Want to provide an excellent service to your community and stand out from the crowd? Starting a medication collection program is an excellent, low-cost way to do so. It also increases foot traffic to your pharmacy, so if you even have only a few patients per year transfer their prescriptions after coming in to drop off medications you have more than paid for the cost of the program.
In short, a medication collection program is a win-win: it is good for your patients, good for the community, and good for business. It is also much less time-consuming to implement than many programs that community pharmacies can offer.
Here are the options and your guide to implementing each one (and no, I am not including 'throw in the trash with coffee grounds' - I mean options that will truly dispose of the medication in a safe and environmentally-friendly way).
One final note: these programs are not intended for pharmacies to use for their own stock. For full bottles, you can send them back through your reverse distributor. For broken tablets and capsules without a stock bottle, you may need to use a deactivating system. Drug Buster is one of the most popular.
Drug Buster is one of the most popular ways for pharmacies to dispose of their own stock that reverse distributors won't take
Activated charcoal pouches
A good example of these are the pouches available from Mallinckrodt. Each pouch can hold 10-15 pills, which is not practical in most situations but for physician office use or the occasional medication issue it can help.
I have had, for example, people come to the pharmacy to turn in a vial of prescription medication (sometimes for medications that have abuse potential) because they found it on the street. For obvious reasons the best option is definitely not to refuse to help them dispose of it, so that is a good example of a time when the pouches can come in handy (although if you have a receptacle you will not need them).
Other times the pouches can be helpful is when a prescription is written for a medication that patient realizes they cannot take after picking it up (which, in spite of confirming the medication with them, still happens) and tries to bring it back to the pharmacy. There is no state that will allow pharmacies to accept medication back to re-dispense (and it is a violation of USP's General Notices and Requirements), of course, but some states go further than that and do not allow the pharmacy to accept medication back for any reason.
As in the above case, without some safe way to dispose of the medication it leaves the pharmacy and pharmacist in a sticky situation:
1) Take the medication back to dispose of it in spite of the Board rule (of course risky)
OR
2) Tell the patient you can't do anything to help them, knowing it could end up on the street?
If you have a pouch to give them it resolves the situation. They are a fast and easy item to obtain and even if your ultimate goal is to get a collection receptacle these still could be a great option in the interim.
At the very least, if you work closely with any providers, it is worth suggesting to them to order a few for their office to have on hand.
Mail-back program
Mail-back programs have much of the same advantages and disadvantages as the activated charcoal pouches. They can be readily ordered either online or from a distributor so are quick to implement.
In the case of envelopes they also, though, add in the additional step of having to mail it out. If your pharmacy either has a USPS drop-off bin or is in a shopping mall/complex with convenient access to one that will help, but many patients simply don't want to go through the extra hassle of going to the post office.
A good example, and probably one of the most common, is this TakeAway Medication Disposal System.
They are also available in larger boxes, like this one, that allow the pharmacy to accept large amounts from multiple patients and take the responsibility for mailing it out, which would eliminate that barrier and improve participation in the program.
Lastly, controlled medications cannot be disposed of through these systems because they do not meet DEA requirements for the disposal of controls. That unfortunately is a big disadvantage and makes these products less than ideal.
DEA Annual Takeback Program
As most of you know, the DEA holds a twice-annual Drug Takeback Event in April and October. It is great for the pharmacies because the DEA coordinates the entire thing and will take any medications, no questions asked (I know for a fact because I have used it before - the police offers involved are not there to look at what is in each vial or take any inventory; patients can just drop them in their bin for secure disposal).
The downside is that it only happens twice per year and many patients are not willing to hold on to medications that long; furthermore, they only have a limited number of sites at each event and they are not always convenient.
You can help with this even by:
Advertising the events with flyers, etc. in the pharmacy and
Register as a participating site (if you don't currently have a collection receptacle)
Collection Receptacles
The Secure and Responsible Drug Disposal Act was passed in 2010, the DEA established a final rule on it in 2014, and in doing so pharmacies were allowed to setup medication collection receptacles (or take back bins) for patients (legally "ultimate users") to dispose of their medications. One important note with this is that pharmacies are not defined as 'ultimate users' and thus are not allowed to dispose of their own stock of medications in the bin. They must continue to utilize their reverse distributor.
Medication take back receptacles are by far the best option for community pharmacies. Overall patients have much higher participation with these because they cost nothing (to the patient), are the most convenient, and are available whenever the pharmacy is open. Once setup they do not have the limitations the other options have.
Your vendors will help guide you through setup and most will provide you with policies, forms, etc. for you to use. I would recommend talking to vendors as soon as you decide to implement the program, but in general here are the steps necessary:
Step 1. Check state laws
Be sure your state allows medication take back programs. Florida, for example, does allow it but at least for a while had a separate section on their community pharmacy inspection form for participating pharmacies.
Step 2: Get registered with the DEA
The DEA does not require a separate registration; rather, they require adding an Authorized Collector modification of the existing registration. Here's how you get that:
Go to this website and follow the instructions. You can print out your modified registration as soon as you are finished. The DEA will then follow up by mailing you a copy of the new registration.
Get familiar with the rules in place using the DEA's Disposal Regulations: Registrant Fact Sheet. One very important point to note - pharmacies cannot use the collection bins to dispose of their inventory (this bin is for ultimate users only). I said that earlier but really want to emphasize that point.
For reference, the full page with the DEA, including both links referenced above, is available here.
Step 3: Select a vendor
To get you started, here are three vendors (among others) in the business:
Sharps Compliance, Inc.: MedSafe
Inmar: Life In Check
MedReturn, LLC: MedReturn
Also, here are some things you might want to ask when selecting a vendor:
What are both the initial and recurring costs for the program?
Do you provide help or have relationships with contractors that can help with the installation of the bin? [Keep in mind the DEA has specific rules to follow with the installation of the bin; for example, it has to be bolted to the ground with four bolts of a specified size]
Will you provide us with all the documentation we need? (Logs, policies and procedures, etc.)
What is the process for obtaining new bags and boxes to place ion the bin? [Some vendors, for example, will mail new materials automatically once you are running low. That way you will never be stuck without an inner liner for the receptacle.]
Step 4: Advertise!!
The pharmacy will automatically be listed on the DEA's directory, but NABP also maintains their own directory. It is easy to get added on their website so I recommend advertising there as well to get as much visibility as possible.
Other good places to advertise would be local newspapers, doctor's offices (doctor's offices in particular might really like having the info, which could drive traffic to your pharmacy), and even the news station. For example, with the opioid epidemic getting so much media attention, maybe you could be interviewed on the news to talk about the ways community pharmacies are fighting back? Get creative and use the take back program as a way to promote your pharmacy and help the community.
Keywords: Authorized collector, DEA, medication take back, opioids, medication safety, medication collection
