identity of controlled substance medications being dispensed under the prescription of a specific prescriber, and the volume and identity of controlled substance medications being dispensed to a specific patient. (5) Any pharmacist who has reason to believe that a prescriber of controlled substances is involved in the diversion of controlled substances shall report such prescriber to the Department of Health. (6) Any pharmacist that dispenses a controlled substance subject to the requirements of this rule when dispensed by mail shall be exempt from the requirements to obtain suitable identification. The above standards can be used as a guide when being presented with a prescription that a pharmacist suspects may not be issued for a legitimate medical purpose. If the pharmacist knows that a patient is admitted to a hospice, many of the above dispensing standards may act as a barrier to end-of-life care. Pharmacists should be empathet-
ic to the needs of the patient and also those who care for them. Be reminded that there is an exemption from reporting to the prescription drug monitoring program for practitioners who “administer” controlled substances to patients receiving care in a hospice. If you are dispensing controlled substances to patients in a hospice you will still have to report that data, however there is a special code for hospice patient prescriptions as described in the E-forcse dispenser implementation guide. Counterfeit Resistant Prescription Blanks Of course, not all laws have made it easy to assist hospice patients. Recent changes in Florida laws have created some new challenges from within the provider community. House Bill 7095, passed during the 2011 legislative session, included language that requires written prescriptions for controlled substances to be on Department of Health (DOH) approved prescrip-
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tion blanks. Inserted in Florida statutes 456.42 was the following: F. S. 456.42 (2) A written prescription for a controlled substance listed in chapter 893 must have the quantity of the drug prescribed in both textual and numerical formats, must be dated with the abbreviated month written out on the face of the prescription, and must be either written on a standardized counterfeit-proof prescription pad produced by a vendor approved by the department or electronically prescribed as that term is used in s. 408.0611. As a condition of being an approved vendor, a prescription pad vendor must submit a monthly report to the department which, at a minimum, documents the number of prescription pads sold and identifies the purchasers. The department may, by rule, require the reporting of additional information. Of interest to FPA members is the effect that this may have on hospice patients. Currently, hospice prescribers, like all others, must use these Department approved blanks. As mentioned
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NOVEMBER 2011
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