Eagle Associates, Inc.
compliance services since 1988
Sample Medication Control
Are you tired of having too many samples that are short dated? Tired of trying to figure out how to dispose of expired samples? If so, the following information can rid your practice of expired samples and keep your sample closet to manageable quantities that have sufficient dating. The problem with expired samples is linked to an over supply of the medications and, in many cases, short dating of the products.
The solution can be found at the start of the problem (how the samples are delivered into the practice). The solution requires establishing written policies, making staff and pharmaceutical representatives aware of the policies, and then enforcing the policies.
1. Establish an access policy – Require pharmaceutical representatives to check in at the front desk (no more walking in without clearance) and receive authorization from management to go beyond the reception area.
2. Establish inventory control – An authorized signature (i.e., office manager, clinical supervisor) must be required for samples to be left in the practice. Require a check of current inventory before adding more samples to the storage area and possible return of expired and short dated items (see next item “establish returns”).
3. Establish returns – Establish a policy that representatives must agree to take back expired and short dated inventory from the practice. Be sure to make a listing of items being returned to the representative and obtain their signature to acknowledge the return. You will be told that they do not have the authority or systems to handle returns. This is where you need to stick to the process.
The advantage for you, to obtain cooperation, is the “Golden Rule” (he who has the gold can make the rules). The gold is the access to your doctors and the practice’s sample closet. If representatives cannot comply with your sampling policies, they cannot leave samples or have access to the doctors (you will need to get your doctors to help support the policy). It can be done and the benefits of control (see below) are there for your practice.
4. Establish sanctions – Sanctions are penalties imposed for failure to follow established policies. Suspension of access to the practice will help obtain compliance.
Benefits - The benefits to your practice are (a) no disposal problems for expired samples, (b) no overstocking or crowding of your sample storage area, and (c) better dating for the samples that are left.
Keep in mind that the EPA (environmental Protection Agency) and your local municipalities may have a problem with the release of pharmaceuticals into the environment (i.e., streams, rivers, and lakes).
Additional resources for more information on disposal of medications:
• Your state’s Department of Environmental Quality (DEQ)
• The Environmental Protection Agency’s website - www.epa.gov
• DEA Office for Diversion Control at (800) 882-9539 or at their website - www.deadiversion.usdoj.gov
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