At its last House of Delegates meeting, the American Medical Association (AMA) introduced a resolution, “AMA Response to Drug Store Intrusion into Medical Practice, Resolution 218 (A-13).”
the AMA resolution title is aimed at “drug store intrusion” and is specifically directed at Walgreens Corporation. for implementation of its Good Faith Dispensing (GFD) policy regarding opioid prescriptions for chronic pain. AMA Resolution 218 (A-13) is not directed at pharmacists per se, but at Walgreen Corp., which is using its pharmacists as pawns to satisfy internal requirements set forth in a deal with the Drug Enforcement Agency (DEA).3 Walgreens, the “drug store” that lit this fuse, has emerged remarkably unscathed.
Walgreens and the U.S. Drug Enforcement Agency (DEA) entered into a Memorandum of Agreement (MOA) in the fall of 2011 as a result of dramatic increases in oxycodone doses dispensed by Walgreens pharmacies in Florida
It appears that as a result of this MOA, Walgreens implemented its Good Faith Dispensing (GFD) policy, but misinformation has accompanied the implementation of this policy. This is exemplified in a “Dear Provider” letter that attempts to explain why Walgreens pharmacists are compelled to call providers and ensure that “the necessary information to confirm the appropriateness of the prescription is documented to satisfy the DEA requirements”.
However, the DEA has issued no such “requirements” for the filling of prescriptions, as the Walgreens “Dear Provider” letter plainly states.
The heart of the GFD policy is Title 21 of the Code of Federal Regulations, Section 1306.4, which states that pharmacists have a corresponding responsibility to ensure that when a prescription for a controlled substance is dispensed, the dispensing must be done for a legitimate medical purpose. This is appropriate, valid, justified, and part of a pharmacist’s responsibility.
However, Walgreens’ GFD policy has bastardized its pharmacists’ ability to make a free-will professional interpretation and, ironically places patient safety at risk.
This policy obstructs the delivery of patient medications, as it requires the gathering of medical chart information above and beyond requirements set forth by any state or federal regulations, prior to the dispensing of an opioid prescription for chronic pain. If Walgreens honestly believed in the validity of that policy, pharmacists would also be required to obtain routine laboratory monitoring tests prior to dispensing statins, hypoglycemic agents, and antibiotics, for example. The thought is absurd!
The most unsettling element of Walgreen’s GFD policy is that, while it promotes the concept of “corresponding responsibility,” there is no advocacy for “corresponding accountability” on the part of the Walgreens pharmacist.
This is a growing trend in any regulations related to the “drug war”: there is never a “corresponding accountability” on the part of the agencies that are restricting access to pain medications.
The question remains as to how a Walgreens pharmacist would be held accountable for “prescribing by omission” if an adverse event occurred through the withholding or delay of a patient’s opioid prescription resulting from Walgreens’ GFD policy.
The real issue
When the above facts are elucidated, it is quite clear that behind the rhetoric of AMA Resolution 218 (A-13), the issue is not that of physicians striking out at pharmacists; to the contrary, it is Walgreen Corp. itself that is being condemned.
This is not simply an issue of “prescription drug abuse.” More precisely, it is the result of corporate “drug store intrusion” into patient’s therapy.
The pharmacist’s healthcare role in this instance is not being defined by our knowledge, collaboration, clinical expertise, and direct patient care attributes, but rather by irresponsible and selfish corporate policy arising from an effort to satisfy previous misgivings and corporate greed, in an escalating lack of due diligence
The business model
Walgreens’ actions here are not based on the contemporary clinical role of pharmacists; they are focused on a singular business model that exudes patient neglect, not safety, as Walgreens claims.
The practice of pharmacy based on a healthcare model places the patient first, incorporates clinical knowledge, and enables the pharmacist to act in a fully collegial, collaborative manner with other healthcare providers in order to deliver the best patient care possible.
The pharmacy profession needs to realize the uncomfortable truth: that in this particular case, Walgreens reflects the worst that the pharmacy business model has to offer.