In order to implement this solution, states would need to grant approval for the provider pharmacy to function at the location of the LTCF, allow use of an ADS, and certify the location to DEA for purposes of controlled substance registration. States could define such an operation so as to avoid the many peripheral requirements of traditional pharmacies such as sinks, reference books, etc. The future implementation of electronic transmission of order forms would make this transfer easier. Transfers of stock for Schedules III-V controlled substances to the LTCF would have to be documented. Parameters for secure storage of the controlled substances in the absence of a registered pharmacist would also need to be defined.
Sufficient flexibility exists to accommodate such a system within the existing law and regulations.
Another possible solution to the accumulation of waste controlled substances at LTCFs is to register LTCFs with DEA as institutional practitioners. 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.