Walgreens’ “secret checklist” reveals controversial new policy on pain pills

http://www.wthr.com/story/23469086/2013/09/18/walgreens-secret-checklist-reveals-controversial-new-policy-on-pain-pills

Walgreens patrons across the nation told Eyewitness News their prescriptions were being delayed or denied because of a new pharmacy policy, but Walgreens would not tell them what the policy is.

WTHR has obtained an internal document the nation’s largest drug store chain has been trying to keep secret. It reveals why Walgreens is now turning away some customers and refusing to fill their prescriptions.

“We were told patients are not supposed to know we’re using [this],” said pharmacy technician

Walgreens’ one-page checklist must be used by its pharmacy staff each time a  customer presents a prescription for a powerful narcotic. Oxycodone, Methadone, Hydromorphone (Dilaudid), Morphine, Fentanyl and Opana are included on the list of Walgreens’ “target drugs” because they are all highly-addictive controlled substances that government regulators have placed in a high-risk category for prescription drug abuse.

According to the GFD checklist: a pharmacist is required to complete four mandatory steps before filling a prescription for one of the GFD Policy target drugs:

• Check Walgreens’ national Itercom Plus computer system to confirm the prescription has not been previously denied by another Walgreens pharmacy

• Review a customer’s personal prescription drug history maintained by a state Prescription Drug Monitoring Program (PDMP). In Indiana, the state tracks all residents’ opiod prescriptions using an online PDMP system called INSPECT.

• Photocopy a valid government photo ID for the individual(s) dropping off and picking up each prescription

• Answer a series of seven questions about the prescription, patient and prescribing doctor to look for “red flags” of possible prescription drug abuse

The additional seven questions include:

• Whether the patient has previously received the same medication from Walgreens (new prescription or new patient is a red flag)
• Whether the prescription is written for the same medication and from the same doctor as the previous fill (new doctor is possible red flag)
• Whether the patient and doctor listed on the prescription are within close geographical proximity to the drug store (far distances that cannot be explained are a red flag)
• Whether the prescription is being filled on time (attempt to fill early is a red flag)
• Whether the patient is paying for the prescription using insurance (cash is a red flag)
• Whether the quantity of pills prescribed is considered excessive (more than 120 pills is a red flag if paying by insurance; more than 60 pills is a red flag if paying cash)
• Whether the patient has been taking the same medication and dosage for a long time (more than 6 months is a red flag)

Based on the results of the previous steps and questions, Walgreen’s checklist instructs pharmacists to use their “professional judgement” (sic) to determine whether the prescription should be filled or the pharmacy should take the additional step of calling the prescribing doctor to ask more questions.

If a call to the physician is needed to further verify the prescription, the checklist directs Walgreens staff to “verify/confirm any number of the following points” with the doctor:

• Prescription is written within prescriber’s scope of practice
• Diagnosis
• Therapeutic regimen is within standard of care
• Expected length of treatment
• Date of last physical and pain assessment
• Use of alternative/lesser prescription medications for pain control
• Coordination with other clinicians involved in patient care

The Walgreens checklist is designed to help pharmacists identify prescription fraud and to keep addictive drugs away from those who abuse them.  But critics say it’s been keeping pain pills away from the people who really need them

If a Walgreens pharmacist refuses to fill your prescription for pain medication, that denial must now be entered into your online customer profile that can be seen by pharmacy staff at more than 8300 Walgreens nationwide. According to the GFD Policy, Walgreens pharmacists will also notify the US Drug Enforcement Administration that your prescription has been refused, and the pharmacy must maintain detailed documentation to justify the reason.

But if you want to know why Walgreens denied pain medication prescribed by your doctor, you’re out of luck.

The company introduced its Good Faith Dispensing Policy and GFD checklist earlier this year as it was embroiled in a massive investigation by the US Department of Justice and US Drug Enforcement Administration.  Federal agents targeted six Walgreens drug stores and a Walgreens distribution center in Florida, where they caught the company repeatedly filling bogus prescriptions for pain pills.

Walgreens agreed to pay an $80 million fine for those violations, and as part of its settlement, the company promised to improve its policies and procedures to help reduce prescription drug abuse involving addictive pain narcotics. That’s when Walgreens rolled out its GFD checklist, and told its employees to implement it – quietly.

The truth is, a lot of bad prescriptions still get approved because the pharmacy manager’s bonus is based on the amount of scripts that get filled.”

Ryan said the GFD Policy was applied inconsistently, with prescription approvals and denials based upon the subjective decisions of the particular pharmacy staff on duty.

Ryan is not alone.  Many doctors also believe Walgreen’s checklist is problematic. Dr. Deborah Peel, founder of the Patient Privacy Rights Foundation, told WTHR she is both disappointed and shocked to learn what Walgreens is doing.

Peel believes Walgreen’s policy discriminates against millions of people, based solely on the type of medication they need. “Everyone — everyone — who has a pain prescription is being treated as a suspected criminal,” she explained. “We need programs that target the abusers, that don’t treat everyone as an abuser. That’s the real problem with this. It’s highly offensive.”

The longtime pain specialist offered the following explanation: “They want to know ‘expected length of treatment?’ I have no idea a lot of times how long it’s going to take to treat pain. The length of treatment may be forever for some patients. “Is the therapeutic regimen within standard of care? Many of the medications we prescribe are ‘off label’ because no other therapy has worked. “Use of alternative prescriptions and lower doses? Patients that are on higher doses than normal may actually need those doses because of the way that genetically their body works. “My concern is: is this a checklist or is this a diagnosis list? Because I don’t think many pharmacists are trained or equipped to really understand the diagnosis. Pain is a very difficult entity to treat.”

The organization responded by creating an online complaint form for doctors and patients who are experiencing difficulty in getting prescriptions for controlled substances filled at Walgreens.

The American Medical Association is also tracking the problem.

“Physicians in more than 20 states tell the AMA that several national pharmacy chains may be inappropriately restricting patients’ access to legitimate pain medication. Such roadblocks are creating serious barriers to patient access to needed medications – including those in hospice,”

See the Walgreens checklist and Good Faith Dispensing Policy.

Having trouble getting a prescription for pain medication filled at Walgreens? File a complaint here.

By using the phrase “use your own professional judgement” Walgreens is asking their pharmacists to practice medicine – isn’t that illegal?