Feedback for Seeking Feedback on Proposed Implementation Timeline for NAPRA's Sterile Compounding StandardsPharmacist · June 24, 2016
A two year deadline is not realistic for hospitals to secure funding for capital and operating costs, to contract external expertise, to complete RFP processes, to complete physical renovations, to recruit staff to develop, implement and maintain the standards. All of this is even more challenging for small, rural hospitals who already struggle with budgets and recruitment.
It is unlikely that the province or LIHNs will allocate additional funding towards the initial capital and operating costs or the continual increases operating costs, and negotiating hospital budgets and hospital foundation fundraising takes time. Expertise is required to assess workflow and to properly design a renovation that meets standards within the physical restraints of available space. Finding that expertise is difficult. A reference list of experts for the province would be very useful. Human resources are limited, especially in smaller hospitals. Managers already wear multiple hats and have conflicting priorities. The implementation and maintenance of the standards will require additional staffing. Recruitment is difficult in small, rural settings, for both pharmacists and registered technicians. The alternative of not providing compounding services in the rural, northern setting would result in patients traveling significant distances to receive care. Or the hospital could consider outsourcing, which is not always a viable option due to transportation issues and cost implications. Training is essential but poses another challenge for smaller hospitals. It is not realistic to assume that multiple staff can be away at the same time to attend training, which means the time to train all staff at an external education location extends over a longer period of time. In conclusion, to meet these standards, there needs to be consideration at the provincial and LIHN levels, and at OCP of the significant costs to each hospital and how those costs are going to be covered; significant improvement in the supports and readily available expertise required to complete all the work necessary; a strong communication network to assist those at the frontline of managing this improvement project, including a shared resource approach; and finally, time in which to complete this significant, and valuable work. A gap analysis of all hospitals and a review of this information by the LIHNs and province would be a good starting point. Armed with that information, a realistic goal for each hospital could be made, and then a timeline determined to either compliance with standards or a different model of service to provide safe patient care.