Charles W. Sauer, R. P.h., J.D.

On behalf of the National Pharmacists Association, which represents approximately 850 professional staff pharmacists living and working primarily in Illinois, I would submit the following for consideration of the Task Force relating to the indicated eight categories/topic areas:

1) Coordination/synchronization of licensure investigations between state agencies. The status of investigations of licensed health care personnel should be shared through confidential information exchanges between Professional Regulation, Public Health, Public Aid, Department of Insurance, and, when appicable, Secretary of State, Department of Revenue and State Police. A facilitator with legislative authority if necessary could effect transfers of data or arrange necessary file reviews.

2) Assurance of appropriate training of...staff for type of service/care. Limiting this scrutiny to nursing personnel unfairly targets that profession, which is sorely understaffed, underpaid and overstressed. Quality assurance of personnel should be effected throughout health care professions. Nursing may be a template for such reviews due to the various aspects of care areas, and the level of training sufficient for (other than directly and personally supervised) exposure should be agreed upon through the nursing professionals.

3) Reservation of certain activities for licensed/certified staff only. This would appear to many as being already the case, but should be put into practice and law. Also, there is a gap of several years of education, training and practice between "licensed" and "certified". A pharmacist is licensed (though called registered pharmacists) and now must go through six years of professional school to achieve licensure. A certified pharmacy technician merely has to complete a course of study over a few weeks and pass an exam for initial certification. Yet medication errors could be reduced if only pharmacists dispensed prescriptions with proper counseling to patients. If business permitted, or the law required, only pharmacists to dispense with counseling, medication errors could be caught before the medication leaves the pharmacy with the patient or caregiver. Similarly, the passing of medications in a hospital or long term care facility is a unique and traditional way to discover and prevent medication errors. The number and severity of errors would be greater if not for the professional and well-educated nurse.

4) A best practices clearinghouse and development/support of pilot/model projects is an idea worthy of follow-through; Professions could have a unique opportunity to work together for the public welfare.

5) Repeat "offender" reporting to DPR. While a pilot program for volunteer data referral may be reasonable, mandatory reporting for the purpose or ultimate result of discipline would appear to defeat a systems approach to medication error problem solving. For example, Pharmacist Smith has two reportable errors each week for three weeks, and is identified as a "repeat" offender. Is Smith to be disciplined when she works twelve hour days for a pharmacy that will not provide sufficient cashiering or technician help, and she is intimidated into not taking lunches or breaks, and is expected to fill & refill 400 prescriptions a day? Will the employing business likewise be considered an offender for permitting and encouraging such practice? The prior title for Department of Professional Regulation was Registration & Education. Will referrals be emphasized for educational purposes, or license disciplinary statistics?

6) Establishment of minimum staffing levels and possibilities for increasing number of licensed...professionals. Again, Nursing as a profession is not alone. Pharmacists are far fewer in number than presciption volume and ever increasing store locations demand. Minimum levels of staffing should be mandated, based on patient to professional ratios. Increasing the number of professional providers ill-serves the objectives if rushing education or providing regulatory fast tracks would graduate or license less-educated/unprepared practitioners. While developing dependable and verifiably professional standards to increase the number of potential licensees, consideration should be given to a certification of need for providers. Hospitals need to demonstrate a need for establishment/licensing. Similar consideration could be argued for pharmacies (do we really need so many within so few city blocks, let alone miles?) and long/intermediate care facilities.

7) Reporting of errors (as part of a mandated system of identification of medical errors at health care facilities) with associated quality improvement practices to reduce/prevent recurrence. Mandated error reporting would seem counter-productive to the ultimate goal of error reduction. Simply stated, it would tend to keep honest folk honest and many errors would not be reported out of fear (discipline) or ignorance/negligent (failure to report due to being too busy, forgetful, concern for practitioner/institution other than oneself). A voluntary approach may better serve the public through better informed practitioners.

8) Impaired health care professionals (drug/alcohol) cases, enhancement of identification and disposition. Has there been any objective studies to identify the impaired practitioner as the source of errors, and if so, what percentage and kind would these be? Impairment appears to be a broad-sweeping term, even for exploration here. Would aggresive enforcement reduce errors if the identified segment accounts for signifcant discovery or prevention of errors (high functioning impaiared professional) ? Enforcement personnel would appear to be less than optimally trained or educated to effectively handle many cases, except to disciplinary ends.

Thank you for the opportunity to express comments and questions. Your consideration in reviewing this is requested and appreciated. Please feel free to contact me if I or this office can be of assistance.

Charles W. Sauer, R.Ph.,J.D., Executive Director