Over the past few years, more dental offices are being approached by vendors who are promoting in-house medication dispensing programs as a convenience to patients, as well as an opportunity for extra income for dentists.

Posted in Risk Management on Thursday, September 3, 2015

Over the past few years, more dental offices are being approached by vendors who are promoting in-house medication dispensing programs as a convenience to patients, as well as an opportunity for extra income for the dentist.

If you have been approached and are considering dispensing medication from your dental office, it is in your best interest to talk with your state dental board to determine its position on the topic. The next step is to talk with your state board of pharmacy to determine if it has any protocols with which you should be familiar in regards to your Drug Enforcement Administration (DEA) number. I bring this up, as a situation occurred where a doctor was accused of negligent dispensing by a pharmacy board and, as a result, it affected his DEA number.

Keep in mind that state and/or federal law may prohibit and/or impact your ability to provide this service. Although the vendor who is presenting the opportunity to you may advise their dispensing software is in compliance with all states and with federal regulation, it is your responsibility (as the doctor) to verify this with your local and state authorities.

From a risk standpoint, if you get approval from your state dental board, are in compliance with your state pharmacy board, and choose to proceed with dispensing medications from your dental office, it is in your best interest to also do the following:

• Detail the education and training protocols of all employees who will dispense and maintain medications
• Confirm that all medications are properly labeled, including the dose, amount, instructions and medication name
• Create a written policy for responding to prescription refill requests
• Create and maintain a protocol for handling expired medications
• Document each patient record with the medication provided, lot number and amount dispensed
• Provide and document patient education; indicating that instructions for consumption, side effects and physical limitations were discussed with the patient. Confirm and document the patient’s understanding of those instructions.