Lawfully Prescribing and Dispensing Controlled SubstancesYour patients have a legitimate need for acute and chronic pain relief. You have an ethical and professional obligation to alleviate needless suffering. As a prescriber or pharmacist, you know that pain itself can not only delay the healing process, but can lead to other damaging diseases and syndromes. The DEA and State Boards state publicly that they do not want to deter doctors and pharmacists from adequately treating pain, but the reality is, they certainly do. You have heard of, or know doctors and pharmacist that have been convicted criminally and/or had their licenses suspended or revoked for "overprescribing" or "over dispensing" controlled substances. I will consult with you to make concrete suggestion for your practice to reduce the hazard of your practice being falsely identified as a diverter of controlled substances. Today it is not enough that your motivation is pure and your patients are legitimate. Unpleasant FactsIf you are a health practitioner prescribing or dispensing controlled substances (CS II-IV), you are prone to be audited or investigated by the State Board or the DEA. Often the initial reason for investigation is a report from a wholesaler or MAPS suggesting you are overprescribing controlled substances, purchasing excessive quantities of controlled substances or abusable drugs. This is especially likely if you practice in pain management or your pharmacy dispenses prescriptions from such prescribers. You may be accused of prescribing or dispensing drugs/medications without legitimate medical need. Paradoxically, pharmacists have a much harder time balancing the need to provide needed controlled substances to legitimate patients while concurrently detecting fake, forged or altered prescriptions and determining whether the prescriber is compliant with 21CFR1306.04(a). The pharmacist, often without access to medical records, asked to make critical determinations of whether a prescription is outside the usual course of professional practice. So how does the pharmacist objectively prove compliance? Sometimes it is good not to be NoticedHow do you comply with these immense responsibilities? Well, if you read this far, you know that you will not receive meaningful guidance from government agencies. I can help you because I have successfully helped many before you. |
