Questions Being Asked By Boards of Medical Examiners to Doctors About Compounded Medications /Potential Questions to Ask During Investigations

Sue Tuck Richmond

June 11, 2013

Various sources are reporting to the blog that State Boards of Pharmacy (BOPs) have begun requesting very specific information, such as pre-printed prescription pads, office-use, from physicians about compounded medications. Physicians are normally governed by state Boards of Medical Examiners with BOPS having no direct jurisdiction over them.  Nonetheless, when BOPs begin questioning physicans about compounded medications this can strain the relationship a pharmacist and a pharmacy has with a physican.   Both the Pharmacist and the Pharmacy should be aware of some of the question be asked by the BOP.  Some of the questions pharmacists and pharmacies should be aware of are:

1. What percentage of the drugs you prescribe are compounded medications?
2. What percentage of the drugs you prescribes are compounded pain medications?
3. What percentage of the drugs you prescribe are compounded medications for patients in state?
4. What percentage of the drugs you prescribe are compounded medications for patients in state?
5. If a pharmacy supplies your office with a pre-printed prescription pad listing the compounded products that you would prescribe for a patient, once a prescription pad is completed with the what does your office do with this? Please explain all scenarios that have taken place.
6. After a pharmacy fills the compounded drug, how does the compounded product reach the patient? Are drugs sent to your office for the patient to pick up? If so, what is the process? Please explain.
7. If compounded products are sent to your office for patient pick up, please explain what is displayed on the outside of the prescription vial?  If there is a label, what information is on this label? Please explain.
8. Has a pharmacy sent any of the compounded products to your office for "office use"? Please explain.
9. What other ways besides pre-printed prescription pads do you prescribe compounded products for patients? Please explain.
10. What are the percentage and the actual number of the prescriptions issued by your office using a pharmacy pads that are for patients residing in state?

Note these are also potential questions that Boards of Medical Examiners and Boards of Pharmacies can use during their investigations.  These questions could also be asked of the veterinarians using compounding medications and compounding veterinarian pharmacies.