Hi all,
I need help with the flowering questions please.
1. Who can phone a prescription? Doctor? nurse? PA? front desk? nurse aid? medical assistant? anyone work in the doc office?
2. If returning C II, who issues DEA 222 form? pharmacy and/or warehouse?
3. Can unopened drugs still in original manufacture bottle be returned back to retail pharmacy?
4. Theft of controlled substance report to DEA, police, local law enforcement, and/or board?
5. Who can inspect a pharmacy? Board? Law enforcements? DEA?
6. If patient need fentanyl patch every 72 hours and leaving town in 10 days. How many emergency patch can be dispensed? If pharmacy has to get CII hard copy in 72 hours per state law. one patch or three patches?
7. if generic is not available, would you dispense brand? or tell patient to go elsewhere?
8. Who is responsible for all the correct information on Rx? MD, Nurse, and/or pharmacist?
9. Vaccines for kids, do they need MD referrals?
Thank you
Based on your past posts, I guess your are from state of CO, Colorado.
If you are asking for different state, please write back here so others can customize the answer to the state you want.
I only know California law so my answer is as if you will take California Law exam....sorry.
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1. Who can phone a prescription? Doctor? nurse? PA? front desk? nurse aid? medical assistant? anyone work in the doc office?
Anyone. Pharmacist does not ask role of that person, we only ask name of that person.
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2. If returning C II, who issues DEA 222 form? pharmacy and/or warehouse?
DEA form: First copy: Sender of drug keeps.
DEA form: Second copy: DEA keeps.
DEA form: Third copy: Receiver of drug keeps.
Trick:
Let's see the movie at my busy retail pharmacy: everyday, the pharmacist does this to buy C2 med:
Retail pharmacy keeps Third copy.
Retail pharmacy gives the rest of DEA form to driver.
Retail pharmacy receives drugs.
So, Receiver of drug issued the DEA form.
Therefore, because warehouse will receive drug, warehouse must issue the DEA form.
For returning to warehouse, pharmacy must contact warehouse, pharmacy must tell warehouse that I am returning C2 so warehouse please send DEA 222 form.
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3. Can unopened drugs, still in original manufacture bottle, be returned back to retail pharmacy?
In general, No.
For the purpose of re-selling, patient can not return anything to retail pharmacy.
Exception: For the purpose of destroying,
if wrong pill was given to patient, pharmacy will take back.
My chain pharmacy does not allow us to take back other medications that the
patients don't need anymore (because pharmacy must spend a lot of time to process those medications: count them, identify them....)
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4. Theft of controlled substance report to DEA, police, local law enforcement, and/or board?
DEA: As soon as possible.
"On July 8, 2003, DEA published a notice of proposed rulemaking (NPRM) (68 FR 40576) to address confusion that exists within the regulated industry as to the exact meaning of the phrases "upon discovery" and "significant loss."
DEA has always viewed "upon discovery" to mean that notification should occur
immediately and without delay."
http://www.deadiversion.usdoj.gov/fed_regs/rules/2005/fr0812.htm
California Board: within 30 days.
1715.6. Reporting Drug Loss.
The owner shall report to the Board within thirty (30) days of discovery of any loss of the
controlled substances, including their amounts and strengths.
http://www.pharmacy.ca.gov/laws_regs/lawbook.pdf
not police, not local law enforcement.
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5. Who can inspect a pharmacy? Board? Law enforcements? DEA?
DEA: yes, instant access.
Pharmacy Board only: yes, instant access.
Others, Dental Board, Medical Board, Nursing Board, insurance....: no instant access, they must go through corporate office, then, they can come in.
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6. If patient need fentanyl patch every 72 hours and leaving town in 10 days. How many emergency patch can be dispensed?
If pharmacy has to get CII hard copy in 72 hours per state law, one patch or three patches?
If hard copy is coming in 72 hours, my educated guess tells me you are dealing with emergency situation in which doctor phoned in C2, we dispense according to state limit.
Exact quote from DEA:
http://www.deadiversion.usdoj.gov/pubs/manuals/pract/section5.htm
"While some states and many insurance carriers limit the quantity of controlled substance dispensed to a 30-day supply, there are no specific federal limits to quantities of drugs dispensed via a prescription. For Schedule II controlled substances, an oral order is only permitted in an emergency situation."
"In an emergency, a practitioner may call-in a prescription for a Schedule II controlled substance by telephone to the pharmacy, and the pharmacist may dispense the prescription provided that the
quantity prescribed and dispensed is limited to the amount adequate to treat the patient during the emergency period."
The emergency period here means 72 hours in your state law. So, the patient will get 1 patch with phone script and the receiver must provide
PHOTO ID (patient or patient's caregiver).
Within 72 hours from the phone call, if pharmacist gets real paper, pharmacist will dispense the rest of patches.
Within 72 hours from the phone call, if pharmacist gets no paper, pharmacist will report to state board.
Within seven days from the phone call, if pharmacist gets no paper, pharmacist will report to DEA.
"The prescribing practitioner must provide a written and signed prescription to the pharmacist within seven days. Further, the pharmacist must notify DEA if the prescription is not received."
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7. if generic is not available, would you dispense brand? or tell patient to go elsewhere?
If doctor allowed brand,
then,
if patient is okay with price,
then, yes, sell brand.
Reason:
I have seen doctor insisting on generic only.
I have seen doctor insisting on brand only.
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8. Who is responsible for all the correct information on Rx? MD, Nurse, and/or pharmacist?
General answer in my humble opinion: Pharmacist.
Real life answer in my humble opinion: it depends on the case, patient's record, mistake made, drugs involved, damage involved..... Tough debate, which I am not going to debate, sorry. This would need a court case with situations to decide. Often, the blame will be argued by lawyers and each party will get some of the blame: prescriber, dispenser, and patient.
If the drug was wrongly prescribed, obviously OVERDOSE wrong like:
AMLODIPINE 10 mg, 3 pills daily.
Given the assistant of computer, pharmacist is supposed to catch the mistake and not dispense, then for this case, the majority of the blame is on pharmacist.
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9. Vaccines for kids, do they need MD referrals?
In general, in California: no need prescriber's referrals.
Kids over 3 years old often came to pharmacy to get vaccines that were authorized in protocol.
Keyword: only Vaccine in Protocol.
Why? Chain pharmacy contracted with a doctor to have a protocol. In protocol, doctor allowed pharmacists to immunize many vaccines, but not all vaccines. So, chain pharmacists can only immunize vaccines or inject anything within the protocol.
Exception: None that I know of. If not in protocol, chain pharmacist would not inject into the body of any patient.
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Again, these are just my humble opinion and knowledge.
If am wrong, please forgive and correct me.
If anybody has better answers, please share.
Good luck and please come back here to help others after you pass the exam. Thank you very much in advance.
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