Kesalahan Umum Saat Membuat Penatausahaan BLUD RS (bagian 1)

Bagan Arus Pemesanan Obat Depo Farmasi

Masih ingat postingan saya sebelumnya tentang penatausahaan?  Ups Sorry mungkin pertanyaannya terlalu jauh.  Bagaimana kalo saya ganti: Sudah baca postingan saya sebelumnya?  Bukan apa-apa, cuma untuk meyakinkan saja agar apa yang ingin saya bahas kali ini dibangun atas pemahaman terhadap apa yang saya ulas sebelumnya.

Saat itu saya memberikan penekanan dua hal penting yang harus kita pegang saat menyusun penatausahaan.  Anda benar!  Yang pertama adalah seluruh tahapan prosedur penatausahaan harus mengakomodir pengendalian internal yang memadai.  Yang kedua tentu saja, tak satupun prosedur itu bertentangan dengan regulasi/perundangan yang ada.  Anda mungkin akan bereaksi dengan mengatakan bagaimana kalau pengendalian internal yang kita terapkan ternyata bertabrakan dengan salah satu perundangan, baik itu UU,, PP maupun Perda dan Perkada.  Nah itu masalahnya .  Saya yakin komen semacam itu timbul karena belum ada gambaran tentang keduanya.  Kali ini berikan saya kesempatan membahas satu kriteria dulu untuk penyusunan penatausahaan.  Selain lebih fokus dan mudah dipahami, juga memberikan kesempatan anda cukup waktu untuk memberikan kontra tesis sebelum kriteria yang kedua saya launching.

Oke guys kita mulai dengan ‘regulation compliance‘ atau mudahnya adalah ketaatan pada peraturan perundangan.

Banyak para pembuat sistem mengabaikan tentang keharusan sistem/penatausahaan untuk tunduk pada peraturan.  Dalam benak mereka sudah tertancap kuat satu doktrin, bahwa sistem yang bagus, yang telah melibatkan pengendalian internal yang kuat, sudah pasti selaras dan berjalan beriringan dengan regulasi.  Apalagi jika sudah bicara efisiensi.  Maka prosedur yang efisien dan terkendali dengan baik menjadi pilihan utama di ‘best practise‘ kan.  Mana mungkin efisiensi dan pengendalian internal melawan arus regulasi kecuali satu simpulan yang muncul di kepala mereka bahwa kesalahan justru terletak pada rumusan regulasinya?  Hebat nian para sistemer ini, hingga berani menyalahkan regulasi.  Mengabaikan fakta bahwa regulasi adalah harmonisasi kerja-kerja teknokrat, birokrat dan wakil rakyat.  Rangkuman berbagai disiplin ilmu.  Bukan hasil kerja perorangan atau tim kecil macam sistemer dan pembuat penatausahaan.

Masih tidak percaya?

Mari kita cermati prosedur pemesanan obat pada suatu rumah sakit yang berhasil saya potret tatkala diminta oleh manajemen rumah sakit untuk membenahi penatausahaan instalasi farmasinya.

Bagan Arus Pemesanan Obat Depo Farmasi

Ada tiga pihak yang terlibat dalam prosedur pemesanan obat tersebut.  Gudang Farmasi, Kepala Instalasi dan Pedagang Besar Farmasi.  Penanggungjawab gudang melakukan verifikasi kartu stok dan mencocokannya dengan fisik obat/AKHP yang ada.  Bila jumlah fisik obat memenuhi kriteria persediaan minimal, maka ia harus memberitahukan kondisi tersebut pada kepala instalasi Farmasi.  Berdasarkan rekap/daftar obat yang tersedia minimal yang dibuat oleh penjaga gudang, kepala instalasi farmasi membuat surat pesan obat dan mengirimkannya ke PBF.  Surat pesan yang dibuatnya adalah dokumen yang meminta agar PBF menyediakan obat dengan jenis dan jumlah sesuai yang tertera pada surat pesanan, lengkap dengan kapan harus dikirim.  PBF pun tak ragu untuk mengirimnya karena merasa yakin bahwa order yang dibuat RSUD pasti akan dibayar.

Prosedur pesan obat kayak di atas lazim diterapkan oleh kebanyakan RSUD.  Tak ada yang salah dengan prosedur ini.  Toh sudah diterapkan bertahun-tahun dan tak pernah ada masalah.  Tak pernah timbul masalah hukum.  Tak ada gugatan ataupun bahkan ditetapkan sebagai tersangka atas dugaan pelanggaran hukum.  Segalanya aman.  Semuanya nyaman.

Bener neh gak ada pelanggaran hukum?  Yakin telah taat hukum?

Untuk memastikannya, saya perlu menyodorkan beberapa pertanyaan pada anda, kepala instalasi farmasi RSUD:

  1. Apakah anda berwenang untuk mencairkan anggaran pembelian obat untuk melunasi hutang atas surat pesanan yang terbit?
  2. Apakah anda memegang kendali penuh atas sumber-sumber keungan rumah sakit yang bisa menjamin bahwa atas semua surat pesanan yang anda bikin pasti akan terbayar?
  3. Apakah nama anda tercantum dalam surat keputusan kepala daerah sebagai pengguna anggaran/Kuasa pengguna anggaran?

Bila ketiga pertanyaan tersebut jawabannya adalah tidak, maka bisa dipastikan ada regulasi yang telah anda langgar.  Tinggal kita telusuri saja peraturan perundangan apa yang telah anda tabrak.  Tak perlu basa-basi, tak perlu susah payah, tak perlu bertele-tele.  Langsung saja saya infokan, anda telah melanggar regulasi karena yang berwenang membuat perikatan dengan pihak ketiga (PBF) adalah Pengguna Anggaran (yang kebanyakan rumah sakit dijabat oleh Direktur).  Hal ini sesuai dgn:

–Pasal 17 UU 1/2004 ttg Perbendaharaan Negara

  • (1) Pengguna Anggaran/Kuasa Pengguna Anggaran melaksanakan kegiatan sebagaimana tersebut dalam dokumen pelaksanaan anggaran yang telah disahkan.
  • (2) Untuk keperluan pelaksanaan kegiatan sebagaimana tersebut dalam dokumen pelaksanaan anggaran, Pengguna Anggaran/Kuasa Pengguna Anggaran berwenang mengadakan ikatan/perjanjian dengan pihak lain dalam batas anggaran yang telah ditetapkan.
–Pasal 10 PP 58/2005 ttg Pengelolaan Keuangan Daerah
  • Huruf g : Pejabat pengguna anggaran/pengguna barang daerah mempunyai tugas dan wewenang  mengadakan ikatan/perjanjian kerjasama dengan pihak lain dalam batas anggaran yang telah ditetapkan;

Karena kepala instalasi Farmasi bukan PA, sudah barang tentu ia dilarang keras membuat surat pesanan langsung kepada PBF.  Karena surat pesanan pada hakikatnya adalah perikatan yang memberikan kepercayaan dan jaminan bahwa atas pesanan tersebut pasti terbayar.  Semisal rumah sakit lantaran manajemen kas yang buruk tidak mampu melunasi hutang obatnya yang jatuh tempo, maka siapa yang harus dituntut oleh PBF?  Kepala Instalasi Farmasi? Atau Direktur?  Direktur bisa saja berkilah bahwa pesanan obat itu tanpa persetujuan dan sepengetahuan dia.  Celakalah kepala instalasi farmasi.  Harus menanggung dampak hukum akibat perikatan yang tidak pada tempatnya.

Namun sayang pengetahuan hukum atas regulasi tidak dimiliki oleh semua kepala instalasi juga direktur rumah sakit.  Hal ini terlihat saat saya mempresentasikan bagan di atas, baru sekedar menampilkan saja langsung dikomentari direktur.

“Nah enak pak Iwan neh.  Sudah dibuatkan prosedur pesan obat.  Pakai ini saja pak.  Bapak belum punya kan?  Daripada susah-susah bikinnya.  Pake aja yang Pak Julianto bikin”, kata direktur mengarahkan Pak Iwan sang kepala farmasi.

Dan begitu saya tuntas menjelaskan tentang pelanggaran hukum yang terjadi dan siapa yang seharusnya membuat perikatan, jelas terdengar oleh telinga saya gumam sang direktur.  Gumam yang mungkin cuma saya yang mendengar, karena beliau duduk tepat disamping kiri saya.

“Waduh tambah berat tugas saya kalo begitu…”

 

Salam tetap semangat !

165 Responses to Kesalahan Umum Saat Membuat Penatausahaan BLUD RS (bagian 1)

  1. ferry75 says:

    salam kenal

  2. antie says:

    Salam Kenal pak…boleh sharing?

    • Julianto Supangat says:

      Salam mengenal Anti juga..

      Silakan mbak, situs ini memang didisain untuk saling sharing tentang apa saja asal masih dalam tema BLUD.

      Salam melayani.. dan
      Tetap Semangat..!

      @Julianto Supangat

  3. usman says:

    Salam Kenal Pak Julianto
    apakah saya bisa mendapat artikel BLUD via email

    Terimakasih

    • Julianto Supangat says:

      Terima kasih atas atensinya Mas Usman..
      Mohon maaf, sampai dengan saat ini , fitur langganan yang tersedia hanya melalui bookmark.
      Silakan klik langganan pada kolom paling kanan. Pilih Bookmark Toolbar.

      Kami belum sempat melengkapi tools untuk langganan via email. Mungkin ke depan akan kami perhatikan.

      Terima kasih dan salam melayani.

      @Julianto Supangat.

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