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.
This article was provided by the Veterinary Information Network.
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