Many organizations may be leaving these opportunities for improvement on the table. Did you know that any toothpaste that contains sodium fluoride contains a National Drug Code and is classified as a medication? We recently verified this with The Joint Commission Standards Interpretation Group. Their team advised this would be determined by how they are classified by the FDA. “If a specialized toothpaste is classified as a medication by the FDA (ex: National Drug Code number) or meets the definition of a medication in the glossary of the hospital accreditation manual, it would be considered a medication subject to the Medication Management standards.” The Joint Commission Glossary defines a medication as:
Medication
Any prescription medications, sample medications, herbal remedies, vitamins, nutraceuticals, vaccines, or over-the-counter drugs; diagnostic and contrast agents used on or administered to persons to diagnose, treat, or prevent disease or other abnormal conditions; radioactive medications, respiratory therapy treatments, parenteral nutrition, blood derivatives, and intravenous solutions (plain, with electrolytes and/or drugs); and any product designated by the Food and Drug Administration (FDA) as a drug. This definition of medication does not include enteral nutrition solutions (which are considered food products), oxygen, and other medical gases.
To avoid these Opportunities for Improvement, organizations need to review the medication management standards and current processes in place in their Dental services to ensure compliance. Remember that all the medication management standards apply to sample medications, to which we need to add certain toothpastes- Look for the NDC number to know how to proceed.