MVMA has been hearing more lately about unexpected outcomes when dealing with pharmacies. While it is appropriate at times for veterinarians to write prescriptions the client then takes to a pharmacy, what do you do when pharmacy actions do not meet your expectations? MVMA is preparing frequently asked questions (FAQs) to address various scenarios. Here is an example:
I believe a Michigan pharmacy changed the medication dose for a prescription I wrote. What should I do?
The pharmacy should not change the dose of a medication on a prescription unless the pharmacist contacts you first to get your approval. In the event of a pharmacy error, your first responsibility is to your client to provide guidance on the correct dose to administer to your patient. This probably will involve contacting the pharmacy to request they correct their error and fill the prescription correctly. Subsequently, you have additional follow-up options ranging from education/outreach with the pharmacy to filing a complaint with the Michigan Department of Licensing and Regulatory Affairs (LARA).
The profession of pharmacy (pharmacies and pharmacists) is regulated by LARA. There is a pharmacy practice and drug control section in the Michigan Public Health Code as well as a set of rules by the Michigan Board of Pharmacy. The Board of Pharmacy General Rules are 33 pages long compared to 8 pages for the Board of Veterinary Medicine Rules (veterinary rules will be longer once the section on continuing education is added). These documents, though primarily focused on the profession of pharmacy, are worth a read since veterinarians are mentioned in a few places. Specifically, veterinarians are included in the definition of “prescriber” and there are responsibilities of “prescribers” stated in both documents.
The specific section in the Michigan Public Health Code that covers pharmacists dispensing prescription drugs is MCL 333.17751. This section says, in part:
333.17751 Dispensing prescription drug or device requiring prescription; requirements.
(6) After consultation with and agreement from the prescriber, a pharmacist may add or change a patient's address, a dosage form, a drug strength, a drug quantity, a direction for use, or an issue date with regard to a prescription. A pharmacist shall note the details of the consultation and agreement required under this subsection on the prescription and shall maintain that documentation with the prescription as required in section 17752. A pharmacist shall not change the patient's name, controlled substance prescribed unless authorized to dispense a lower cost generically equivalent drug product under section 17755, or the prescriber's signature with regard to a prescription.
To help assure that the prescriptions you write are appropriately filled at a pharmacy, consider taking the proactive actions below. The focus here is noncontrolled substances. As you know, there are special requirements for controlled substances.
· As suggested by one MVMA member, put your prescriptions in writing; do not rely on telephone communication.
· Review requirements for submitting prescriptions to pharmacies to help assure you are ameliorating the process of filling the prescription. For example, if you print out a prescription from your computer, be sure you manually sign the prescription rather than relying on an electronic signature. See MCL 333.17754.
· Be sure you understand the pharmacist’s ability to provide generic equivalents. If you do not want a generic equivalent provided, be sure your “dispense as written” provision is done correctly. See MCL 333.17755. This section is newly amended as of September 26, 2018.
· Review the detailed rules for information that needs to be part of the prescription. See R 338.479b Noncontrolled prescriptions.
· If you find that clients are using certain pharmacies, consider a meet and greet with pharmacy staff. Here is what AVMA has to say as part of their policy on Writing Veterinary Prescriptions:
The AVMA encourages prescribing veterinarians to exercise initiative and establish strong collegial relationships with pharmacists in their sphere of practice. Proactively establishing open lines of communication will establish the pharmacist as part of the veterinary health care team, promote education and foster consultations to address issues and questions that ultimately will arise.
Nancy Frank, DVM, MPH, DACVPM
Michigan Veterinary Medical Association
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