Since “Nothing good comes from the expiry of Scheduled II products,” establish PAR levels for these products. Don’t rely on the PAR levels provided by your wholesaler, as they fail to include in their calculations the products and related quantities that have expired and were never dispensed.
Restrict the pharmacy buyer from purchasing Scheduled II products above the identified PAR Levels, unless approved by pharmacy management.
Upon receipt of a Scheduled II Product shipment, require that the pharmacy buyer and an additional pharmacy employee verify product and quantity receipt. The additional pharmacy employee should be rotated so as not to have the same employee involved in the receipt and documentation of Scheduled II Product.
Never, ever, allow a third party reverse distributor’s employee to document Scheduled II products and prepare Form 222s without the direct supervision of a pharmacy employee, preferably a supervisor.
And finally, provide your third party reverse distributor only Scheduled II products that have actually expired. The process of sweeping your pharmacy of products that will expire during the next 3 months may require your reverse distributor to “age” Scheduled II products to qualify for a credit. Manufacturer’s return’s policies may require that product be within one (1) month of expiration to qualify for credit, not two (2) or three (3) months prior. The longer a third party possesses your Scheduled II products, the more opportunity for theft. Also, to audit your “aged” returns to verify that they were processed and destroyed at some future date would require a significant amount of time to review product, expiration date and lot number comparisons, an effort that you certainly do not have time for.
The leadership team of Cost Control Solutions hopes the suggestions provided for the management and security of your Scheduled II products is of value to you.
Please feel free to contact us should you have additional questions or concerns regarding the management of Scheduled II products. We have direct knowledge and experience in the management of Scheduled Products.
Robert A. Miller
Cost Control Solutions