January 23, 2014

Question: In the movie It’s a Wonderful Life, a young George Bailey (Jimmy Stewart) personally delivered medications from Mr. Gower’s pharmacy to the customers at home.  Fast forward six plus decades, and a modern Mr. Gower III has contacted your hospital and proposed a similar arrangement.  For the convenience of the hospital’s patients, any e-prescriptions sent to Gower Pharmacy will be delivered by the pharmacy’s delivery man to the patient in the hospital.  Mr. Gower suggests that pleased patients will also think well of the hospital for allowing this service.  Does it make sense for the hospital to accept Mr. Gower’s offer?

Answer: This certainly could be very convenient for a hospital’s patients, and the hospital could enjoy the goodwill it generates.  Imagine, not having to stop off at the pharmacy at all; having all your medications in hand even before you leave the hospital.

But what starts out as a seemingly good idea quickly gets complicated by a number of concerns.  On the regulatory front, how do pharmacy licensing regulations and hospital licensing regulations (including for its own pharmacy) fit together here?  HIPAA questions arise, including that there are any number of incidental disclosures that would be seen by the delivery person.  Risk management probably creates the biggest concerns:  Is the hospital responsible to check the delivery bag, to make sure that the right medication is being delivered?  In the right amount and dosage?  Is the name of the right person on the container?  Do you have to see that the delivery person enters the correct patient room?  What if the patient takes too large a dose in her room, with a bad outcome?  What kind of protocol would have to be written to manage all of this?  The time, energy and staff needed?

Of course, there are other pharmacies in town, and they likely will not be happy with Mr. Gower’s arrangement with the hospital.  Is the hospital trying to steer its patients to Gower Pharmacy?  What’s the hospital getting for that?  Shouldn’t all of the pharmacies have the same delivery arrangement with the hospital?  That means the hospital will have to manage an increasingly large number of medication deliveries, not an easy thing given all the concerns involved.

What started out as a potentially good idea can’t make it over the legal/risk management analysis and implementation hurdles.  That happens sometimes, even to good ideas.