By now, you have heard the successes of physicians who are direct dispensing medications to their patients. Physicians across America are increasing revenue, patient satisfaction and positive health outcomes.
Direct dispensing, even when implemented on a small scale, has many advantages for both the patient and they physician. And because it takes very little money to start, physicians can recoup their investment in a year or less.
Furthermore, this ancillary service leads to other programs that can bring in higher revenue with not much more effort on the physician’s part.
So, how does a physician become eligible for direct dispensing? Below are guidelines to follow.
Each State has their own set of rules and guidelines that must be followed.
Currently there are just a handful of States that do not allow in-office dispensing of medications. These include Texas, Montana, Wyoming and Illinois.
Common regulations among States include the following:
- State issued controlled substance dispensing license is required for those of you who wish to dispense Drug Enforcement Administration (DEA) scheduled drugs.
- Nurse Practitioner or Physician Assistant credentials updated and legal if you plan to allow them to dispense medications.
- Your State issued dispensing license, if required, which it is in many States.
In addition to meeting these regulations, many States require you meet the Pharmacy Board regulations also.
State Pharmacy Board Regulations
Pharmacy regulations vary by State, but you can expect certain laws to be uniform. For instance, most states will require you follow the rules for professional conduct. This includes maintaining patient confidentiality and avoiding fraudulent activities.
Each State requires your prescription order contain specific documentation related to the medicine and the patient, especially if it is a controlled substance. Other information must include dates, doses, and refill availability.
You may not fill an order if it is older than one year.
You must keep good records of medications prescribed. These records need to be available for review by State agencies during inspections.
Furthermore, you must keep track of your inventory, use computerization of prescriptions, follow poison prevention packaging requirements, and maintain privacy and security to patients. You will need to follow safe disposal laws.
When working with a medication distributor, like when you purchase prepackaged medications, you will need to ensure that company meets all regulations as set forth by their State or Federal agencies.
All Drug Enforcement Administration rules apply when it comes to your DEA number and when prescribing controlled substances.
State License and DEA Number
Your DEA number allows you to write prescriptions that are considered controlled substances by the government. Controlled substances are ranked and put into five categories. A DEA number allows your prescriptions to be tracked and reported in case of negligent practices.
If you do not already have a DEA number, you can simply apply online using form 224. This is the application for controlled substances registration. You cannot dispense controlled substances without this approval.
You will be expected to give personal information as well as background history. If you do not supply this information, you will not be allowed to register.
Just as important are the rules and regulations your staff must follow. These policies and procedures should be clearly understandable to all staff. And they should have access to answers to any questions they may have as needed.
Policies and Processes for Staff
You need dedicated staff that place importance on patient care. They need to be committed to providing all documentation related to in-office dispensing. This may include anything from symptoms to compliance.
The processes used in your office by you and your staff need to be well documented. Everyone needs to know how to label, dispense, inventory, update charts, reporting and any other tasks that may be completed during the process of filling prescriptions.
This policies and procedures manual should be a go-to guide for everyone in the office who has a question about dispensing medications.
Your dispensing manual may be like a pharmacist’s manual. It will include important forms and instructions. For instance, the initial screening form that helps you determine eligibility for your program should be included.
The manual will also include important medication recalls, dispensing guidelines, reports on any emergency or negative events, and disposal guidelines. The manual should also include how and when staff have been trained on all things related to point of care prescription processes.
Trainings should be ongoing and required by all staff. These too should be documented and signed by those attending the trainings.
Ethical Dispensing Practices
In the end, you will need to prove you are following good dispensing practices to any Federal, State or local agency that may govern your practice.
The World Health Organization defines good dispensing practices as the way you provide medicine to your patients. Using good practices, you give the right patient the correct medication. The medication is labeled correctly, with all accurate data, including clear instructions for the patient to follow.
From the time you write a prescription until the time the medicine is given to the patient; all the actions in between can determine if your practices are good or bad.
There are a few things you can do to ensure this entire process is consistently successful. You can regularly take part in safety checks with your staff. Provide trainings that keep you and your staff updated on changes to laws and regulations.
Finally, monitoring and documenting all relative information can assist you in making improvements from year to year, or even month to month.
You can also employ the services of in-office dispensing companies who can assist you in maintaining compliance laws, up-to-date on inventories and re-orders, provide you with technology and computer assistance, and give you premium access to modern prepackaged medicines.
Using such a service makes becoming eligible for direct medication dispensing that much easier.
Most likely, you already meet many, if not all, of the above requirements needed for eligibility. Most physicians implement good practices. This means that with a little bit of work, direct dispensing could be added to the services you provide.