Medication History Gathering & Medication Reconciliation FAQ
The term “medication reconciliation” is defined by the Joint Commission as “the process of comparing the medications a patient is taking (and should be taking) with newly ordered medications” in order to address duplications, omissions, and interactions, and the need to continue current medications. This definition emphasizes the importance of the reconciliation process, which is the act of comparing medication lists by a clinician to identify and resolve discrepancies versus the act of gathering a medication history list. It is recommended by the American Society of Health System Pharmacists that pharmacists be directly involved including, but not limited to, developing policies and procedures, implementing and continuously improving these processes, and training and ensuring the continuing competency of those involved in medication reconciliation. When pharmacy is involved, the Board expects a pharmacist to establish policies and procedures for pharmacy staff roles in medication reconciliation processes, including supervision of pharmacy technicians, interns, and other personnel.
When implementing a pharmacy technician medication history program, it is essential to comply with Board statutes and rules. Pharmacy technicians are not permitted to make clinical decisions of any kind during the medication history gathering process. A technician may document the information gathered from the patient, from secondary sources, if needed, and present the list to a pharmacist for verification.
For example, a patient reports taking furosemide as needed based on his or her weight. However, the pharmacy technician finds that the patient’s prescription has a direction for furosemide 20 mg daily. In this scenario, the pharmacy technician may not make a judgment call to include only the direction from the prescription and omit the information about how the patient is taking it. In a different scenario, a patient tells the pharmacy technician that he or she takes a medication for blood pressure at home and is unable to recall the name. The pharmacy technician then reviews the ‘Prior to Admit’ medication list and picks out a drug that he or she believes is the blood pressure medication. By doing that, the pharmacy technician uses clinical judgement to identify which drug has an indication for high blood pressure, which is not within the scope of pharmacy technician duties and is not permitted by the Board (this means that the pharmacy technician has violated law and rule by practicing pharmacy without a license).
Pharmacy technicians who perform medication history gathering must have proper training on how to collect and document medication history and interview a patient. Pharmacy technicians may make note of discrepancies or questions when updating the patient’s medication history list. It is a pharmacist’s responsibility to resolve discrepancies in and verify the patient’s medication history list prior to providers making prescribing decisions. Pharmacists must routinely provide oversight and ongoing training for activities performed by technicians under their supervision.
The following frequently asked questions are provided to address pharmacy involvement in the medication history gathering phase of the medication reconciliation process. The Board does not have jurisdictional oversight over what functions non-pharmacy personnel (such as nurses or providers) are permitted to perform.
Question: What is medication reconciliation?
Answer: Medication reconciliation (or “med rec”) is the process of creating the most accurate list possible of all medications a patient is taking – including a drug name, dosage, frequency and route – and comparing that list against the physician’s admission, transfer, and/or discharge orders, which the goal of providing correct medications to the patient at all transitions of care.
Question: Are pharmacy technicians allowed to gather and document medication history without a pharmacist oversight and review?
Answer: No. However, a pharmacy technician who has received training appropriate for the medication reconciliation process may gather and document medication history in order to obtain the best possible medication history for the patient. Please note that while pharmacy technicians are allowed to assist in gathering and documenting medication history, they may not do so independently. A supervising pharmacist must verify the medication history list collected by a pharmacy technician and be available to assist the technician if requested.
A person licensed to perform the duties of a pharmacy technician may perform the duties of a pharmacy technician only under supervision, direction, and control of a licensed pharmacist.
Question: Is a pharmacist required to verify the medication history list obtained by a pharmacy technician?
Answer: Yes. A pharmacist is required to verify all medication history lists obtained by pharmacy technicians in the medication reconciliation process. This task may not be delegated to non-pharmacist staff, such as nurses or physicians.
Question: Are pharmacy technicians allowed to make clinical decisions during the medication reconciliation process?
Answer: No. Pharmacy technicians are not allowed to make clinical decisions of any kind during the gathering of medication history lists, or otherwise. Making clinical decisions is a non-delegable practice of pharmacy. If a technician makes a clinical decision, the technician, pharmacist, and outlet may be subject to discipline for engaging in the practice of pharmacy without a license.
Question: Is the verbal communication of a patient’s medication history from a secondary source to a pharmacy technician allowed? This could be a request for a patient’s medication history from a health care provider outside of a hospital or health system, such as a patient’s local pharmacy or primary care provider.
However, such communication requires verifiable documentation (i.e., faxed/emailed medication history) for the pharmacist who is verifying the medication history to be able to validate the information. Clinical decisions may not be made by a pharmacy technician during communications such as these.