Let's face it, the day to day operations of working in a dental practice can get crazy! As the dentist, you can be pulled in three (or more) different directions, and your team members try their best to keep you on track! There are times when a patient needs a prescription and you need one of your staff members to help facilitate the process.
Do your employees have delegated duties, such as:
1. Preparing, for your signature, written prescriptions for controlled substances in those instances where you have expressly directed the employee to do so and where you have specified to the employee the required elements of the prescription (set forth in 21 CFR 1306.05).
2. To convey to a pharmacist by telephone oral prescriptions for controlled substances in Schedules III, IV, and V in those instances where you have expressly directed the employee to do so and where you have specified to the employee the required elements of the prescription (set forth in 21 CFR 1306.05).
3. To transmit by facsimile to a pharmacy prescriptions for controlled substances in those instances where you have expressly directed the employee to do so and where you have specified to the agent the required elements of the prescription (set forth in 21 CFR 1306.05) and you have signed the prescription.
4. Transporting controlled substances between facilities for you for official use by you during the course of the practice of dentistry.
5. To access the state Prescription (Drug) Monitoring Program to retrieve patient drug histories.
6. To handle controlled substances for ordering, inventorying, shipping/receiving, and/or preparing your administration to a patient(s).
Have you:
- Adequately screened each employee who will be a ‘designated agent’ (either a criminal background check or at very least a completed Designated Agent Screening form)?
- Authorized your designated agent(s) in writing by completing a Designated Agent Authorization form for each employee you so authorized?
- Updated as employees are replaced or no longer authorized?
About the Author
A former Law Enforcement Officer/ Dental Board investigator, Duane Tinker is the CEO of Dental Compliance Specialists. Mr. Tinker provides compliance consulting, auditing and training services for dentists and Dental Service Organizations on compliance risks including OSHA, HIPAA, Dental Board rules/ regulations, state radiology rules, DEA and state drug regulations, and Medicaid. Mr. Tinker is a frequent speaker for dental societies and study clubs. He also hosts a podcast called Talking with the Toothcop. Mr. Tinker can be reached by calling (817) 755-0035 or through his company’s website DentalCompliance.com.