Drug Enforcement Administration Diversion Investigators Angela Lee Rita Esquivel DEA Pharmacy Registration Requirements � Valid Louisiana State Pharmacy Permit � Adherence to all State & Federal Laws � Adherence to Louisiana Board of Pharmacy Rules & Regulations � DEA registration renewable every three years Before Dispensing Controlled Substances Make sure… � The prescription is valid � The prescription was issued by a physician authorized to prescribe controlled substances Code of Federal Regulations 21 § 1306.03 and 1306.04 1
A Valid Prescription is… � Issued for a legitimate medical purpose � Issued by a practitioner acting in the usual course of professional practice � Issued after a valid doctor patient relationship has been established Code of Federal Regulations 21 § 1306.04(a) Who is Responsible to Ensure a Prescription is Valid? � Prescribing Physician � Pharmacist also maintains a CORRESPONDING RESPONSIBILITY CORRESPONDING RESPONSIBILITY Code of Federal Regulations 21 § 1306.04(a) Pharmacist’s Corresponding Responsibility � Ensure proper prescribing of controlled � Ensure proper prescribing of controlled substances substances � � Ensure proper dispensing on controlled Ensure proper dispensing on controlled substances substances Code of Federal Regulations 21 § 1306.04(a) 2
Pharmacist’s Corresponding Responsibility Note: An order claiming to be Note: An order claiming to be prescription, not issued in the usual prescription, not issued in the usual course of professional treatment, is course of professional treatment, is NOT considered a prescription NOT considered a prescription Code of Federal Regulations 21 § 1306.04(a) Issues to Consider Suspicious Doctor Patient Relationship � Physician issuing same controlled substances to all patients � Pre ‐ printed controlled substance prescriptions Issues to Consider Excessive number of prescriptions from a physician � A physician seeing 50+ patients a day � 8 hour day = less than 10 minutes per patient � All patients prescribed controlled substances 3
Issues to Consider � Excessive number of prescriptions from a patients � A patient bringing in prescriptions for the same controlled substances from various physicians Issues to Consider Out of State Physician � Why is the patient traveling out of state to fill prescriptions? � Why is patient traveling out of state to see a physician? � Be realistic Issues to Consider Patient traveling long distances � If a patient lives in Lafayette, why are they seeing a Houston physician and getting prescriptions filled in Baton Rouge? Patients traveling in groups � Patients arriving in large groups to fill prescriptions from same physician or clinic 4
Issues to Consider � A physician can not issue a prescription A physician can not issue a prescription � to obtain controlled substances for the to obtain controlled substances for the purpose of general dispensing to patients purpose of general dispensing to patients Code of Federal Regulations 21 § 1306.04(b) � Louisiana Board of Medical Examiners Louisiana Board of Medical Examiners � no longer allows physicians to dispense no longer allows physicians to dispense controlled substances controlled substances General Issues to Consider � Volume of Prescriptions Volume of Prescriptions � � Amount of each prescription Amount of each prescription � Range of prescriptions � Range of prescriptions � Payment method � � Payment method � % of controlled vs. % of non % of controlled vs. % of non ‐ ‐ controlled controlled � Theft or Loss of Theft or Loss of Controlled Substances Controlled Substances � Notify local DEA office and local police Notify local DEA office and local police � immediately immediately � Submit a DEA form 106 online via Submit a DEA form 106 online via � www.deadiversion.usdoj.gov www.deadiversion.usdoj.gov 5
Prescription Monitoring Prescription Monitoring Program Program � Obtain access through Louisiana Board Obtain access through Louisiana Board � of Pharmacy of Pharmacy Verify patients are not receiving similar � Verify patients are not receiving similar � prescriptions from multiple doctors prescriptions from multiple doctors � Verify patients are not receiving similar Verify patients are not receiving similar � prescription from multiple pharmacies prescription from multiple pharmacies Combat Methamphetamine Epidemic Act 2005 Initiated to prevent Methamphetamine � Initiated to prevent Methamphetamine � problem problem � All retail sellers of ephedrine & All retail sellers of ephedrine & � psuedoephedrine must self psuedoephedrine must self ‐ ‐ certify with DEA certify with DEA (www.deadiversion.usdoj.gov ( www.deadiversion.usdoj.gov) ) Combat Methamphetamine Epidemic Act 2005 Ephedrine & pseudoephedrine pseudoephedrine are are � Ephedrine & � legitimately used to make cough, cold, and legitimately used to make cough, cold, and allergy drug products allergy drug products � Ephedrine & Ephedrine & pseudoephedrine pseudoephedrine can be used can be used � to illegally make methamphetamine to illegally make methamphetamine � Be aware of individuals using multiple IDs Be aware of individuals using multiple IDs � to purchase ephedrine & pseudoephedrine to purchase ephedrine & pseudoephedrine products products 6
Combat Methamphetamine Epidemic Act 2005 � All Ephedrine & All Ephedrine & pseudoephedrine pseudoephedrine retail retail � sales must be maintained in a written or sales must be maintained in a written or electronic logbook electronic logbook � Retail seller must write/enter the name & Retail seller must write/enter the name & � amount of the product purchased amount of the product purchased � Customer must write/enter their name, Customer must write/enter their name, � address, date & time of the sale, and sign address, date & time of the sale, and sign Combat Methamphetamine Epidemic Act 2005 Retail seller must check customer’s photo � Retail seller must check customer’s photo � ID to verify information in logbook ID to verify information in logbook � Products must be stored behind the counter Products must be stored behind the counter � or in a locked cabinet – or in a locked cabinet – NOT on the counter NOT on the counter Combat Methamphetamine Epidemic Act 2005 � Cannot sell more than 3.6 grams per day to Cannot sell more than 3.6 grams per day to � each customer each customer Cannot sell more than 9 grams in a 30 ‐ ‐ day day � Cannot sell more than 9 grams in a 30 � period to each customer period to each customer Retail seller must have a system in place to � Retail seller must have a system in place to � ensure customers cannot purchase more than ensure customers cannot purchase more than these amounts these amounts 7
Internet Pharmacy Internet Pharmacy � Prescriptions issued solely from an Prescriptions issued solely from an � electronic questionnaire are not valid electronic questionnaire are not valid � A valid doctor patient relationship must A valid doctor patient relationship must � be established be established A Valid Doctor/Patient Relationship Consists of: � Patient has a medical compliant Patient has a medical compliant � � A medical history has been taken A medical history has been taken � � A physical examination has been preformed A physical examination has been preformed � � Some logical connection exists between the Some logical connection exists between the � medical complaint, medical history, physical medical complaint, medical history, physical examination, and medication prescribed examination, and medication prescribed 8
Internet Pharmacy � Web servers target independently Web servers target independently � owned pharmacies owned pharmacies � May send a fax or call the pharmacy May send a fax or call the pharmacy � � May offer nice compensation and a May offer nice compensation and a � computer computer Internet Pharmacy Bottom Line If it is too good to be true, If it is too good to be true, it probably is it probably is Internet Pharmacy Internet Pharmacy Complaints ‐ Complaints ‐ Controlled Substances Controlled Substances � File a report online at File a report online at � www.deadiversion.usdoj.gov www.deadiversion.usdoj.gov � Call 1 Call 1 ‐ ‐ 877 877 ‐ ‐ RX RX ‐ ‐ Abuse (1 Abuse (1 ‐ ‐ 877 877 ‐ ‐ 792 792 ‐ ‐ 2873) 2873) � 9
We need your help Pharmacists are on front line to prevent � Pharmacists are on front line to prevent � drug diversion drug diversion � If a prescription seems suspicious, take If a prescription seems suspicious, take � necessary steps to ensure the prescription is necessary steps to ensure the prescription is legitimate legitimate Contact local DEA office for assistance � Contact local DEA office for assistance � Drug Enforcement Administration Diversion Group New Orleans Division Office New Orleans Division Office 3838 North Causeway Blvd. #1800 3838 North Causeway Blvd. #1800 Metairie, Louisiana Metairie, Louisiana 504 ‐ ‐ 840 840 ‐ ‐ 1100 1100 504 www.deadiversion.usdoj.gov www.deadiversion.usdoj.gov 10
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