General Questions about the Returns Process

1. Who initiates the return? Does the RD alert the healthcare facility that credit is available 

for certain pharmaceuticals or do health care facilities periodically go through inventory 

to return un-needed items? Health care facilities (HCFs) typically place their damaged, 

recalled, expired, or otherwise unwanted, pharmaceuticals into a box or bin set aside for 

the RD’s next visit or for shipping directly to the RD without an onsite visit by the RD. 

Visits can be set up as regularly scheduled appointments (i.e. monthly, quarterly, etc.) or 

as needed based on time or space constraints at the HCF. After the return of product

from the HCF to the RD, the RD will evaluate the product for credit eligibility and notify 

the HCF, via online or paper reporting, of available credits.

2. Does the RD have reps that go to healthcare facilities to pull and prepare pharmaceuticals 

for shipment to the RD? If so, does the rep know which items will/will not receive 

credit? Services vary for each RD. EXP’s procedure includes onsite visits by reps for 

documentation of DEA controlled substances prior to shipping. EXP’s reps do not know 

which items will receive credit. The evaluation of drug data and decisions about credit 

eligibility take place at our corporate office. Some RDs offer full onsite services that 

include making credit and waste determinations at the HCF. However, it increases the 

cost of the service event due to the significantly increased time it takes each service 

representative to review and categorize each pharmaceutical item. In essence, making the 

waste determinations onsite transfers a large portion of the work conducted at the RD to 

the HCF. If required of all service events, it could make reverse distribution prohibitively 

expensive. Also, in many instances EXP is able to obtain credit for items that are deemed 

waste pursuant to a manufacturer’s policy by calling the manufacturers on behalf of HCF.

3. Is credit received per container? Per pill if container has been opened? Credit is based 

on criteria from each manufacturer’s return goods policy (RGP) and is issued on 

estimated or exact quantities, including partials.

4. Do healthcare facilities return pharmaceuticals from the patient floors (e.g., drugs that 

have been re-packaged)? Are re-packaged pharmaceuticals creditable? Dispensed 

pharmaceuticals from the patient floors are generally non-creditable unless the drug has 

been recalled by the manufacturer. Non-dispensed, re-packaged pharmaceuticals may be

credit eligible, depending on the RGP.

5. Once the shipment arrives at the RD facility, what is the timeframe for processing? The 

timeframe for processing varies, but may be completed within a couple days.

6. Are generic brands creditable? Yes.

7. Do expired items typically get credit? Yes.

8. How is the RD paid for its services? Does the RD receive a percentage of the credit? Is 

there a flat fee? Are there additional charges to the healthcare facility for waste 

management? Yes, yes, and yes. RDs are typically paid a percentage of the anticipated 

return value (ARV), buy may include flat fees or minimum fees to cover costs for less 
valuable orders. Fees are also charged for the disposal of waste generated as a result of 

non-creditable items.

9. Under what circumstances would a healthcare facility return pharmaceuticals to a 

(forward) distributor in lieu of sending to a RD? Do you process pharmaceuticals from 

(forward) distributors? HCFs may return product to a forward distributor if that forward 

distributor’s RGP does not allow for the return of product through a RD. EXP does 

process product from forward distributors.

10. When pharmaceuticals are received at the RD, are they ever shipped to another RD’s 

facility for crediting? Yes. Certain manufacturer’s RGPs require pharmaceuticals to be 

returned to an agent of the manufacturer, which is usually a reverse distributor.

11. Do you accept non-pharmaceutical products? Yes.

Shipment 

1. Are returned pharmaceuticals shipped to the RD via commercial mail carrier or USPS or 

private hauler? Is the shipment tracked and is the healthcare facility notified by the RD 

that the shipment has been received? Do healthcare facilities notify the RD that a 

shipment has been sent? Shipments are sent using common carriers (i.e. UPS, FedEx, 

USPS, etc.) utilizing barcodes or other means for tracking. Upon request, EXP notifies

HCFs upon receipt of a shipment. In other instances the HCFs receive notice of receipt 

when they receive the processing reports for that shipment. EXP has advance notice that

a shipment is on its way to EXP for all onsite service events; its representatives have 

entered information related to the shipment into EXP’s system. In some instances, HCFs 

notify EXP that an offsite shipment is on its way to EXP. 

2. Are controlled substances shipped separately from other pharmaceuticals? Can you 

explain more about the process of handling returned controlled substances? Controlled 

substances are usually shipped with other pharmaceuticals, but are packaged separately. 

Controlled substances are documented in accordance with DEA regulation prior to 

shipping from the HCF to the RD. They are placed in non-descript boxes and shipped 

using a carrier that offers tracking. All shipments are inspected for tampering prior to 

receipt. Once received at the RD, they are placed into a DEA-approved security cage (for 

CIII-CV) or vault (for CI & CII). They are then evaluated for credit like other noncontrolled substances.

3. Have there been incidences where shipments have been lost or stolen? Yes. Incidences 

of missing product, whether lost or stolen, are investigated by the HCF after the loss is 

reported to them by the RD.

Waste Determination and Management
1. What percentage of returned pharmaceuticals are typically RCRA hazardous wastes once 

it is determined credit will or will not be given? Typically, do pharmaceuticals that meet 

RCRA’s definition of a hazardous waste get credit? Do you ever manage non-hazardous 

pharmaceuticals as RCRA hazardous waste? The percentage of pharmaceutical product 

received at EXP that is generated as RCRA hazardous waste is less than 2%. Some 

pharmaceuticals are creditable that would otherwise meet the definition of RCRA 

hazardous waste. Non-hazardous pharmaceuticals may be managed as RCRA hazardous 

waste, if we feel that is the best method.

2. Is the manufacturer always contacted prior to disposal of a creditable pharmaceutical? 

For a non-creditable pharmaceutical? Disposal of creditable pharmaceuticals is never 

done without prior approval from the crediting entity. Disposal of non-creditable 

pharmaceuticals is typically done without prior consent from the manufacturer.