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Practice Management

Keeping Dermatology Rx Samples Safe

Erin Romanski

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. Wolff.

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 (MGMA).

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 purposes."

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 night.

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 employees."

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.

Who's Helping?

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 locations."

"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 Gooden.

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 Prescription

"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 cabinet."

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.

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Disclaimer: The material above has been prepared by Physicians Practice. It has not been reviewed by the DermQuest Editorial Board for its accuracy or reliability. Reference to any products, service, or other information does not constitute or imply endorsement, sponsorship, or recommendation by members of the Editorial Board.