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New Mexico News: Who Is Responsible?
Published in the September 2007 New Mexico Board of Pharmacy Newsletter.
This year there have been numerous issues involving the delivery of CS from drug wholesalers. These issues can include shipping overages, shortages, receipt of items not ordered, or something different within the bottle. When a pharmacy receives a delivery, the pharmacy personnel should verify that the order is complete and You should open the shipping container and verify the contents. Once you sign for the order, you are responsible for the contents. If there is a discrepancy of CS, the pharmacy, not the wholesaler, is responsible for reporting the loss to both the Board of Pharmacy and DEA. If the discrepancy is noticed prior to signing, then the wholesaler is responsible for reporting the loss. In such a case, the pharmacy can accept receipt of the order as long as the discrepancy is documented and the wholesaler is immediately contacted prior to acceptance of the delivery.
It is imperative to communicate any of these discrepancies with the Board of Pharmacy and DEA. Even if the wholesaler advises that the pharmacy will be given a financial credit for the missing CS, the wholesaler is still reporting that it sent you the CS. The pharmacy is responsible for the accountability of these CS after you sign for them.
The Board of Pharmacy requires that you report within five (5) days of becoming aware of the loss of any Schedule II through V CS. The loss must be reported on a DEA Form 106. DEA requires that you report to the Albuquerque office in writing of the theft or loss of any CS within one business day of discovery. You must also send the completed DEA Form 106 to the Albuquerque DEA office. You can fax DEA at 505/346-7421.
