that are route-specific and physically incompatible with connectors for other routes. Examples include:
Enteral-specific connectors (ENFit connectors for feeding tubes): Standardize the use of ENFit connectors for all enteral feeding tubes and devices. ENFit connectors are physically incompatible with standard IV connectors, making it impossible to connect IV tubing to an enteral feeding tube and vice versa.
Epidural-specific connectors: Utilize specialized connectors for epidural catheters that are also incompatible with IV connectors.
Regional anesthesia connectors (e.g., NRFit connectors for neuraxial regional anaesthesia): Adopt NRFit connectors for regional anesthesia catheters that are incompatible with both IV and enteral connectors.
Prompt user to take correct action: Implement systems and workflows that prompt users to double-check connections and route compatibility before making connections. Examples:
Pre-use checks and visual inspection: Train staff to always visually inspect connectors and tubing before making connections to ensure they are compatible and route-appropriate.
"Independent double-check" for high-risk connections: For connections involving high-risk routes (epidural, intrathecal, arterial lines), require a second qualified staff member to independently verify the correct connector and tubing are being used before connection.
"Line reconciliation" process: Implement a process of "line reconciliation" during patient handovers, shift changes, and at key points in care to systematically trace and verify all lines and connections.
Avoid using IV extension tubes for epidurals, irrigation, drains, central lines and to extend enteric feeding tubes: Strictly prohibit the routine use of standard IV extension tubing for routes other than IV administration. This is because standard IV extension sets can mistakenly be connected to various types of catheters and tubing, creating misconnection hazards. Use route-specific tubing whenever possible. If extension sets are absolutely needed for non-IV routes, use clearly labelled, route-specific extension sets that are distinct from standard IV extension sets (e.g., enteral extension sets with ENFit connectors).
Position functionally dissimilar tubes away from each other: In patient care areas, physically position and organize different types of tubing and catheters (IV lines, feeding tubes, drainage tubes) in a way that they are visually distinct and are less likely to be confused with each other. Avoid coiling them together or running them in parallel if possible. Use distinct labels and color-coding for different types of lines to further enhance visual differentiation.
Trace all lines from origin to connection port to verify attachments: Train staff to always trace lines from their origin to the connection port before administering any medication or fluid or making any connection. This involves physically following the tubing from the fluid/medication source, tracing it along its entire path to the patient's catheter or access port, to verify that it is connected to the intended and correct route and port. This is a critical step to ensure correct attachments and rule out misconnections before administration.
Key Phrase: "Medication administration is documented." Complete and accurate documentation of administration.
Requirement: Every instance of medication administration must be accurately and completely documented in the patient's medical record. This documentation serves as a legal record of administration, aids in patient care continuity, and is essential for medication safety monitoring.
Rationale: Documentation of medication administration is vital for:
Legal Record: The medication administration record (MAR) is a legal document that verifies that medications were administered as prescribed and is often required for regulatory compliance and medico-legal purposes.
Patient Care Continuity: Accurate MARs provide a clear and up-to-date record of the patient's medication history, allowing all members of the healthcare team to know what medications have been given, when, and by whom. This is essential for coordinating care and making informed treatment decisions.
Error Tracking and Prevention: MARs can be reviewed to track medication administration patterns, identify potential missed doses or errors, and analyze administration timing. This data can be used to improve medication administration processes.
Billing and Reimbursement: Accurate documentation is essential for billing purposes and for hospital reimbursement for medication costs.
Practical Implementation - Medication Administration Documentation:
Documentation Elements: The medication administration record (MAR) should, at a minimum, document the following essential elements for each medication administration:
Name of medication: Generic and/or brand name.
Strength: Strength of the administered dose.
Route of administration: How it was given (oral, IV, etc.).
Timing: Date and exact time of administration.
Name/employee ID number, signature of authorised person: Identify the healthcare professional who administered the medication (typically a nurse). Include their printed name, employee ID, and signature (or electronic signature in EMRs).
Infusions: Start time, rate of infusion and end time: For intravenous infusions, document the start time, infusion rate (mL/hour or units/hour), and the end time of the infusion. This is important for tracking complete infusions and calculating total doses given.
Points to Remember:
Document in uniform location: Use a standardized medication administration record (MAR) form (paper or electronic) that is consistently used across the hospital. This ensures all documentation is in a predictable location and format.
Document each dose of the same medication separately: Record each individual dose of a medication on a separate line in the MAR, even if it is the same medication given multiple times a day. Do not group multiple doses on a single entry, as this can obscure timing details and make tracking individual doses difficult.
Record should reflect actual administration: The MAR must accurately reflect what was actually administered to the patient. Document any deviations from the original order, medication refusals, or reasons for non-administration.
Examples:
If brand Y was given instead of brand X (same generically), then documentation should be done for brand Y: If, due to formulary substitution or availability issues, a different brand (Brand Y) was dispensed and administered instead of the originally ordered Brand X (but both are the same generic drug), document exactly what was administered (Brand Y) in the MAR. Do not document Brand X if that was not what the patient received.
If order was for tablet of 250mg, but ½ tablet of 500 mg was administered, then document the latter: If a dose adjustment is made (e.g., splitting a 500mg tablet to administer 250mg), document the actual dose administered (250mg, or "½ of 500mg tablet") in the MAR. Do not just document the originally ordered dose if the administered dose was different.
Document patient's refusal to take medication: If a patient refuses a scheduled medication, document this refusal in the MAR, including the time, the medication refused, and the reason for refusal (if known and documented). Follow hospital policy on managing medication refusals (e.g., notifying physician, offering alternatives).
Key Phrase: "Govern patient's self-administration of medications." Policies and procedures for patient self-administration.
Requirement: If the hospital allows patients to self-administer their own medications (e.g., in specific units, for specific patient types), there must be established policies and procedures in place to govern this process and ensure patient safety.
Rationale: Patient self-administration can promote patient autonomy and engagement in their care. However, it also introduces potential risks if not properly managed:
Medication Errors by Patients: Patients might not have the same level of knowledge or training as healthcare professionals and could make errors in self-administration (wrong dose, wrong timing, wrong route, missed doses, drug interactions).
Storage and Security: Patients storing medications at their bedside requires secure storage to prevent unauthorized access by other patients or visitors and to ensure medication integrity.
Monitoring and Education: Patients need adequate education and ongoing monitoring to ensure they are self-administering medications correctly and safely and to detect any potential problems early.
Policy Consistency: Hospitals need to have a clear and consistent approach to when and how self-administration is permitted.
Practical Implementation - Self-Administration Policies and Procedures:
The organisation can define if it would permit self-administration of medications: Hospitals have the discretion to decide whether or not to allow patient self-administration at all. Some hospitals may choose not to permit self-administration due to concerns about safety and complexity. Others may allow it in specific units (e.g., rehabilitation units, well-patient units) or for certain patient populations.
Written guidance: If self-administration is permitted, written guidelines are essential to define and govern the process:
If permitted, provide list medications which can be self-administered: Define a limited list of medications that are considered suitable for self-administration. Typically, this would be limited to:
Oral solid dosage forms (tablets, capsules).
Relatively low-risk medications with clear dosing instructions.
Medications that the patient is already familiar with taking at home.
Excluding high-risk medications, injectables, controlled substances, or complex medication regimens.
Adopt a method to remind patient to take medication (before every dose): Establish a system to remind patients to take their medications at the correct times, especially if self-administration is intended to be done independently by the patient. Reminder methods could include:
Verbal reminders from nurses.
Visual aids (charts, checklists).
Electronic reminders (alarms, timer devices).
Involving family members in reminders, if appropriate.
Document relevant information: Documentation is still crucial, even with self-administration. Document:
Patient's ability and willingness to self-administer (assessment of cognitive and physical capacity).
Patient education provided on medication self-administration.
List of medications authorized for self-administration for that specific patient.
Any deviations from self-administration or concerns noted during monitoring.
Location of medication storage at bedside (ensure secure storage - locked drawer or container).
Patient education: Provide thorough education to patients who are approved for self-administration. Education should include:
Correct medication names, doses, timing, and routes.
Potential side effects and what to do if they occur.
Proper storage instructions (keeping medications secure, away from others).
Importance of adhering to the prescribed regimen and seeking help if they have questions or concerns.
Ongoing monitoring: Regularly monitor patients who are self-administering medications to:
Assess their ongoing ability to self-administer correctly and safely.
Address any questions or concerns they might have.
Detect any potential errors or issues related to self-administration.
Key Phrase: "Govern patient's medications brought from outside." Policies for patient-owned medications.
Requirement: If the hospital permits patients to bring their own medications from home or outside sources for use during their hospital stay, there must be policies and procedures in place to govern this practice, ensuring patient safety and medication management control.
Rationale: Allowing patient-brought medications (sometimes called "home medications" or "patient-supplied medications") can be beneficial in some situations (e.g., ensuring continuity of medication regimens, especially for patients with complex outpatient medications, or when hospital formulary lacks a specific needed drug). However, it also introduces potential risks:
Unidentified Medications: Medications brought from home may not be clearly identified or labelled, increasing the risk of medication errors if hospital staff rely on unverified patient-supplied medications.
Quality and Safety Concerns: The hospital cannot guarantee the quality, storage conditions, or integrity of medications brought from outside. They may be expired, counterfeit, or inappropriately stored at home.
Drug Interactions: Medications brought from home may not be documented in the hospital's medication records and could lead to missed drug interaction checks or therapeutic duplication if not reconciled properly.
Policy Consistency: Hospitals need a clear and consistent policy on whether and how patient-brought medications are managed to ensure patient safety and maintain medication management control.
Practical Implementation - Policies for Patient-Brought Medications:
The organisation can define if it would permit patient to get his/her medications: Hospitals have the option to decide whether to allow patient-brought medications at all. Some hospitals have a policy of not allowing patient-brought medications, relying entirely on hospital-supplied medications for inpatient care, to maintain full control over medication quality and safety. Others may allow it under specific, controlled conditions.
Written guidance: If patient-brought medications are permitted, written guidelines are necessary to govern the process:
If permitted, include prerequisites for such medication (Clear label): If patient-brought medications are allowed, establish prerequisites that must be met before the hospital can consider using them. A crucial prerequisite is that the medication must be clearly labelled. "Clear label" implies:
Original manufacturer's packaging is preferred.
Label must be legible and intact.
Label must clearly identify the:
Name of the medication (brand and generic).
Strength.
Expiry date.
Batch number (if available).
Patient's name (if it's a prescription container specifically for the patient).
Content of medication label (Points to Remember): Reiterate the key elements that the label of a patient-brought medication must contain for it to be considered acceptable (Name of the medication, Strength, Expiry date, Batch number).
Procedure for Verification and Review: Establish a procedure for pharmacy to verify and review any patient-brought medications before they are used. This procedure should include:
Patient interview: Question the patient (or family) about the medication, why they brought it, and where it was obtained.
Label inspection: Pharmacy staff must carefully inspect the label to ensure it meets the "clear label" prerequisites (drug name, strength, expiry, batch number, no tampering).
Medication identification: Pharmacist should visually identify the medication to confirm it matches the label description and is consistent with expectations.
Formulary check: Check if the medication is on the hospital formulary. If it is a formulary medication, hospital-supplied stock should generally be used instead of the patient-brought medication (to maintain quality control and billing consistency). Patient-brought medications are usually considered only for non-formulary medications or in exceptional circumstances (e.g., short-term need when hospital stock is temporarily unavailable).
Documentation: Document the fact that patient-brought medications were reviewed by pharmacy, the details of the medication, and the decision to use or not use patient-supplied medication in the patient's medical record.
Storage of Patient-Brought Medications: If patient-brought medications are approved for use, they should typically be:
Identified as "patient-owned medications."
Stored separately from hospital stock (e.g., in a designated, labelled bag at the patient's bedside or in a locked medication drawer within the patient room).
Returned to the patient upon discharge if unused and appropriate.
MOM Standard 7 is a comprehensive set of objective elements designed to ensure medication administration is performed safely and accurately at every stage. It emphasizes:
Authorised Personnel (MOM 7a): Restricting administration to legally qualified individuals.
Preventing Preparation Mix-ups (MOM 7b): Sequential preparation and labelling.
Patient Identification (MOM 7c): Mandatory two-identifier patient verification before administration.
Verification of "5 Rights" (MOM 7d, 7e, 7f, 7g): Thorough verification of drug, dose, strength, route, and timing against the order and physical inspection before administration.
Tubing Misconnection Prevention (MOM 7h): Using design features and workflow measures to avoid catheter and tubing misconnections.
Complete Documentation (MOM 7i): Mandatory and detailed documentation of medication administration in the MAR.
Controlled Self-Administration (MOM 7j): Policies and procedures for governing patient self-administration, if permitted.
Governed Patient-Brought Medications (MOM 7k): Policies and procedures for managing patient-owned medications, if permitted.
This standard is crucial as it focuses on what happens after a medication is administered. It ensures that the hospital actively monitors patients to assess the effects of medications, both intended therapeutic benefits and unintended adverse effects. This monitoring is vital for optimizing therapy, detecting problems early, and continuously improving medication safety.
Let's dissect each objective element within MOM 8:
Key Phrase: "Patients are monitored after medication administration." Emphasizing post-administration surveillance.
Requirement: The hospital must have a system in place to ensure that patients are systematically monitored after they receive medications. This monitoring is not just a passive observation; it requires active assessment to determine if the medication is working as intended and if any adverse effects are occurring.
Rationale: Post-medication monitoring is essential to:
Verify Therapeutic Effectiveness: Confirm if the medication is achieving its intended therapeutic effect (e.g., pain relief, blood pressure control, infection resolution).
Detect Adverse Drug Reactions (ADRs) Early: Promptly identify any ADRs (allergic reactions, side effects, toxicities) as soon as they appear, allowing for timely intervention and management to minimize harm.
Guide Therapy Adjustments: Monitoring data (clinical response, lab results, ADRs) informs decisions about continuing, adjusting, or changing the medication regimen to optimize patient outcomes.
Improve Medication Safety Processes: Analysis of monitoring data can identify patterns of ADRs or areas where medication safety processes can be further improved.
Practical Implementation - Patient Monitoring System:
Verify if medicine has its intended effect: Monitoring should include assessing if the medication is achieving its desired therapeutic goal. This can involve:
Clinical assessment: Nurses and physicians should regularly assess the patient's signs and symptoms related to the condition being treated by the medication. Examples:
Pain scales for analgesics to assess pain relief.
Blood pressure monitoring for antihypertensives.
Temperature monitoring for antipyretics.
Respiratory assessment for bronchodilators.
Patient feedback: Ask patients about their subjective experience with the medication - are they feeling better? Are their symptoms improving as expected?
Monitor effects of medications through laboratory results (beneficial or adverse): Laboratory monitoring is often essential to objectively assess medication effects, both therapeutic and adverse. This may include:
Therapeutic monitoring: Lab tests to measure medication blood levels (e.g., digoxin, aminoglycosides) to ensure they are within the therapeutic range and to guide dose adjustments.
Monitoring for organ toxicity: Regular lab tests to detect early signs of organ damage (e.g., renal function tests for nephrotoxic drugs, liver function tests for hepatotoxic drugs, complete blood counts for drugs causing bone marrow suppression).
Monitoring for electrolyte imbalances: Electrolyte levels (potassium, sodium, magnesium) should be monitored for drugs that can cause imbalances.
Specific disease-related markers: Lab tests relevant to the condition being treated (e.g., blood glucose for diabetic medications, INR for anticoagulants, tumor markers for chemotherapy).
Identify near misses, medication errors and adverse drug reactions: Monitoring should be designed to detect not only ADRs but also:
Adverse drug reactions (ADRs): Active surveillance for signs and symptoms that could indicate an ADR. Educate staff on common ADRs of commonly used medications.
Medication errors: Even if no immediate harm occurs, monitoring may uncover medication errors that reached the patient but did not cause overt harm ("near misses").
Near misses: Also actively look for "near misses" - situations where a medication error was prevented before reaching the patient (e.g., a nurse caught a wrong dose before administration). Learning from near misses is valuable for system improvement.
Note: "The organisation should define situations when more frequent monitoring should be done. For example: After administering high-risk medicines." Hospitals should proactively define specific scenarios where more intensive or frequent monitoring is needed. Examples include:
After administering high-risk medicines: For medications on the hospital's high-risk medication list (MOM 3c), implement enhanced monitoring protocols. This could involve more frequent vital signs checks, specific symptom monitoring, more frequent lab tests, or longer observation periods post-administration.
For medications with narrow therapeutic indices: Drugs with low therapeutic window require close monitoring of blood levels and clinical response to maintain therapeutic effect without toxicity.
For patients at high risk of ADRs: Elderly patients, patients with multiple comorbidities, patients with impaired organ function, or patients with a history of ADRs may need closer monitoring.
When starting new medications, especially high-risk drugs: More frequent monitoring is important when a patient is first started on a new medication to assess initial response and detect early ADRs.
Compliance Level: (C) - Commitment Level. Establishing a system for post-medication monitoring is a fundamental commitment to patient safety.
Key Phrase: "Medications are changed where appropriate based on the monitoring." Action based on monitoring findings.
Requirement: The results of patient monitoring (from MOM 8a) must be used to inform clinical decision-making regarding medication therapy. If monitoring indicates that a medication is not working as intended, is causing unacceptable adverse effects, or if new information emerges, the medication regimen should be changed as clinically appropriate. This emphasizes the dynamic and responsive nature of medication management.
Rationale: Monitoring data is only valuable if it leads to action. Making medication changes based on monitoring:
Optimizes Therapy: Ensures patients receive the most effective medication regimen based on their individual response and needs.
Minimizes ADRs and Toxicity: If monitoring reveals ADRs or signs of toxicity, prompt medication changes can prevent further harm and improve patient comfort and safety.
Improves Patient Outcomes: By adjusting therapy based on monitoring data, clinicians can enhance the likelihood of achieving desired therapeutic outcomes and improving patient health.
Reflects Patient-Centered Care: Tailoring medication therapy based on individual patient response demonstrates a patient-centered approach to care.
Practical Implementation - Responding to Monitoring Data:
Clinical response: If monitoring indicates that a medication is not achieving the desired therapeutic response, clinicians should consider:
Dose adjustment: Increasing the dose of the medication (if appropriate and within safe limits).
Frequency adjustment: Changing the frequency of administration.
Route of administration change: If possible and clinically indicated, switching to a more effective route (e.g., from oral to IV for better absorption in some cases).
Medication change: Switching to a different medication within the same therapeutic class or to an entirely different class of medication if the current drug is deemed ineffective for that patient.
Adding adjunctive therapy: Adding another medication to enhance the effect of the primary medication or address a different aspect of the patient's condition.
Adverse drug reactions (if any): If monitoring reveals that a patient is experiencing an adverse drug reaction (ADR) that is unacceptable or outweighs the benefit of the medication, clinicians should:
Reduce dose: If possible, reduce the dose of the medication to see if the ADR can be minimized while still maintaining some therapeutic effect.
Temporarily hold the medication: Stop the medication temporarily to see if the ADR resolves and to assess if the ADR is indeed drug-related.
Discontinue the medication: Permanently stop the medication if the ADR is severe, persistent, or outweighs the therapeutic benefit.
Switch to an alternative medication: If the medication is essential, consider switching to an alternative medication within the same class or a different class that is less likely to cause the same ADR (if a suitable alternative exists).
Treat the ADR: Implement appropriate treatment for the ADR itself (e.g., antihistamines for allergic reactions, antiemetics for nausea, etc.).
Multidisciplinary approach: Medication changes based on monitoring data should often be discussed and decided upon in a collaborative way, involving physicians, pharmacists, and nurses, to ensure a holistic and well-informed decision.
Documentation of changes: All medication changes made based on monitoring findings must be clearly documented in the patient's medical record, including the reason for the change and the new medication orders.
The slides include important definitions that are directly relevant to MOM 8, as monitoring is aimed at detecting these events. Understanding these definitions is crucial for effective monitoring and reporting:
Adverse Drug Event (ADE): "Harm resulting from medical intervention related to a drug (IOM). This includes medication errors, adverse drug reactions, allergic reactions and overdoses."
Broadest category: ADE is the broadest term, encompassing any harm related to drug use due to medical intervention, regardless of the cause or preventability.
Includes both errors and reactions: ADE includes harm caused by medication errors (preventable) and harm caused by adverse drug reactions (often not preventable), as well as allergic reactions and overdoses.
Estimated prevalence: The slides note that ADEs account for a significant proportion of hospital adverse events and hospital stays, highlighting their clinical and economic impact.
Adverse Drug Reaction (ADR): "Is drug-induced harm occurring with appropriate use of medication (i.e., not caused by an error). It includes any response to a drug which is noxious and unintended that occurs at doses normally used in man..." (WHO definition quoted).
Appropriate use: ADRs occur even when the medication is used correctly (right drug, dose, route, time, for the right indication). They are not due to medication errors.
Noxious and unintended: ADRs are harmful, unwanted, and are not the intended therapeutic effect of the drug.
Normal doses: ADRs can occur even at usual therapeutic doses, not just with overdoses.
Subtype of ADE: ADR is a subtype of ADE – all ADRs are ADEs, but not all ADEs are ADRs. ADE is the broader umbrella term.
Medication Errors: "are mistakes that occur during prescribing, transcribing, dispensing, administering, adherence, or monitoring a drug."
Mistakes in the medication use process: Medication errors are preventable mistakes that can occur at any stage of the medication use process (prescribing, dispensing, etc.).
Potential for harm: Medication errors have the potential to cause patient harm (ADE), but not all medication errors actually result in harm.
Near misses: Medication errors that are detected and corrected before they reach the patient or before harm occurs are called "near misses." These are also important to track and learn from to improve the system.
Common but often without harm: Medication errors are very common, but fortunately, they often do not result in significant harm. However, they can and do lead to harm in a proportion of cases.
Key Phrase: "Captures near miss, medication error and adverse drug reaction." Establishing a system for detection and documentation.
Requirement: The hospital must have a systematic approach to actively capture and document instances of:
Near misses: Medication errors that were caught before reaching the patient.
Medication errors: Medication errors that did reach the patient, whether or not harm resulted.
Adverse drug reactions (ADRs): Harmful reactions to medications, even when used appropriately.
Rationale: Capturing these events is essential for:
Learning from Errors and Near Misses: Analyzing captured data provides insights into the types of errors occurring, system weaknesses, and areas for improvement to prevent future errors.
Identifying ADRs and Trends: Systematic ADR reporting and collection helps identify potential drug safety signals, track ADR rates, and inform formulary decisions or usage guidelines.
Quality Improvement: Data on medication safety events is crucial for driving continuous quality improvement initiatives in medication management.
Compliance and Transparency: Having a reporting system is often required for accreditation and demonstrates a commitment to transparency and patient safety.
Practical Implementation - Medication Safety Event Capture System:
Written guidance (Near miss, medication errors and ADR): The slide outlines a cyclical process that should be reflected in written policies and procedures for capturing medication safety events:
Identify: Establish mechanisms to actively identify medication safety events. This may include:
Incident reporting system (paper-based or electronic): A system for staff to voluntarily report errors, near misses, and suspected ADRs. Make reporting easy and non-punitive to encourage staff to report openly.
Proactive surveillance: Pharmacists or specially trained staff actively review patient charts, medication administration records, lab results, and clinical notes to proactively detect potential medication errors or ADRs.
Patient/family reporting: Encourage patients and families to report any suspected medication problems or concerns.
Document: Establish standardized forms (paper or electronic) and procedures for documenting identified medication safety events. Documentation should include:
Detailed description of the event (what happened, when, where, who was involved, what medications were involved).
Patient identifiers (without compromising privacy).
Severity of the event (harm, near miss).
Contributing factors (system issues, human factors, etc.).
Actions taken in response to the event.
Report: Define clear reporting pathways for medication safety events. Reports should flow to:
Pharmacy department: Pharmacy is often the central point for receiving and managing medication safety event reports.
Medication Safety Officer (if role exists - as per 6th edition updates): The MSO is specifically responsible for overseeing medication safety initiatives.
Multidisciplinary committee (MOM 1b): The committee reviews and analyzes aggregated data and trends from reported events.
Quality and Safety department: For integration into hospital-wide quality improvement efforts.
Analyse: Establish a process for analyzing the collected data on medication safety events. This analysis should:
Identify trends and patterns in errors or ADRs.
Determine common root causes and contributing factors (using tools like root cause analysis).
Prioritize areas for improvement.
Act: Based on the analysis, develop and implement action plans to address identified issues, prevent recurrence, and improve the medication management system. These actions might include:
Process changes.
Policy revisions.
Staff training and education.
System redesign (e.g., CPOE system modifications, barcode scanning implementation).
Formulary changes.
Implementation of new safety strategies.
Note: "The organisation should define near miss, medication errors and adverse drug reaction (ADR) based on the best practices." Hospitals need to clearly define what constitutes a "near miss," "medication error," and "ADR" within their own context to ensure consistent reporting and data analysis. Definitions should be:
Consistent with standard definitions used in medication safety (e.g., those provided by ISMP, NCCMERP).
Clear, unambiguous, and easily understood by all staff who will be reporting.
Communicated and regularly reinforced to staff.
Key Phrase: "Reported within a specified time frame." Emphasis on timely reporting.
Requirement: Reported medication safety events (near misses, errors, ADRs) must be reported and entered into the hospital's reporting system in a timely manner, within a defined timeframe after the event occurs or is discovered. This ensures that information is captured while it is still fresh and actionable.
Rationale: Timely reporting of events is important because:
Enables Prompt Investigation and Intervention: Early reporting allows for quicker investigation of events, identification of root causes, and implementation of corrective actions before similar errors can recur or cause harm to other patients.
Data Accuracy and Completeness: Details of events are more accurately recalled and documented when reported soon after they occur. Delayed reporting can lead to loss of crucial information or incomplete data.
Real-time System Improvement: Timely reporting facilitates a more "real-time" quality improvement cycle, enabling the hospital to respond to emerging safety issues quickly.
Practical Implementation - Timely Reporting Procedure:
Define timeframe: Establish a specific timeframe within which medication safety events must be reported. Common timeframes include:
Within 24 hours of event detection: This is a typical benchmark for serious events or medication errors that reached the patient.
Within 48-72 hours for near misses and less severe errors: A slightly longer timeframe might be acceptable for less severe events or near misses.
The timeframe should be reasonable and achievable while still ensuring timely reporting. Communicate the defined timeframe clearly to staff.
Adhere to timeframe: Actively promote and reinforce adherence to the defined reporting timeframe. This involves:
Education and training: Educate staff on the importance of timely reporting and the defined timeframe.
Make reporting easy and accessible: Ensure the reporting system (paper forms or electronic system) is user-friendly and readily accessible to staff.
Non-punitive reporting culture: Foster a non-blaming and non-punitive reporting culture to encourage staff to report openly and without fear of reprisal, focusing on system improvement rather than individual blame.
Monitor reporting timeliness: Periodically monitor reporting data to assess if events are being reported within the defined timeframe. Provide feedback to departments or units if reporting timeliness is consistently lagging.
Key Phrase: "Collected and analysed." Data utilization for improvement.
Requirement: Collected data on near misses, medication errors, and ADRs (from MOM 8c and reported within the timeframe of MOM 8d) must be systematically collected, aggregated, and analysed. This analysis is the key step to derive meaningful insights and drive quality improvement.
Rationale: Data collection and analysis are essential to:
Identify Patterns and Trends: Aggregating and analyzing data allows hospitals to identify recurring types of errors, common contributing factors, and trends in ADRs that might not be apparent from individual incident reports alone.
Prioritize Improvement Efforts: Data analysis helps prioritize which areas of the medication management system need the most attention and resources for improvement based on the frequency and severity of identified issues.
Measure Impact of Interventions: After implementing corrective actions (MOM 8f), data analysis is crucial to measure the effectiveness of these interventions and assess if they are indeed reducing errors and improving patient safety.
Benchmarking (internally over time, or externally): Data on medication safety events can be tracked over time to monitor progress and benchmark against internal targets or, cautiously, against external benchmarks (though direct comparison across hospitals can be complex).
Practical Implementation - Data Collection and Analysis:
Who is responsible?: "Multidisciplinary committee. A clinical pharmacologist/clinical pharmacist can be part of this exercise." Responsibility for data collection and analysis should be clearly assigned. The slide suggests:
Multidisciplinary committee (MOM 1b): The medication safety committee (or a designated subcommittee) is ideally suited to oversee data analysis as it brings diverse expertise.
Clinical pharmacologist/clinical pharmacist: These professionals have specialized skills in medication safety data analysis, ADR evaluation, and pharmacoepidemiology. They can play a lead role in data analysis or provide expert input to the committee.
Quality and safety department: Quality improvement professionals can also be involved in data analysis and applying quality improvement methodologies.
When should it be done?: "Within a defined timeframe." Data analysis should be done regularly and within a defined timeframe to ensure timely insights and action. Common frequencies include:
Monthly analysis: For routine monitoring and trend detection.
Quarterly analysis: For more in-depth review and to assess longer-term trends.
Ad hoc analysis: Perform more focused analysis in response to specific events, clusters of errors, or emerging safety signals.
Data Analysis Techniques: Data analysis should go beyond simply counting event numbers. Employ techniques such as:
Descriptive statistics: Calculate frequencies, percentages, and rates of different types of errors, ADRs, near misses.
Trend analysis: Track data over time to identify increases or decreases in event rates and detect trends or patterns.
Categorical analysis: Categorize events by medication type, error type (prescribing, dispensing, administration), root cause categories, departments, time of day, etc.
Root Cause Analysis (RCA): Conduct in-depth RCA for significant events or recurring error types to identify underlying system factors.
Failure Mode and Effects Analysis (FMEA): Proactively use FMEA to identify potential failure points in medication processes and implement preventative measures.
Key Phrase: "Corrective and/or preventive action(s) are taken based on the analysis." Closing the loop with action.
Requirement: The analysis of medication safety event data (MOM 8e) must directly lead to the implementation of corrective and/or preventive actions. This is the crucial step of translating data insights into tangible improvements in the medication management system. Analysis without action is insufficient.
Rationale: Action based on data analysis is what drives true quality improvement and enhances patient safety in the long run. It ensures that the effort of data collection and analysis translates into real-world improvements.
Practical Implementation - Action Planning and Implementation:
Perform root cause analysis: As mentioned in MOM 8e, for significant or recurring issues identified in the data analysis, conduct more detailed root cause analyses to pinpoint the underlying system-level factors contributing to the problems.
Take CAPA (Corrective and Preventive Action): Develop a CAPA plan based on the analysis and RCA findings. The CAPA plan should outline:
Corrective actions: Actions to directly address the immediate problem identified in the data. Examples: retraining staff on a specific procedure, revising a policy, providing feedback to individuals involved in an error.
Preventive actions: Actions to prevent recurrence of similar issues in the future and to improve the system more broadly. Examples: redesigning a process, implementing a new technology (e.g., barcode scanning), developing new clinical decision support alerts in the EHR, updating staff training programs, revising the formulary, improving communication protocols.
Assign responsibility: Clearly assign responsibility for implementing each CAPA action item to specific individuals, departments, or teams.
Set timelines: Establish realistic and trackable timelines for completing each CAPA action.
Maintain records of the action taken: Document all corrective and preventive actions taken, including:
Specific actions implemented.
Who was responsible.
Completion dates.
Evidence of implementation (e.g., training records, policy revision documents, system change logs).
Evaluate effectiveness of actions: After implementing CAPA actions, evaluate their effectiveness. Re-analyze data after a period of time to assess if the actions have led to a measurable reduction in the targeted errors or ADRs. If actions are not effective, revisit the analysis and CAPA plan to identify further improvement strategies. This completes the quality improvement cycle.
MOM Standard 8 is dedicated to the crucial function of post-medication monitoring and continuous improvement of medication safety through data-driven action. It emphasizes:
Systematic Patient Monitoring (MOM 8a): Actively monitoring for therapeutic effects and adverse events after medication administration.
Data-Driven Therapy Adjustments (MOM 8b): Using monitoring data to make informed decisions about medication changes.
Event Capture and Definition (MOM 8c): Establishing a system to capture near misses, medication errors, and ADRs with clear definitions.
Timely Reporting (MOM 8d): Ensuring medication safety events are reported promptly.
Data Analysis for Insights (MOM 8e): Collecting and analyzing event data to identify trends, patterns, and root causes.
Action for Improvement (MOM 8f): Implementing corrective and preventive actions based on data analysis to continuously enhance medication safety and optimize patient care.
This standard addresses a group of medications that are considered particularly high-risk due to their potential for abuse (narcotics and psychotropics), toxicity (chemotherapeutics), or radiation hazards (radio-pharmaceuticals). It mandates that hospitals have robust systems in place to ensure these medications are used safely and appropriately, minimizing risks associated with their unique properties.
Let's dissect each objective element within MOM 9:
Key Phrase: "Used safely." Overarching emphasis on safe handling of these specialized medications.
Requirement: This objective element sets the general principle for MOM 9. It requires that the entire process of using narcotic drugs, psychotropic substances, chemotherapeutic agents, and radio-pharmaceuticals within the hospital, from procurement to disposal, must be conducted with a paramount focus on safety. This encompasses safety for patients, staff, and the environment.
Rationale: These medication categories are high-risk due to:
Narcotic drugs and psychotropic substances: High potential for addiction, abuse, diversion, and significant central nervous system (CNS) and respiratory depression risks if misused or overdosed. Legal and regulatory controls are stringent due to their abuse potential.
Chemotherapeutic agents: Highly cytotoxic drugs used in cancer treatment. They have narrow therapeutic windows and can cause significant side effects to patients and pose occupational hazards to staff if not handled properly.
Radio-pharmaceuticals: Radioactive drugs used for diagnostic imaging and therapy. They pose radiation safety risks to patients, staff, and the environment if not handled and disposed of according to strict radiation safety protocols.
Practical Implementation - Ensuring Safe Use (General Principles for MOM 9):
Written guidance: The slide emphasizes written guidance, indicating the need for comprehensive policies and procedures for all aspects of managing these medications.
Develop: In consonance with local and national regulations/guidelines: Hospital policies and procedures must be developed and implemented in strict accordance with all applicable local, state, and national regulations, legal requirements, and professional guidelines governing the handling of these specific medication categories. This is a non-negotiable foundation. For example, in India, this includes the Narcotic Drugs and Psychotropic Substances Act, and AERB (Atomic Energy Regulatory Board) guidelines for radio-pharmaceuticals. These regulations often dictate storage requirements, prescribing authority, dispensing and administration controls, record-keeping, and disposal procedures.
Address: All objective elements of this standard: The remaining objective elements of MOM 9 (9b, 9c, 9d, 9e) detail specific aspects of safe management for these medications. The overarching principle of MOM 9a is that all of these subsequent objective elements must be addressed and effectively implemented to achieve overall safe use.
Point to Remember: Regulations/Guidelines: The slide highlights two crucial sets of regulations/guidelines that hospitals must be aware of and compliant with:
Narcotic Drugs and Psychotropic Substances Act: This Act (and related rules) in India governs the control, manufacture, sale, purchase, possession, and use of narcotic drugs and psychotropic substances. Hospitals handling these drugs must comply with its provisions.
AERB guidelines: The Atomic Energy Regulatory Board (AERB) in India sets safety standards and regulations for all activities involving radioactive materials, including radio-pharmaceuticals used in healthcare. Hospitals using radio-pharmaceuticals must strictly adhere to AERB guidelines for radiation safety, handling, storage, and disposal.
Comprehensive System Approach: Safe use of these medications requires a comprehensive and multi-faceted system that includes:
Controlled procurement and inventory management.
Restricted prescribing authority.
Secure storage.
Safe preparation and handling procedures.
Verified dispensing and administration processes.
Patient monitoring protocols.
Strict record-keeping.
Proper disposal procedures.
Staff training on safe handling and risk management.
Key Phrase: "Prescribed by appropriate caregivers." Restricting prescribing authority to qualified personnel.
Requirement: These specialized medications must only be prescribed by healthcare professionals who are specifically authorized and qualified to prescribe them, based on their training, expertise, and hospital-granted privileges. This ensures that prescribing decisions are made by individuals with the necessary knowledge to use these complex and potentially dangerous medications safely and appropriately.
Rationale: Restricting prescribing to appropriate caregivers is essential because:
Specialized Knowledge Required: These medications often require specialized clinical knowledge for proper indication, dosage selection, monitoring, and management of potential side effects or complications. Not all prescribers have this specialized expertise.
Controlled Substance Regulations: For narcotics and psychotropics, regulations often specify which types of practitioners are authorized to prescribe them and under what conditions.
Chemotherapy and Radio-pharmaceuticals: Complex Regimens: Chemotherapy and radio-pharmaceutical regimens are highly complex and individualized, requiring specialized training in oncology, nuclear medicine, and related fields to prescribe safely and effectively.
Patient Safety and Efficacy: Ensuring prescriptions are written by qualified caregivers improves the likelihood of patients receiving appropriate therapy, minimizing errors, and optimizing patient outcomes.
Practical Implementation - Defining Appropriate Prescribers:
Type of drug & Who should prescribe?: The slide specifies suggested categories of prescribers for each medication type, which hospitals should adapt based on their own context and staffing:
Narcotic drugs: "Designated medical officer(s)." Hospitals should designate specific medical officers (physicians) who are authorized to prescribe narcotic drugs. This designation might be based on:
Their specialty (e.g., pain management specialists, palliative care physicians, surgeons in certain specialties).
Hospital-granted privileges for prescribing controlled substances.
Completion of specific training in pain management or controlled substance prescribing.
Chemotherapy: "Medical oncologist or a doctor who has a knowledge to monitor and treat adverse effect of chemotherapy." Chemotherapy prescribing should ideally be restricted to:
Medical oncologists: Physicians specifically trained and certified in medical oncology and chemotherapy management.
Doctors with equivalent expertise: In settings where medical oncologists are not readily available, the hospital may authorize other doctors who can demonstrate and document adequate knowledge and experience in chemotherapy prescribing, including:
Knowledge of chemotherapy protocols for specific cancer types.
Competence in monitoring and managing adverse effects of chemotherapy drugs.
Familiarity with relevant guidelines and safety precautions for chemotherapy.
This authorization process should be rigorous and documented.
Radioactive agents: "Caregiver authorised by statutory body." Prescribing of radio-pharmaceuticals is heavily regulated due to radiation safety concerns. Prescribing authority should be limited to:
Caregivers (physicians, typically nuclear medicine physicians or radiologists trained in nuclear medicine) specifically authorized by a statutory body (like AERB in India). Prescribing authority is tied to obtaining specific licenses and certifications from regulatory bodies to handle radioactive materials.
Hospitals must verify that prescribers of radio-pharmaceuticals have the necessary regulatory licenses and are authorized to prescribe these agents.
Key Phrase: "Shall be stored securely." Emphasis on robust security measures for storage.
Requirement: These high-risk medications must be stored with enhanced security measures to prevent unauthorized access, diversion, theft, misuse, and abuse. Secure storage is non-negotiable for these categories due to their inherent risks.
Rationale: Secure storage is crucial because:
Prevent Diversion and Abuse (Narcotics/Psychotropics): Secure storage is essential to prevent diversion of narcotic drugs and psychotropic substances for illicit use or abuse, both by hospital staff and external individuals. This is mandated by legal and regulatory requirements.
Protect Staff and Patients (Chemotherapeutics): Secure storage limits unauthorized access to chemotherapeutic agents, reducing occupational exposure risk for staff and preventing accidental access by patients or visitors.
Radiation Safety (Radio-pharmaceuticals): Secure storage of radio-pharmaceuticals is necessary to maintain radiation safety, prevent accidental exposure, and comply with radiation safety regulations.
Maintain Inventory Control: Secure storage supports accurate inventory tracking and helps detect any loss or diversion of these high-value and controlled medications.
Practical Implementation - Secure Storage Strategies:
Type of drug & How to store?: The slide provides guidance for secure storage tailored to each medication category:
Narcotic drugs: "Securely in consonance with security requirements. Security measures should ensure that they are not diverted or abused." Storage should be:
Securely locked: Stored in substantially constructed, locked cabinets, drawers, safes, or automated dispensing systems with restricted access control.
Double-locked (often required for Schedule II narcotics): For Schedule II controlled substances (under US DEA scheduling, or equivalent local classifications), double-locked storage (two locks or a locked cabinet within a locked room) is often legally mandated.
Limited access: Access to storage locations must be strictly limited to authorized pharmacy personnel and designated individuals.
Inventory controls: Implement robust inventory tracking systems (perpetual inventory, dispensing logs, receiving logs) for narcotics. Regular inventory audits and reconciliation are essential to detect any discrepancies and prevent diversion.
Alarm systems and surveillance (recommended for high-volume or high-risk areas): Consider alarm systems on storage areas and video surveillance in high-risk pharmacy or storage locations as additional security measures.
Chemotherapeutic agents: "Should be accessible only to authorised personnel." Storage areas should:
Restricted access: Access limited to trained and authorized pharmacy personnel and potentially designated nursing staff who are involved in chemotherapy preparation and administration.
Separate storage from other medications: Chemotherapeutic agents should be stored separately from other medications, ideally in designated chemotherapy storage areas within the pharmacy or in chemotherapy compounding units.
Appropriate environmental conditions: Storage areas should have appropriate ventilation, temperature, and humidity control to maintain drug stability and staff safety (as per manufacturer instructions and USP 800 guidelines in some regions for hazardous drugs).
Radioactive agents: "Store as per AERB guidelines." Storage must be strictly compliant with AERB (or equivalent regulatory body) guidelines for radiation safety:
Designated, shielded storage areas: Radio-pharmaceuticals must be stored in specifically designed, shielded storage areas that provide adequate radiation protection to staff and the environment.
Radiation shielding materials: Storage areas should be constructed with appropriate radiation shielding materials (lead, concrete) to minimize radiation exposure.
Controlled access: Access restricted to trained and authorized nuclear medicine personnel.
Radiation monitoring: Implement radiation monitoring and dosimetry programs to ensure radiation safety in storage areas and for personnel handling radio-pharmaceuticals.
Specific labeling and warnings: Clearly label all radio-pharmaceutical containers and storage areas with radiation warning symbols and appropriate handling precautions.
Note: "These medications should be stored separately from other medications." As a general principle, all three categories (narcotics/psychotropics, chemotherapeutics, and radio-pharmaceuticals) should be stored separately from routine medications to further emphasize their special handling requirements and enhance security and control. Within each category, further segregation (e.g., separating different schedules of narcotics, or different types of chemotherapeutic agents) may also be beneficial for organization and error prevention.
Key Phrase: "Prepared properly and safely and administered by qualified personnel." Focus on safe handling during preparation and administration.
Requirement: Chemotherapeutic agents and radio-pharmaceuticals, due to their inherent hazards, must be:
Prepared properly and safely: Preparation (compounding, manipulation, reconstitution, dilution, etc.) must be performed using specialized techniques, equipment, and safety precautions to protect personnel from exposure and maintain drug sterility and integrity.
Administered by qualified personnel: Administration must be performed by healthcare professionals who are specifically trained and competent in the safe handling and administration of these agents and understand potential risks and management of complications.
Rationale: Safe preparation and administration are critical for:
Staff Safety (Chemotherapeutics and Radio-pharmaceuticals): Exposure to chemotherapeutic agents and radiation can pose significant occupational hazards to healthcare workers (carcinogenicity, teratogenicity, mutagenicity for chemotherapeutics; radiation exposure risks for radio-pharmaceuticals). Proper preparation and handling procedures are crucial for staff protection.
Patient Safety (Chemotherapeutics and Radio-pharmaceuticals): Administering these potent agents incorrectly or without proper safeguards can lead to severe patient toxicity or adverse reactions. Safe preparation and administration techniques minimize these risks.
Maintaining Drug Quality and Sterility (Chemotherapeutics and Radio-pharmaceuticals): Proper preparation techniques, especially for sterile preparations like chemotherapy admixtures and radio-pharmaceutical injections, are essential to maintain sterility and prevent contamination.
Regulatory Compliance (Radio-pharmaceuticals): Administration of radio-pharmaceuticals is strictly regulated for radiation safety, and qualified personnel and specific procedures are often mandated by regulatory bodies like AERB.
Practical Implementation - Safe Preparation and Administration:
Chemotherapy agents:
Staff in-charge: Specially trained qualified personnel: Chemotherapy preparation and administration should be performed by:
Pharmacists specifically trained in chemotherapy compounding and sterile preparation techniques (often referred to as oncology pharmacists or specialized compounding pharmacists).
Nurses specifically trained and certified in chemotherapy administration (oncology nurses).
Ongoing competency assessment and training is vital to maintain skills and knowledge.
Area: It should be prepared in a bio-safety cabinet of class II (preferably IIA): Chemotherapy compounding must be performed in a certified Class II Biological Safety Cabinet (BSC). Preferably, a Class II Type A2 or Type B2 BSC is recommended (IIA is an older designation, current recommendation is for Type A2 or better). BSCs provide:
Personnel protection: Protect staff from exposure to hazardous chemotherapy drugs during compounding.
Product protection: Maintain a sterile compounding environment to prevent contamination of chemotherapy preparations.
Environmental protection: Contain hazardous drug aerosols within the cabinet.
Safety measures: Staff should wear appropriate personal protective equipment: Compounding and administration personnel must wear appropriate Personal Protective Equipment (PPE) to minimize skin contact and inhalation exposure to chemotherapy drugs. Minimum PPE should include:
Chemotherapy-rated gloves (double gloving often recommended).
Protective gowns (impermeable, disposable).
Eye protection (goggles or face shield).
Respiratory protection (N95 respirator or higher, especially during powder handling or spill cleanup).
Hospital policy should detail specific PPE requirements and procedures for donning and doffing PPE.
Radioactive agents:
Staff in-charge: Caregiver authorised by statutory body: Preparation and administration must be performed by:
Nuclear medicine technologists and physicians (typically nuclear medicine physicians or radiologists trained in nuclear medicine) who are specifically authorized by a statutory body (like AERB in India) to handle radio-pharmaceuticals. This authorization is tied to radiation safety training, licenses, and certifications.
Radiation safety practices: Strict adherence to radiation safety practices is essential during preparation and administration of radio-pharmaceuticals, including:
Working in designated, shielded areas with radiation protection equipment.
Using remote handling devices (syringes, forceps) to minimize direct hand exposure.
Wearing radiation dosimetry badges to monitor personal radiation exposure.
Following ALARA ("As Low As Reasonably Achievable") principles to minimize radiation exposure.
Proper handling of radioactive waste.
Regular radiation safety training and drills for personnel.
Key Phrase: "A proper record is kept of the usage, administration and disposal." Strict documentation and audit trails.
Requirement: For all four categories of high-risk medications (narcotics/psychotropics, chemotherapeutics, radio-pharmaceuticals), the hospital must maintain meticulous and detailed records of their:
Usage: Inventory tracking, dispensing logs, and records of how much of each drug is used within the hospital system.
Administration: Patient-specific medication administration records (MARs) that document administration details.
Disposal: Records of how unused or expired portions of these medications, and any contaminated waste, are disposed of according to regulations and hospital policy.
Proper record-keeping is essential for accountability, regulatory compliance, and audit trails.
Rationale: Comprehensive record-keeping is vital for:
Controlled Substance Accountability (Narcotics/Psychotropics): Strict record-keeping is legally mandated for controlled substances to prevent diversion and abuse. Accurate usage, dispensing, and disposal logs provide a complete audit trail.
Chemotherapy Tracking and Safety: Detailed records of chemotherapy preparation, dispensing, and administration are essential for tracking doses, regimens, and managing patient safety and treatment efficacy.
Radiation Safety and Accountability (Radio-pharmaceuticals): Detailed records of radio-pharmaceutical usage, administration, and disposal are required for radiation safety compliance and to track radiation exposure.
Inventory Management and Cost Control: Record-keeping supports accurate inventory management, helps detect discrepancies, and contributes to cost control for these often-expensive medications.
Legal and Regulatory Compliance: Many regulations mandate specific record-keeping requirements for these medication categories.
Practical Implementation - Record-Keeping Practices:
Narcotic drugs: "Record usage. Adhere to statutory requirements. Dispose as per existing statutory requirements..." Record-keeping for narcotics must be rigorous and compliant with legal requirements (Narcotic Drugs and Psychotropic Substances Act in India or equivalent in other regions):
Record usage: Maintain detailed records of:
Receipt of narcotics into pharmacy inventory (receiving logs, invoices).
Dispensing of narcotics (patient-specific dispensing logs, medication orders).
Wastage of narcotics (witnessed wastage records, disposal logs).
Inventory adjustments (loss, gain, authorized removal - with proper documentation).
Adhere to statutory requirements: Records must be maintained in the format and with the details specified by regulations. This often includes:
Drug name, strength, dosage form, batch number, expiry date.
Patient name and MRN.
Prescriber details.
Date, time, quantity dispensed/administered/disposed.
Name and signature of dispensing/administering/witnessing personnel.
Balance on hand (perpetual inventory system).
Dispose as per existing statutory requirements: Disposal of unused or expired narcotics must be done according to legal requirements. This usually involves:
Securely destroying the narcotics (often by incineration or chemical destruction).
Witnessed disposal (typically requiring two authorized professionals as witnesses).
Detailed documentation of disposal process (date, time, quantity, method, witnesses).
Chemotherapeutic agents: While not typically subject to the same level of legal control as narcotics, detailed records are essential for safe and quality chemotherapy management:
Compounding records: Maintain detailed records of all chemotherapy compounding activities, including:
Drug names, batch numbers, expiry dates of components.
Calculations and compounding worksheets.
Pharmacist verification of compounding.
Sterility testing results (if applicable).
Batch preparation logs.
Personnel involved in compounding.
Patient-specific administration records: Document chemotherapy administration details in the patient's MAR.
Radioactive agents: "Points to Remember: The organisation should keep strict inventory control for: Narcotic drugs, Psychotropic substances, Chemotherapeutic agents. Radioactive agents." Record-keeping for radio-pharmaceuticals is also highly regulated and must comply with AERB (or equivalent) guidelines:
Receipt, inventory, and dispensing records: Maintain detailed records of:
Receipt of radio-pharmaceuticals (isotope, activity, batch number, supplier).
Inventory logs for radio-pharmaceutical stock.
Dispensing logs for patient-specific doses (patient name, date/time of dispensing, prescribed activity, actual activity dispensed, person dispensing).
Administration records: Document radio-pharmaceutical administration in the patient's nuclear medicine records, including:
Radio-pharmaceutical used, activity administered.
Route of administration.
Date and time of administration.
Personnel administering.
Radioactive waste disposal records: Maintain logs of radioactive waste disposal, documenting:
Type and quantity of waste.
Date of disposal.
Method of disposal (e.g., decay-in-storage, licensed waste disposal service).
Radiation levels before and after disposal (for decay-in-storage).
MOM Standard 9 is dedicated to the highly specialized and high-risk categories of medications: narcotics/psychotropics, chemotherapeutics, and radio-pharmaceuticals. It mandates:
Safe Use as Overarching Principle (MOM 9a): Comprehensive safety framework aligned with regulations.
Restricted Prescribing (MOM 9b): Limiting prescribing authority to qualified and authorized caregivers.
Secure Storage (MOM 9c): Robust security measures to prevent diversion, misuse, and radiation hazards.
Safe Preparation and Administration (MOM 9d): Specialized procedures and qualified personnel for chemotherapy and radio-pharmaceutical handling.
Strict Record-Keeping (MOM 9e): Meticulous documentation of usage, administration, and disposal for accountability, safety, and regulatory compliance.
This standard shifts focus from medications in the traditional sense to implantable items. It emphasizes that the selection, use, and management of implantable prosthesis and medical devices must be governed by established criteria to ensure patient safety, efficacy, and appropriate utilization. It recognizes that these devices, while not medications, are critical medical interventions requiring careful management.
Let's dissect each objective element within MOM 10:
Key Phrase: "Usage...guided by scientific criteria...and national/international recognised guidelines/approvals." Emphasizing evidence-based selection.
Requirement: The hospital must ensure that the selection and usage of implantable prosthesis and medical devices are not arbitrary but are guided by:
Scientific criteria for each item: Decisions about using a specific implantable device for a patient should be based on relevant scientific evidence supporting its efficacy, safety, and appropriateness for the clinical indication.
National/international recognised guidelines/approvals for such specific item(s): The devices used should be those that have been evaluated and approved or recommended by reputable national or international regulatory bodies or professional guidelines. This ensures that implants used are evaluated for safety and efficacy and are not experimental or unproven.
Rationale: Evidence-based selection and usage of implants is essential for:
Patient Safety: Ensuring that implanted devices are safe for patient use and are less likely to cause adverse events or complications.
Clinical Efficacy: Selecting devices that have demonstrated clinical effectiveness for the intended purpose, maximizing the likelihood of therapeutic benefit for the patient.
Appropriate Utilization: Guiding usage based on established criteria helps prevent overuse, misuse, or inappropriate application of implants.
Standard of Care: Adhering to recognised guidelines and approvals reflects accepted standards of care in device implantation practices.
Regulatory Compliance: Using approved and guideline-recommended devices aligns with regulatory expectations for medical device safety and efficacy.
Practical Implementation - Evidence-Based Implant Selection:
Before selection: Relevant and sufficient scientific data should be available: Before deciding to use a particular implantable prosthesis or medical device within the hospital, the multidisciplinary committee (or a designated device evaluation committee - see note below) should ensure that:
Scientific literature review: Relevant scientific literature (clinical studies, systematic reviews, meta-analyses) supporting the device's efficacy and safety for the intended indication is reviewed and evaluated.
Sufficient data exists: Ensure there is sufficient and robust scientific evidence, not just preliminary or anecdotal data, to support the use of the device. Evidence should be from reputable sources and peer-reviewed publications.
Consider patient population: Evaluate if the scientific data is relevant to the specific patient population being treated at the hospital (age, comorbidities, etc.).
For product approval: International or national notification: Prioritize the use of implantable devices that have received regulatory approval or recommendation from recognised bodies. The slide provides examples:
International notification: US-FDA: Approval by the U.S. Food and Drug Administration (FDA) is a widely recognised international benchmark for medical device safety and efficacy. FDA approval signifies that the device has undergone rigorous pre-market evaluation and meets certain standards.
National notification: Central Drugs Standard Control Organisation notification based on Drugs and Cosmetics Act: In India, approvals and notifications from the Central Drugs Standard Control Organisation (CDSCO), under the Drugs and Cosmetics Act, are the relevant national regulatory approvals for medical devices. CDSCO approval indicates that the device has been evaluated and meets Indian regulatory requirements. Hospitals should prioritize devices approved by CDSCO for use in India. Similar regulatory bodies exist in other countries (e.g., EMA in Europe, Health Canada in Canada).
Other recognised guidelines: In addition to regulatory approvals, consider using implantable devices that are recommended or endorsed by reputable:
National or international clinical practice guidelines: Guidelines from medical societies for specific clinical specialties may provide recommendations on the use of specific types of implants for particular conditions.
Professional organizations: Organizations like specialty medical societies or device-specific professional groups may issue guidance on appropriate device usage.
Note: "The multidisciplinary committee should be responsible for approving the use of an implant." While MOM 1b establishes the multidisciplinary committee for medication management, for MOM 10 on implants, a dedicated sub-committee or a separate 'Implantable Devices Committee' within the hospital may be more appropriate to handle device-specific evaluations and approvals. This committee would ideally include:
Surgeons or physicians who will be implanting the devices.
Pharmacists (to consider any associated medications).
Biomedical engineers or device specialists.
Quality and safety representatives.
Administrators.
This committee would be responsible for reviewing scientific data, regulatory approvals, guidelines, and hospital-specific factors to approve the use of specific implantable prosthesis and medical devices within the hospital formulary (or equivalent device approval process).
Key Phrase: "Implements a mechanism for the usage." Establishing a structured process for device management.
Requirement: The hospital must have a well-defined mechanism or structured process in place to manage the entire lifecycle of implantable prosthesis and medical devices, from procurement to usage. This mechanism ensures that devices are handled in a controlled, safe, and traceable manner throughout their journey within the hospital.
Rationale: A structured mechanism for device usage is essential for:
Quality Control: Ensuring that only approved and quality-assured devices are procured and used.
Traceability and Recall Management: Having a system to track devices from procurement to implantation allows for effective traceability, which is crucial for managing device recalls if they occur (as per MOM 10e).
Inventory Management: Controlling procurement, storage, and issuance optimizes device inventory and prevents stock-outs or wastage.
Standardization and Consistency: A mechanism promotes consistent practices across the hospital in device selection, handling, and documentation.
Regulatory Compliance: Having a defined mechanism often aligns with regulatory expectations for medical device management and traceability.
Practical Implementation - Mechanism for Device Usage:
Written guidance: The slide emphasizes written guidance, indicating the need for policies and procedures to document the mechanism. Areas to be covered in written guidance include:
Procurement: The mechanism should outline the process for device procurement, including:
Vendor selection: Criteria for selecting reliable and reputable device vendors.
Purchase process: Steps for ordering devices, ensuring proper authorization and budgetary approvals.
Receipt and inspection: Procedures for receiving device deliveries, verifying quantities, checking for damage, and confirming device specifications (model, size, lot number, serial number, etc.).
Storage/Stocking: Guidance on device storage and stocking:
Storage conditions: Defining appropriate storage conditions (temperature, humidity, sterility) to maintain device integrity, based on manufacturer's recommendations.
Inventory management: Implementing inventory control methods to track device stock levels, expiry dates, and prevent stock-outs or wastage.
Secure storage: Ensuring secure storage areas to prevent loss, damage, or unauthorized access to devices, especially high-value or critical devices.
Issuance: Procedures for device issuance and tracking for implantation:
Device request process: How surgeons or relevant clinical staff request devices for planned procedures.
Issuance from pharmacy or central supply: Designated personnel responsible for issuing devices from inventory upon authorized requests.
Device tracking system: Implementing a system to track each device individually (by lot number, serial number) from issuance to implantation. This can be manual (logbooks) or electronic (inventory management software, EHR integration).
Usage: Guidelines for device usage and documentation during implantation procedures:
Pre-implantation verification: Procedure for verifying device sterility, integrity, and appropriateness immediately before implantation.
Documentation in operative records: Requirements for documenting details of the implanted device in the patient's operative notes, surgical records, or procedure notes.
Recording device details (MOM 10d): Specifically outlining procedures for accurately recording the batch number and serial number (or unique device identifier - UDI) of the implanted device in the patient's medical record, master logbook, and discharge summary (as detailed in MOM 10d).
Note: "The written guidance should address statutory regulations/guidelines and manufacturer's recommendation(s)." The hospital's mechanism and written guidelines for device usage must be developed in compliance with all applicable statutory regulations, legal requirements, and should incorporate manufacturer's recommendations for device handling, storage, and use.
Key Phrase: "Patient and his/her family are counselled for the usage." Emphasis on patient education and pre-implantation counseling.
Requirement: Before implantation, patients and their families must be adequately counselled and educated about the implantable prosthesis or medical device. This counseling should cover:
Usage: Explanation of the purpose, function, and expected benefits of the implanted device.
Precautions if any: Information about any necessary precautions the patient needs to take after implantation, including any limitations on activity, specific care instructions, or potential drug interactions or contraindications.
Reporting: Guidance on what symptoms or issues the patient should report to the hospital or physician after implantation and when to seek medical attention.
Rationale: Patient and family counseling is essential for:
Informed Consent and Patient Autonomy: Providing patients with adequate information enables them to make informed decisions about undergoing implantation and actively participate in their care.
Improved Patient Outcomes: Counseling and education can enhance patient understanding of the device and its proper use, improving adherence to post-implantation care instructions and maximizing device effectiveness.
Reduced Complications: Educating patients about precautions and warning signs helps them prevent potential complications and seek timely medical attention if problems arise.
Enhanced Patient Satisfaction: Patients who are well-informed and prepared for the implant and post-implantation care are generally more satisfied with their care experience.
Practical Implementation - Patient Counseling Process:
Usage: Of implantable prosthesis and medical devices: Counseling should include:
Explain the purpose of the implant: Clearly explain to the patient and family why the implant is recommended, what condition it is intended to treat or address, and what benefits are expected. Use language that is easily understandable for a layperson, avoiding complex medical jargon.
Describe device function: Provide a basic explanation of how the device works and what it does within the body. Use visual aids, diagrams, or models if helpful.
Expected outcomes and benefits: Explain the anticipated outcomes and benefits of the implantation procedure. Set realistic expectations about what the patient can expect in terms of symptom relief, functional improvement, or quality of life improvement.
Precautions: Non-usage of specific drugs: Counseling should include information about any specific precautions the patient must take after implantation, such as:
Drug-drug interactions: Inform patients about any medications they should avoid taking or use with caution due to potential interactions with the implanted device or any medications they will need to take in conjunction with the device.
Drug-device interactions: Explain if there are any specific drug classes or medications that are contraindicated or should be used with caution in patients with the implanted device.
Reporting: To the hospital if a particular symptom occurs: Counseling should provide clear guidance on what symptoms or warning signs the patient and family should be vigilant for and when to report to the hospital or physician. Examples include:
Signs of infection at the implantation site (redness, swelling, pain, discharge, fever).
Device malfunction symptoms (if applicable to the device type).
Unexpected pain, discomfort, or limitations in function after implantation.
Allergic reactions or other adverse events that might be related to the implant.
Provide clear contact information for the hospital or physician's office to facilitate reporting and seeking medical advice if needed.
Documentation of counseling: Document the patient counseling in the patient's medical record, including:
Date and time of counseling.
Topics covered during counseling (usage, precautions, reporting).
Patient's (and family's, if involved) understanding and any questions asked.
Materials provided to the patient (written information sheets, videos, etc.).
Key Phrase: "Batch and serial number...recorded." Emphasis on traceability and unique device identification.
Requirement: For every implantable prosthesis and medical device implanted in a patient, the hospital must accurately record and document the:
Batch number (Lot number): Indicates the production batch of the device, helpful for identifying devices from the same manufacturing run in case of quality issues or recalls.
Serial number (Unique Device Identifier - UDI, if available): The unique serial number that specifically identifies each individual device. UDIs are increasingly common and provide the highest level of traceability.
These details must be recorded in at least three key locations:
Patient's medical record: For a permanent and easily accessible record linked to the specific patient who received the implant.
The master logbook (Device logbook or implant registry): A centralized logbook (paper or electronic database) that tracks all implants used in the hospital, serving as a comprehensive device registry for inventory management, recall tracking, and quality assurance.
The discharge summary: Include implant details in the discharge summary provided to the patient upon discharge, ensuring they have a record of their implanted device for future medical reference.
Rationale: Recording batch and serial numbers is critical for:
Device Traceability for Recalls: In the event of a device recall issued by the manufacturer or regulatory body, having batch and serial numbers allows the hospital to quickly identify which patients received the recalled devices. This is essential for contacting affected patients and implementing recall procedures effectively (as required by MOM 10e).
Adverse Event Investigation: If a patient experiences an adverse event potentially related to an implant, batch and serial number information helps trace the device back to its manufacturing origin for investigation and quality control analysis.
Product Liability and Legal Issues: Accurate device records are essential for managing product liability issues or legal claims related to implant failures or defects.
Inventory Management and Audit Trails: Batch and serial number tracking supports more precise inventory management and provides a robust audit trail for devices from procurement to implantation to disposal.
Practical Implementation - Recording Device Details:
Does the implant have a pre-labelled sticker? Flowchart addresses different scenarios for recording device details:
YES -> Record batch number and serial number: If the device packaging comes with a pre-labelled sticker containing batch and serial number (or UDI), the most efficient method is to:
Peel off the sticker from the device packaging immediately before implantation.
Affix the sticker directly onto the designated location in the patient's medical record (e.g., implant log sheet, operative note).
Also record the batch and serial number (or UDI) in the master device logbook (manual or electronic).
Document the implant details in the discharge summary, either by manually transcribing or electronically linking the information.
NO -> Use a mechanism to identify implant (Manufacturer, type, size, batch number and serial number and other important detail): If the device package does not have a pre-labelled sticker, a more manual approach is needed:
Before implantation, carefully record the following details directly from the device packaging onto designated forms or electronic fields:
Manufacturer name
Device type/model name
Device size (if applicable)
Batch number (lot number)
Serial number (or UDI if present)
Any other important identifying details (expiry date, reference number, etc.).
Ensure that these details are accurately recorded in the patient's medical record, master device logbook, and discharge summary. This might involve manual transcription or data entry.
Note: "The implant details should be recorded in the patient's medical record, master logbook and discharge summary." Reinforces the requirement to record device details in all three locations.
Master Logbook (Device Registry): The master device logbook should be a centralized record that tracks all implants used in the hospital. It can be:
Paper-based logbook: A physical register where device details are manually entered.
Electronic database or registry: A preferred method for better data management, searching, and reporting. An electronic system can be integrated with the EHR or a dedicated device registry software. Electronic systems facilitate recall management and data analysis.
The master logbook should contain fields for: Patient identifier (MRN), Patient name, Date of implantation, Device type, Manufacturer, Model name, Size (if applicable), Batch number, Serial number (or UDI), Implanting surgeon/physician, and date of record entry.
Key Phrase: "Process of recall...handled effectively." Ensuring a robust recall management system.
Requirement: The hospital must have a well-defined and effective process in place to handle recalls of implantable prosthesis and medical devices. This process should ensure that recalled devices are promptly identified, tracked, patients who received recalled devices are identified and notified, and appropriate actions are taken to manage the recall effectively.
Rationale: Effective device recall management is crucial because:
Patient Safety: Recalls are often issued due to safety concerns. A robust recall process is essential to protect patients from potential harm associated with recalled devices.
Legal and Ethical Obligations: Hospitals have a legal and ethical responsibility to act promptly and effectively upon device recalls to protect their patients.
Regulatory Compliance: Device recall management is often a regulatory expectation for healthcare organizations.
Risk Mitigation: Prompt and effective recall management minimizes the potential for legal liabilities, reputational damage, and negative impact on patient trust.
Practical Implementation - Effective Device Recall Process:
Based on: Triggers for initiating the recall process:
Communication from regulatory authorities: Medical device regulatory bodies (like FDA, CDSCO) issue recall notices for devices deemed unsafe or ineffective. Hospitals must have a system to promptly receive, monitor, and act upon these official recall communications (e.g., subscribing to alerts, monitoring agency websites).
Manufacturer's or internal feedback: Device manufacturers may initiate voluntary recalls. Hospitals should have channels to receive recall notices directly from manufacturers (e.g., through vendor networks, direct communications). Internal feedback (e.g., from surgeons, biomedical engineers, infection control) might also trigger a review and potential internal recall if a device problem is identified within the hospital.
Inform: Actions upon receiving recall information:
Appropriate regulatory authority and manufacturer in case of recall due to internal feedback: If a recall action is initiated based on internal feedback or hospital-identified device issues, consider informing the appropriate regulatory authority and the device manufacturer about the findings, especially if the issue has broader safety implications or affects multiple devices.
Steps in a Device Recall Procedure: A comprehensive device recall process should include steps like:
Prompt receipt and verification of recall notice: Confirm the authenticity and details of the recall notice from a reliable source (regulatory body, manufacturer).
Identify and quarantine recalled devices: Using the master device logbook and implant records (MOM 10d), immediately identify and locate all inventory stocks of the recalled device within the hospital, including:
Pharmacy or central supply inventory.
Operating room stock.
Catheterization labs, procedure areas.
Any other storage locations.
Quarantine all identified stocks of the recalled device to prevent further use or implantation.
Patient identification: Using the device logbook and patient implant records (MOM 10d), systematically identify all patients who have received implantation of the recalled device (using batch numbers and serial numbers/UDIs).
Patient notification and follow-up: Develop a plan for patient notification and follow-up, guided by the nature of the recall, potential risks, and regulatory recommendations. This may involve:
Contacting affected patients directly (letters, phone calls, secure messaging) to inform them about the recall and the nature of the issue.
Providing patients with information about potential risks, symptoms to watch for, and recommended follow-up actions (clinical evaluation, device explantation if necessary, etc.).
Establishing a dedicated phone line or clinic for patient inquiries related to the recall.
Device return or disposal: Arrange for the return of quarantined recalled devices to the manufacturer as per recall instructions, or dispose of them according to hospital policy and regulatory requirements for medical waste (if return is not possible).
Documentation: Document all steps taken during the recall process, including receipt of recall notice, device quarantine, patient identification, patient notification process, device return/disposal, and any patient follow-up actions. Maintain records for audit trails and regulatory compliance.
Staff training: Train all relevant staff (pharmacy, surgery, nursing, device inventory personnel, etc.) on the hospital's device recall procedure and their roles in implementing it.
MOM Standard 10 focuses on ensuring the safe and appropriate use of implantable prosthesis and medical devices, emphasizing:
Evidence-Based Device Selection (MOM 10a): Using scientific criteria and recognised guidelines/approvals for device selection.
Structured Usage Mechanism (MOM 10b): Implementing a comprehensive mechanism to manage the entire lifecycle of devices.
Patient Counseling (MOM 10c): Providing thorough pre-implantation counseling to patients and families.
Traceability and Recording (MOM 10d): Mandatory recording of batch and serial numbers for effective tracking and recall management.
Effective Recall Management (MOM 10e): Establishing a robust process for handling device recalls to protect patients and ensure regulatory compliance.
This standard, the final one in the MOM chapter, broadens the scope beyond medications and implantable devices to include general medical supplies and consumables. It emphasizes that these items, while perhaps less technically complex than medications or implants, are nonetheless essential for patient care and require proper storage and availability to ensure effective and safe healthcare delivery.
Let's dissect each objective element within MOM 11:
Key Phrase: "Defined process for the acquisition." Emphasizing a structured procurement system.
Requirement: The hospital must have a clearly defined and documented process for the acquisition (procurement, purchasing) of medical supplies and consumables. Furthermore, the hospital must actively adhere to this defined process in practice. This ensures a systematic and controlled approach to obtaining these essential items.
Rationale: A defined acquisition process for medical supplies is essential for:
Consistent Supply: Ensuring a reliable and continuous supply of medical supplies and consumables is crucial for uninterrupted patient care. Stock-outs of even seemingly basic supplies can disrupt procedures and patient care workflows.
Quality Assurance: A structured procurement process allows for vendor selection based on quality criteria, helping ensure that the hospital purchases medical supplies that meet safety and performance standards.
Cost-Effectiveness: A well-managed procurement process can incorporate strategies for vendor negotiation, bulk purchasing, and competitive bidding, optimizing costs for medical supplies.
Standardization: A defined process promotes standardization in the types and brands of medical supplies used across the hospital, potentially simplifying inventory management and staff training.
Regulatory Compliance: Procurement procedures may need to comply with hospital purchasing policies, ethical sourcing guidelines, and any relevant regulations for medical supplies.
Practical Implementation - Establishing and Adhering to an Acquisition Process:
Vendor selection: Define a process for selecting vendors of medical supplies and consumables. This process should include:
Vendor qualification criteria: Establish criteria for vendor selection based on factors like:
Reputation and reliability.
Quality certifications or accreditations (e.g., ISO certification).
Compliance with quality standards.
Price competitiveness.
Delivery reliability and timelines.
Responsiveness to issues and customer service.
Approved vendor list: Maintain a list of approved vendors for different categories of medical supplies based on vendor evaluation.
Periodic vendor evaluation: Conduct periodic evaluations of vendor performance (delivery, quality, service) to ensure ongoing vendor quality and to inform future vendor selections.
Vendor evaluation: (Reiterated from Vendor selection, likely emphasizing ongoing performance evaluation). See above points under Vendor selection about ongoing assessment of vendor performance.
Indenting process: Establish a clear and streamlined "indenting" or requisition process for hospital departments to request medical supplies and consumables from the central supply or pharmacy (depending on the item). This process should include:
Standardized requisition forms (paper or electronic) that are easy to use.
Clear guidelines on who is authorized to raise indents from each department.
Defined approval workflows for indent requests (e.g., departmental head approval).
Efficient communication between departments and supply/pharmacy for indent processing.
Generation of purchase order: Define the process for generating purchase orders (POs) based on approved indent requests. This step should involve:
Verification of indent approval.
Selection of appropriate vendor from the approved vendor list.
Generation of a formal purchase order with all necessary details (item names, quantities, specifications, vendor details, pricing, delivery instructions, terms and conditions).
Proper authorization and budgetary approvals for purchase orders.
Documentation and record-keeping of all purchase orders generated.
Receipt of goods: Establish clear procedures for receiving deliveries of medical supplies and consumables:
Designated receiving area: Have a designated and organized receiving area for deliveries.
Verification of delivery against purchase order: Upon receipt of goods, verify that the items delivered match the details on the purchase order (item name, quantity, specifications).
Inspection of goods for quality and damage: Inspect incoming supplies for any visible damage, defects, or signs of compromise.
Expiry date check (if applicable): For supplies with expiry dates (e.g., sterile dressings, certain disposables), check expiry dates and ensure they are within acceptable limits.
Documentation of receipt of goods: Properly document the receipt of goods, noting any discrepancies, damages, or issues.
Proper storage after receipt (as per MOM 11c and 11d).
Points to Remember:
Medication supplies and consumables are items that are used in patient care: Clarify the scope of "medical supplies and consumables." This generally refers to items used directly in patient care but are not medications in the traditional sense. Examples: syringes, needles, IV sets, catheters, dressings, bandages, gloves, suction tubing, wound care products, etc.
Medications and implants do not belong to this category: Explicitly exclude medications (covered by MOM 1-9) and implants (covered by MOM 10) from the scope of MOM 11. MOM 11 focuses on general medical supplies and consumables used in patient care, excluding the more specialized categories of medications and implants which have their own dedicated standards.
Key Phrase: "Used in a safe manner, where appropriate." Emphasis on safe usage practices.
Requirement: Medical supplies and consumables must be used in a safe manner wherever applicable. This means implementing practices and precautions to minimize risks associated with their use, protecting both patients and healthcare staff. "Where appropriate" acknowledges that the level of safety measures might vary depending on the specific type of supply and its intended use (e.g., sterile supplies require stricter safety precautions than non-sterile items).
Rationale: Safe use of medical supplies is important for:
Preventing Infection: Proper handling and use of sterile supplies are critical for preventing healthcare-associated infections (HAIs).
Patient Safety during Procedures: Safe use of devices like catheters, needles, and tubing is essential to avoid injuries, complications, and adverse events during procedures.
Staff Safety: Safe handling and disposal of sharps and potentially contaminated supplies are crucial for protecting staff from injuries and exposure to infectious agents.
Effective Functionality: Using supplies correctly ensures they function as intended and are effective for their clinical purpose.
Practical Implementation - Safe Use Practices:
Take relevant precautions: Implement relevant safety precautions during the use of medical supplies, which will depend on the specific item and its intended purpose. Examples of precautions:
Sterile technique: Use strict aseptic technique when handling and using sterile supplies (syringes, needles, IV catheters, central line insertion kits, surgical instruments, etc.) to maintain sterility and prevent contamination. This includes proper hand hygiene, use of sterile gloves, sterile field preparation, and avoiding contamination during handling.
Sharps safety: Implement sharps safety practices for needles and other sharps (scalpels, lancets):
Use safety-engineered sharps devices with sharps injury prevention features (e.g., retractable needles, safety scalpels).
Activate safety mechanisms immediately after use.
Never recap needles.
Dispose of used sharps immediately and safely in approved sharps containers.
Provide sharps safety training to all staff handling sharps.
Appropriate use of personal protective equipment (PPE): Use appropriate PPE (gloves, gowns, masks, eye protection) when handling potentially contaminated supplies or performing procedures where there is a risk of exposure to blood, body fluids, or infectious agents.
Correct usage techniques: Train staff on the correct techniques for using various medical supplies and devices (e.g., proper catheter insertion techniques, correct use of suction devices, appropriate dressing application methods).
Maintain sterility and integrity of items: Focus on maintaining the sterility and integrity of sterile medical supplies:
Store sterile supplies in designated, clean, and dry storage areas that protect packaging integrity (MOM 11c).
Check packaging integrity before use: Inspect sterile packaging immediately before use to ensure it is intact, dry, and not damaged or compromised in any way. Do not use supplies with damaged packaging.
Use within expiry date: Always check expiry dates on sterile supplies before use and do not use expired items.
Handle sterile supplies using aseptic technique to avoid contamination during preparation and use.
Use single-use devices only once and dispose of them properly after single patient use. Do not reuse single-use medical devices.
Key Phrase: "Stored in a clean, safe and secure environment; and incorporating manufacturer's recommendation(s)." Similar storage requirements to medications.
Requirement: Medical supplies and consumables must be stored in an environment that is:
Clean: Storage areas must be clean and hygienic to prevent contamination, especially for sterile supplies.
Safe: Storage must be safe for the supplies themselves, protecting their integrity and functionality.
Secure: Storage should be secure enough to prevent loss, theft, or unauthorized access, especially for high-value or controlled items (if any, in the consumables category).
Incorporating the manufacturer's recommendation(s): Storage should also adhere to any specific storage instructions provided by the manufacturers of the medical supplies (e.g., temperature, humidity, light sensitivity requirements for certain specialized dressings or solutions).
Rationale: Appropriate storage of medical supplies is crucial for:
Maintaining Sterility (Sterile Supplies): Clean and controlled storage environments are essential to maintain the sterility of sterile medical supplies until they are used, preventing contamination and HAIs.
Preserving Functionality and Integrity: Proper storage protects supplies from damage, degradation, or loss of functionality due to environmental factors (temperature, humidity, light, physical damage).
Preventing Loss and Waste: Secure storage helps prevent loss, theft, or unauthorized use of supplies, reducing wastage and ensuring cost-effectiveness.
Facilitating Easy Access and Retrieval: Organized and appropriate storage makes it easier for staff to locate and retrieve needed supplies efficiently, improving workflow and responsiveness.
Practical Implementation - Compliant Storage Environment:
Storage requirements: Follow manufacturer's guidelines in all areas (including wards): Always consult the manufacturer's instructions provided with medical supplies and consumables for specific storage requirements. These recommendations should be adhered to in all storage areas, including:
Central supply stores.
Pharmacy storage areas (if pharmacy manages some supplies).
Ward medication rooms or supply cabinets.
Procedure rooms.
Clinics.
Manufacturer's recommendations might specify temperature ranges, humidity limits, protection from light, or specific storage configurations.
Storage area: Should be clean: Storage areas for medical supplies should be maintained in a clean and hygienic condition:
Regular cleaning schedules: Implement regular cleaning schedules for storage areas, shelves, and bins.
Appropriate cleaning agents: Use cleaning agents that are suitable for healthcare environments and do not leave residues or damage supplies.
Pest control: Implement pest control measures to prevent infestation in storage areas.
Dust control: Minimize dust accumulation in storage areas, especially for sterile supplies.
Points to Remember:
Protect items from loss or theft: Implement measures to prevent loss or theft of medical supplies:
Secure storage areas: Use locked cabinets, rooms, or storage areas, especially for high-value supplies or those that might be prone to unauthorized use.
Limited access: Restrict access to supply storage areas to authorized personnel only (nurses, supply staff, designated staff).
Inventory tracking: Implement inventory management systems to track supply levels and detect any unusual discrepancies that might indicate loss or theft.
Identify and store hazardous materials safely: If the hospital uses any hazardous medical supplies or consumables (e.g., certain disinfectants, chemicals, compressed gases - although not strictly "consumables" in the same sense), ensure these are:
Identified as hazardous materials.
Stored in designated, separate storage areas that are specifically designed for hazardous materials (ventilated, fire-resistant, compliant with safety regulations for chemical or hazardous material storage).
Labeled with appropriate hazard warning labels.
Staff handling hazardous materials should be properly trained on safe handling, storage, and spill procedures.
Key Phrase: "Sound inventory control practices guide storage." Efficient and organized storage driven by inventory management.
Requirement: Storage practices for medical supplies and consumables must be guided by "sound inventory control practices." This means using effective inventory management techniques to organize storage in a way that supports efficient stock management, minimizes waste, and ensures supplies are readily available when needed. (Similar to MOM 3b for medications, but applied to supplies).
Rationale: Sound inventory control for medical supplies is essential for:
Preventing Stock-Outs: Ensuring consistent availability of supplies for patient care, avoiding delays and disruptions.
Minimizing Wastage and Expiry: Proper inventory control, especially FEFO, reduces expiry of supplies and wastage due to obsolescence or damage.
Optimizing Stock Levels: Maintaining appropriate stock levels to balance availability with minimizing storage space and tied-up capital.
Improving Efficiency: Organized storage based on inventory principles makes it faster and easier for staff to locate, retrieve, and manage supplies, improving workflow efficiency and reducing time spent searching for items.
Practical Implementation - Inventory Control Methods for Supply Storage:
Always, better and control (ABC) (Based on cost): Categorize supplies based on annual cost consumption to prioritize inventory control efforts.
"A" items: High-cost supplies – require tight inventory control, frequent monitoring, and optimized stock levels. Examples: expensive surgical dressings, specialized catheters.
"B" items: Medium-cost supplies – moderate level of control and monitoring. Examples: routine dressings, standard gloves.
"C" items: Low-cost supplies – simpler inventory control methods. Examples: cotton swabs, tongue depressors.
Storage strategies can be adapted based on ABC categories (e.g., more frequent checks for "A" items).
Vital, essential and desirable (VED) (Based on criticality): Categorize supplies based on clinical criticality to prioritize stock availability.
"Vital" supplies: Absolutely essential for life-saving procedures or emergency care. Must always be in stock. Examples: emergency resuscitation supplies, critical airway management devices.
"Essential" supplies: Needed for routine patient care and common procedures. Should be readily available. Examples: standard syringes and needles, routine dressings, gloves.
"Desirable" supplies: Useful but not strictly essential, or used for less critical aspects of care. Stock levels can be more flexible. Examples: specialized comfort items, certain types of patient education materials.
Storage and access priority should be given to "Vital" supplies.
Fast moving, slow moving and non-moving (FSN): Categorize supplies by consumption rate to optimize storage layout and stock rotation.
"Fast-moving" supplies: High consumption items. Require larger stock levels and frequent replenishment. Store in readily accessible locations for quick retrieval.
"Slow-moving" supplies: Lower consumption rate. Smaller stock levels and less frequent ordering. Can be stored in less prime locations.
"Non-moving" supplies: Very low or no consumption. Need review. May indicate overstocking or obsolescence. Minimize stocking to avoid waste.
Storage layout should reflect FSN classification, with fast-moving items in easily accessible positions.
First expiry, first out (First expiry, first out): Apply FEFO principle (as with medications) to minimize expiry and waste, especially for supplies with expiry dates:
Store supplies with earlier expiry dates in front, ensuring they are used before later-expiring stock.
Train staff to always check expiry dates and pick the supplies with the earliest expiry dates first.
Lead time analysis: Analyze lead times for supply procurement to inform reorder levels and prevent stock-outs (as with medications - MOM 3b).
Key Phrase: "Mechanism in place to verify the condition." Proactive quality checks before use.
Requirement: The hospital must have a mechanism or procedure in place to verify the condition of medical supplies and consumables before they are dispensed or used for patient care. This is a quality control step to ensure supplies are in good condition, sterile (if intended to be), and fit for their intended purpose.
Rationale: Verifying supply condition before use is important for:
Patient Safety: Preventing the use of damaged, compromised, or non-sterile supplies that could lead to infections, complications, or ineffective procedures.
Maintaining Functionality: Ensuring supplies are in good working order so they function as intended during procedures or patient care.
Quality Assurance: Proactive verification is a key component of a comprehensive quality assurance system for medical supplies.
Practical Implementation - Condition Verification Mechanism:
Ensure item is in good condition for safe dispensing and usage: The verification mechanism should be designed to confirm that supplies are:
Physically intact and undamaged.
Sterile (if intended to be sterile) and packaging integrity is maintained.
Functionally sound and fit for their intended purpose.
Within their expiry date (if applicable).
Check the following: The slide lists examples of what to check during condition verification, but the specific checks will vary depending on the type of supply:
Is the package opened? For sterile supplies, check if the packaging is sealed and intact. If the package is opened, torn, or compromised in any way, the item is considered non-sterile and should not be used as a sterile item.
Is the cotton roll damp? (Example specific to cotton rolls/dressings, but principle applies to other supplies). Check for any signs of moisture, dampness, or discoloration that might indicate contamination or compromise of the supply. For example, dressings should be dry and clean; IV solutions should be clear and free of particulate matter.
Is there a physical damage? Check for any physical damage to the supply itself or its packaging. Examples: damaged syringes, broken vials, cracked containers, torn dressings. Do not use damaged supplies.
Is there unwanted discolouration? Check for any unusual discoloration of the supply itself, which might indicate degradation, contamination, or expiry. For example, some solutions might become discolored if they are no longer stable.
Responsibility for verification: Define who is responsible for performing the condition verification. This may vary depending on the supply type and setting:
Pharmacy staff (for supplies dispensed from pharmacy).
Nursing staff (before using supplies at the point of care on wards, procedure areas).
Central supply staff (upon issuing supplies from central stores).
Documentation of verification: In some cases, for critical or high-value supplies, documentation of verification may be required (e.g., in receiving logs, dispensing records, or procedure records). For routine supplies, visual verification just before use is typically sufficient.
MOM Standard 11, while focusing on seemingly less complex items (medical supplies and consumables), emphasizes that these are also crucial for patient care and require proper management. Key themes include:
Structured Acquisition Process (MOM 11a): A defined process for procurement to ensure consistent supply, quality, and cost-effectiveness.
Safe Use Practices (MOM 11b): Implementing precautions and promoting safe usage of supplies to prevent infections, injuries, and ensure effectiveness.
Appropriate Storage Environment (MOM 11c): Clean, safe, secure storage adhering to manufacturer's recommendations.
Inventory Control for Storage (MOM 11d): Using sound inventory practices (ABC, VED, FSN, FEFO) to guide storage organization and efficient stock management.
Condition Verification Before Use (MOM 11e): Establishing a mechanism to verify the quality and condition of supplies before dispensing or use, preventing the use of compromised or damaged items.
This section is crucial for establishing a common understanding of key terms used throughout the MOM chapter, particularly in MOM 8 (Patient Monitoring and Adverse Events). Consistent understanding of these terms is vital for accurate reporting, analysis, and improvement of medication safety. The slides define three core concepts:
Definition (as per slide): "Harm resulting from medical intervention related to a drug (IOM). This includes medication errors, adverse drug reactions, allergic reactions and overdoses."
Breakdown of the Definition:
Harm resulting from medical intervention: This emphasizes that an ADE is not just any negative health outcome; it must be a direct result of a medical intervention involving a drug. This means it's related to the process of using a drug in healthcare.
Related to a drug (IOM): The harm must have a causal link to the use of a medication. The "IOM" reference is to the Institute of Medicine (now the National Academy of Medicine) - a highly respected body that has extensively studied patient safety. Referencing IOM lends authority and credibility to the definition.
This includes...: The definition explicitly lists categories of events that are included under the umbrella of ADEs:
Medication errors: Harm caused by preventable mistakes in the medication use process.
Adverse drug reactions (ADRs): Harmful reactions to a drug even when used appropriately (explained in detail below).
Allergic reactions: Harmful immune responses to a drug.
Overdoses: Harm caused by intentionally or unintentionally administering too much of a drug.
Key Takeaways about ADEs:
Broadest category: ADE is the widest term, encompassing all types of drug-related harm arising from medical care.
Not necessarily preventable: ADEs include both preventable harm (due to errors) and harm that is often unavoidable (ADRs).
Focus on harm: The defining feature of an ADE is that harm to the patient must have occurred.
Slide Information (Beyond Definition):
ADE - (all blue areas): The slide likely uses a visual (blue shaded area) to represent ADEs, possibly in relation to diagrams on subsequent slides showing the relationships between ADEs, ADRs, and Medication Errors.
Account for an estimated 1 in 3 of all hospital adverse events: Highlights the significant contribution of ADEs to overall hospital adverse events.
Affect about 2 million hospital stays each year: Emphasizes the high frequency of ADE-related hospitalizations (likely referencing US data, but similar trends exist globally).
Prolong hospital stays by 1.7 to 4.6 days: Underscores the economic impact of ADEs by showing they significantly increase length of hospital stay.
Definition (as per slide): "Is drug-induced harm occurring with appropriate use of medication (i.e., not caused by an error). It includes any response to a drug which is noxious and unintended that occurs at doses normally used in man for prophylaxis, diagnosis, or therapy of disease, or for the modifications of physiological function (WHO)."
Breakdown of the Definition:
Drug-induced harm: ADRs are specifically caused by the drug itself.
Occurring with appropriate use of medication (i.e., not caused by an error): A crucial distinction. ADRs are not due to medication errors. They occur even when the right drug, right dose, right route, right time are given to the right patient. They are often unavoidable, but may be predictable in some cases.
Noxious and unintended: ADRs are harmful (noxious) and are not the intended therapeutic effects of the drug (unintended). They are undesirable and negative outcomes.
Occurs at doses normally used in man for prophylaxis, diagnosis, or therapy of disease, or for the modifications of physiological function (WHO): This part is a direct quote from the World Health Organization (WHO) definition of ADRs, further establishing the definition's authority. It clarifies that ADRs can occur at normal therapeutic doses, not just in cases of overdose. ADRs can occur when drugs are used for prevention (prophylaxis), diagnosis, treatment (therapy), or even to modify normal bodily functions (e.g., contraceptives).
Key Takeaways about ADRs:
Subtype of ADE: ADRs are a subset of ADEs. All ADRs are ADEs (they are drug-related harm from medical intervention), but not all ADEs are ADRs (some ADEs are due to medication errors, not inherent drug reactions).
Unavoidable harm (often): While ADRs can be managed and their risk minimized, they are often an inherent risk of using medications, even when used correctly. They are generally considered non-preventable adverse events in many contexts, distinguishing them from preventable adverse events like medication errors.
Occurs with appropriate use: This is the key defining feature differentiating ADRs from harm caused by errors.
Slide Information (Beyond Definition):
ADE (all blue areas): ADR: The slide visually represents ADRs as a smaller, nested circle within a larger circle representing ADEs, illustrating the subtype relationship.
Definition (as per slide): "Medication errors are mistakes that occur during prescribing, transcribing, dispensing, administering, adherence, or monitoring a drug. Medication errors that are stopped before harm can occur are sometimes called "near misses" or more formally, a potential adverse drug event. Though medication errors are very common, they result in harm less than 1% of time."
Breakdown of the Definition:
Mistakes that occur during...: Medication errors are mistakes in the medication use process itself. The definition lists the key stages of this process where errors can occur:
Prescribing: Errors in drug selection, dose, route, frequency, or other aspects of the prescription order.
Transcribing: Errors when transferring a prescription from one format to another (e.g., from doctor's order sheet to pharmacy system or medication administration record).
Dispensing: Errors in selecting, preparing, or labeling the medication in the pharmacy.
Administering: Errors during the actual act of giving the medication to the patient (wrong patient, wrong dose, wrong route, wrong time).
Adherence (or compliance): Errors related to patients not taking their medications as prescribed (omitting doses, incorrect timing, etc.). While patient adherence is often the patient's responsibility, healthcare systems can contribute to adherence issues and may have system-level errors in patient education or support.
Monitoring: Errors in failing to adequately monitor patient response to medication or failing to detect adverse events through monitoring.
Medication errors that are stopped before harm can occur are sometimes called "near misses" or more formally, a potential adverse drug event: This distinction is crucial. Medication errors are not always harmful.
Near misses (or "close calls"): These are medication errors that were detected and intercepted before they reached the patient or before harm occurred. They are valuable learning opportunities as they highlight system vulnerabilities without patient injury.
Potential adverse drug event: "Potential ADE" is a more formal term sometimes used for near misses, emphasizing that a harm event was narrowly avoided.
Though medication errors are very common, they result in harm less than 1% of time: This provides context about the frequency and impact of medication errors. While medication errors are common occurrences in healthcare, most of them do not result in significant harm to patients. However, even a small percentage of errors causing harm still translates to a large number of preventable adverse events due to the high volume of medication use in hospitals.
Key Takeaways about Medication Errors:
Preventable mistakes: Medication errors are fundamentally preventable through system improvements and adherence to safe practices. This is a key difference from ADRs, which are often unavoidable.
Potential for harm (but often without): Medication errors have the potential to cause harm (ADE), but many are intercepted or do not result in clinically significant harm.
Focus for improvement: Reducing medication errors is a primary focus of medication safety initiatives, as they represent preventable harm. Near miss analysis is also crucial for proactive prevention.
Slide Information (Beyond Definition):
Medication errors (No harm, Near misses) Harm: The slide likely visually represents medication errors as a circle (or area), with a smaller section labeled "Harm" and a larger section labeled "Medication errors (No harm, Near misses)." This illustrates that most medication errors are near misses or do not cause harm, but a subset does lead to patient harm.
Adverse Drug Events diagram: The slide presents a diagram (likely a pie chart or Venn diagram) visually representing the relationship between Adverse Drug Events and Medication Errors.
About 50% of adverse drug events are due to medication errors and are preventable. These are called preventable adverse events: This key statistic underscores the significant contribution of medication errors to ADEs and emphasizes their preventability. About half of all ADEs in hospitals are considered preventable because they are caused by medication errors. These preventable ADEs are the primary target for medication safety improvement efforts.
Medication errors that did not result in harm are called potential adverse events: Reiterates the concept of "potential ADEs" or near misses. These are important because they indicate system vulnerabilities that could lead to harm in the future if not addressed, even if no harm occurred in a specific instance.
Adverse reaction or side effects of drugs are called non-preventable adverse events: ADRs (and side effects) are often classified as non-preventable adverse events (though their risk can be minimized, they are not completely avoidable with current knowledge). This contrasts with preventable adverse events like medication errors. Understanding this distinction helps in focusing quality improvement efforts – reducing preventable errors while also managing the risk of unavoidable reactions.
Diagram breakdown (likely approximate): The diagram probably shows pie slices or sections representing:
Preventable AE (Due to medication errors resulting in harm): A section, possibly representing about 50% of ADEs, visually showing the portion of ADEs that are preventable medication errors that caused harm.
Potential AE (Due to medication errors resulting in near misses): A section showing medication errors that were near misses (no harm). These are still important but did not lead to ADEs in that instance.
(ADR/Side effects) (Non-preventable AE): A section representing ADRs and side effects. These are non-preventable ADEs as they occur despite appropriate drug use.
Non-preventable AE (Other causes): A smaller section (possibly) for non-preventable ADEs not related to ADRs/side effects. This category is less common and less emphasized.
While the slides don't have a dedicated "References" slide, references are implied and explicitly mentioned throughout the presentation:
World Health Organization (WHO) Definition of ADR (Page 67): The presentation quotes the WHO definition of ADR. This is a direct reference to a reputable and authoritative source for defining ADRs, lending weight and global consensus to the definition.
Institute of Medicine (IOM) Definition of ADE (Page 66): Referencing "IOM" (now National Academy of Medicine) connects the ADE definition to a well-respected US-based health policy and advisory body, again enhancing the definition's credibility.
ISMP (Institution for Safe Medication Practices) Guidelines (Pages 42 & 58): The presentation refers to "Institution for Safe Medication Practices' guidelines" in MOM 5c (Legible orders) and "ISMP Acute Care Guidelines for Timely Administration of Scheduled Medications" in MOM 7g (Timing Verification). This is a crucial implied reference. ISMP is a non-profit organization globally recognized as a leader in medication safety. Referencing ISMP guidelines implies that NABH MOM standards are aligned with internationally recognized best practices in medication safety. Hospitals seeking NABH accreditation should definitely be familiar with and implement relevant ISMP guidelines.
'Drugs and Cosmetics Act' and 'Code of Medical Ethics' (Page 32): Mentioned in MOM 4b (Minimum prescription requirements). These refer to Indian legal and ethical frameworks relevant to medication use in India, providing the local regulatory and ethical context for the NABH MOM standards in India.
AERB guidelines (Pages 75 & 77): Mentioned in MOM 9a and 9c (Narcotic drugs & psychotropic substances). The Atomic Energy Regulatory Board (AERB) guidelines are referenced for the safe handling of radio-pharmaceuticals in India. This highlights the importance of compliance with local regulatory frameworks for specialized medications like radio-pharmaceuticals.
General "best practices" (Page 70): MOM 8c Note mentions "adverse drug reaction (ADR) based on the best practices," implying that the hospital's definition of ADR should be aligned with widely accepted "best practices" in the field.
Importance of Definitions and References:
Clarity and Consistency: Definitions ensure that everyone using the MOM standards (hospital staff, assessors, trainers) has a common understanding of key terms, promoting clear communication and consistent implementation of the standards.
Authority and Credibility: Referencing authoritative bodies like WHO, IOM, ISMP, and regulatory acts lends credibility and authority to the MOM standards and underlying principles.
Guidance for Implementation: References to guidelines and best practices (like ISMP, AERB) provide hospitals with practical resources and actionable recommendations for implementing the MOM standards effectively.
Context and Rationale: References help understand the broader context of medication safety and the evidence base or regulatory drivers behind specific MOM standard requirements.
Here is a comprehensive list of policies and procedures that are either explicitly stated or strongly implied as being required within the NABH 6th Edition MOM (Management of Medication) Chapter, categorized by MOM Standard for clarity:
1a. Written Guidance for Pharmacy Services and Medication Usage:
Policy/Procedure for Formulary Management: Process for creating, reviewing, updating, and accessing the hospital formulary.
Policy/Procedure for Medication Procurement: Steps for vendor selection, evaluation, ordering, receiving, and managing medication supplies.
Policy/Procedure for Medication Storage: Guidelines for safe and secure storage, considering temperature, light, humidity, security, and segregation of medications, including high-risk and emergency medications.
Policy/Procedure for Medication Prescription (Rational Prescription): Guidelines for rational prescribing practices, addressing good practices and potentially specific clinical guidelines.
Policy/Procedure for Dispensing of Medications: Steps for safe dispensing, prescription verification, labeling, handling recalls, and managing near-expiry medications.
Policy/Procedure for Medication Administration: Protocols for safe medication administration, including patient identification, verification of orders, techniques for various routes, and documentation.
Policy/Procedure for Patient Monitoring After Medication Administration: Process for monitoring patients for therapeutic effects, adverse drug reactions, and reporting mechanisms.
Policy/Procedure for Medication Usage: Overarching guidelines on appropriate and rational medication use within the hospital, including aspects like antimicrobial stewardship, handling patient-brought medications, etc.
1d. Procedure to Obtain Medication When Pharmacy is Closed:
Standard Operating Procedure (SOP) for After-Hours Medication Access: Procedure to obtain medications when the hospital pharmacy is closed, including steps for authorization, access to limited stock, or procurement from outside sources
1e. Mechanism to Inform Staff of Key Changes:
Procedure/Mechanism for Communication of Pharmacy Service Changes: Process for informing relevant staff about key changes in pharmacy services and medication management (e.g., medication shortages, drug recalls, serious adverse events).
2e. Procedure for Acquisition of Formulary Medications:
Procedure for Acquisition of Formulary Medications: Detailed process for acquiring medications listed in the hospital formulary, including vendor management, ordering, receiving, and stock-out management.
2f. Procedure to Obtain Medications Not Listed in the Formulary:
Procedure for Acquisition of Non-Formulary Medications: Process for clinicians to request and obtain medications not listed in the formulary, including steps for evaluation, authorization, and ratification.
3a. Guidelines for Storage Environment and Manufacturer's Recommendations:
Guidelines for Medication Storage Environment: Detailed guidelines outlining requirements for clean, safe, and secure storage environments for medications, addressing temperature, humidity, light, security, and organization, and incorporating manufacturer recommendations.
Guidelines for Vaccine Storage: Specific guidelines for vaccine storage addressing temperature monitoring, separate storage, and handling in vaccine refrigerators.
3b. Sound Inventory Control Practices:
Procedure for Inventory Control Practices for Medication Storage: Procedure detailing the implementation of sound inventory control practices (ABC, VED, FSN, FEFO, Lead time analysis) to guide medication storage and stock management throughout the organization.
3c. Definition of High-Risk Medication List:
Procedure for Defining and Updating High-Risk Medication List: Process for developing and regularly updating a list of high-risk medications specific to the hospital.
3f. Procedure for Defining Emergency Medication List:
Procedure for Defining Emergency Medication List: Process for developing and regularly reviewing the hospital's list of emergency medications to be included in crash carts and emergency medication sets.
3g. Procedure for Emergency Medication Replenishment:
Procedure for Emergency Medication Replenishment and Inventory Check: Process for ensuring emergency medications are available at all times and are promptly replenished after use, including daily inventory checks and procedures for sealed emergency carts.
4a. Guidelines for Rational Prescription of Medications:
Guidelines for Rational Prescription of Medications: Written guidelines promoting good prescribing practices and evidence-based medication use, addressing both OP and IP prescriptions.
4b. Policy on Minimum Requirements of a Prescription:
Policy Defining Minimum Requirements of a Prescription: Policy outlining the determined minimum requirements for a complete and valid prescription (IPD, OPD, and emergency).
4f. Procedure for Implementing Verbal Orders:
Procedure for Verbal Medication Orders: Procedure outlining the process for accepting and implementing verbal medication orders, including restrictions, permitted medications, authentication, and documentation practices.
4h. Procedure for Corrective and/or Preventive Actions based on Audit:
Procedure for Corrective and Preventive Actions (CAPA) Following Medication Order Audits: Procedure outlining steps for performing root cause analysis and implementing CAPA based on medication order audit findings.
5a. Policy on Authorized Personnel to Write Orders:
Policy on Personnel Authorized to Write Medication Orders: Policy defining who is authorized to write medication orders within the hospital, specifying requirements and limitations based on legal and organizational permissions.
5b. Guidelines for Uniform Location of Medication Orders:
Guidelines for Uniform Location of Medication Orders in Medical Records: Guidelines specifying the designated uniform location within medical records for documenting medication orders, ensuring patient identification and order clarity.
5c. Guidelines for Legible, Dated, Timed, and Signed Orders:
Guidelines for Prescription Writing - Legibility, Dating, Timing, and Signature: Guidelines emphasizing legibility standards, use of capital letters, approved abbreviations, avoidance of error-prone abbreviations, and requirements for dating, timing, and signing medication orders.
6a. Written Guidance for Dispensing Medications Safely:
Guidelines for Safe Dispensing of Medications: Written guidelines outlining safe dispensing practices, including prescription verification, medication checks, handling of physician's samples, and specific instructions for both bulk and retail pharmacy settings.
6b. Procedure for Handling Medication Recalls Effectively:
Procedure for Managing Medication Recalls: Procedure for effectively handling medication recalls, outlining steps for receiving recall notices, identifying affected stock, quarantining, patient notification (if needed), and reporting to regulatory bodies in case of internal recalls.
6c. Procedure for Handling Near-Expiry Medications Effectively:
Procedure for Handling Near-Expiry Medications: Procedure for defining near-expiry medications, withdrawing them from active stock, and managing them to minimize wastage and prevent dispensing of expired drugs.
6f. Written Guidance for Return of Medications to Pharmacy:
Guidelines for Return of Medications to Pharmacy: Written guidelines outlining the policy and procedures for accepting returned medications to the pharmacy, specifying types of medications accepted and minimum conditions for return.
7a. Policy on Personnel Permitted to Administer Medications:
Policy on Authorized Personnel for Medication Administration: Policy specifying who is permitted by law and hospital policy to administer medications, outlining authorized roles and responsibilities.
7j. Written Guidance for Patient's Self-Administration of Medications:
Guidelines for Patient Self-Administration of Medications: Written guidance governing the process of patient self-administration of medications, including criteria for patient eligibility, list of permissible medications, methods for reminders, and documentation requirements.
7k. Written Guidance for Patient's Medications Brought from Outside:
Guidelines for Managing Patient-Brought Medications: Written guidance outlining the policy for managing medications brought by patients from outside the organization, including prerequisites for acceptance, verification procedures, labeling requirements, and storage guidelines.
8c. Written Guidance for Capturing Medication Safety Events:
Procedure/Guideline for Capturing Near Misses, Medication Errors, and Adverse Drug Reactions: Written guidance detailing the hospital's system for identifying, documenting, reporting, analyzing, and acting upon near misses, medication errors, and adverse drug reactions.
8d. Procedure for Reporting Medication Safety Events Within a Time Frame:
Procedure for Timely Reporting of Medication Safety Events: Procedure defining the specified timeframe for reporting near misses, medication errors, and ADRs, and outlining the reporting process.
9a. Written Guidance for Safe Use of Specialized Medications:
Guidelines for Safe Use of Narcotic Drugs and Psychotropic Substances, Chemotherapeutic Agents, and Radio-Pharmaceuticals: Overarching written guidance encompassing all objective elements of MOM 9, ensuring safe and compliant handling of these specialized medications in consonance with local and national regulations and guidelines.
9b. Policy on Appropriate Caregivers for Prescribing Specialized Medications:
Policy on Personnel Authorized to Prescribe Specialized Medications: Policy specifying which caregivers are authorized to prescribe narcotic drugs, psychotropic substances, chemotherapeutic agents, and radio-pharmaceuticals, based on their qualifications and training.
9c. Procedure for Secure Storage of Specialized Medications:
Procedure for Secure Storage of Narcotic Drugs and Psychotropic Substances, Chemotherapeutic Agents, and Radio-Pharmaceuticals: Procedure detailing secure storage practices for these medications, addressing security requirements, access control, and compliance with regulations.
9d. Procedure for Safe Preparation and Administration of Chemotherapy and Radio-pharmaceuticals:
Procedure for Safe Preparation and Administration of Chemotherapy and Radio-Pharmaceuticals: Procedure outlining the steps for safe preparation and handling (e.g., in BSC for chemotherapy, radiation safety measures for radio-pharmaceuticals) and administration of these agents by qualified personnel.
9e. Procedure for Record Keeping of Specialized Medications:
Procedure for Record Keeping - Usage, Administration, Disposal of Specialized Medications: Procedure outlining the detailed record-keeping requirements for the usage, administration, and disposal of narcotic drugs, psychotropic substances, chemotherapeutic agents, and radio-pharmaceuticals, compliant with statutory and regulatory requirements.
10b. Mechanism for Usage of Implantable Prosthesis and Medical Devices:
Mechanism for Usage of Implantable Prosthesis and Medical Devices: Mechanism outlining the process for managing the usage of implantable prosthesis and medical devices, covering procurement, storage, issuance, and usage guidelines.
10e. Procedure for Handling Recall of Implantable Prosthesis and Medical Devices Effectively:
Procedure for Managing Recall of Implantable Prosthesis and Medical Devices: Procedure for effectively handling recalls of implantable prosthesis and medical devices, including steps for receiving recall notices, identifying affected devices, patient notification, and reporting to regulatory authorities.
11a. Procedure for Acquisition of Medical Supplies and Consumables:
Procedure for Acquisition of Medical Supplies and Consumables: Detailed process for acquiring medical supplies and consumables, including vendor management, ordering, receiving, and inventory control for these items.
11e. Mechanism to Verify Condition of Medical Supplies and Consumables:
Procedure/Mechanism for Verification of Condition of Medical Supplies and Consumables: Procedure outlining steps for verifying the condition of medical supplies and consumables before dispensing or use, ensuring quality and integrity.
Note: This list is extensive and reflects a best-practice approach to documentation for NABH MOM compliance. Depending on the size and complexity of the hospital, some of these procedures might be combined or streamlined within a broader "Medication Management Manual" as suggested by the slides. The key is to ensure that all the objective elements of the MOM Chapter are addressed through documented policies and procedures and are effectively implemented in practice.