Audit Report - Hillsborough CHD
13 Pages
English
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Audit Report - Hillsborough CHD

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13 Pages
English

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OFFICE OF THE INSPECTOR GENERAL INTERNAL AUDIT Purchases, Distributions, and Dispensing of Pharmaceuticals at Hillsborough County Health Department AC-07-006 November 7, 2007 the Status of Prior Review Findings SUMMARY section of this report). DOH’s executive office at that time took a stern approach We performed an audit of controls to address identified weaknesses in the established by Hillsborough County internal control system over Health Department (CHD) related to the pharmaceuticals. Generally, DOH movement of controlled substances management placed responsibility of during the period July 1, 2005 through such controls and processes squarely June 30, 2006. with CHD upper level management, including the pharmacy manager and Our objective was to determine the CHD business manager. DOH’s written extent to which controls are in place at policy was subsequently updated to the Department of Health (DOH) reflect these responsibilities and (including CHDs) so that sites under its processes. Issues identified by the Office control can accurately account for of the Auditor General in 2004 were still controlled substances. found during this examination. DOH’s public health system includes The following issues should receive dispensing pharmaceuticals to CHD additional review by Hillsborough CHD clients by medical staff, a licensed management: pharmacy operated by the CHD or ● Some pharmaceuticals were missing contracted provider. Some ...

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OFFICE OF THE INSPECTOR GENERAL
INTERNAL AUDIT

Purchases, Distributions, and
Dispensing of Pharmaceuticals at
Hillsborough County Health Department

AC-07-006 November 7, 2007

the Status of Prior Review Findings SUMMARY
section of this report). DOH’s executive
office at that time took a stern approach We performed an audit of controls
to address identified weaknesses in the established by Hillsborough County
internal control system over Health Department (CHD) related to the
pharmaceuticals. Generally, DOH movement of controlled substances
management placed responsibility of during the period July 1, 2005 through
such controls and processes squarely June 30, 2006.
with CHD upper level management,
including the pharmacy manager and Our objective was to determine the
CHD business manager. DOH’s written extent to which controls are in place at
policy was subsequently updated to the Department of Health (DOH)
reflect these responsibilities and (including CHDs) so that sites under its
processes. Issues identified by the Office control can accurately account for
of the Auditor General in 2004 were still controlled substances.
found during this examination.
DOH’s public health system includes
The following issues should receive dispensing pharmaceuticals to CHD
additional review by Hillsborough CHD clients by medical staff, a licensed
management: pharmacy operated by the CHD or
● Some pharmaceuticals were missing contracted provider. Some CHDs with a
and unaccounted for; licensed pharmacy also dispense
● Actual ending inventories did not pharmaceuticals to persons that are not
agree with amounts reported and CHD clients for prescriptions written by 1input into FLAIR ; licensed physicians not related to the
● Adjustments to inventory were not CHD or DOH.
supported by sufficient
documentation; Central Pharmacy, CHDs, and A.G.
● Pharmaceuticals were not timely Holley Hospital purchased
counted at some pharmacies; and, pharmaceuticals totaling $129,569,929
● Purchases of Pharmaceuticals were from Cardinal Health, Inc. during the 2not coded to correct OCAs in fiscal year ended June 30, 2006. 1FLAIR , and did not accurately reflect
the programs for which these We conducted this audit in part, because
pharmaceuticals were purchased. we wanted to update the agency on the
status of corrective action taken by
CHDs as a result of a 2004 audit
performed by the Office of the Auditor
1 Florida Accounting Information Resource General, Pharmaceuticals at County
Subsystem Health Departments (You may refer to 2 Other Cost Accumulators
Page 1 of 13 Purchases, Distributions, and Dispensing of Pharmaceuticals at AC-07-006
Hillsborough County Health Department

during the period July 1, 2005 through INTRODUCTION
June 30, 2006.
3 Florida law charges DOH’s Office of the
Our objective was to determine the Inspector General responsibility to
extent to which controls are in place at provide a central point for coordination
DOH (including its CHDs) so that sites for activities that promote accountability,
under its control can accurately account integrity and efficiency in government.
for all purchases, transfers, returns, and Audits are conducted to review and
the filling of prescriptions of controlled evaluate internal controls necessary to
substances. ensure the fiscal accountability of DOH.

To obtain an understanding and This audit was initiated as the result of a
document the components of internal prior internal audit in which we identified
control related to controlled substances, a number of contracts where CHDs
we interviewed appropriate personnel at appeared to be selling pharmaceuticals
Headquarters and Hillsborough CHD. to outside entities, including hospitals.
We reviewed applicable law and DOH We also wanted to update the agency on
policies and procedures. We the status of corrective action taken by
documented our understanding of CHDs as a result of an Operational Audit
internal controls and tested selected performed by the Office of the Auditor
controls to determine whether the General in 2004, Pharmaceuticals at
controls were in place and working County Health Departments, (Please
effectively. refer to the Status of Prior Review
Findings section of this report).
COMPLIANCE WITH GENERALLY ACCEPTED
GOVERNMENT AUDITING STANDARDS Audit fieldwork took place December
2006 through May 2007 at DOH
headquarters in Tallahassee, and We conducted this performance audit in
included on-site examination at accordance with generally accepted
4Hillsborough County Health Department government auditing standards, in
5in February 2007. The audit was accordance with Florida law . Those
conducted by Office of the Inspector standards require that we plan and
General audit staff Mark H. Boehmer, perform the audit to obtain sufficient,
C.P.A., Management Analyst, Level 4, appropriate evidence that provides a
Lead Auditor, under the supervision of reasonable basis for our findings and
Lynn H. Riley, C.P.A., Director of conclusions based on our audit
Auditing. objectives. We believe that the evidence
obtained provides a reasonable basis for
our findings and conclusions based on SCOPE, OBJECTIVES, AND METHODOLOGY
our audit objectives.
We examined controls established by
BACKGROUND the Bureau of Statewide Pharmaceutical
Services, and Broward, Duval, and
Hillsborough CHDs related to the DOH’s public health system includes
movement of controlled substances, dispensing pharmaceuticals to CHD
(which may include purchases, transfers,
returns, and the filling of prescriptions)
4 2007 revision of Government Auditing
Standards, Comptroller General of the
United States
3 5 Section 20.055, Florida Statutes Section 20.055(5)(a), Florida Statutes
Page 2 of 13 Purchases, Distributions, and Dispensing of Pharmaceuticals at AC-07-006
Hillsborough County Health Department

clients. This may include prescriptions data obtained from Cardinal Health, Inc.,
dispensed by Central Pharmacy in the following purchases of Schedule 2
Tallahassee and shipped to a specific pharmaceuticals were made by these
client at the CHD. Pharmaceuticals are entities for the period July 1, 2005
also received by CHDs in bulk from through December 31, 2006:
Central Pharmacy to be dispensed by
Entity Purchase of medical staff at the CHD.
Schedule 2 Pharmaceuticals are typically also
Controlled purchased at the CHD level and
Substances from
dispensed by either medical staff at the Cardinal Health, Inc.
CHD or (in larger CHDs) a licensed Duval CHD $25,211
pharmacy operated by the CHD or a Hillsborough CHD 8,831
CHD contracted provider. Some CHDs TOTAL $34,042
with a licensed pharmacy also dispense
No instances of fraud, illegal acts, pharmaceuticals to persons who are not
CHD clients for prescriptions written by violations of provisions of contracts or
grant agreements, or abuse were noted. licensed physicians not related to the
CHD or DOH.
We concluded that controls are not
sufficiently in place at the selected CHDs We obtained data from Cardinal Health,
Inc. (a wholesale distributor of examined so that sites under its control
can accurately account for purchases, pharmaceuticals) documenting all
purchases made related to the State of distributions, and dispensing of
prescriptions of controlled substances. Florida’s contract with that vendor for the
period July 1, 2005 through June 30, There are specific controls that were
previously identified by the Office of the 2006. Total purchases of
Auditor General that continue to not be pharmaceuticals and related supplies
(this includes federal, state, and local sufficiently addressed by CHDs.
funding) made by DOH and its CHDs
from Cardinal Health, Inc. are detailed The following findings and
recommendations address issues that below:
have not been appropriately addressed
Facility Purchases of and should receive additional review by
pharmaceuticals and management.
related supplies from
Cardinal Health, Inc.
FINDINGS, RECOMMENDATIONS, AND Central Pharmacy $98,643,510
Hillsborough CHD $5,436,379 MANAGEMENT’S RESPONSES AND
Broward CHD $5,201,390 CORRECTIVE ACTION PLANS
Duval CHD $3,035,325
All other CHDs $16,455,054
FINDING 1 – Some pharmaceuticals were A.G. Holley Hospital $798,271
missing and unaccounted for. TOTAL $129,569,929

We focused our examination on Central There should be documentation to
Pharmacy in Tallahassee, and 3 CHDs support every transaction of a Controlled
which operate licensed pharmacies. Substance, including purchases,
Each of these entities handled Schedule dispensing, returns to the Reverse
3 through Schedule 5 Controlled Distributor, transfers to/from entities
Substances. Only 2 entities handled a under common control, and other
material quantity of Schedule 2 adjustments (as required). Those
Controlled Substances. According to transactions should reconcile from the
Page 3 of 13 Purchases, Distributions, and Dispensing of Pharmaceuticals at AC-07-006
Hillsborough County Health Department

quantity of inventory counted June 30, meaning 197 tablets (or approximately 2
2005 to the quantity of inventory counted bottles of 100) were unaccounted for.
June 30, 2006.
Management believed that a regular
Hillsborough CHD operates one physical inventory count is a sufficient
pharmacy site. control to identify possible discrepancies
in inventory. CHD management did not
We tested a sample of 14 Controlled routinely perform (on a sample basis) the
Substances (Adderall XR 20MG, Ambien type of exercise we performed during our
10MG 100, Fentanyl 75MCG/HR 5, testing, to determine whether physical
Kadian 100MG/24HR, Lunesta 2MG quantities counted agreed with a
100, Methadone HCL 10MG, Morphine reconciliation of beginning to ending
Sulfate ER 30MG TER, Niravam 0.5MG, inventory.
Oxandrin 10MG, Oxycodone HCL
15MG, Oxycodone/APAP 10-650MG, Without sufficient controls,
Percocet 2.5-325MG, Phenobarbital pharmaceuticals may disappear. As
97.2MG, and Roxicodone 30MG). For pharmaceuticals disappear, there is a
each test, we began with the quantity monetary loss, and pharmaceuticals may
documented as counted by CHD staff be inappropriately used and/or abused.
June 25, 2005, adding purchases that
increased inventory, subtracting RECOMMENDATION:
quantities dispensed to clients. We also An individual inventory control record
considered all other transactions, such was not able to be printed for each
as quantities returned to the Reverse pharmaceutical in stock that included
Distributor. For each of the beginning balance, purchases,
pharmaceuticals tested, we should have adjustments, returns, and dispensing, to
been able to arrive at the quantity reconcile to an ending balance.
documented as counted by CHD staff Accordingly, we recommend pharmacy
June 24, 2006. We did additional testing management include a procedure (as a
through an inventory count taken compensating control) to routinely (on a
December 7, 2006. sample basis) reconcile beginning to
ending inventory, accounting for
Although pharmacy staff counted 160 purchases, dispensing, transfers,
tablets of Oxandrin 10MG (Schedule 3 returns, and other adjustments, and
Controlled Substance) on June 24, 2006, determine whether calculated quantities
there was documentation to support agree with the ending physical inventory
there should have been 180, meaning 20 count. Discrepancies should be
tablets were unaccounted for. On investigated by management.
December 7, 2006 pharmacy staff
counted 510 Oxandrin 10MG tablets. MANAGEMENT’S RESPONSE AND
There was documentation to support CORRECTIVE ACTION PLAN:
there should have been 670 tablets on Hillsborough CHD pharmacy processes
hand. Hillsborough CHD was missing an over 66,000 prescriptions annually with a
additional 160 tablets between June 24, pharmaceutical value of approximately
2006 and December 7, 2006. $9 million which validates the need to
use commercial pharmacy software
Although pharmacy staff counted 153 following standard pharmacy practices.
tablets of Phenobarbital 97.2MG We use the latest commercially available
(Schedule 4 Controlled Substance) on Pharmacy management system software
June 24, 2006, there was documentation from Cerner Etreby. This commercial
to support there should have been 350, pharmacy software system used by
Page 4 of 13 Purchases, Distributions, and Dispensing of Pharmaceuticals at AC-07-006
Hillsborough County Health Department

pharmacies nationwide does not have pharmaceuticals inventory by that
the capability to print an individual amount. We re-calculated the actual
inventory control record for each value intended to be reported by the
pharmaceutical in stock that includes CHD as $829,504.
beginning balance, purchases,
adjustments, returns, and dispensing, to Hillsborough CHD contracted pharmacy
reconcile to an ending balance. staff did not update its electronic
inventory system to reflect actual
We will: quantities on hand identified during the
• Perform inventories per guidelines year-end physical count before preparing
inventory valuation reports to be sent to (monthly, quarterly, or annually) on
7Headquarters for input into FLAIR for all drugs maintained within the
either year ended June 30, 2005 or Pharmacy.
2006. Examples included: • Establish a procedure to routinely
● 160 Oxandrin 10MG tablets counted reconcile physical inventories with
on June 24, 2006, but 120 tablets calculated quantities.
were reported to Headquarters. • Develop an internal procedure for
● 550 Phenobarbital 97.2MG tablets investigating discrepancies between
counted on June 25, 2005, but 1015 physical inventories and calculated
tablets were reported to quantities.
Headquarters.
● A May 10, 2006 purchase of 100 Anticipated completion date:
Percocet 2.5-325MG tablets was not Management asserts this corrective
keyed into the inventory software action plan has been completed.
until after the physical inventory
count June 24, 2006, although it was FINDING 2 – Actual ending inventories did
recorded in the pharmacy’s Manual not agree with amounts reported and
Log. However, only 50 tablets were input into FLAIR.
reported to Headquarters in the
6 annual inventory valuation for DOH’s policy requires a written
recording into FLAIR. inventory and respective inventory
● 165 Ambien 10MG tablets counted values obtained from associated
on June 24, 2006, but 136 tablets acquisition costs to be prepared annually
were reported to Headquarters. no later than close of business on the
last working day of June. This inventory
CHD fiscal management responsible for value report as of June 30 must be
reporting values to Headquarters at forwarded to the Bureau of Finance &
th fiscal year end requested valuation Accounting by July 16 . The inventory
records from Pharmacy staff. Because shall be conducted under the supervision
the same pharmacy staff did not of the CHD Business Manager and the
understand the purpose of the request, Pharmacy Manager.
the report was provided before
adjustments were made to agree with Hillsborough CHD reported June 30,
the year-end physical count. 2005 total inventory of $854,645 on
Form F1. A sub-total amount of $25,141
This issue was previously discussed in for a batch of pharmaceuticals was
the Office of the Auditor General’s counted twice, overstating total
October 2004 audit of Pharmaceuticals

6 DOHP 150-1-01, Pharmacy Services
7 Policies and Procedures for County Health Florida Accounting Information Resource
Departments Subsystem
Page 5 of 13 Purchases, Distributions, and Dispensing of Pharmaceuticals at AC-07-006
Hillsborough County Health Department

at County Health Departments (see year-end physical inventory count prior
Status of Prior Review Findings section to the actual numbers being reported to
of this report). Management’s Corrective headquarters on Form F1-Inventory.
Action Plan has not been sufficiently
addressed. Anticipated completion date:
Management asserts this corrective
When fiscal year-end valuations do not action plan has been completed.
accurately agree with the year-end
physical count, the pharmacy cannot FINDING 3 – Adjustments to inventory
reconcile from one year’s valuation to were not supported by sufficient
the next. Beginning quantities and documentation.
valuations, plus purchases, less
dispensing, and accounting for other Pharmacy management did not have a
transactions should reconcile exactly to process to document signed, prior
ending quantities and valuations, approval of adjustments, including
whether this exercise is tested on a adjustments (made by pharmacy staff at
daily, monthly or yearly basis. individual pharmacy sites) required to
Additionally, incorrectly reported make inventory records agree with
valuations cause amounts in the state’s physical inventory counts. Adjustments
financial records to be incorrect. may be necessary throughout the year to
reconcile the inventory system to actual
RECOMMENDATION: inventory counts and other changes in
We recommend pharmacy management inventory.
ensure the fiscal year-end physical
inventory count for each pharmacy is Adjustments to inventory should be
completed and any adjustments required supported by appropriate documentation
to make the inventory system agree with substantiating why such an adjustment
8the physical count be made before the will be necessary. DOH’s policy
summary reports with valuations are specifically addresses separate approval
reported to Headquarters on Form F1- of adjustments to inventory and
Inventory. recognizes the need for segregation of
duties to reduce the opportunities to
MANAGEMENT’S RESPONSE AND allow any person to be in a position to
CORRECTIVE ACTION PLAN: both perpetuate and conceal errors or
As was determined during the audit, fraud in the normal course of his or her
CHD fiscal management staff duties. All inventory adjustments must be
responsible for reporting values to carefully checked and appropriate
Headquarters at fiscal year end entries made on the drug record to
requested valuation records from explain such adjustments.
Pharmacy staff. Because the same Documentation must be maintained. The
pharmacy staff did not understand the policy discusses the requirement to
purpose of the request, the report was maintain good documentation so that
provided before adjustments were made inventory counted by anyone (including
to agree with the year-end physical pharmacy staff or examiners on any
count. This oversight resulted in actual specific date) may be reconciled, stating
ending inventories disagreeing with that good records help rectify
amounts reported and input into FLAIR.


8We will establish policy and/or procedure DOHP 150-1-01, Pharmacy Services
to ensure appropriate adjustments and Policies and Procedures for County Health
valuations are recorded into the fiscal Departments
Page 6 of 13 Purchases, Distributions, and Dispensing of Pharmaceuticals at AC-07-006
Hillsborough County Health Department

discrepancies between actual inventory DOH DOHP 150-1-01 section VII.E.8-9
and calculated inventory. does not describe or outline a procedure
for requirements for any prior approval
This issue was previously discussed in process to document any discrepancies
the Office of the Auditor General’s or adjustments to the inventory report.
October 2004 audit of Pharmaceuticals Original count sheets and corrected
at County Health Departments (see inventory count sheets are kept in the
Status of Prior Review Findings section pharmacy and copies given to the
of this report). Management’s Corrective contract manager and retained for 2
Action Plan has not been sufficiently years as recommended. Administrative
addressed. Services Staff through the Fiscal Office
are involved with a disinterested party
When physical inventory counts were performing the actual inventory. Each
made and an adjustment in the CHD’s disinterested staff person signs off on
inventory record was necessary to make the inventory control sheets with on-
the record agree to the quantity of pills hand counts of actual medications. The
counted, the adjustment was made pharmacy manager is notified of any
without prior signed approval by discrepancies and/or adjustments.
management.
We will develop an internal procedure to
When prior approval is not received from ensure adjustments to inventory receive
a secondary, upper-level person, a prior signed approval by a second,
quantity of pills could more easily be upper-level staff person and contain an
fraudulently removed from inventory and appropriate explanation substantiating
adjusted out of inventory without being why the adjustment is necessary.
noticed by management.
Anticipated completion date:
Management asserts this corrective RECOMMENDATION:
We recommend management improve action plan has been completed.
its process to include prior signed
approval by a second, upper-level staff FINDING 4 – Pharmaceuticals were not
person, by specific pharmaceutical, with timely counted.
a pre-numbered identifier that would be
9referenced in the inventory record when DOH’s policy explains the CHD
such an adjustment is necessary, so the business manager is responsible for
inventory control record matches a assuring the completion of a written
physical inventory count. Such quarterly inventory for "high-risk"
documentation should include an pharmaceuticals. All pharmaceuticals
appropriate explanation substantiating must be counted annually (June 30th).
why the adjustment is necessary. All inventory counts shall be conducted
Inventory records by specific drug should under the supervision of the CHD
then be periodically and regularly Business Manager and the Pharmacy
examined by management as its process Manager.
to identify any adjustments that may
have been made in the inventory system We examined documentation supporting
that are not supported by prior-approval inventory counts of pharmaceuticals.
documentation. Documentation was not maintained to


9MANAGEMENT’S RESPONSE AND DOHP 150-1-01, Pharmacy Services
CORRECTIVE ACTION PLAN: Policies and Procedures for County Health
Departments
Page 7 of 13 Purchases, Distributions, and Dispensing of Pharmaceuticals at AC-07-006
Hillsborough County Health Department

support that inventory counts for "high- Pharmaceuticals were counted timely
risk" pharmaceuticals were made for the and documentation does exist to support
quarters ending September and inventory counts for “high-risk”
December 2005. pharmaceuticals from January 2006
through the present.
This issue was previously discussed in
the Office of the Auditor General’s We will:
October 2004 audit of Pharmaceuticals • Ensure high-risk inventories are
at County Health Departments (see more clearly addressed in the HCHD
Status of Prior Review Findings section inventory control procedure.
of this report). Management’s Corrective • Complete high-risk inventories
Action Plan has not been sufficiently quarterly by the Business Office
addressed. and/or specific disinterested third-
party designee.
There are a couple of possibilities for
this issue: 1) The count was not Anticipated completion date:
performed; 2) Site pharmacists Management asserts this corrective
conducting the inventory count did not action plan has been completed.
maintain documentation and were not
required to submit a copy to the CHD FINDING 5 – Purchases of
pharmacy manager who also did not Pharmaceuticals were not coded to
maintain documentation to ensure the correct OCAs in FLAIR, and did not
count was performed. accurately reflect the programs for which
these pharmaceuticals were purchased.
When inventory counts are not
conducted with the required frequency, OCAs are used to assist fiscal offices in
there is an increased risk quantities of budget management by identifying the
pharmaceuticals may be stolen without specific programs or projects budgeted
prompt identification. Missing within an appropriation category, in order
pharmaceuticals may be more quickly to prepare analyses and projections, and
and easily identified to a particular identify alternatives when corrective
quarter when such counts are timely action appears necessary.
performed.
During the fiscal year ended June 30,
RECOMMENDATION: 2006 Hillsborough CHD coded all
We recommend the CHD Business pharmaceutical purchases in FLAIR to
Manager and the Pharmacy Manager either 8K000-County Health Department
add a control to verify that such quarterly Direct Service or 39Y00-Ryan White
inventory counts of “high-risk” Cost Reimbursement Hillsborough CHD.
pharmaceuticals are timely conducted at Hillsborough CHD maintains subsidiary,
each pharmacy and maintain such in-house records by program and
documentation. corresponding OCAs of actual
MANAGEMENT’S RESPONSE AND pharmaceutical purchases which
CORRECTIVE ACTION PLAN: document Hillsborough CHD expended
Due to changes in pharmacy and clinic $1,429,518 on pharmaceuticals
staffing during the last half of calendar associated with 39Y00-Ryan White Cost
year 2005, documentation was not Reimbursement Hillsborough CHD.
maintained to support that inventory Hillsborough CHD staff coded
counts for "high-risk" pharmaceuticals $2,903,557 under this OCA in FLAIR.
were performed for the quarters ending
September and December 2005.
Page 8 of 13 Purchases, Distributions, and Dispensing of Pharmaceuticals at AC-07-006
Hillsborough County Health Department

Accounting staff explained tracking and
coding expenditures to the correct OCAs
for the 209 purchases of
pharmaceuticals from Cardinal Health,
Inc. which usually includes coding
multiple OCAs for each purchase, is a
work-load issue. However, accounting
staff agreed adjusting entries should be
made before closing out the fiscal year in
FLAIR to accurately reflect purchases in
accordance with their subsidiary records.

Costs associated with pharmaceuticals
are not accurately reflected in the state’s
accounting records when material
amounts are not correctly coded.

RECOMMENDATION:
We recommend Hillsborough CHD
ensure purchases of pharmaceuticals
are coded to correct OCAs in FLAIR to
accurately reflect the program areas for
which the pharmaceuticals were
purchased and dispensed.

MANAGEMENT’S RESPONSE AND
CORRECTIVE ACTION PLAN:
During the fiscal year that ended June
30, 2006 the HCHD piloted a project
authorized through Central Pharmacy as
an improved business practice to use
Central Pharmacy budget authority for
pharmaceutical purchases made by our
CHD. While this pilot project was
financially advantageous, it proved to be
far more complicated than expected with
local transactions not being translated
easily through FLAIR at the local level.

We will code purchases of
pharmaceuticals to correct OCAs in
FLAIR to accurately reflect the programs
for which these pharmaceuticals are
purchased and dispensed.

Anticipated completion date:
Management asserts this corrective
action plan has been completed.

Page 9 of 13 Purchases, Distributions, and Dispensing of Pharmaceuticals at AC-07-006
Hillsborough County Health Department

STATUS OF PRIOR REVIEW FINDINGS
Office of the Auditor General
Report No. 2005-039 – October 2004
Operational Audit - Pharmaceuticals at County Health Departments

The Office of the Auditor General performed this audit to determine whether pharmaceuticals were procured by CHDs in an economic and
efficient manner, adequately safeguarded, and dispensed or administered only to CHD clients. The scope included Bay, Broward, Collier, Leon,
Martin, Orange, Osceola, Pasco, Pinellas, Polk, Sarasota, Seminole, St. Lucie, Volusia, and Washington CHDs.

We tested to determine whether the findings could be found at the CHDs we examined in the current audit. The following findings,
recommendations and corrective action plans relate to pharmaceuticals at Hillsborough CHD.

No. Finding Recommendation Headquarters’ Corrective Action Plan Current Status at Hillsborough CHD
directed toward CHDs
1a Risk-related controls The Department Develop and adopt a list of Please refer to Finding No. 4 in the
should consider the pharmaceuticals considered “high risk” in current report, discussing that “high-risk”
relative risk of each terms of dollar value, abuse potential, or pharmaceuticals were not timely
diversion potential. counted at Hillsborough CHD.
drug. Controls that
might be considered
for high-risk Each CHD business manager will be
pharmaceuticals responsible for assuring the completion
include: increased of a written quarterly inventory for “high
risk” drugs. The CHD pharmacy manager
physical security;
more frequent will forward the completed written
inventories; inventory to the CHD business manager.
additional focus
during internal and
An internal control policy and review
external quality
questionnaire will be developed, and
control inspections;
policy implemented for CHD pharmacies.
requiring additional

levels of approval for
Drugs identified as “high risk” will be
ordering, receiving,
ordered and received under the direct
and disposals; and
supervision of the pharmacy manager.
patient identification

prior to dispensing.
Page 10 of 13