What to Do When Your Wholesaler Won’t Ship You Controls, And How to Prevent It
We are receiving a panicked calls from pharmacies whose wholesalers will not send them controls. The pharmacies are adamant that they are operating as usual or the problem that triggered the issue is not their fault.
First, some background.
Wholesalers used to ship pharmacies controls with few questions asked. Then the opioid epidemic came and the press and public started putting pressure on politicians and prosecutors. This resulted is mega fines against wholesalers. The big three AmerisourceBergen, Cardinal Health and McKesson — paid $21 billion.
As I am writing this article, Morris Dickson is at risk of losing it’s DEA registration for the same reasons.
Suffice to say, the wholesalers are taking a “guilty until proven inncent approach” when cutting off pharmacies. Here is how to prevent issues:
- Wholesalers use a ratio of control v. not-controlled in determining if your store is a problem, so if a patient needs controls, you should require them to get all of their other non-controls from you. This is the optimal
- Make sure you have a relationship with these patients. Make sure you are 100% comfortable giving them controls. Pharmacies only make a few dollars dispensing these scripts. It’s not worth the risk. Just tell the patient “sorry, we are not able to fill this because we have already reached our quota for the month.” When in doubt, kick the patient out.
- Do not dispense any control to any patient that has any red flags. The DEA lists the following indicators of improper prescribing in the “⦁ Pharmacist’s Guide to Prescription Fraud”:
- The prescriber writes significantly more prescriptions (or larger quantities) compared to other practitioners in the area
- The patient is returning too frequently for refills.
- The prescriber writes prescriptions for antagonistic drugs, such as depressants and stimulants, at the same time. Drug abusers often request prescriptions for “uppers and downers.”
- The patient presents prescriptions written for other people.
- Multiple patients appear simultaneously, or within a short time, all presenting similar prescriptions from the same physician.
- People who are not regular patrons or residents of the community present prescriptions from the same physician.
- Make sure your biennial count is completed and documented.
- Make sure your staff – and relief staff — know about all of the above.
- Talk to prescribers and patients about non-controlled therapeutic alternatives.
- Talk to patients about giving them these drugs for a limited time and then weaning them off of it.
- My best advice: Get a reputation in the community as a pharmacy that doesn’t give out controls easily. The abusers of these products talk to each other and you want them telling each other to avoid your store.
If your wholesaler has cut you off, get on the phone with their compliance department and figure out what control caused the problem. Don’t waste time with your rep – they cannot help you. They are just an intermediary that will slow things down. Talk to the decision maker in compliance. If the compliance department says it’s one class or NDC, ask them to just reduce or cut you off of that one class of drugs until things are resolved so you can keep filling the rest.
Ask the wholesaler for a specific ratio and keep to it during an agreed probationary period. Wholesaler want to see you working with them to resolve any concerns they have. Don’t waste your time threatening that you will go to another wholesaler. They don’t care – the amount they make from your store is a pittance compared to what they stand to lose if the DEA cuts them off.
If you were cut off because someone in your store was in the news for anything related to controlled substances, such as a pharmacist or staff member being arrested for stealing controls, you must immediately terminate this staff member, take their keys, cut off their ordering access, and cooperate with authorities. A wholesaler will likely not consider dealing with you until you do this, so do it immediately.
Next, be prepared to explain why your ratio is higher. Do you serve hospice? Is there a surgical center nearby and you are filling for a bunch of patients that have short-term post-surgical pain? Is there a psychiatrist nearby with a large ADHD population?
Next, get on the phone with some secondaries or another new wholesaler and get the account set up ASAP. It can take longer than anyone would like to resolve these issues with a wholesaler, so getting a backup in place is a good idea.
Last, communicate with patients open and honestly. Just say you are having temporary issues getting certain products. Most patients will understand if you are honest.