Repackaging meds- LTC /Assisted living

[Newpharmacist]

So we have VA patients moving in assisted living facility we serve. Since we can’t process VA insurance ; the facility staff insists us on repackaging the VA meds in blister packs using our pharmacy label so it can be scanned via barcode in their EMAR!!

I am at tired of explaining as to how it’s not possible to repackage the meds under our label when I don’t own the script and I haven’t dispensed the medication.
Somehow I am having hard time explaining the illegality of this option to the management as well.

Did I miss something ? Are LTC pharmacies allowed to repackage meds and just hand write on the label - “this is for administration purpose only” ( - a suggestion from management) ? Is this even legal ?!?

Thoughts?

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[owlegrad]

My faculty does repackage and relabel scripts not filled at our facility. We require an order (so that we can print an accurate label) and we charge a fee for the service (pretty hefty too I am told). I am told this is not legal for controls however and we do not do it for them.

Actually now that I think about it, we might only do this for OTC meds. It's been so long since we have done it I do not recall the details.

 

[Newpharmacist]

My faculty does repackage and relabel scripts not filled at our facility. We require an order (so that we can print an accurate label) and we charge a fee for the service (pretty hefty too I am told). I am told this is not legal for controls however and we do not do it for them.

Actually now that I think about it, we might only do this for OTC meds. It's been so long since we have done it I do not recall the details.

Thank you for sharing your thoughts.

But this is how I see it — those meds weren’t filled by your facility nor verified by your facility RPh..after repackaging the label will display your pharmacies label - so technically your taking the liability of adequacy of those meds in the blister!
Is this safe or even legal ?

I did read a document somewhere about LTCs repackaging but it didn’t have specifics how it’s carried out ..

 

[owlegrad]

Thank you for sharing your thoughts.

But this is how I see it — those meds weren’t filled by your facility nor verified by your facility RPh..after repackaging the label will display your pharmacies label - so technically your taking the liability of adequacy of those meds in the blister!
Is this safe or even legal ?

I did read a document somewhere about LTCs repackaging but it didn’t have specifics how it’s carried out ..

Well to be fair we DO require an order, we are not just packaging them on blind faith. We also charge a fee so it's not charity. It's basically like any other script, except that the source of the meds is the home rather than the wholesaler. How is it any less safe than any other script you check? Presumably you identify any medications you send out so how is this different?

 

[Newpharmacist]

Well to be fair we DO require an order, we are not just packaging them on blind faith. We also charge a fee so it's not charity. It's basically like any other script, except that the source of the meds is the home rather than the wholesaler. How is it any less safe than any other script you check? Presumably you identify any medications you send out so how is this different?

I see your point.
At the risk of being mocked at for being paranoid — What if the meds dispensed by the other pharmacy were expired (by mistake / or carelessly ) or they dispensed a recalled lot ?!
By putting your label and RPh initials on it you take the ownership of those pills for their adequacy ... unless somewhere on the label it’s mentioned that it’s a repacked blister with meds from so and so pharmacy.

 

[owlegrad]

I see your point.
At the risk of being mocked at for being paranoid — What if the meds dispensed by the other pharmacy were expired (by mistake / or carelessly ) or they dispensed a recalled lot ?!
By putting your label and RPh initials on it you take the ownership of those pills for their adequacy ... unless somewhere on the label it’s mentioned that it’s a repacked blister with meds from so and so pharmacy.

Yeah I can see why you would be worried about repacking sosoo's scripts.

I kid!

Let's be real for a moment. How would you be liable for the other pharmacies mistake? The bottle you have says that the expiration date is such and such. How can you be liable for that bottle being wrong? As for lot numbers, how would it be possible to track that lot to you?

Which state are you in? Someone here might be willing to comb through your state laws and see what it has to say about LTC repackaging.

 

[Newpharmacist]

Yeah I can see why you would be worried about repacking sosoo's scripts.

I kid!

Lol!

Let's be real for a moment. How would you be liable for the other pharmacies mistake? The bottle you have says that the expiration date is such and such. How can you be liable for that bottle being wrong? As for lot numbers, how would it be possible to track that lot to you?.

Coz the blister has my pharmacy label on it with my initials and my Rx number.

Which state are you in? Someone here might be willing to comb through your state laws and see what it has to say about LTC repackaging.

MI

 

[owlegrad]

Coz the blister has my pharmacy label on it with my initials and my Rx number.

I mean I see what you are saying, but are you also liable if the manufacturer lists the wrong expiration date on their bottle? You can only be as accurate as the information provided to you.

 

[Newpharmacist]

I mean I see what you are saying, but are you also liable if the manufacturer lists the wrong expiration date on their bottle? You can only be as accurate as the information provided to you.

Agreed- but here it would be manufacturer’s fault.
For repackaged — my wholesaler/ manuf cant be held liable as he may have never supplied me that NDC ..

I do think it’s doable — if it can be specified on the script that provider of those meds was the “x” pharmacy with “z” expiration date and that we have only repackaged those meds.

 

[Litha]

Did I miss something ? Are LTC pharmacies allowed to repackage meds and just hand write on the label - “this is for administration purpose only” ( - a suggestion from management) ? Is this even legal ?!?

Thoughts?

No. Do not repackage medications filled by other pharmacies. There is so much liability in placing your name on something that you did not originally verify and cannot guarantee has been stored in proper conditions. I work LTC and we have a lot of patients with this issue. The best way we have found to deal with it is providing cold packing supplies to the ALF's so they can repackage themselves. We do not provide labels because (at least in my state) it is not legal for a nurse or aide to label a medication. But they can repackage it! As long as they provide us a copy of the order, we can update the MAR and they manually checkmark the box in their system if the medication was given or not.

 

[Idk17]

What Owl's pharmacy does seems fine, if they just adjust the expiration date to be no longer than what was on the previous pharmacy's package. If they have an order, they're still verifying everything like normal.. it's like they're just borrowing the meds from the VA pharmacy.

With that said, it still seems like a bad idea; my pharmacy doesn't repackage anything.

 

[Newpharmacist]

My question is - is it even legal for pharmacies to repackage ? Anyone knowing anything on what MI law states on this ?

 

[Newpharmacist]

I did some internet search - it depends on the state law. PA allows it but with proper documentation and has a protocol for it. Iowa however does not allow.
Still not sure of MI ..

 

[Xarelto-10]

At my former hospital job POM (pts own meds) could be used in-house with MD’s order. So the standard was we had a generic-order set created I.e NF med to where we will write the Rx name dose and administration frequency and etc.
That will automatically upload onto the e-Mar as POM or NF- drug.
But at the same time it will generate a label or a barcode I forgot which- that can be scanned by nursing for emar documentation and it will not be repackaged and stays by patients bedside.

So I don’t think you should re-package POM. That will be legally murky area but having some system in place to circumvent this will make your day a little easier.
Good luck.

 

[Newpharmacist]

At my former hospital job POM (pts own meds) could be used in-house with MD’s order. So the standard was we had a generic-order set created I.e NF med to where we will write the Rx name dose and administration frequency and etc.
That will automatically upload onto the e-Mar as POM or NF- drug.
But at the same time it will generate a label or a barcode I forgot which- that can be scanned by nursing for emar documentation and it will not be repackaged and stays by patients bedside.

So I don’t think you should re-package POM. That will be legally murky area but having some system in place to circumvent this will make your day a little easier.
Good luck.

That’s a great way out.. the EMAR also recognizes it as NF /POM. You guys had diligently worked around the system while immunizing yourself from any civil liabilities.

Unfortunately at my place - it’s being thought as a ‘no brainer’- just print out your label and write on the label - it is repacked . In essence documenting that we are repackaging - while no one knows if this is even lawful in the state.