Pill planners medication administration vs dispensing

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HI all. I'm trying to get some information regarding pill planners. I work in an out patient facility where they have the patients bring in their pills in and we store them at the facility. We then either fill a wkly pill planner for them or give them a wkly,daily bubble pack that has been supplied by the pharmacy. My concern is and i'm uncomfortable with this process because we are "holding" their medications and aren't we dispensing their medications? At no point are we administering their medications to take in front of us. Here are some additional concerns:

1. this does not seem like a closed system to me regarding DEA regulations. The patient gets the script from the pharmacy or the case manager and brings them in. Couldn't this be considered holding their medications over their head to come in for treatment?

2. and if it is a scheduled II-V isnt it illegal for the patient to give those medications to someone else? because the patient is the end user?

The way to change this is to have the patient fill the weekly med planner themselves when they come in, with you overseeing it. You are not dispensiing the bubble packs because you are not taking them out of their original container, are not giving the individual pills to the patient.

And you can hold controlled substances for another person as you are a healthcare provider. You could count them with the patient if you don't have another staff member to count them with.

As for holding it over their head? I could not answer that.

You may want to look into the rules/regs for the Board of Pharmacy in your state regarding what constitutes dispensing, etc.

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