Walgreens in AZ refusing to xfer CIV before first fill?

[Corpseman]

Transfer of Prescription Information | Arizona State Board of Pharmacy
https://pharmacy.az.gov/sites/default/files/documents/files/sps8.pdf

They changed the practice rules quite a bit ago, and it requires the script verified. My aunt was cited for calling in the prescription rather than getting a number set up right as they were changing the policy and started pressuring the political side for change in the AAC. A bunch of pharmacists from her generation still won't transfer new scripts, because they've been hit with complaints anyway, so the local practice is usually to refuse the transfer and ask the pharmacist to call the prescriber's agent.

I ran into this for the first time trying to get a script from a CVS. I guess CVS doesn't assign a number until it's been verified at least once which was weird so I had the pharmacist push it through and then just reverse it and it had a number and she could transfer it. It was a pretty weird situation that I had me at a loss at first.

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[CetiAlphaFive]

I'll have to find the message (love getting things in writing), but the Oregon Board said transfers of unfilled controls are alright, and they provided a statement from NABP with their message.

I'm gonna send that to TSBP as soon as you post it

 

[KimChiSlap]

They had refills they just refused to transfer it to me.

Oh in that case, I don't see why not.
Especially if the patient had requested it.
I usually wouldn't go that far to ask about the license but sometimes I get the patient on board to do some convincing =)

 

[owlegrad]

I just love this idea that the only way to forward a prescription is to do it electronically in your software. A feature that has never existed. You might think that if that was the board of pharmacy or DEA’s intention they would have said so.

Perhaps it’s a conspiracy to set up Pharmacies so that the DEA or BOP can bust them. It certainly shouldn’t be taken at face value to mean what it says. :eye roll:

 

[CetiAlphaFive]

I just love this idea that the only way to forward a prescription is to do it electronically in your software. A feature that has never existed. You might think that if that was the board of pharmacy or DEA’s intention they would have said so.

Perhaps it’s a conspiracy to set up Pharmacies so that the DEA or BOP can bust them. It certainly shouldn’t be taken at face value to mean what it says. :eye roll:

We've entered dark times when *****s like [Walmart's chief compliance person] are basically allowed to legislate.

 

[lord999]

Legislation is almost always reactive, and always with the 2000 mile pencil relay (in the sense that there is removal of passing the law from the ones enforcing it). Pharmacy is one of the most highly legally regulated fields (much more so than medicine) as it combine aspects of medicine, chemical law, hazardous law, and old-time alcohol and tobacco control, and I don't expect legislatures to get it right without Board prompting. And even so, I know that there are technicians who made more than the Assistant Attorney General (basically the in-house counsel) to the AZ State Board (her salary was around $62-65k to put up with a bunch of opposition lawyers who made an order of magnitude more than she did) which limits the career tenure of anyone worth having in that job. Most use it as a stepping stone to either private practice or political gain.

 

[lord999]

It wouldn't be a big deal if these pharmacies would just follow existing state and federal law. Who suffers when the sending pharmacy refuses the transfer? The patient.

Yes, but you coming from a Class A, D, or S from Texas, how the hell am I supposed to know in AZ what Texas and those other 49 lesser states' laws are with reference to what you or you cannot do (and vice-versa) ? Spoken tongue-in-cheek because I do have a Texas license and I found it to be really confusing how punitive Texas was with those rules (and how anti-patient and drug control happy they are alongside with TABC), but I kind of wish all states would pass some kind of a Model Pharmacy Practice Act and do away with the state specific quirks. And what is the law supposed to provide at some level, a measure of safety and confidence in actions supposedly? The patient definitely suffers from the lack of trust and confusion over the ambiguity of the laws and regulations that are state specific. Thank god they eliminated the provisions where you could not accept controls from a state not adjacent to the state of practice (MN, IA, and WI).

 

[owlegrad]

We've entered dark times when *****s like [Walmart's chief compliance person] are basically allowed to legislate.

So true. I mean I can understand one person reading the part about refills and thinking "ok, only refills can be transferred since it doesn't say anything about unfilled scripts". Easy enough. But then that person is able to convince their entire company that is the case? A bit of a stretch, but ok. Then other companies react by...agreeing with them 100% and all of a sudden something that almost everyone has been doing for years is suddenly illegal and even when the DEA and BOPs say "No guys it's fine, it has always been fine" the response is to say "You aren't being clear enough! What is original prescription information anyway? What does that mean? Also how do I forward something? No one can know what forwarding means!". I mean holy crap does this level of needing handholding exist in any other aspect of life?

I picture someone at the DEA setting at a desk going, "I am so glad we put that issue to bed by publishing our statement in the Federal Register stating that it is permitted. Oh crap, we are getting comments about this, no problem, I will just issue a response to the comments and 100% settle the matter. Oh, we are still getting questions about this? No problem, I will just send a statement to NABP to alleviate any concerns they have about this. Oh no, that didn't work either? I give up, lunch time."

 

[lord999]

So true. I mean I can understand one person reading the part about refills and thinking "ok, only refills can be transferred since it doesn't say anything about unfilled scripts". Easy enough. But then that person is able to convince their entire company that is the case? A bit of a stretch, but ok. Then other companies react by...agreeing with them 100% and all of a sudden something that almost everyone has been doing for years is suddenly illegal and even when the DEA and BOPs say "No guys it's fine, it has always been fine" the response is to say "You aren't being clear enough! What is original prescription information anyway? What does that mean? Also how do I forward something? No one can know what forwarding means!". I mean holy crap does this level of needing handholding exist in any other aspect of life?

I picture someone at the DEA setting at a desk going, "I am so glad we put that issue to bed by publishing our statement in the Federal Register stating that it is permitted. Oh crap, we are getting comments about this, no problem, I will just issue a response to the comments and 100% settle the matter. Oh, we are still getting questions about this? No problem, I will just send a statement to NABP to alleviate any concerns they have about this. Oh no, that didn't work either? I give up, lunch time."

Most of the DEA SAC's think in one-word sentences. So in reference to your scenario:
Works. Good. Questions? Whatever. Lunch.

Possibly without Questions or Whatever. They are law enforcement with few lawyers in their chain of command. Their Policy unit is notoriously inept and have to depend on FBI (shudder) to get it straight. I would probably get a Title 5 action if I said my opinion on the (Non)Intelligence unit, I've spent last quarter sorting out of a hell of a mess that they caused my place over traceable paperwork. The DEA is good about beating up small time change while the real dinguses make bank and work at will. Not to mention that there's an ongoing scandal about missing evidence as there's a couple of field offices that have people sampling the merchandise, for purity reasons, of course.

 

[zelman]

Semantics. Are you really trying to suggest that the Board has made up an entirely new class of prescription transfer? You can forward the prescription to me the same way you forward any other prescription.

As others have said, I believe this is referring to electronic prescriptions being forwarded electronically intact. It is not referring to verbal transfers. The fact that C2s are included strengthens my interpretation.

 

[zelman]

I just love this idea that the only way to forward a prescription is to do it electronically in your software. A feature that has never existed.

Did you expect the software people to waste time on an illegal feature before the law was created?

This “forward” concept was created because of concerns of out of stock C2’s Rx’s being trapped where the MD ordered them. When it’s an eRx the patient can’t just take the hard copy elsewhere. The law came from there, not in reaction to a software feature that has fallen to disuse.

 

[Sine Cura]

Would it be that hard for boards of pharmacy to issue a substantive policy statement on transferring CIIs instead of parroting what the DEA said without any further elaboration? "For now follow existing regulation on transfers of CII-CV in the practice act." Done.

Some states don't even allow transfers of controls, including ERx (at least in certain situations like transfer to a pharmacy in another state) so the BOPs in these states would have to address specifically the CII ERx case.

 

[BenJammin]

You should take that up with the company they work for, not the pharmacist. If the system doesn't allow you to transfer out a prescription, how are you going to report that pharmacist? He/she won't be able to document all the information in the system to do a transfer required by law.

In that scenario, would it be much trouble for you to call the doctor and ask for a prescription? Or is that too much work if you truly cared for the patient?

Not my problem. Transfers of prescriptions is a patient right. If your software doesn't know how to do it then figure it out. Why does the patient have to suffer because of your refusal to follow the law?

Are you sure you're a pharmacist? The physicians who work outpatient at my facility all leave at 5. What is the patient supposed to do when it's 6PM? Go to the emergency room? All because you don't want to follow the law and satisfy some sort of ego problem. That's outrageous.

 

[CetiAlphaFive]

Not my problem. Transfers of prescriptions is a patient right. If your software doesn't know how to do it then figure it out. Why does the patient have to suffer because of your refusal to follow the law?

Are you sure you're a pharmacist? The physicians who work outpatient at my facility all leave at 5. What is the patient supposed to do when it's 6PM? Go to the emergency room? All because you don't want to follow the law and satisfy some sort of ego problem. That's outrageous.

Ok SosooJammin

Call TSBP now. It's Monday.
Ask them if it's legal to transfer an unfilled prescription for C2-5 that isn't electronic.

Go ahead.

 

[BenJammin]

Ok SosooJammin

Call TSBP now. It's Monday.
Ask them if it's legal to transfer an unfilled prescription for C2-5 that isn't electronic.

Go ahead.

It's not and I never said it was.

 

[doublehh03]

Not my problem. Transfers of prescriptions is a patient right. If your software doesn't know how to do it then figure it out. Why does the patient have to suffer because of your refusal to follow the law?

Are you sure you're a pharmacist? The physicians who work outpatient at my facility all leave at 5. What is the patient supposed to do when it's 6PM? Go to the emergency room? All because you don't want to follow the law and satisfy some sort of ego problem. That's outrageous.

So you're expecting an employee to figure out how to resolve a company's issue? Lol this is laughable.

You do know you can page doctors after 5 right? What YOU can do to help the patient is do what you have to do within your power to help him/her. What I have done in this situation is page the MD. If it's not the same MD, I ask for a 3 day supply from a covering MD and call the right MD the next day.

Again, have you worked retail recently? It seems like you don't know how the process works once office closes.

Reporting pharmacists over this. How pathetic. You must work in a very poor environment to report your fellow professionals over something they can't control.

 

[BenJammin]

So you're expecting an employee to figure out how to resolve a company's issue? Lol this is laughable.

You do know you can page doctors after 5 right? What YOU can do to help the patient is do what you have to do within your power to help him/her. What I have done in this situation is page the MD. If it's not the same MD, I ask for a 3 day supply from a covering MD and call the right MD the next day.

Again, have you worked retail recently? It seems like you don't know how the process works once office closes.

Reporting pharmacists over this. How pathetic. You must work in a very poor environment to report your fellow professionals over something they can't control.

Yes I absolutely expect the employee to fix the issue and so does the state board of pharmacy. You do understand that as a pharmacist you're responsible for compliance with all state and federal regulations, yes? Instead of criticizing me for not using the page system (which doesn't work very well at my facility, covering docs won't authorize prescriptions for patients they've never seen) why don't you just do your job? You know, follow the law?

 

[CetiAlphaFive]

Yes I absolutely expect the employee to fix the issue and so does the state board of pharmacy. You do understand that as a pharmacist you're responsible for compliance with all state and federal regulations, yes? Instead of criticizing me for not using the page system (which doesn't work very well at my facility, covering docs won't authorize prescriptions for patients they've never seen) why don't you just do your job? You know, follow the law?

Yeah!

Just code an entirely new process into your company's Rx system to "forward" the prescription and also program the receiving pharmacy's system to receive this "forwarded" prescription, all to comply with a nascent legal concept regarding transfers.

What's so hard about that?

 

[Son_Goku]

So you're expecting an employee to figure out how to resolve a company's issue? Lol this is laughable.

You do know you can page doctors after 5 right? What YOU can do to help the patient is do what you have to do within your power to help him/her. What I have done in this situation is page the MD. If it's not the same MD, I ask for a 3 day supply from a covering MD and call the right MD the next day.

Again, have you worked retail recently? It seems like you don't know how the process works once office closes.

Reporting pharmacists over this. How pathetic. You must work in a very poor environment to report your fellow professionals over something they can't control.

It really doesn't matter what your personal philosophy is. The system your employer uses will dictate whether you are allowed to transfer or not on the first fill (news flash, they don't allow it).

 

[doublehh03]

Yeah!

Just code an entirely new process into your company's Rx system to "forward" the prescription and also program the receiving pharmacy's system to receive this "forwarded" prescription, all to comply with a nascent legal concept regarding transfers.

What's so hard about that?

Ok I'll do that during y 1 hour lunch break. That dude is delusional lol.

 

[KimChiSlap]

Garlic

 

[radio frequency]

In one state where I'm registered, the Board specifically came out and said you cannot transfer unfilled controls, and they based this on their interpretation of DEA rules. It's interesting how this has been interpreted differently across different states.

 

[BenJammin]

hmm... please enlighten me on EPCS that includes C2-C5 that can be forwarded.
Do tell me how is it done?
And how pharmacy # 2 accept such a script?

It's called a "transfer". Any pharmacist can do it.

In one state where I'm registered, the Board specifically came out and said you cannot transfer unfilled controls, and they based this on their interpretation of DEA rules. It's interesting how this has been interpreted differently across different states.

Blows my mind since the DEA public comment is clear as crystal.

 

[Hibiclens]

I have to ask, is it a patient right, that their prescription be transferred? I don’t know. Now I’m not asking about the ethics of this.

I’ve had mail order deny a transfer to them from me and the VA deny all transfers to me. Now perhaps they are closed system(s)...does the patient have right to transfer then?

 

[KimChiSlap]

nevermind.
I'll read from the sidelines

 

[CetiAlphaFive]

It's called a "transfer". Any pharmacist can do it.



Blows my mind since the DEA public comment is clear as crystal.

Are you sure it's not bright as day?

 

[Charcoales]

This whole "debate" feels so pointless. There is already a rule in place and it's the "one-time" transfer between two pharmacy chains for c3-5. Adding this weird filled/unfilled stipulation is pointless and unnecessary and most of all makes NO sense.

 

[Dr Wario]

This kind of quibbling is exactly why pharmacists cannot make any significant impacts on the profession. What do you think the average physician or mid-level would think when reading this garbage topic? These stupid pharmacists are threatening to report each other because of poor word choice in a law that no one actually cares about while following company policy?

This is why it is 2017 and we are still forced to take call in prescriptions from office janitors because the doctor is "too busy" to sign a piece of paper or click a button on the computer.

Honestly, I am embarrassed to be in the same profession as some of you.

 

[Dr Wario]

Actually, how about we remove the entire concept of transfers alltogether? I mean god forbid the patient or prescriber have to do some actual work instead of pushing it on the pharmacist like always. I can't tell you how many times I have gotten a call from an office secretary saying, "oh hey, we accidentally sent Mrs. Smith's prescription to the wrong pharmacy, can you call XYZ pharmacy across town and give it to them?" The only response you should ever give to this request btw the way is, "no, but you can".

 

[Dr Wario]

.

 

[VA Hopeful Dr]

This kind of quibbling is exactly why pharmacists cannot make any significant impacts on the profession. What do you think the average physician or mid-level would think when reading this garbage topic? These stupid pharmacists are threatening to report each other because of poor word choice in a law that no one actually cares about while following company policy?

This is why it is 2017 and we are still forced to take call in prescriptions from office janitors because the doctor is "too busy" to sign a piece of paper or click a button on the computer.

Honestly, I am embarrassed to be in the same profession as some of you.

Meh, we don't care. I get that y'all are more heavily regulated than we are and your corporate masters are more nit-picky than ours are.

Actually, how about we remove the entire concept of transfers alltogether? I mean god forbid the patient or prescriber have to do some actual work instead of pushing it on the pharmacist like always. I can't tell you how many times I have gotten a call from an office secretary saying, "oh hey, we accidentally sent Mrs. Smith's prescription to the wrong pharmacy, can you call XYZ pharmacy across town and give it to them?" The only response you should ever give to this request btw the way is, "no, but you can".

Yeah if I send it to the wrong place, that's on me. If the patient changes their mind about what pharmacy after I send it, I make them get it transferred.

 

[CetiAlphaFive]

This whole "debate" feels so pointless. There is already a rule in place and it's the "one-time" transfer between two pharmacy chains for c3-5. Adding this weird filled/unfilled stipulation is pointless and unnecessary and most of all makes NO sense.

Well, that's what happens when you allow a ***** at Walmart who is a member of a fly over state's board to legislate for an entire nation.

 

[owlegrad]

This kind of quibbling is exactly why pharmacists cannot make any significant impacts on the profession. What do you think the average physician or mid-level would think when reading this garbage topic? These stupid pharmacists are threatening to report each other because of poor word choice in a law that no one actually cares about while following company policy?

You think "average" physicians or mid-level don't disagree or argue, sometimes over things you would consider garbage? Or never threaten to report each other? Please tell me more about these perfect physicians and mid-levels.

 

[PharmD.girl]

Wow! I had no idea what a hot button issue this was when I started this thread. I simply wanted to find out why another Walgreens pharmacy would not be able to fill my Viberzi e-Rx since mine was out of stock on a holiday weekend and the chain is considered "real time". I was unable to get a hold of my dr's office. The near decade I spent in retail was in a local chain not in "real time" and I left just before controlled e-RX's were legal in AZ.
From reading the DEA and state regulations, it appears to be legal. However after reading many posts on the thread, it seems to be against most major chain's company policy, likely because it is not clear how one pharmacy can "forward" the e-Rx to another.
Am I understanding the answer to my question correctly?

 

[owlegrad]

Wow! I had no idea what a hot button issue this was when I started this thread. I simply wanted to find out why another Walgreens pharmacy would not be able to fill my Viberzi e-Rx since mine was out of stock on a holiday weekend and the chain is considered "real time". I was unable to get a hold of my dr's office. The near decade I spent in retail was in a local chain not in "real time" and I left just before controlled e-RX's were legal in AZ.
From reading the DEA and state regulations, it appears to be legal. However after reading many posts on the thread, it seems to be against most major chain's company policy, likely because it is not clear how one pharmacy can "forward" the e-Rx to another.
Am I understanding the answer to my question correctly?

I would say so, yes.

 

[CetiAlphaFive]

Wow! I had no idea what a hot button issue this was when I started this thread. I simply wanted to find out why another Walgreens pharmacy would not be able to fill my Viberzi e-Rx since mine was out of stock on a holiday weekend and the chain is considered "real time". I was unable to get a hold of my dr's office. The near decade I spent in retail was in a local chain not in "real time" and I left just before controlled e-RX's were legal in AZ.
From reading the DEA and state regulations, it appears to be legal. However after reading many posts on the thread, it seems to be against most major chain's company policy, likely because it is not clear how one pharmacy can "forward" the e-Rx to another.
Am I understanding the answer to my question correctly?

Precisely.
It's an artificially created, complex **** storm.

People who are insisting that it's simple are being intentionally obtuse as an attempt to virtue signal.

 

[owlegrad]

Precisely.
It's an artificially created, complex **** storm.

People who are insisting that it's simple are being intentionally obtuse as an attempt to virtue signal.

LOL and people who are exaggerating the complexity are doing the same.

 

[waiter]

Consumers must accept this policy

The chain has endorsed this policy

There is no margin for error

Accept it.

 

[CetiAlphaFive]

LOL and people who are exaggerating the complexity are doing the same.

Lol, i do think an issue is very complex if it's caused problems for pharmacists across the country and literally invented a new legal term for the profession.

 

[CetiAlphaFive]

Consumers must accept this policy

The chain has endorsed this policy

There is no margin for error

Accept it.

Chill out Narutis

 

[owlegrad]

Lol, i do think an issue is very complex if it's caused problems for pharmacists across the country and literally invented a new legal term for the profession.

I mean rude customers cause problems for pharmacies across the country and create new terms all the time but they aren't particularly complex.

Point owlegrad.

<Obviously I am being facetious and dense here>

 

[CetiAlphaFive]

I mean rude customers cause problems for pharmacies across the country and create new terms all the time but they aren't particularly complex.

Point owlegrad.

<Obviously I am being facetious and dense here>

 

[pharm B]

I'm gonna send that to TSBP as soon as you post it

Man. So I went to look for the email. All the board rep says is “please see attached,” and he included the NABP and DEA statements. On the phone he said we were fine to “forward” the unfilled prescription (with ZERO emphasis on “forward,” he didn’t grant it any special meaning).

I believe the Oregon Board supports the transfer, but I’ll try to tie it down in black and white.

 

[DiscoverID]

In Nevada, we can't transfer anything that has not been filled at least once.

 

[BenJammin]

I'm still blown away at the stupidity of this entire conversation. Transfer vs forward. I mean the word "forward" isn't even in the DEA Pharmacist Manual in any context of transfers. It appears regarding the mailing of DEA Form 224a, mailing expired drugs to the DEA, and sending expired drugs to reverse distributors. Now some people are trying to convince us that the DEA created an entire new category of moving controlled substances around thanks to an email. This is just nuts.

In Nevada, we can't transfer anything that has not been filled at least once.

Our outpatient pharmacy found a loophole for states like Nevada and New York. All they do is sell the patient 1 days worth and then transfer it out. Texas passed a rule allowing med syncs to be billed properly so our patients only pay a partial copay (if a drug is $30 for 30 days then we can charge them $1 for 1 day then send it off). It's brilliant.

 

[Apotheker2015]

This kind of quibbling is exactly why pharmacists cannot make any significant impacts on the profession. What do you think the average physician or mid-level would think when reading this garbage topic? These stupid pharmacists are threatening to report each other because of poor word choice in a law that no one actually cares about while following company policy?

This is why it is 2017 and we are still forced to take call in prescriptions from office janitors because the doctor is "too busy" to sign a piece of paper or click a button on the computer.

Honestly, I am embarrassed to be in the same profession as some of you.

I’m not embarrassed to be in this profession. Though, I do agree with your first statement. This inability to agree on basic things. I can’t find this article I ran into a couple of days ago about nurses in Ohio almost getting prescribing & dispensing rights in clinics. Ultimately, the board did not allow it as it would deprive patients’ drug therapy from the oversight of a pharmacist and a final check on dosing, drug interaction, clinical appropriatenes.

While we bicker, nurses are coming up with ways to absorb our profession. PharmD/NP programs are about to pop up under the pretense to expand pharmacists’ scope of practice.

Every time the topic comes up, the old violin starts playing the “student loans/ no additional pay” song. It ends there. Time and time again, we fail to see that for nurses it’s a sweet deal. It’s definitely an expansion of their scope of practice and a bump in pay. Schools of pharmacy will love the plan because they’ll have more sheep to skin for years to come. Faculty will continue to enjoy their cushy jobs and salaries. What do they care what happens to us...

*steps off soap box*

 

[CetiAlphaFive]

I'm still blown away at the stupidity of this entire conversation. Transfer vs forward. I mean the word "forward" isn't even in the DEA Pharmacist Manual in any context of transfers. It appears regarding the mailing of DEA Form 224a, mailing expired drugs to the DEA, and sending expired drugs to reverse distributors. Now some people are trying to convince us that the DEA created an entire new category of moving controlled substances around thanks to an email. This is just nuts.



Our outpatient pharmacy found a loophole for states like Nevada and New York. All they do is sell the patient 1 days worth and then transfer it out. Texas passed a rule allowing med syncs to be billed properly so our patients only pay a partial copay (if a drug is $30 for 30 days then we can charge them $1 for 1 day then send it off). It's brilliant.

Loren Miller invented "forward" in the super vague guidance released last year

 

[Charcoales]

Has any rph or pharmacy even got in trouble for xfering a c3-5 that was stored, never transferred before, and never filled?? Is this crap even enforced or is it all just vague toothless threats?

 

[CetiAlphaFive]

Has any rph or pharmacy even got in trouble for xfering a c3-5 that was stored, never transferred before, and never filled?? Is this crap even enforced or is it all just vague toothless threats?

I really doubt it would.


This entire fiasco is a result of the mindless Corporate RPh that take SOP as gospel without worsening questioning anything

 

[Apotheker2015]

Has any rph or pharmacy even got in trouble for xfering a c3-5 that was stored, never transferred before, and never filled?? Is this crap even enforced or is it all just vague toothless threats?

I did a few transfers that had never been filled. It wasn’t a big deal. If you didn’t know, you didn’t know. At that point, other chains didn’t know either and hey, if a pharmacist who is familiar to you, asks you for a transfer, you’re getting a tacit confirmation that it is OK to do so.

No one was asked to print an audit of all
CIII - CV transfer which is easy to do. It’s not a huge deal and it’s easy to forget. It’s not the worst mistake you can make if everything else still checks out; in my opinion.