Keeping Dermatology Rx Samples Safe
Thursday, December 15, 2005
You may assume that your staff already knows better than to
abuse the privilege of having prescription samples so accessible,
but some employees think of the drug sample closet as free and
within reach as the office supply closet. Fortunately, a written
policy can help staff avoid this misconception altogether, as long
as it is obeyed.
Take Dermatology Associates of Virginia, for example. The
nine-physician practice, based in Richmond, Va., has an employment
manual that outlines its policy on maintaining the prescription
supply closet. The manual limits employee access to the drug closet
to its physicians.
"The staff knows they cannot go into a drug cabinet without the
express permission of a physician. And that's where the actual
pharmacy samples are," says clinical administrator Anne T.
Office policies are more likely to be ignored if there are not
consistently applied procedures to back them up. That's why every
dermatologist's office should have a plan for monitoring both drug
inventory and access to the prescription sample storage area, have
at least one person responsible for overseeing the area, and ensure
that everyone understands and follows the rules.
"I've seen a lot more [practices] that have sloppy systems than
have good systems. This is an area that's ripe for abuse and
misuse, and is not very well policed by practices or by a lot of
the regulatory agencies," says William Jessee, MD, FACMPE,
president and CEO of the Medical Group Management Association
Secure the Space
So what can your dermatology practice do to keep sample
prescriptions secure and up-to-date?
According to Jessee, "Step one is to take a look at your
physical environment. Think about how easy it is for someone to get
access to your samples - and that could be a patient, a patient's
child, or a staff member. You may want to ...centralize your
samples into a single location, put it under lock and key, and
establish a policy about who has access to it and for what
Then again, trying to keep samples locked up may not work for a
busy dermatology practice. Jessee emphasizes that whatever steps
you take should fit your dermatology practice's workflow. "As a
practical issue, you don't want to create a barrier to the
physicians' dispensing samples - and if you have to unlock the
cabinet every time, most people are going to leave it open."
One solution is to make sure that samples are stored in an area
that is not isolated from the hubbub of daily activity. Also, keep
the area locked whenever possible. At Dermatology Associates of
Virginia, says Wolff, the sample closet is locked each and every
How to Track
Monitoring what's in the sample closet is as important as
knowing who's going in. Assign a staff member to keep track of
inventory - perhaps the same person who orders other medical
supplies for your dermatology practice.
The person in charge of the sample closet should keep a log of
all inventory and check it "at least once a month," suggests
Jessee. "If you are tracking your inventory as [it] comes in, that
makes it very easy. When you add new inventory, you can record the
expiration dates and pull any of the remaining lot if that
expiration date comes around."
"In general, we check the closet and log once a month - and that
is in our protocol to do that once a month," says practice
administrator Kim Gooden of Dermatology Consultants PC in Atlanta,
Ga. "The pharmaceutical reps come through just once a week and
rearrange, throw out… so it's not that big of a chore for our
Wolff describes a similar tracking system. "We check [inventory]
weekly," she says. "The medical assistants periodically are going
in there every three to four weeks and checking expiration dates as
well. But we use these drugs so rapidly that they're not sitting on
the shelf very long."
According to Gooden, "most of the time in dermatology there are
not prescription medications that are narcotics that would have to
be under lock and key." Most are creams, lotions, shampoos, and
antibiotics - specifically those for patients suffering from eczema
and other similar skin irritations.
"We have [the sample closet] divided into two different things:
there's a sample closet that has sample medications or creams that
are prescriptions and some are nonprescriptions," says Gooden.
Some dermatology practices also look to outside help - in the
form of pharmaceutical company representatives - to help them
maintain the sample inventory and take some of the burden off of
the staff. Most dermatology practices are grateful for the help
because it allows them to better meet patients' needs - but
oversight of the reps' activities is often lacking.
"Drug reps are to log in when they come in and log in how many
of what items they have left," says Wolff. "We use the samples so
frequently that they run out very quickly. We have four locations,
so we actually do that to make sure they are servicing all of our
"We have a log in our closet where someone checks off once a
month and goes through all the prescriptions, and throws away
anything that's outdated and just cleans the sample closet," says
Jessee, however, cautions against relying solely on
pharmaceutical reps to maintain the sample closet. "If something is
misdispensed, whose responsibility is it? Not the drug reps'." He
agrees that providing samples is a good idea, but insists that
dermatology practices must maintain control and be accountable for
the sample closet.
The Patient-Centered Dermatology
"The whole point is to dispense enough for starter doses to make
sure patients start [on the regimen]. The other purpose is, if you
are concerned about a patient's ability to afford a medication,
[to] give that patient a full course of samples," says William
Jessee, MD, FACMPE, president and CEO of the Medical Group
Management Association (MGMA). "If those are your primary
objectives, you need to maintain control over that sample
Take control and ensure that your patients will receive the best
possible care by restricting access and maintaining the inventory
of your prescription samples in your dermatology practice. Here are
some steps to get started:
- Have written policies in place that clearly state who can
retrieve and dispense samples.
- Designate one person on the staff to monitor inventory at least
once a month.
- Do spot audits of the sample area.
- Track expiration dates, lot numbers, number of samples
dispensed, and directions; give a copy to patients and keep a copy
in their records.