New industry guidance is directing pharmacies and third-party
processors to accept veterinarians’ license numbers as a means for
identifying prescribers of non-controlled medications for animals.
That
means pharmacists soon may stop asking for veterinarians’ DEA (Drug
Enforcement Agency) numbers when filling scripts for non-controlled
medications. The same goes for National Provider Identifier (NPI)
numbers, which veterinarians aren’t eligible to receive because they do
not meet the regulatory definition of “health care provider.”
The
new guidance comes from the National Council for Prescription Drug Programs
(NCPDP), a not-for-profit organization that develops industry standards
and guidance related to medications, supplies and services within the
U.S. health care system. Approved by NCPDP members during a Nov. 6-8
meeting in Portland, Ore., the guidance
adopts veterinary license numbers as a new way
for pharmacies and third-party processors to identify prescribing
veterinarians in their databases.
The changes were motivated by
inquiries from the American Veterinary Medical Association (AVMA). Use of license numbers, advocates say, could clear up problems
veterinarians encounter as more of their clients take pet prescriptions
outside of veterinary practices and fill them at local retail pharmacies. It’s not uncommon for pharmacists to ask doctors — veterinarians included — for NPI or DEA numbers as a means
for verifying and tracking all prescriptions, not just controlled
substances.
That's a problem for veterinarians, who are advised
by federal regulators to stave off potential abuse by keeping their DEA
numbers under wraps unless prescribing narcotic pain relievers and the
like. In general, NPI numbers aren't available to veterinarians. Some
don't have DEA numbers, either.
“We have a task force that’s
discussed with the AVMA the use of identifiers for prescribing
veterinarians,” said Lynne Gilbertson, NCPDP vice president of standards
development. “It was recommended that state license numbers should be
used for non-controlled medication prescriptions by veterinarians, and
the industry has approved guidance for this.”
Caught in the middle
That’s
welcome news to Dr. Beth Neuman of Tucson, Ariz., who recently refused
to give a local Walgreens her DEA number to fill steroid, antifungal
and antibiotic prescriptions for a canine patient.
The
drug store declined to fill the prescription without Neuman's DEA number. “My client,” Neuman recalled, “was livid.”
DEA
numbers are needed for customers to take advantage of the
Walgreens Prescription Savings Club, which
offers discounts on certain medications to club members' families, including their pets, said Tasha Polster, director of pharmaceutical integrity.
She
pointed to the company Walgreens hired to process medical and savings
club claims: “They require DEA numbers to validate prescriptions.” When
asked to identify the company, Polster said she wasn’t privy to that
information.
Walgreens isn’t the only retail pharmacy that
requires DEA numbers for non-controlled medications. On the Veterinary
Information Network (VIN), an online community for the profession,
veterinarians report getting such requests from a variety of drug store
chains. Some are said to assign veterinarians a dummy NPI number to
fulfill the pharmacy's identification requirement.
Attempting
to appease her client, Neuman matched Walgreens’ prices, selling the
medications from her in-house pharmacy at a loss to her practice.
“Now
I have a pissed-off client, I lost some money selling the drugs and I’m
uncomfortable with Walgreens sharing my DEA number with a third party,”
she lamented. “I think that my DEA number should be somewhat private.”
Regulatory perspective vs. reality
So
does the DEA. On its website,
the agency states: “DEA
strongly opposes the use of a DEA registration number for any purpose
other than the one for which it was intended, to provide certification
of DEA registration in transactions involving controlled substances.
“The
use of DEA registration numbers as an identification number is not an
appropriate use and could lead to a weakening of the registration
system,” the DEA warns.
Even so, there’s no legal basis for the DEA to preclude insurance providers and pharmacy benefit managers from doing just that.
"DEA
is in the business of regulating controlled substances, and our numbers
are legitimately required from practitioners by pharmacies to meet
their legal obligation to conduct due diligence in determining that a
controlled substance prescription is legitimate..." the DEA's Office of
Diversion Control said in a statement by email. "Beyond that, how a
company uses the numbers is their own business practice, which we don’t
regulate.”
It's not as though DEA numbers are private, remarks
Doug Kemp, a pharmacist and VIN consultant. He points out that a national
database of DEA registrants
exists online. Subscribers
must pay to access the information.
Kemp understands why pharmacists, insurance companies and the
third-parties that process claims adopt DEA numbers as universal
identifiers rather than other unique numerical codes, including state
licenses.
"Veterinarians' license numbers from one state to
another will overlap in the database of national chains," he said by
email. "You might have many John Smiths in the database. Since
veterinarians are not eligible for NPI numbers, the only unique
numerical identifier is the DEA registration number."
It remains
to be seen whether the use of veterinarians' license numbers to track
prescribers causes confusion. Meanwhile, uncertainty of another kind exists.
While text of the guidance says state license numbers should be used to identify prescribing veterinarians, a parenthetical "or DEA" also is in
the language. Some believe this invites pharmacies and processors to continue using DEA numbers as a universal identifier, even on non-controlled substances.
The NCPDP's Gilbertson thinks otherwise. She explained that the guidance addresses the fact that NPI numbers are not available to veterinarians, so there needs to be another means for identifying them.
"NPI is used on non-controlled claims. DEA is used on controlled claims. So the verbiage is addressing that state license is used instead of NPI (for veterinarians)," she said.
The NCPDP's guidance will go out this week
to members and stakeholders via its electronic newsletter.
VIN News Service commentaries are opinion pieces presenting insights, personal experiences and/or perspectives on topical issues by members of the veterinary community. To submit a commentary for consideration, email news@vin.com.