This is a page out of the Oregon Board of Pharmacy meeting a couple of months ago.. The person proposing this discussion Penny Reher from her LinkedIn profile https://www.linkedin.com/pub/penny-reher/27/597/a7 appears to be a Director of Pharmacy for a large hospital complex for the last 16 yrs.
Since the issue of corresponding responsible falls heavily on those in the community pharmacy setting, I am having trouble seeing how a Pharmacist working as an ADMINISTRATOR in a hospital setting can relate to the pertinent issues in the community settings. Unless, she is getting information direnlty from some publication http://deachronicles.quarles.com/
Corresponding responsibility is an issue that is affecting the entire supply chain. DEA’s regulation (21 C.F.R. 1306.04) addressing corresponding responsibility states that the pharmacist is in the same position as the practitioner who issued the prescription (but without having actually conducted a medical examination of the patient) and must exercise professional judgment to determine whether a prescription for a controlled substance was issued for a legitimate purpose.
I have always stated that the DEA is putting forth their interpretation of corresponding responsibility that they are expecting Pharmacist to exceed their Practice Act and Scope of Practice… apparently this BOP seems to believe that Pharmacists in Oregon making a diagnoses on pts without doing a medical exam… are capable of making a determination of the medical necessity … as the licensed prescribed did.
In this statement, they are still failing to recognize the multitude of forged ID’s out there… but suggesting that the PDMP is a panacea of catching those that are doctor or pharmacy shopping.
So according to this proposal… the medical necessity for a pt and the Pharmacist’s professional discretion to fill or not fill, could be boiled down to a fairly simple CHECK LIST…
I could send them a letter and tell them that they are way off track by following the lead of the DEA, but since I am not licensed or live in Oregon.. it would most likely be put in the circular file.. The Board of Pharmacy’s major charge is to protect the health/safety of the public… This (half-baked) proposal is targeting the 2% of the population that we have been trying to stop abusing some substance for over 100 yrs WITHOUT SUCCESS… all this will lead to is increase use/abuse/deaths from Heroin , increase of denial of care of those who have a legit need for controlled substances and increased suicides..
If you live or licensed in Oregon.. I suggest that you send these bureaucrats a letter… if you think that this proposal is LAME !
ORBOPFebruary 2015 <<— full pdf
Corresponding Responsibility
BOARD MEETING MINUTES
Oregon Board of Pharmacy
800 NE Oregon Street
Portland, OR 97232
February 11-13, 2015
The mission of the Oregon State Board of Pharmacy is to promote, preserve and protect the public health, safety and welfare by ensuring high standards in the practice of pharmacy and by regulating the quality, manufacture, sale and distribution of drugs.
Board Member Penny Reher presented an article for discussion from the DEA Chronicles on a Pharmacist’s Obligation: Corresponding Responsibility and Red Flags of Diversion. Penny indicates that over the past couple of years the operations of wholesale distributors have been under more scrutiny from the DEA. As a result pharmacies are receiving more scrutiny from wholesale distributors. Corresponding responsibility is an issue that is affecting the entire supply chain. DEA’s regulation (21 C.F.R. 1306.04) addressing corresponding responsibility states that the pharmacist is in the same position as the practitioner who issued the prescription (but without having actually conducted a medical examination of the patient) and must exercise professional judgment to determine whether a prescription for a controlled substance was issued for a legitimate purpose. Penny believes that the pharmacy community is looking for guidance on this matter. She drafted a checklist for narcotic prescribing red flags which includes the following elements: pattern prescribing, prescribing combinations of frequently abused controlled substances, geographic anomalies, shared addresses by customers presenting on the same day, large quantities and large strengths, paying cash, patients with the same diagnosis code from the same doctors, prescriptions written by doctors for infirmaries not consistent with their area of specialty, fraudulent prescriptions, and prescriptions that other pharmacies refused to fill.
Penny asked for feedback on the checklist and if other Board Members had additional suggestions. It was suggested that steroids be added to the list and that pharmacists check the Prescription Drug Monitoring Program.
Sally Logan from Kaiser Permanente indicated that she has conducted training relating to this matter and that they advise pharmacists to look into the prescription if it’s more than 250 tablets of an opiate. Sally also stated that they had developed a clarification document and in the end, the pharmacist is responsible for documentation within the prescription.
Dennis McAllister commented that the National Association of Boards of Pharmacy is looking at this matter on a national level and will be issuing a report that should be available in March.
Filed under: General Problems
A indication for a controlled substance is a reason for it. If you are “somebody” or a person long on a drug, you may be maintained. Woe is the person who doesn’t qualify. I don’t have pain everyday, but when it occurs it’s bad. One finds if you dress in expensive clothes one get’s better treatment. Using the proper term,such as “trying to mitigate or ammaliarate one’s pain is a proper term to be savvy. If you just are not giving the best terms and dress improperly you may not do well. The poor have a more difficult time receiving treatment. This is sad because even under the best of the situation it is most difficult to navigate the system.