Chief Compliance and Ethics Officer Health Care

Sample medications

  • 1.  Sample medications

    Posted 04-18-2019 02:23 PM
    I would like to see what other physician office are doing in regards to documenting over the counter sample medications. We recently implemented a policy for the storage, documentation, and inventory of sample medications. Do most physicians document when an OTC med is given to the patient or just those sample medications that require a prescription? We have a specific spot for documentation of sample medications in our EMR.

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    Savannah Knuettel
    Compliance Officer
    Galen Medical Group
    Hixson,TN

    The views expressed herein are my own and do not represent those of my employer or clients. They are not meant to constitute legal advice or create an attorney-client relationship.
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    2019 HCCA Compliance Institute


  • 2.  RE: Sample medications

    Posted 04-18-2019 05:48 PM
    Many states have laws that address prescription sample management, but, OTC is another thing altogether and not generally required. I'm a lot curious as to why they're giving out OTC meds in the first place but generally it seems the med should be recorded as any OTC is in the MED list....beyond that and in absence of any state guidance...seems like it'll be a reflection of your risk tolerance but other than a mass recall of a lot #, hard to clearly identify a unique risk. I'm a little more worried about why they're giving out OTC meds as samples.....those are just my thoughts...



    2019 HCCA Compliance Institute


  • 3.  RE: Sample medications

    Posted 04-19-2019 09:11 AM
    Tricia,
    For example, our allergy patients sometime forget to take an antihistamine before their injections so we often give the patient  zyrtec or give them a sinus rinse. At other offices its  tylenol or motrin that is given in office to reduce fever,etc. So it is not really that they are giving out samples of OTC meds, its given while the patient is at the office. I also felt like we would need to look at the risk tolerance as well and my only concern would be potential counter interaction and the mere fact that I think every medication we personally give to the patient OTC or not needs to be documented. I think this is more of an inventory recording burden for the providers when documenting as they have to put in more information than the simple statement patient  was given 5ml motrin under our sample medication section in EMR.

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    Savannah Knuettel
    Compliance Officer
    Galen Medical Group
    Hixson,TN

    The views expressed herein are my own and do not represent those of my employer or clients. They are not meant to constitute legal advice or create an attorney-client relationship.
    ------------------------------

    2019 HCCA Compliance Institute


  • 4.  RE: Sample medications

    Posted 04-19-2019 11:24 AM
    Ahhhhh. I agree with you; if they gave it in the office it was for particular reason that you would think should be documented. 



    2019 HCCA Compliance Institute


  • 5.  RE: Sample medications

    Posted 04-22-2019 01:50 PM
    ​A little off the theme of this post but be sure your billing system never charges a patient or a payor for sample medications, Rx or OTC, which are given to the patient.
    Charlie

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    Charles Colitre BBA, CHC, CHPC
    Compliance & Privacy Officer
    Crystal Clinic Orthopaedic Center
    Akron,OH
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    2019 HCCA Compliance Institute