Originally published in the May/June 2017 issue of the OVMA Observer.
It unfortunately has become all too clear that our country and Ohio in particular have an opioid problem. All healthcare prescribers, of course, have a responsibility to balance the needs of serving their patients with a recognition and awareness that at times opioids are being misused.
OVMA has created an Opioid Diversion Awareness Task Force chaired by Dr. Alice Jeromin. The Task Force seeks to explore proactive ways we can provide our members with the educational resources to combat potential client misuse of their animals’ medications, as well as heighten awareness of the potential for internal diversion.
Look for important work coming out of this Task Force in future issues of The Observer and other OVMA communications. In the interim, here are a few reminders of Ohio Board of Pharmacy regulations that are relevant to this issue.
Ohio’s Automated Rx Reporting Service (OARRS) is a state database designed to prevent “doctor shopping” of prescription medications. All pharmacies and human healthcare prescribers are required to be part of OARRS. It is not mandatory that veterinarians be part of this system for a number of reasons, including in large part the manner in which the system operates with human patient parameters. That said, a veterinarian can voluntarily participate in OARRS. It can also be helpful to point out that if you suspect a client may be attempting to divert an animal’s pain medication, you could elect to write a prescription instead of dispensing. Then when the pharmacist fills the prescription, it will be entered into OARRS, and if there is a prior or emerging history of concern, it can be identified at that point.
Security of Controlled Substances
Both federal and state regulations require controlled substances to be secured at all times and to be under the control and oversight of a prescriber during office hours. Technicians can handle and prepare controlled substances to be dispensed and/or administered per the direction of a veterinarian, but a DVM must be on the premises and take responsibility whenever a controlled substance is removed from its secured location. Ohio Administrative Code 4729-5-17 also requires a prescriber to check a prescription drug order prior to dispensing and acknowledge the same in a written record.
Keys to a controlled drug safe/cabinet should also be controlled by prescribers to preclude easy access by unauthorized persons. Remember that the veterinarian is the one who is ultimately responsible for the security of the controlled substances on the premises.
In-Office Drug Theft
Ohio Administrative Code 4729-9-15 stipulates that a prescriber must do three things upon the discovery of a theft or significant loss of any prescription drug, whether the theft was internal or external in nature.
First, they must immediately contact the Ohio Board of Pharmacy by phone (614.466.4143). If it is after hours or on a weekend, leave a message and follow up during normal business hours.
Second, if the prescription drug is also a controlled substance, contact the DEA Field Office for your area (for northern Ohio, the office is in Cleveland at 216.522.3705; for central and southern Ohio the regional office is in Columbus at 614.469.2595) and file DEA Form 106.
Third, contact local law enforcement authorities.