Tag Archives: Colorado State Board of Pharmacy

Colorado Pharmacists Prescribing Contraceptives Under a New Statewide Protocol

by admin on March 17th, 2017 at 7:21 am

Under a new statewide protocol based on Senate Bill 16-135, only Colorado-licensed pharmacists that have completed an Accreditation Council for Pharmacy Education (ACPE) accredited educational training program related to the prescribing of contraceptives by a pharmacist, may dispense hormonal contraceptive patches and oral hormone contraceptives to patients who are at least 18 years of age.

Additionally, for new patients requesting contraceptive services, a participating pharmacist must:

  • Obtain a completed Colorado Self-Screening Risk Assessment Questionnaire;
  • Utilize and follow the Colorado Standard Procedures Algorithm to perform the patient assessment;
  • Prescribe, if clinically appropriate, the hormonal contraceptive patch or self-administered oral hormonal contraceptive, or refer to a healthcare practitioner;
  • Provide the patient with a Visit Summary;
  • Advise the patient to consult with a primary care practitioner or women’s health care practitioner;
  • Refer any patient that may be subject to abuse to an appropriate social services agency; and
  • Ensure that the pharmacy provides appropriate space to prevent the spread of infection and ensure confidentiality.

Colorado Board of Pharmacy Approved Protocols include:

Hormonal Contraception Protocol A (includes Standard Procedures Algorithm and the Self-Screening Risk Assessment Questionnaire)

Smoking Cessation: currently being addressed the Colorado Board of Pharmacy (watch for updates)

 

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Colorado Board of Pharmacy Considering Rule Amendments to Address Medical Board Telehealth Guidelines

by admin on December 9th, 2015 at 7:15 am

As previously discussed on the Baer Law Blog in August, the Colorado Medical Board (Medical Board) adopted Guidelines for the Appropriate Use of Telehealth Technologies in the Practice of Medicine (Guidelines).

The Medical Board defined telehealth as:

“‘a mode of delivery of health care services through telecommunications systems, including information, electronic, and communication technologies, to facilitate the assessment, diagnosis, consultation, treatment, education, care management, or self-management of a person’s health care while the person is located at an originating site and the provider is located at a distant site. The term includes synchronous and store-and-forward transfers.’

The Colorado Board of Pharmacy (Pharmacy Board) is considering amending some of its rules to improve the administration and enforcement of the Pharmacists, Pharmacy Business and Pharmaceuticals Act.

Presently, the Pharmacy Board Rule 3.00.21 states, in part the following:

  • A pharmacist shall make every reasonable effort to ensure that any order, regardless of the means of transmission, has been issued for a legitimate medical purpose by an authorized practitioner.
  • A pharmacist shall not dispense a prescription drug if the pharmacist knows or should have known that the order for such drug was issued on the basis of an internet-based questionnaire, an internet-based consultation, or a telephonic consultation, all without a valid preexisting patient-practitioner relationship.

The proposed 3.00.21 rule is as follows:

  • A pharmacist shall make every reasonable effort to ensure that any order, regardless of the means of transmission, has been issued for a legitimate medical purpose by an authorized practitioner.
  • A pharmacist shall not dispense a prescription drug if the pharmacist knows or should know that the order for such a drug was issued without a valid preexisting patient-practitioner relationship. Such relationship need not involve an in-person encounter between the patient and practitioner if otherwise permissible under Colorado law. 
The above changes are only proposed draft rules. After soliciting views from interested stakeholders, the Pharmacy Board will likely commence the formal rule making process to ensure Rule 3.00.21 is consistent with the telehealth provisions of HB 15-1029.
Baer Law will keep you updated on the final rule. 
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New Telehealth Guidelines Approved by the Colorado Medical Board: Should Colorado Pharmacists Be Concerned?

by admin on August 26th, 2015 at 7:13 am


The Colorado Medical Board (Board) has adopted Guidelines for the Appropriate Use of Telehealth Technologies in the Practice of Medicine (Guidelines) as the state seeks to enact a new law expanding telehealth services.

The Board defines “telehealth” as:

‘a mode of delivery of health care services through telecommunications systems, including information, electronic, and communication technologies, to facilitate the assessment, diagnosis, consultation, treatment, education, care management, or self-management of a person’s health care while the person is located at an originating site and the provider is located at a distant site. The term includes synchronous and store-and-forward transfers.’

Interestingly, the Guidelines include the following, which, presently are directly at odds with the Colorado Board of Pharmacy Rules as discussed previously on the Baer Law Blog:

1. Establishment of a Patient-Physician Relationship.

  • Where an existing patient-provider relationship is not present, a provider must take appropriate steps to establish a patient-provider relationship consistent with the guidelines identified in Board Policy 40-03. Patient-provider relationships may be established using telehealth technologies so long as the relationship is established in conformance with generally accepted standards of practice.

2. Prescribing

  • Prescribing medications, in-person or via telehealth technologies, is at the professional discretion of the provider. The indication, appropriateness, and safety considerations for teach telehealth visit prescription must be evaluated by the provider in accordance with current standards of practice and consequently carry the same professional accountability as prescriptions delivered during an encounter in person. However, where such measures are upheld, and the appropriate clinical consideration is carried out and documented, providers may exercise their judgment and prescribe medications as part of telehealth encounters.
  • The recommendation of medical marijuana via telehealth is prohibited.

The Colorado Board of Pharmacy rules that state, in part, the following:

3.00.21. 

  • A pharmacist shall make every reasonable effort to ensure that any order, regardless of the means of transmission, has been issued for a legitimate medical purpose by an authorized practitioner.
  • A pharmacist shall not dispense a prescription drug if the pharmacist knows or should have known that the order for such drug was issued on the basis of an internet-based questionnaire, an internet-based consultation, or a telephonic consultation, all without a valid preexisting patient-practitioner relationship.

Colorado pharmacists should continue to use extreme caution when they identify prescriptions issued to patients based on telehealth consultations until Colorado Board addresses issues such as:

Can a valid, preexisting patient-practioner relationship be established using telehealth technologies without first having to meet in-person such that a pharmacist can legally fill the prescription if issued for a legitimate medical purpose?’

In conclusion, pharmacists should consider contacting the Colorado Medical Board or the Board of Pharmacy directly to determine if (1) a patient-practitioner relationship was established under the new policy and (2) obtain guidance on whether that relationship was sufficient enough to satisfy the “preexisting” relationship requirement under current Colorado pharmacy rules.

 


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Colorado Pharmacy Law: Telehealth and Identifying Valid Preexisting Patient-Practitioner Relationships

by admin on July 31st, 2015 at 11:49 am

The Colorado Medical Board recently published a new draft policy, No. 40-27, on “Guidelines for Appropriate Use of Telehealth Technologies in the Practice of Medicine.” The projected effective date is August 20, 2015.

The new guidelines, however, appear to be at odds with the existing Colorado Board of Pharmacy rules that state, in part, the following:

3.00.21. A pharmacist shall make every reasonable effort to ensure that any order, regardless of the means of transmission, has been issued for a legitimate medical purpose by an authorized practitioner. A pharmacist shall not dispense a prescription drug if the pharmacist knows or should have known that the order for such drug was issued on the basis of an internet-based questionnaire, an internet-based consultation, or a telephonic consultation, all without a valid preexisting patient-practitioner relationship. 

Based on Colorado pharmacy case law, pharmacists that violated the Rule 3.00.21 have been disciplined by the Colorado Board of Pharmacy. In many cases, the pharmacists were issued letters of admonition, which is public reprimand issued to a pharmacist.

Ultimately, Colorado pharmacists should continue to use extreme caution when they identify prescriptions issued to patients based on telehealth consultations. Right now, the best course of action may be to contact the Colorado Medical Board directly to determine if (1) a patient-practitioner relationship was established under the new policy and (2) obtain guidance on whether that relationship was sufficient enough to satisfy the “preexisting” relationship requirement under current Colorado pharmacy rules that would then allow the pharmacist to lawfully dispense the prescription medication.

Follow the Baer Law Blog, for updates on both the Colorado Medical Board guidelines and any Colorado Board of Pharmacy rule updates.

 

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Colorado Pharmacy Reaches HIPAA Settlement

by admin on May 7th, 2015 at 10:49 am

 

Last month, the U.S. Department of Health and Human Service’s Office for Civil Rights (OCR) announced that Cornell Prescription Pharmacy (Cornell Pharmacy)  in Denver, Colorado agreed to settle potential violations of the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

As part of the settlement, Cornell Pharmacy has agreed to pay a $125,000 penalty and enter into a two year Corrective Action Plan (CAP) to improve its HIPAA compliance program.

OCR was first made aware of Cornell Pharmacy’s HIPAA violations in January 2012 after a local Denver news outlet reported that Cornell Pharmacy appeared to have disposed of unsecured documents containing protected patient information into a public dumpster. After investigating, OCR confirmed that the documents contained the private health information of over 1,600 patients.

During its investigation, OCR also found that Cornell Pharmacy had not implemented written policies and procedures or provided adequate HIPAA training to its workforce as required by HIPAA . Cornell Pharmacy, pursuant to its CAP, will develop and adopt written HIPAA policies and procedures that must be reviewed and approved by OCR.

 

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Analyzing Colorado 2014 Prescription Drug Outlet Disciplinary Actions: Repeated Deficiencies

by admin on March 21st, 2015 at 10:58 am

Baer Law recently completed an analysis of thirty-two (32) separate disciplinary actions against Colorado Prescription Drug Outlets (PDOs) by the Colorado State Board of Pharmacy (Board).

The Board registers and licenses pharmacy businesses, both in-state and out-of-state, including:

  • Prescription Drug Outlets;
  • Wholesale distributors of prescription drugs;
  • Manufacturers of prescription drugs;
  • Other outlets; and
  • Limited licenses.

The Board has jurisdictions over PDOs, or in-state pharmacies, pursuant to provisions of the Pharmacists, Pharmacy Businesses, and Pharmaceuticals Act at Title 12, Article 42.5, C.R.S (Article 42.5) and Board of Pharmacy Rules and Regulations (3 CCR 719-1).

PDOs failure to timely address repeated deficiencies and not promptly reporting changes in the status of a pharmacist-in-charge are of particular interest, not only because over fifty percent of the disciplinary cases analyzed involved one or both of these issues and resulted in fines ranging from $1000 to $10,000, but that, in most instances, the fines could have been avoided had the PDOs promptly addressed the prior documented deficiencies.

Issues addressing changes in the status of a pharmacist-in-charge will be discussed in the next Baer Law blog.

Baer Law identified three recent cases that resulted in probation and large fines simply because repeated deficiencies were never addressed or corrected. Again, it is important to note that had these deficiencies been promptly addressed each PDO could have avoided fines, probation and the burden of continued monitoring.

In the first case, during a routine inspection, the Board discovered six repeated deficiencies from previous Board inspections, including:

  1. Vaccine administration records not in compliance;
  2. Casual sales records that were not in compliance;
  3. Labeling on non-sterile compounded products made in anticipation of orders not in compliance with Board Rules;
  4. Return of stock records not in compliance;
  5. A compounded product was assigned a beyond use date that exceeded the expiration date of the individual component; and
  6. Compounding records did not accurately reflect the date a compounded product was prepared.

Additionally, the Board found five dispensing errors and discrepancies between what the prescriber’s directions for use were and what was placed on the patient’s prescription label. Ultimately, the Board placed the Pharmacy on five years probation with numerous strict stipulations on monitoring.

In the second case, the Board identified seven repeated deficiencies from previous inspections which included:

  1. Invoices not in compliance with Board rules;
  2. Notice of initial interpretation and final evaluation posting not in compliance with Board rules;
  3. Prescription files were not maintained in three (3) different prescription files: Schedule II, Schedule III-V, and non-controlled substance prescription orders;
  4. Beyond use dating for non-sterile compounded products were not in compliance with Board rules;
  5. The labeling non-sterile compounded products did not comply with Board rules; 
  6. The labeling of anabolic steroid prescriptions were not in compliance with Article 42.5 rules; and
  7. Four prescriptions orders were filled without valid DEA numbers on the orders.
As a result of these repeated deficiencies, the Pharmacy was fined $5000 and placed on probation with stipulations.

In the final case, a pharmacy was fined for nine repeated deficiencies including:

  1. Pharmacist manager immunization training documentation that could not be located;
  2. Prepack records for cassettes that did not include the name or initials of the pharmacist responsible for packaging;
  3. Vaccine records that did not include, among other things, the site of administration;
  4. Invoices for prescription drugs that were not dated upon receipt;
  5. Compounding records for non-sterile compounded products that did not contain appropriate beyond-use dating;
  6. A compounding record for a non-sterile aliquot preparation that did not include the date of preparation; 
  7. The policy and procedure manual for central processing could not be located;
  8. Electronic storage of controlled substance prescriptions is not allowed; and
  9. Transferred prescription orders did not include, among other things, the phone number of the transferring outlet, first fill date and last fill date.

For these repeated violations, the Board fined the Pharmacy $3000 and placed the Pharmacy on probation.

Colorado PDOs must take notice when the Board identifies a deficiency. PDOs must make a conscious effort to promptly address all documented Board deficiencies to avoid any future fines or disciplinary actions. Failure to do so, as documented in these three cases, could result in probation, significant fines and continued close monitoring by the Board.

In conclusion, by ignoring the Board’s recommendations, each PDO is placing the health, safety and welfare of the citizens of Colorado at risk, which is clearly unacceptable.

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Analyzing Colorado Pharmacist 2014 Disciplinary Actions: Controlled Substances, Red Flags and Pharmacist Corresponding Responsibility

by admin on March 12th, 2015 at 12:29 pm

Baer Law recently completed an analysis of thirty-three (33) separate 2014 disciplinary cases against Colorado pharmacists by the Colorado State Board of Pharmacy (Board).

Certain cases, especially those involving controlled substance dispensing errors and pharmacists dispensing controlled substances when no valid patient-prescriber relationship existed, should be of particular interest to all licensed Colorado pharmacists.

Out of the thirty-three cases analyzed, twenty-four (24) letters of admonition were issued to pharmacists. A letter of admonition is a public reprimand issued to a pharmacist in the form of an actual letter or as part of a stipulation, which is an agreement between the Board and the pharmacist prior to a formal hearing. With a stipulation, both parties agree to facts, sanctions and the terms and conditions for continued practice, if applicable. Though a stipulation resolves the case both a letter of admonition and stipulation are public records.

Of the twenty-four letters of admonition issued to pharmacists in 2014, Baer Law identified eleven cases involving controlled substances.

In some instances, the pharmacist dispensed the wrong controlled substance medication as cited by the Board. In these cases, the pharmacist:

  • “Performed the initial interpretation on an order for Fentanyl 25 mcg transdermal patches but dispensed fentanyl 75 mug patches;”
  • “Performed the initial interpretation and final evaluation on an order for Fiorinal/Codeine #3 which was dispensed as butalbital/acetaminophen/caffiene/codeine;”
  • “Performed the initial interpretation on a prescription of Butalbital/ASA/Caf when the order was written for Butalbital/ASA/Caf/Codeine;”
  • “Performed the initial interpretation on an order for MS Contin 30mg, but dispensed morphine sulfate ER 100mg tablets;”
  • “Admittedly dispensed a prescription with 20 tablets of methadone 5mg on an order for 720 methadone 10mg tablets;”
  • “Performed the initial interpretation on an order for Oxycontin 15mg tablets which was dispensed with oxycodone 15mg immediate release tablets.”

In another case, the pharmacist was cited for filling “a prescription for Adderall 20mg tablets, a schedule II controlled substance, before the filling date authorized by the prescriber.”

In the last four cases, pharmacists were cited for dispensing controlled substances when no valid patient-prescriber relationship existed or when a pharmacist dispensed controlled substances after an out-of-state prescriber had lost his license to prescribe controlled substances.

In the first case, multiple pharmacists, and their pharmacy, were disciplined for performing the initial interpretation on controlled substance orders for oxycodone, Soma, and Xanax after it was later determined during a routine Board inspection that:

  • No valid preexisting patient-prescriber relationship existed between an out-of-state prescriber and a patient residing in Colorado and
  • At the time these orders were dispensed, the out-of-state prescriber was prohibited from prescribing any Schedule II-IV controlled substances.

In another case that was previously cited on the Baer Law Blog, Pharmacists Must Ensure Prescription Orders are Issued for a Legitimate Medical Purpose by an Authorized Prescriber and Have a Recognized Medical Utility or Application, a pharmacy manager was disciplined after her pharmacy filled orders for controlled substances for patients of a California based prescribing practitioner who the pharmacist mistakenly believed, after investigation, had a valid, pre-existing patient-practitioner relationship with the patients.

The final four cases should be a learning experience for all pharmacists as the disciplinary actions may have been avoided had the pharmacists involved exercised corresponding responsibility and proactively identified certain “red flags” that could have assisted them in identifying prescriptions that are not legitimate.

As previously discussed on the Baer Law Blog, Corresponding Responsibility: A Pharmacist’s Obligation to Understand, pharmacists must exercise sound professional judgment with determining the legitimacy of a controlled substance prescription. When a pharmacist is presented with a doubtful, questionable or suspicious prescription, the law does not require a pharmacist to dispense the prescription. On the contrary, a pharmacist who deliberately ignores a questionable prescription when there is reason to believe the prescription was not issued for a legitimate medical purpose may be prosecuted along with the prescribing physician for knowing and intentionally distributing controlled substances.

All pharmacists should be able to identify certain “red flags” that could assist in identifying prescriptions that are not legitimate.

Common red flags include but are not limited to:

  • Pattern prescribing (i.e. prescriptions for the same drugs and the same quantities from the same doctors);
  • Irregularities on the face of the prescription itself;
  • Nervous patient demeanor;
  • Multiple or duplicative therapies (i.e. Oxycontin and MS Contin);
  • Prescribing of combinations or “cocktails” of frequent abused controlled substances;
  • Geographic anomalies;
  • Shared Addresses;
  • Filling a larger percentage of cash prescriptions;
  • Customers with the same diagnosis code from the same doctor;
  • Prescriptions written that are not consistent with their area of specialty;
  • Prescriptions for medications with no logical connection to diagnosis or treatment;
  • Consistent requests for early refills; and
  • (Re)filling prescriptions of patients or doctors located hundreds of miles away

While there are no clear and concise answers or guidelines, a pharmacist should always exercise his or her independent judgment when determining whether a prescription was issued for a legitimate medical purpose by a prescriber in their normal course of professional practice. Failure to do so could result in disciplinary action by the Board.
Please contact Baer Law with any questions.

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Colorado Pharmacy Legislation Update: Modifying the PDMP

by admin on February 24th, 2015 at 6:42 am

HB14-1283: Modify Prescription Drug Monitoring Program

HB14-1283 modifies the electronic prescription drug monitoring as follows:

  • The dissemination of automatic reports to prescribers and pharmacies when a patient meets a defined threshold that takes into account the number of prescribers and pharmacies visited within a certain timeframe. Reports started in September 2014.
  • Allows a prescribing practitioner or a pharmacist to delegate authority to access the database to up to 3 designees acting for the practitioner or pharmacist, and requires each designee to register with the program under a sub-account of the practitioner or pharmacist. Delegated Access started in January 2015.
  • Requires prescribing practitioners and pharmacists to register and create user accounts with the program by a deadline established by the Director of the Division of Professions and Occupations.
  • Allows the Colorado Department of Public Health and Environment (CDPHE) to access data from the PDMP for public health research. CDPHE access began in the late 2014.
  • Allows an out-of-state pharmacist to obtain Colorado PDMP data in connection with a current patient to whom the pharmacist is dispensing a controlled substance or is providing clinical patient care services. This ability to obtain such data is already available.
  • Adds individual pharmacies as an eligible subject for information requests by law enforcement officials if the request for information is accompanied by a court order or subpoena beginning immediately.
  • Allows federally owned and operated pharmacies to submit data to the database beginning immediately.
  • Authorizes the executive director of the department of regulatory agencies to create a prescription drug monitoring program task force, or to request assistance from the team assembled by the governor’s office to develop a plan to reduce prescription drug abuse, to study the program and make recommendations to the executive director on ways to ensure that the program is effective at reducing prescription drug abuse and misuse. The Executive Director has requested the Governor’s Consortium for Prescription Drug Abuse serve as the task force.

 

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Pharmacists Must Ensure Prescription Orders are Issued for a Legitimate Medical Purpose by an Authorized Prescriber and Have a Recognized Medical Utility or Application

by admin on October 6th, 2014 at 11:41 am

 

As discussed previously on the Baer Law Blog, corresponding responsibility remains one of the most misunderstood or unknown concepts found in the Drug Enforcement Administration’s (DEA) regulations. The DEA’s regulations (21 CFR 1306.04) regarding corresponding responsibility state:

A prescription for a controlled substance to be effective must be issued for a legitimate medical purpose by an individual practitioner acting in the usual course of his professional practice. The responsibility for the proper prescribing and dispensing of controlled substances is upon the prescribing practitioner, but a corresponding responsibility rests with the pharmacist who fills the prescription. An order purporting to be a prescription issued not in the usual course of professional treatment or in legitimate and authorized research is not a prescription within the meaning and intent of section 309 of the Act (21 U.S.C. 829) and the person knowingly filling such a purported prescription, as well as the person issuing it, shall be subject to the penalties provided for violations of the provisions of law relating to controlled substances.

Many states, including Colorado, have incorporated similar language into their own Board of Pharmacy Rules and Regulations. The Colorado State Board of Pharmacy (Board), for example, uses the following language addressing both medical need and corresponding responsibility issues:

3.00.20  Medical Need. No license or registrant shall compound, dispense, deliver or distribute any drug to any person in such quantity or in any situation where the licensee or registrant knows or reasonably should know said drug has no recognized medical utility or application. Violation of this rule shall constitute prima facie proof of violation of CRS 12-42.5-123, or unprofessional conduct and ground for discipline.

3.00.21 A pharmacist shall make every reasonable effort to ensure that any order, regardless of the means of transmission, has been issued for a legitimate medical purpose by an authorized practitioner. A pharmacist shall not dispense a prescription drug if the pharmacist knows or should have known that the order for such drug was issued on the basis of an internet-based questionnaire, an internet-based consultation, or a telephonic consultation, all without a valid preexisting patient-practitioner relationship.

In a recent Colorado case, both issues were addressed. Pharmacists did not make reasonable efforts to ensure prescriptions for Schedule III controlled substances or other compounds were issued for a legitimate medical purpose by an authorized prescriber and had a recognized medical utility.

The facts of the case are as follows:

During a routine inspection of a registered, in-state prescription drug outlet (Pharmacy) in mid-2014, the Board identified over 20 prescriptions that were dispensed pursuant to orders based on Skype internet-based consultations from a Naturopathic Doctor (ND) in California.

The identified prescriptions included the following:

  1. Human Chorionic Gonadotropin (HCG), a schedule III Controlled Substance in the State of Colorado;
  2. “B Lipo,” a vitamin B supplement compounded as a sterile product at the Pharmacy
  3. “Garcinia,” a plant that is presumed to control appetite and fat storage in the body when properly compounded and ingested.

In California, a ND can prescribe a legend and Schedule IV-V controlled substances under MD/DO supervision and prescribe Schedule III drugs under a patient-specific protocol checked by a supervising MD or DO.  In this case, pharmacists did not verify the ND was practicing under a supervising MD/DO or that a valid patient-practitioner relationship existed as the relationship appeared to be based only on an internet-consulatations. Due to the many Federal and State violations, the Pharmacy was cited by the Board and the has since voluntarily relinquished its license to practice pharmacy. Cases against the pharmacists involved are still pending and could be severe.

This case should remind all pharmacists to use due diligence when verifying all prescription orders, especially in light of the reclassification of hydrocodone containing products (HCPs) as Schedule II controlled substances.

Pharmacists are expected to exercise sound professional judgment when making a determination about the legitimacy of all prescriptions, not just controlled substance prescriptions. It is no longer sufficient for a pharmacist to accurately fill a prescription if the prescription is unreasonable on its face.  In fact, under the corresponding responsibility rule, a pharmacist who deliberately ignores a questionable prescription where there is reason to believe the prescription was not issued for a legitimate medical purpose may be prosecuted along with the issuing practitioner for knowingly and intentionally distributing controlled substances.

Ultimately, pharmacists should continue to monitor prescriptions for “red flags,” closely scrutinize all prescriptions, and ensure that valid MD/DO supervisory relationships exist when checking any controlled substances, especially Schedule II HCPs as there will likely be much confusion over the next few weeks as practitioners adjust to the new rule.

 

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Notice to All Licensed Colorado Pharmacists and Registered DEA Prescribing Practitioners

by admin on August 18th, 2014 at 10:56 am

All Colorado licensed pharmacists and registered DEA prescribing practitioners are required to register an individual user account with Colorado’s Prescription Drug Monitoring Program (PDMP) pursuant to CRS 12-42.5-403 of the Pharmacy, Pharmacy Businesses and Pharmaceuticals Practice Act.  The following due dates for each profession are:

  • Pharmacists and DEA-registered Advanced Practice Nurses:  September 30, 2014
  • DEA-registered Dentists, Veterinarians, Optometrists and Podiatrists:  October 31, 2014
  • DEA-registered Medical Board licensees:  November 30, 2014

For more information pharmacists and practitioners should use the following link to create a PDMP account prior to the above due dates:  http://www.hidinc.com/copdmp

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