Hospice Compliance

Actually, I'm surprised any pharmacy will even accept a verbal from a nurse on CII. None of ours around here would. Ultimately it would be the pharmacist/pharmacy that would be fined for this - which is why they simply will not do it.

Thank you for responding. I've spoken with DEA. We'll see what happens.

I'm in San Antonio and we call in emergency mesds to pharmacy, then the pharmacist calls the doctor if they know them and have filled for them before and the c2 is faxed the next day. If it is a new doctor, the doctor does have to fax it. You may not be aware of what goes on after you call. Why didn't you ask the pharmacist before you called the DEA. The pharmacies are not employees of the hospice companies, they are not going to risk their companies by allowing us to call it in without proper protocol.

So you're saying you call pharmacy and say so & so needs Norco and that's it? And then you hope the doctor will answer the pharmacist and fax the cii so your patient gets their med? Every nurse here is phoning in every cii to pharmacy. They're not calling the doctor & having him/her fax pharmacy a cii for their patient.

I have never worked at a hospice like that- and I wouldn't. I can remember when some pharmacies refused to accept a faxed C2 from our medical directors at all, or if they did we had to bring them the original within 24 hrs. And that was in 2011.

I have called and asked pharmacists to call me if they DON'T get a C2 from my doc, but I never ever call in C2 refills. I worked too hard for my license!

So - here is the deal:

Hospice agencies/hospice care varies from acute care and even regular home care in many ways.

All hospice agencies/hospices are connected to a pharmacy that is usually specialized in that kind of service and also compound.

The whole idea of hospice is to relief suffering at EOL (~6 months or less - but you are dying for sure ...).

All hospice medical directors /physicians need to fax or e prescribe the orders for controlled substances to the pharmacy. However, because the MDs are not always close to a fax (many of them actually see patients as well or work part time for hospice), the pharmacies will typically accept a phone order for a limited amount of medication or certain substances when the provider is known to them - they will still request a written order, which usually get faxed or submitted the same day/hours later.

This is all based on a verbal order from the MD and requires the same protocol like any other verbal order including repeat back & verified if this is not covered under the standing orders!

If the patient is regularly admitted to hospice, the standing orders get send to the PCP who signs of on them and basically says that he/she agrees with the standing orders from hospice - which typically also includes roxanol and ativan for example (and more...). The MD still faxes or e prescribes a written order for all medications but there can be refills because most patients get only 10 days worth of meds at a time or even only 3 if addiction (family members) is a problem. In that case, you call the pharmacy and order the refill typically verbally.

I had emergencies where I needed stat roxanol for example or a new cassette for a CADD pump and the MD was not close to a fax as they cover 24/7 but may be doing something like food shopping.

If you are uncomfortable please ask your educator and/or manager about the process to understand if it is legally/regulations ok or not as well. Hospice is very different in that pharmacies will typically accept phone orders to a certain degree.

is this for a dedicated hospice pharmacy, or a local cvs/walgreens type scenario? For our dedicated hospice pharm, once we call the scripts in and give info on the prescribing doc, they will send a request to the doc (email, fax, or escript if the doc is set up with that program). most of the time, I have already called the doc and have asked them to fax a script, but sometimes i'll be calling the pharm for an unrelated med and in the review they will note that a c2 script has expired or something and then they will initiate the request with the doc. so don't assume that there isn't follow through.

DEA Register October 2010 - look it up. Clearly explains CII prescriptions process for ltc/hospice. Any R.N. who's phoning in CII's on physician's behalf is violating the law. End of story. Either the doctor has to do his job or the hospice can hire a P.A. or N.P. with DEA license. These doctors have their regular practices & are required to be available 24/7 in order to be a hospice physician. It's just a matter of time before DEA or State Board of Nursing makes an example of someone. I worked too hard for my license to allow that to happen to me.

Are you sure you are not just "Profiling" the meds with the hospice pharmacy but having the order filled by the local pharmacy with the hard script? Your scenario seems odd to me, any company whether hospice/MD or otherwise that is allowing this to go on is obviously breaking the law.