The pharmacist plays a crucial role in preventing drug diversion and has to be on the watch out for doubtful, questionable or suspicious activities when dispensing controlled substances. Drug abuse and misuse is rampant in the United States, making it a thorn in the side of the government. Stringent regulatory requirements have been instituted by the Controlled Substances Act and the Drug Enforcement Administration (DEA) strictly administers the policies to identify illegal activities and ensnare the perpetrators. Constant monitoring and inspections are underway and the penalties for even the slightest mistake or violation can be hefty with far-reaching repercussions. The DEA controlled substance regulations govern every link of the supply chain from manufacturers and distributors to practitioners and pharmacies. In fact, the pharmacy forms the last link in the chain before the scheduled drugs reach the hands of the patient. Therefore, pharmacists are considered the last line of defense for preventing diversion! Accordingly, there is a corresponding responsibility on the pharmacist that fills the prescription for a controlled substance. Given all that is riding on the dispensing of scheduled drugs, the pharmacist is duty bound to:
Therefore, he or she should pay due attention to the following red flags and can even refuse to fill the prescription until the suspicion is cleared:
In such cases, the pharmacist should proactively practice due diligence by taking the following precautionary measures:
In case of concern, taking the appropriate action – like reporting to the DEA, law enforcement or other entity –is mandatory. So much so that, if it comes to light that a pharmacist ignored a dubious prescription that could have been for an illegitimate purpose, he/she can face prosecution for knowingly distributing controlled substances! Simple professional judgment will not suffice here. It is better to seek specialized assistance along with DEA compliance training for handling such extenuating situations. A compliance consultant can help in staying on the right side of the law in regular circumstances as well – be it for matters related to registration and renewal or maintaining proper documentation, reporting, security, monitoring and disposal. This will bring proficiency in handling the audits and inspections too.
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