CVS Health - Prescription Initiative
It has been brought to our attention, through the AAPA, that CVS Health will be conducting an effort in many states to make certain statutory/regulatory requirements relating prescription medications are being followed. Specifically the initiative will look at the requirement for collaborating/supervising physician documentation.
Make sure you are in compliance with all Kansas requirements when providing written or electronic orders for medications. Inaccurate or incomplete prescription documentation may create a need for addition contact from the dispensing pharmacy and could delay the fulfillment of prescribed drugs for your patients.
As a reminder the State of Kansas PA Practice Act requires the following:
Kansas Statute Annotated § 65-28a08(d)(2)
(Practice of physician assistant; direction and supervision of physician; prescription of drugs; identification to patient of physician assistant; rules and regulations; “drug” defined.)
The board shall adopt rules and regulations governing the prescribing of drugs by physician assistants and the responsibilities of the supervising physician with respect thereto. Such rules and regulations shall establish such conditions and limitations as the board determines to be necessary to protect the public health and safety. In developing rules and regulations relating to the prescribing of drugs by physician assistants, the board shall take into consideration the amount of training and capabilities of physician assistants, the different practice settings in which physician assistants and supervising physicians practice, the degree of direction and supervision to be provided by a supervising physician and the needs of the geographic area of the state in which the supervising physician’s physician assistant and the supervising physician practice. In all cases in which a physician assistant is authorized to prescribe drugs by a supervising physician, a written agreement between the supervising physician and the physician assistant containing the essential terms of such authorization shall be in effect. Any written prescription order shall include the name, address and telephone number of the supervising physician. In no case shall the scope of the authority of the physician assistant to prescribe drugs exceed the normal and customary practice of the supervising physician in the prescribing of drugs.
Kansas Administrative Regulation § 68-7-14
(Prescription labels; Miscellaneous Provisions)
(a) The label of each drug or device shall be typed or machine-printed and shall include the following information:
(1) The name, address, and telephone number of the pharmacy dispensing the prescription;
(2) the name of the prescriber;
(3) the full name of the patient;
(4) the identification number assigned to the prescription by the dispensing pharmacy;
(5) the date the prescription was filled or refilled;
(6) adequate directions for use of the drug or device;
(7) the beyond-use date of the drug or device dispensed;
(8) the brand name or corresponding generic name of the drug or device;
(9) the name of the manufacturer or distributor of the drug or device, or an easily identified abbreviation of the manufacturer's or distributor's name;
(10) the strength of the drug;
(11) the contents in terms of weight, measure, or numerical count; and
(12) necessary auxiliary labels and storage instructions, if needed.
(b) A pharmacy shall be permitted to label or relabel only those drugs or devices originally dispensed from the providing pharmacy.
Kansas Administrative Regulation § 100-28a-13(f)
(Prescription-only drugs; Physician Assistants)
Each written prescription order by a physician assistant shall meet the following requirements:
(1) Contain the name, address, and telephone number of the supervising physician;
(2) contain the name, address, and telephone number of the physician assistant;
(3) be signed by the physician assistant with the letters "P.A." following the signature; and
(4) contain any DEA registration number issued to the physician assistant if a controlled substance is prescribed.