How Do You Respond to Corresponding Responsibility?

Abstract

This article provides a structure upon which to build working policies and procedures for implementing the key concepts of corresponding responsibility to pharmacists who dispense controlled substances to outpatient populations. The pharmacist is given the resources to find and archive pertinent data from the “five Ps,” purpose, prescriber, practice, patient, and pharmacy, enabling him to develop a database that also incorporates CURES data and applies universal precautions in a way that mitigates most kinds of diversion. Following the California Board of Pharmacy and DEA red flag lists, the paper gives recognizable, real-world examples of these red flags and lists possible ways to resolve them. A sample red flag resolution form is included. Finally, there is a suggested response to unresolved red flags. The pharmacist is encouraged to develop a written policy based on the tools and information presented. Appendices include sections of pertinent law, letters from regulators and sample forms.