Review of Mental Health Clinical Pharmacists in Veterans Health Administration Facilities

Report Information

Issue Date
Report Number
18-00037-154
VISN
State
District
VA Office
Veterans Health Administration (VHA)
Report Author
Office of Healthcare Inspections
Report Type
Hotline Healthcare Inspection
Recommendations
9
Questioned Costs
$0
Better Use of Funds
$0
Congressionally Mandated
No

Summary

Summary
The VA Office of Inspector General (OIG) conducted a healthcare inspection to assess Veterans Health Administration (VHA) facilities’ utilization of clinical pharmacists who work under a scope of practice in a mental health outpatient care setting. After reviewing relevant policies and conducting interviews, the OIG found that mental health clinical pharmacists’ (MHCPs’) independence levels were not clearly identified by staff or facilities’ bylaws. Guidance provided conflicting instructions regarding requirements for collaborating agreements and lacked provision for oversight by a specific physician. Facilities’ scopes of practice were inconsistent in describing delegated duties that were specific to mental health. VHA policy was insufficient to ensure the chief of mental health reviews and endorses MHCPs’ scopes of practice. Referral processes were not clear or standardized regarding how diagnoses were conveyed to MHCPs or whether involvement of a licensed independent practitioner with prescriptive authority was considered to determine appropriateness for patients’ referrals. VHA policy does not require a defined process to consider patient’s clinical complexity and policies lacked guidance instructing MHCPs on when or how to refer patients to a higher level of care. The OIG made nine recommendations to the VHA Under Secretary for Health related to autonomy, collaborating agreements, collaborating with licensed independent practitioners with prescribing authority, scopes of practice, and referrals.

Open Recommendation Image, SquareOpenClosed and Implemented Recommendation Image, CheckmarkClosed-ImplementedNot Implemented Recommendation Image, X character'Closed-Not Implemented
No. 1
Closed and Implemented Recommendation Image, Checkmark
to Veterans Health Administration (VHA)
The Under Secretary for Health ensures facility medical staff bylaws are consistent with Veterans Health Administration policy regarding clinical pharmacist practice as non-independent practitioners.
No. 2
Not Implemented Recommendation Image, X character'
to Veterans Health Administration (VHA)
The Under Secretary for Health ensures collaborating agreements, also referenced as collaborative practice agreements, are in place for mental health clinical pharmacists who provide outpatient collaborative medication management.
No. 3
Closed and Implemented Recommendation Image, Checkmark
to Veterans Health Administration (VHA)
The Under Secretary for Health ensures that the Veterans Health Administration Office of Mental Health and Suicide Prevention Director reviews existing Veterans Health Administration guidance and provides assistance in outlining the mental health clinical pharmacist’s responsibilities for communication with the collaborating licensed independent practitioner who has prescribing authority.
No. 4
Closed and Implemented Recommendation Image, Checkmark
to Veterans Health Administration (VHA)
The Under Secretary for Health affirms allowable clinical duties within mental health clinical pharmacists’ scopes of practice include comprehensive provisions related to mental health.
No. 5
Closed and Implemented Recommendation Image, Checkmark
to Veterans Health Administration (VHA)
The Under Secretary for Health ensures a process is in place for chiefs of mental health service to document review, recommendation, and endorsement of all outpatient mental health clinical pharmacists’ scopes of practice, regardless of whether the clinical pharmacist is aligned with the mental health service line, and monitor compliance.
No. 6
Closed and Implemented Recommendation Image, Checkmark
to Veterans Health Administration (VHA)
The Under Secretary for Health ensures the Veterans Health Administration Office of Mental Health and Suicide Prevention Director reviews and provides input into the patient referral process to mental health clinical pharmacists with consideration for ensuring that accurate diagnoses can be reliably identified by and conveyed to the mental health clinical pharmacists.
No. 7
Closed and Implemented Recommendation Image, Checkmark
to Veterans Health Administration (VHA)
The Under Secretary for Health ensures the Veterans Health Administration Office of Mental Health and Suicide Prevention Director reviews the patient referral process to mental health clinical pharmacists and provides input with consideration for clinical settings or scenarios in which a review of the clinical complexity of the referral by a licensed independent practitioner with prescribing authority would be appropriate, prior to treatment.
No. 8
Not Implemented Recommendation Image, X character'
to Veterans Health Administration (VHA)
The Under Secretary for Health ensures the Veterans Health Administration Office of Mental Health and Suicide Prevention Director establishes guidance and provides assistance in outlining when and how mental health clinical pharmacists are to refer patients to a higher level of mental health care.
No. 9
Closed and Implemented Recommendation Image, Checkmark
to Veterans Health Administration (VHA)
The Under Secretary for Health initiates a risk assessment of outpatient mental health clinical pharmacists’ practice and establish mitigation plans; and includes the Veterans Health Administration Office of Mental Health and Suicide Prevention Director in the design, implementation, and analysis processes.