Early refills and the DEA

[BenJammin]

Does the DEA have an official comment on early refills of controlled substances? I find it very weird that a nearby Walgreens doesn't fill early, CVS does the day before, Kroger does 2 days early, and the local independent doesn't have an early refill rule. Why is this enforced so differently across the board?

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[beautifulrobot]

Does the DEA have an official comment on early refills of controlled substances? I find it very weird that a nearby Walgreens doesn't fill early, CVS does the day before, Kroger does 2 days early, and the local independent doesn't have an early refill rule. Why is this enforced so differently across the board?

The DEA doesn't define early refills or say anything specific to early refills. Just as long as you don't exceed 5 refills in 6 months: https://www.deadiversion.usdoj.gov/21cfr/cfr/1306/1306_22.htm

 

[beautifulrobot]

You might run into some problems with your state board, though: http://www.medscape.com/viewarticle/749833

 

[CetiAlphaFive]

I think this is one of those things that's left intentionally vague.

Vague enough to help people who need it and vague enough to bust people who mess up.

 

[josh6718]

Does the DEA have an official comment on early refills of controlled substances? I find it very weird that a nearby Walgreens doesn't fill early, CVS does the day before, Kroger does 2 days early, and the local independent doesn't have an early refill rule. Why is this enforced so differently across the board?

I actually had spoken with two DEA investigators, and what their concern about early fills was from a diversion point of view. The pharmacist(s) had been deliberately shorting patients on their pills, then fill the next months prescription early so that the patient would not run out and complain. When they began looking at who was overriding the early fills, it lead them to ultimately discover what was happening.

 

[ldiot]

It's vague because they want to give the pharmacist room to exercise their own professional judgement. Every patient and every case is different. If you are responsible and use common sense it's really not something to lose sleep over.

 

[BenJammin]

So if I decide to enact a policy of 5 day early refills, that's not a big deal?

 

[Claydoe]

So if I decide to enact a policy of 5 day early refills, that's not a big deal?

Right, but you still have to use common sense. Someone aware of your policy can set aside potentially 30-40 pills every fill and if they're consistently filling 5 days early then that's a pretty big red flag.

 

[CetiAlphaFive]

Right, but you still have to use common sense. Someone aware of your policy can set aside potentially 30-40 pills every fill and if they're consistently filling 5 days early then that's a pretty big red flag.

Yup. If a patent fills 3 days early for 10 months, they've consumed or stocked an extra month of medication.

It's an interesting perspective on a "normal" policy for early fills

 

[sosoo]

Yup. If a patent fills 3 days early for 10 months, they've consumed or stocked an extra month of medication.

and with that extra month of medication, they can pour it to an empty bottle of another prescription that they finished. and claim that you fill it incorrectly. and file a lawsuit. and the judge will believe them that you filled incorrectly. i had this lawsuit with zolpidem/lisinopril. they got extra zolpidems lying around so they dump it in lisinopril bottle and filed lawsuit. the meds were filled in 2013. the lawsuit filed one year later, 2014.... at that point our video recordings are already wiped clean.

 

[BenJammin]

Yup. If a patent fills 3 days early for 10 months, they've consumed or stocked an extra month of medication.

It's an interesting perspective on a "normal" policy for early fills

Why does that matter if diversion isn't the reason for early refills?

 

[CetiAlphaFive]

Why does that matter if diversion isn't the reason for early refills?

Are you kidding?

Poor adherence can be associated with negative outcomes.

Tolerance, etc...

 

[Rockinacoustic]

Are you kidding?

Poor adherence can be associated with negative outcomes.

Tolerance, etc...

Maybe I can't get down to the pharmacy every 30th day?

 

[zelman]

Maybe I can't get down to the pharmacy every 30th day?

Well, if you come the 28th day one month and the 32nd the next month, that makes sense. When you get it the 28th day every month, the math doesn't add up after a while.

 

[CetiAlphaFive]

Maybe I can't get down to the pharmacy every 30th day?

Yeah, I can appreciate that transportation barriers exist for some patients.

A common occurrence is a patient who requests a refill on day 25 and is told to come back on day 27 every single month.

This simply can't be accounted for by any barrier I can think of

 

[BenJammin]

Well, if you come the 28th day one month and the 32nd the next month, that makes sense. When you get it the 28th day every month, the math doesn't add up after a while.

Why does it matter?

 

[zelman]

Why does it matter?

That's a question for the DEA.

 

[owlegrad]

Why does it matter?

Are you really a pharmacist? What could a possible legitimate motive be to stockpile a controlled substance? A history of early refills is one of the biggest red flags.

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[Deja]

Are you really a pharmacist? What could a possible legitimate motive be to stockpile a controlled substance? A history of early refills is one of the biggest red flags.

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lol yeah not sure if he's just trying to antagonize or just really clueless

also having a loose controlled med policy invites bad customers

 

[PharmDBro2017]

Kroger allows 3 day early refill here, as well as some other chains in close distance.

You refill 3 days early, every month of the year = 1 extra prescription to get.... I don't see how it's allowed still.

 

[Sine Cura]

Only chronic opioid regimens, stimulants and benzos are subject to this phenomenon of "hyperadherence" where patients always run out exactly on the earliest day the script is supposed to run out and are hypervigilant about getting things as early as a pharmacy allows, even with "PRN" use. NOT ARVs, not anti-rejection drugs, not oral oncology meds.

 

[zelman]

Only chronic opioid regimens, stimulants and benzos are subject to this phenomenon of "hyperadherence" where patients always run out exactly on the earliest day the script is supposed to run out and are hypervigilant about getting things as early as a pharmacy allows, even with "PRN" use. NOT ARVs, not anti-rejection drugs, not oral oncology meds.

You forgot glucometer strips.

 

[BenJammin]

Are you really a pharmacist? What could a possible legitimate motive be to stockpile a controlled substance? A history of early refills is one of the biggest red flags.

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Ironically I should be asking you that question. The idea that we should turn away John Doe because he's 3 days early on his Ambien even though the living facility he resides in only takes patients outside to the pharmacy/grocery store/etc on a set schedule is asinine. All because of some made up regulation not enforced by the DEA. It boggles the mind.

 

[owlegrad]

Ironically I should be asking you that question. The idea that we should turn away John Doe because he's 3 days early on his Ambien even though the living facility he resides in only takes patients outside to the pharmacy/grocery store/etc on a set schedule is asinine. All because of some made up regulation not enforced by the DEA. It boggles the mind.

Three days early the first refill, then the same day every month after that. Or does the living facility make sure to bring him 3 days early every month? Maybe his care taker is helping themselves to a few every month?

Just admit it, there is no legitimate reason to need an extra 36 day supply every year. It is a red flag.

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[CetiAlphaFive]

Ironically I should be asking you that question. The idea that we should turn away John Doe because he's 3 days early on his Ambien even though the living facility he resides in only takes patients outside to the pharmacy/grocery store/etc on a set schedule is asinine. All because of some made up regulation not enforced by the DEA. It boggles the mind.

Find a calendar. Any calendar.

Point at a day in January. Let's say the 1st. Then point at that day on the next 11 months.
How often do they fall on the same day of the week? Twice.

You seem to have a problem with creating simplistic theoretical situations that fit your argument, which you then generalize to a broader, real world problems.
I sincerely hope you don't do this with clinical problems.

 

[BenJammin]

Find a calendar. Any calendar.

Point at a day in January. Let's say the 1st. Then point at that day on the next 11 months.
How often do they fall on the same day of the week? Twice.

You seem to have a problem with creating simplistic theoretical situations that fit your argument, which you then generalize to a broader, real world problems.
I sincerely hope you don't do this with clinical problems.

As a clinical pharmacist, I know that there is no cookie cutter plan that fits every patient every time in every situation. You have to adapt. But this isn't rocket science and the fact that you cannot show me a statute or precedent that shows pharmacists present a danger by giving Mrs Jones her Ambien refill 3 days before she runs out is very telling. This is nothing more than retail pharmacists enforcing made up rules that inconvenience patients and their access to medications.

Maybe state boards should act? Texas acted due to patient outcry when CVS delayed transfers for days even weeks. Enough people complain and they'll act.

 

[CetiAlphaFive]

As a clinical pharmacist, I know that there is no cookie cutter plan that fits every patient every time in every situation. You have to adapt. But this isn't rocket science and the fact that you cannot show me a statute or precedent that shows pharmacists present a danger by giving Mrs Jones her Ambien refill 3 days before she runs out is very telling. This is nothing more than retail pharmacists enforcing made up rules that inconvenience patients and their access to medications.

Maybe state boards should act? Texas acted due to patient outcry when CVS delayed transfers for days even weeks. Enough people complain and they'll act.

You're being intentionally obtuse in order to protect your position.

Like I said before, you have a problem with fabricating theoreticals to support your position.
You're demanding statutes and evidence while only supplying convenient "what if" situations and conjuring images of poor, betrodden patients denied access to meds by the cruel devils of retail.

Of course I will dispense a controlled Rx early to a patient I know is using it for a legitimate medical purpose.

Joe Schmoe that I see on PMP has gotten it early every month for the past 3 years?

No.

Here's a "statute":
http://www.deadiversion.usdoj.gov/21cfr/cfr/1306/1306_04.htm

If the legitimate medical purpose for the prescription is 1 tab 4 times daily, are the others being used outside of a legitimate medical purpose?
Is stockpiling medication a legitimate medical purpose?

Ask this guy:

http://health.state.tn.us/Downloads/Pharm_Min11706.pdf

Ask this guy too:

http://www.ncbop.org/Disciplinary Actions - PHARMACISTS/R Lawson 7465 Mt Pilot Drug 5907.pdf


Here's an anecdote I experienced that's directly related to this:

I was floating at another Target and refused to fill an rx 4 days before the due date.

The patient then told me he was going to "take all of the extra _____ I have at home and kill myself like Robin Williams did"
(This was a few weeks after the comedian had committed suicide)

Should I have dispensed the medication to avoid inconveniencing him?


Either come up with something solid besides "but wut if dey relly need it u dont no if dey are diverting" or stop replying to this garbage bait thread.

 

[PikminOC]

You're being intentionally obtuse in order to protect your position.

Like I said before, you have a problem with fabricating theoreticals to support your position.
You're demanding statutes and evidence while only supplying convenient "what if" situations and conjuring images of poor, betrodden patients denied access to meds by the cruel devils of retail.

Of course I will dispense a controlled Rx early to a patient I know is using it for a legitimate medical purpose.

Joe Schmoe that I see on PMP has gotten it early every month for the past 3 years?

No.

Here's a "statute":
http://www.deadiversion.usdoj.gov/21cfr/cfr/1306/1306_04.htm

If the legitimate medical purpose for the prescription is 1 tab 4 times daily, are the others being used outside of a legitimate medical purpose?
Is stockpiling medication a legitimate medical purpose?

Ask this guy:

http://health.state.tn.us/Downloads/Pharm_Min11706.pdf

Ask this guy too:

http://www.ncbop.org/Disciplinary Actions - PHARMACISTS/R Lawson 7465 Mt Pilot Drug 5907.pdf


Here's an anecdote I experienced that's directly related to this:

I was floating at another Target and refused to fill an rx 4 days before the due date.

The patient then told me he was going to "take all of the extra _____ I have at home and kill myself like Robin Williams did"
(This was a few weeks after the comedian had committed suicide)

Should I have dispensed the medication to avoid inconveniencing him?


Either come up with something solid besides "but wut if dey relly need it u dont no if dey are diverting" or stop replying to this garbage bait thread.

Did Lawson fill opioids without prescription?