Registration would address the waste issue, as well as ancillary issues that have been raised regarding the problems associated with prescriptions as opposed to medical orders. As DEA registrants, the LTCFs could order and maintain institutional stocks of controlled substances that could be administered to patients pursuant to medical orders issued by the practitioners. The use of institutional registrations would allow medications to be dispensed pursuant to medication orders rather than prescriptions. With prescriptions, the medications are dispensed when they are delivered by the pharmacy to the LTCF for the patient. With medication orders, the drugs are not dispensed until they are administered to the patient.
Any unused drugs remain institutional stock and are available for dispensing to other patients.
The institutional practitioner would be able to dispose of any remaining waste as a registrant. It is conceivable that the use of the automated dispensing system, as described previously, would suffice in this instance as well. DEA believes this option is less likely to succeed and raises a number of problematic issues. If a LTCF is registered as an institutional practitioner, it may need staff pharmacists to dispense medications. Hospitals operate as one entity with the doctors and pharmacists all working, either as staff members or through contract, for the liable party.