- 1. The # 1 question asked by physicians concerning point of care medication dispensing: Is it legal?
- 2. What is Point of Care Dispensing?
- 3. Does point of care medication dispensing comply with state and federal drug dispensing regulations?
- 4. What is Stark law? How does this affect me if I become a dispensing practitioner?
- 5. What is the profit potential to my practice?
- 6. Can our patients use insurance?
- 7. Are there any start-up costs?
- 8. Will I have to bottle my own medications?
- 9. Who else is doing this?
- 10. Why have I not heard of this before, is point of care medication dispensing a new concept?
- 11. Who can dispense the medications in our office? Will I need additional staff to dispense?
- 12. What liability does the physician practice assume with point of care medication dispensing?
- 13. What if we have multiple physicians in our practice?
- 14. Will dispensing cause my malpractice premiums to increase?
- 15. Do we have to file insurance for drugs dispensed in the practice? How do we handle Medicare and Medicaid patients? Drug cards?
- 16. Is the DispensingPhysician software program easy to use? Will DispensingPhysician train my staff and how long will the training take?
- 17. Is point of care dispensing efficient? How much time will it take my staff to dispense a medication?
- 18. Does the DispensingPhysician program have a patient database with dispensing history?
- 19. How much time will it take to enter a new patient into the database?
- 20. Does the DispensingPhysician program have an inventory tracking process?
- 21. How secure is the DispensingPhysician program?
- 22. Are the pre-packaged medications supplied as starter doses or full course doses?
- 23. How do we determine which medications and how many to order? Can DispensingPhysician provide any medications I choose, including controlled substances?
- 24. How do we re-order medications?.
- 25. Which medications generate the most income for the practice?
- 26. What about theft?
- 27. Why purchase re-packaged medications?
- 28. Why are repackaged medications repackaged in negative airflow sterile rooms?
- 29. What happens if there is a product recall from a drug manufacturer?
1. The # 1 question asked by physicians concerning point of care medication dispensing: Is it legal?
Yes, every physician is allowed by law to dispense medications to his/her own patients within the practice environment. Under Stark regulations, physician dispensing is considered acceptable when the dispensing is limited to the physician’s own patients; and the medications and products dispensed meet FDA guidelines for re-packaging and labeling. There are only five states (Massachusetts, Montana, New York, Utah, and Texas) that have more restrictive laws concerning point of care dispensing; it is allowed, but limited. back to top
2. What is Point of Care Dispensing?
Point of care dispensing is when the physician directly provides medications to their patient instead of handing their patient a prescription to take to a pharmacy. back to top
3. Does point of care medication dispensing comply with state and federal drug dispensing regulations?
The DispensingPhysician dispensing system complies with all DEA and FDA requirements. Repackaging companies are held to more stringent guidelines than pharmacies and all medications are repackaged in sterile environments to assure compliance. back to top
4. What is Stark law? How does this affect me if I become a dispensing practitioner?
Stark law pertains to physician self-referral for Medicare and Medicaid patients. There are exemptions to this status for in-office ancillary services including physician dispensing. The in-office ancillary services exception of Stark law permits physician owners of a medical group, and other members of the group, to refer patients to their group for certain Designated Health Services (DHS). An outpatient prescription drug given to a patient in the physician’s office, but taken by the patient at home, is now covered by the in-office ancillary services exception.
To qualify for protection under the in-office ancillary services exception, the DHS must be furnished personally by the referring physician or another physician member in the same group practice or by individuals who are “directly supervised” by the referring physician or group practice member. The in-office ancillary services must be furnished in the same building in which the referring physician or a group practice member furnishes substantial physician services unrelated to the furnishing of DHS. back to top
5. What is the profit potential to my practice?
If your practice is using the DispensingPhysician dispensing system by promoting it to all patients and encouraging use of the program, the profit potential can be significant. As with any program, utilization is the key. For a single physician practice seeing 30 patients per day on average, the annual income can range from $70,000-$125,000. Workers compensation costs and profit margins vary by state and will produce much higher margins. back to top
6. Can our patients use insurance?
For patients with pharmacy benefits, often the better and sometimes more profitable solution is the cash/carry program. However with DispensingPhysician you have a choice. With our billing scripts program, your practice can also adjudicate claims for both commercial and Medicare insurance. back to top
7. Are there any start-up costs?
DispensingPhysician will help you all the way to make sure you can get this opportunity going. We have established an easy path for you to be able to get started. Through our ongoing relationship with BVVA Compass Bank, you can apply to a credit card with a rotatory line of credit of up to $10,000. To get you started, necessary supplies include a bar code scanner, laser printer, an initial supply of pharmacy paper, and the first inventory order. The credit card with BVVA Compass will provide you with an initial loan at 0 % for the first 6 months, to make sure you can get started in the best terms possible. back to top
8. Will I have to bottle my own medications?
All your medications will arrive in a safety sealed pre-labeled unit of use bottle that is ready to dispense directly to your patient. back to top
9. Who else is doing this?
Many years ago most physicians dispensed their own medications. With the rise of modern pharmacies most moved away from it. Modern technology, primarily high speed computers and fast data connections, have allowed S.A.S (Software As a Service) solutions to be developed that simplifies reporting and medicine management requirements. The dispensing practice of today spends only a fraction of the time spent by their counterparts only 5 years ago.
For this reason, point of care dispensing is actually growing quite rapidly today, but the fact that it is still early in the adoption cycle may have kept it under the radar for many physicians.
According to a recent survey by Advanstar Research, dispensing is one of the three ancillary services most frequently offered by primary care physicians in the U.S. (36%), along with lab services (38%) and radiology (34.2%).
For medical practices looking to add ancillary programs that improve practice profitability and improve patient care and satisfaction, the DispensingPhysician cash and carry and billing and funding in-office physician dispensing programs do so with a very easy and practical set of steps that you follow to get you started. back to top
10. Why have I not heard of this before, is point of care medication dispensing a new concept?
The practice of point of care medication dispensing has been around since physicians began practicing medicine; but a re-emergence as an industry began in the early 1980′s with repackaged drugs being introduced into the market. In 1983, a nationwide campaign lead by the retail pharmacy industry was begun with the intent to eliminate the physician’s rights to dispense. In 1985, legislation in Congress was passed in 46 states to secure the physician’s rights to dispense FDA approved medications to their own patients. The 1990′s dispensing systems were developing to make the process fast, easy and cost effective for the physician and now in the 2000′s with reimbursement cut backs to physicians and only a limited amount of time to see patients which decreases the chance of a physician increasing his patient load, physicians are turning to ancillary services such as dispensing to help increase their profit margins. back to top
11. Who can dispense the medications in our office? Will I need additional staff to dispense?
In most states, a directive from the physician allows other staff members to dispense medications within the office. A few states do require that the physician actually do the dispensing. back to top
12. What liability does the physician practice assume with point of care medication dispensing?
The liability is the same as it would be when a physician writes a prescription which is filled by a pharmacy. A general liability policy of 1/3 million in coverage is required. In point of care dispensing, there are stringent guidelines concerning packaging and labeling of the re-packaged medications. The DispensingPhysician system meets all DEA and FDA requirements. back to top
13. What if we have multiple physicians in our practice?
Having multiple physicians in a practice is not a problem, as each physician is assigned a specific password and can track their dispensing history separately for bookkeeping, documentation or patient information purposes. You can also have security access assigned at different levels to approved staff members who will be assisting in the dispensing process. back to top
14. Will dispensing cause my malpractice premiums to increase?
No, whether a physician prescribes medications that are filled at a pharmacy or at his practice, the physician’s responsibility is the same. Malpractice carriers do not charge higher rates for dispensing physicians. back to top
15. Do we have to file insurance for drugs dispensed in the practice? How do we handle Medicare and Medicaid patients? Drug cards?
DispensingPhysician offers and recommends the use of the insurance adjudication program it is not necessary to file insurance claims for medications dispensed in your office. The patient can always opt of using their insurance card and simply pay out of pocket- otherwise termed as a cash dispense. back to top
16. Is the DispensingPhysician software program easy to use? Will DispensingPhysician train my staff and how long will the training take?
DispensingPhysician dispensing software is an internet based application. This means that any computer within the office that has an internet connection can be used as a dispensing terminal. The application requires minimal time, is easy to navigate and insures an accurate dispense. It features a drug utilization review for possible contraindications, allergies, conditions etc as well as generates bottle labeling and pharmacy education printouts. State mandated reporting is also compiled and submitted by the intuitive software application. DispensingPhysician will provide complete training on the software and technical support when you have questions or concerns. back to top
17. Is point of care dispensing efficient? How much time will it take my staff to dispense a medication?
The DispensingPhysician dispensing program is easily integrated into your office procedures and is a streamlined process that can be completed between 30 seconds to 2 minutes depending on the level of information the physician requires on each patient. Trained staff can handle dispensing with minimal interruption to other office responsibilities. back to top
18. Does the DispensingPhysician program have a patient database with dispensing history?
Yes, patients are loaded in the database automatically when you dispense a medication and you can pull reports on dispensing history by patient, medication, date, etc. back to top
19. How much time will it take to enter a new patient into the database?
A new patient can be added within 30 seconds to 2 minutes while dispensing, depending on the amount of information that the physician requests on each patient. Other demographic information is built into the system and can be added at time of dispense or at a later date if desired. This will vary with each individual office and the specific software programs in which the office participates. You do not have to add this additional information for a dispensing order to be completed. back to top
20. Does the DispensingPhysician program have an inventory tracking process?
The DispensingPhysician program will automatically tell you when a particular medication is below the pre-set levels that will be determined by each individual office at the time of installation and training. You can re-order medications at the inventory site with the click of a button. back to top
21. How secure is the DispensingPhysician program?
A sophisticated password protection system is built into the DispensingPhysician software. Each function performed by the software can be password protected to accommodate the needs and parameters of the individual physician practice. A double check system will not allow you to dispense a medication through the system that does not have a code match to the scanned bottle. In addition, the drug utilization review feature confirms with insurance pay or on previous dispense history. back to top
22. Are the pre-packaged medications supplied as starter doses or full course doses?
Most dispensing physicians prefer to prescribe a full course dose of medication therapy to their patients, but starter doses can be dispensed in some situations. back to top
23. How do we determine which medications and how many to order? Can DispensingPhysician provide any medications I choose, including controlled substances?
DispensingPhysician can supply any schedule 2-5 controlled substance as well as over the counter medications, injectables, and compounded medications. We suggest that initially you stock one week’s supply of the 15-20 meds you prescribe daily. This offering can always be expanded but it is best to start with a conservative inventory. The system will track all dispenses which will accurately determine which medications you are using most frequently and an accurate level of inventory control keeps your practice from running low on a particular medication. Your practice’s drug offering may develop over time and can change with seasonal practice activity. back to top
24. How do we re-order medications?
DispensingPhysician dispensing program will automatically alert you of low inventory on specific drugs; these inventory levels are determined at the time of installation and training by the physician. When you receive a low inventory notice, you simply click a button to reorder that specific medication. You can expect delivery, under normal circumstances, within 3-5 business days from order submission. back to top
25. Which medications generate the most income for the practice?
Generally, generic medications and drug products offer the most profit potential for a physician’s practice and the greatest savings to the patients. back to top
26. What about theft?
The DispensingPhysician dispensing process is managed in such a way that theft is rarely a problem. Password protection, an automatic inventory system and dispensing records of who dispensed make it difficult to hide theft of medications. Every container is accounted for in the inventory system and the reports allow the staff to easily and quickly determine if there is a problem; unlike the basic “supply closet” concept. back to top
27. Why purchase re-packaged medications?
State and Federal regulations state that dispensing is allowed through the physician practice only if the medications are properly packaged and labeled. Products must comply to federally mandated current Good Manufacturing Practices (GMP’s) as noted in Title 21 of Code of Federal Regulations. Noncompliance with these laws could render the medication as “adulterated” and or “misbranded”. It is a federal crime to dispense an adulterated or misbranded medication to a patient. back to top
28. Why are repackaged medications repackaged in negative airflow sterile rooms?
FDA reports that 50% of all drug reactions in the United States are caused by penicillin and cephalosporin contamination. It is almost impossible to get medications from a pharmacy that do not have some contamination of dust spores from penicillin or cephalosporin based medications as all medications are sorted using the same trays as the penicillin/cephalosporin based medications and cross contamination is a constant problem. One unit of penicillin is invisible to the naked eye, and many patients are highly allergic to penicillin/cephalosporin which can lead to anaphylactic shock. Repackaging medications in sterile negative airflow environments greatly decreases the chance of cross contamination. back to top
29. What happens if there is a product recall from a drug manufacturer?
DispensingPhysician software program can help you quickly identify any patients who are currently using a medication that has been recalled. back to top