Drug Enforcement Administration Diversion Investigators Angela Lee - - PDF document

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Drug Enforcement Administration Diversion Investigators Angela Lee - - PDF document

Oct 10, 2022 405 likes •518 views

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

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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

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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)

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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

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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

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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

  • 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

Code of Federal Regulations 21 § 1306.04(b)

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

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Prescription Monitoring Prescription Monitoring Program Program

  • Obtain access through Louisiana Board

Obtain access through Louisiana Board

  • f Pharmacy
  • f 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 psuedoephedrine must self must self‐ ‐certify with DEA certify with DEA ( (www.deadiversion.usdoj.gov www.deadiversion.usdoj.gov) )

Combat Methamphetamine Epidemic Act 2005

  • Ephedrine &

Ephedrine & pseudoephedrine pseudoephedrine are are 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 & to purchase ephedrine & pseudoephedrine pseudoephedrine products products

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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

  • r in a locked cabinet
  • r 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

Cannot sell more than 9 grams in a 30‐ ‐day day 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

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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

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Internet Pharmacy

  • Web servers target independently

Web servers target independently

  • wned pharmacies
  • wned 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)

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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 504 504‐ ‐840 840‐ ‐1100 1100 www.deadiversion.usdoj.gov www.deadiversion.usdoj.gov