NY law questions! Please help!

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wiwikiwi22

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Hey everyone. I haven't graduated yet but I'm a little confused. From what I learned, I thought pharmacists in NY did not have to check PMP, the prescription monitoring program unless they wanted to. In other words, it isn't required for them to check it. I checked this website though and it says PRACTITIONERS MUST check PMP before prescribing or dispensing controls... Since pharmacists dispense, does this apply to them or is this just for practitioners as in doctors who may also dispense?


2) I see my pharmacists at the chain check the PMP just for CIIs like oxycodone--not the combinations like percocet. I guess that's up to you whether you want to use PMP at all, if in fact it isn't required for pharmacists to use it. When we get a script, we check the computer profile to see when they last got it. If it's been 28-29 days since the last fill, we tell them it is fine (c2-5). Then later the pharmacist checks PMP (for CII) to see if the last time they got it with us was the last time they got it at all or if they also got it a different pharmacy. They don't look at previous fills to count how many days supply they may have on hand. I'm confused about the law which mentions you cannot fill a controlled substance unless the patient has exhausted all but a 7 days supply of that medication in ANY PREVIOUSLY ISSUED Rx. Even if checking the pmp isn't required for pharmacists in Ny, this law about 7 days makes it seem like you still need to look at the PMP for controls c2-5 and count to see if they ever got it a day or two before the 30 day supply ran out, and if those early fills add up to >7 days then u dont fill? I never see any pharmacist do this though because technically if it says any previously issued rx, how far back would you be looking?! A patient might be on the med for years. Yes they may have gotten it filled on the 28th or 29th day each time and that will accumulate. Either they ended up taking more of it or gave it to friends or whatever the case is, they might not actually have any on hand now. Are you supposed to tell the patient you've gotten it early for so many months or years so I can't fill it til next year? Lol. I'm confused!!! Pictures are attached on the bottom with screenshots of the laws I'm referring to. Thank you!

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1) You're not a practitioner. Apologies to APhA. It's good practice to do it, but not necessary.

2) PMP only goes back 6 months, so that's all you can reliably do for the 7 day rule. It has been argued about for years, and no clear guidance has been given about it. If it's all filled at your store, you can go back to the first time they filled and keep tally over 20 years, but that's obviously unrealistic.
 
That's annoying. So by law it seems you should check the pmp then for every controlled regarding that 7 day nonsense? Cuz if u look just in your store profile then ur going to be standing there counting for years back.. Ugh. I guess you can look at it for up to 6 months then since the pmp goes back that far, but in terms of the store profile.... :/

None of my pharmacists told me to count though so I don't know what the deal is or what to do as a pharmacist
 
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Use PMP wisely....it's a waste to check if there are no red flags or if the patient is a regular. I do catch a few exceptions...again, the scripts have red flags. Helps cut down on Polypharmacy; however, the system isn't perfect in some parameters of monitoring (border states).
 
Wouldn't the easiest thing to do in NY be go zero days early (relative to last POS transaction) on every controlled substance?
 
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