Dispensing

Pharmacist Responsibility in the Drug Distribution Process

Policy 0028

02/01/2000 Introduced
02/01/2005 Reapproved
02/01/2010 Reapproved

04/07/2015 Reapproved

02/21/2021 Reapproved

AMCP supports the pharmacist's authority to control and direct the drug distribution process and the requirement that the pharmacist bear responsibility for all completed medication orders regardless of practice setting.

AMCP supports the establishment of a class of drugs that would allow consumers, with the intervention of a pharmacist, to purchase certain medications without a prescription. The establishment of a behind-the-counter (BTC) classification would grant patients access to necessary medications while being counseled by a pharmacist to ensure that the patient meets certain criteria prior to dispensing and to provide education on proper use and monitoring. AMCP supports the establishment of a third class of BTC drugs if the following conditions are met:

• Medications selected for BTC status must provide a benefit to the public
• Decisions on which drugs are selected for BTC status must be based on clinical effectiveness and safety
• Standardized processes for ordering and dispensing of BTC drugs must be established
• Pharmacists must be required to perform clinical evaluation and interventions before dispensing BTC drugs
• Pharmacist training requirements must be based on knowledge and skills required to interpret objective clinical data and to apply selection criteria in order to dispense BTC products
• Patient health information must be protected
• Program oversight requirements must be developed

(See AMCP Managed Care Pharmacy Practice Positions – Behind-the-Counter Drugs)

Audits serve two main purposes: 1) detecting fraud, waste and abuse, and 2) validating data entry and documentation to ensure they meet regulatory and contractual requirements. The audit process should be transparent and have a fair design and implementation. The managed care organization should supply the pharmacy provider with a document that defines the requirements on which it may base an audit. The actual audits should be conducted in a manner that leads to continuous quality improvement of the services of the provider, rather than as a source of revenue. Further, the provider must review and be comfortable with these documents before it agrees to a contract. It is imperative that pharmacists-in-charge, and their staff, understand the dispensing and billing requirements and the implications of non-compliance. A bilateral professional level of performance can make the audit process run smoothly, be educational and improve quality.

(See AMCP Model Audit Guidelines for Pharmacy Claims)