Pharmacy Jurisprudence

Transcription

1 Pharmacy Jurisprudence For pharmacists in states with a pharmacy law continuing education (CE) requirement. Index: 2 The DEA Opines on Corresponding Responsibility of Pharmacists Accreditations (Pharmacy): This continuing pharmacy education activity has been approved by the Ohio State Board of Pharmacy for Ohio Board-approved jurisprudence and accredited by ACPE for law-related continuing education for pharmacists and technicians. Credit(s): 1.0 contact hours (0.1 C.E.U.) Release Date: August 17, 2011 Expiration Date: May 13, 2013 Cost: $15.00 Select CE is accredited by the Accreditation Council for Pharmacy Education as a provider of continuing pharmacy education. Except for states of ID, NV, and OR, which each have special state board requirements. Programs in this booklet are acceptable for mandatory law CE in states of AZ, CT, MA, NJ, OH, and UT, and in all other states which recognize ACPE accreditation.

2 Program Title: Target Audience: The DEA Opines on Corresponding Responsibility of Pharmacists All Pharmacists and Pharmacy Technicians Release Date: August 17, 2011 Expiration Date: May 13, 2013 Ohio State Board of Pharmacy Program No.: ACPE Program No.: H H03-P knowledge-based activity H03-T knowledge-based activity Accreditations: This continuing education activity is approved by the Ohio State Board of Pharmacy for 1.0 contact hours, or 0.10 C.E.U. s, of continuing pharmacy education in Board-approved jurisprudence. This program is also accredited by ACPE for pharmacists and pharmacy technicians under our trade name Select CE. Select CE is accredited by the Accreditation Council for Pharmacy Education as a provider of continuing pharmacy education. Media: Enduring print material and interactive test-taking at Fee Information: $15.00 Estimated Time to Complete the Activity: 60 minutes Procedures: To receive a Statement of Credit, read this program, complete the post-test questions and evaluation on the Answer Sheet, and either: i) mail the Answer Sheet and the program fee of $15.00 to us. You will receive a Statement of Credit mailed to you within 2 weeks. Checks or money orders are encouraged. Mail to: Pharmacy Jurisprudence, P.O. Box 21186, Columbus, Ohio Refunds are generally not provided. or ii) use our online test-taking website Follow the instructions on the website, using any major credit card to pay the $15 program fee. Upon passing the test, you will receive immediate confirmation via , and your official Statement of Credit will be sent via U.S. mail within 5 days but in most cases within 2 days. Refunds are not Pharmacy Jurisprudence, L.L.C. and Select CE 2011 All rights reserved. Page 2

3 provided, unless you mistakenly make too many online payments or some such other online snafu. A minimum score of 70% is required to earn a Statement of Credit. Faculty: Patricia A. Nussle, R.Ph., J.D., is the founder of Pharmacy Jurisprudence and Select CE. She is also a healthcare attorney who has written and published continuing education programs in pharmacy law and nursing law for over 200,000 healthcare professionals since Disclosure of Commercialism, Unlabeled Uses, Bias, Conflicts of Interest: Prior to the delivery of the content, we will disclose any commercial support, and we do so here: No commercial support was requested or accepted for developing or presenting this program. All development, printing, and mailing costs, as well as accreditation services and fees, come solely from your program fees. No unlabeled uses of drugs are discussed in this program. Faculty Patricia A. Nussle, Pharmacy Jurisprudence and Select CE have no real, apparent, or potential conflicts of interest or financial relationships to disclose, other than that Patricia A. Nussle is the owner of Pharmacy Jurisprudence and Select CE, and she warrants that she presents this information fairly and without bias. Objective: At the conclusion of this program, pharmacists should be able to list factors found in corresponding responsibility failures according to the DEA. Objective: At the conclusion of this program, pharmacy technicians should be able to list factors found in corresponding responsibility failures according to the DEA. Important Note: Colleagues, this is a continuing education program. It is not legal advice. Do not rely on this CPE program as legal authority. If you do have a legal problem or question, please consult an attorney experienced in pharmacy law matters to discuss your specific situation. Questions? Call us at (614) , or us at patti@selectce.org. Thank you! We truly enjoy serving you. Pharmacy Jurisprudence, L.L.C. and Select CE 2011 All rights reserved. Page 3

4 The DEA Opines on Corresponding Responsibility of Pharmacists Summary Under federal law and under nearly each state s law, pharmacists have a corresponding responsibility with the prescriber for the proper prescribing and dispensing of controlled substance medications. What is this corresponding responsibility? It arises from the Drug Enforcement Administration ( DEA ) regulations which state that "[a] prescription for a controlled substance to be effective must be issued for a legitimate medical purpose by an individual practitioner acting in the usual course of his professional practice. The responsibility for the proper prescribing and dispensing of controlled substances is upon the prescribing practitioner, but a corresponding responsibility rests with the pharmacist who fills the prescription." 1 DEA s regulation applies only to controlled substances prescriptions. As a federal regulation it is applicable to prescriptions in all 50 states. Yet, some state boards of pharmacy have expanded this rule so that it applies to all prescriptions, not just controlled substance prescriptions. This is true for Ohio 2, but Massachusetts, New Jersey, California 3 and most other states follow the DEA and limit the pharmacist s corresponding responsibility to controlled substance prescriptions only. A pharmacist s corresponding responsibility is so important that a state board of pharmacy recently stated: [Corresponding responsibility] is axiomatic in the pharmacy profession. This means that a pharmacist must review every prescription for legitimacy and must then make a professional judgment on whether or not to fill the prescription. Every pharmacist is accountable to this Board and to society for what he knew or should have known due to professional training, 1 21 CFR (a) 2 OAC MGL c94c: section 19(a); N.J.A.C. 8:65 (Chapter 65 of Title 8, Controlled Dangerous Substances, was recodified as Chapter 45H of Title 13, effective March 17, 2011); Cal. Admin. Code tit. 16, 1761 Pharmacy Jurisprudence, L.L.C. and Select CE 2011 All rights reserved. Page 4

5 experience, licensure, and continuing pharmacy education in pharmacy law. 4 And yet, in the same case in which the board of pharmacy made its above proclamation, the state appeals court stated: There is sparse Ohio case law regarding the scope of a pharmacist s corresponding responsibility to properly dispense prescription medicine; however federal courts have developed substantial case law in the context of criminal prosecutions under the federal Controlled Substances Act 5. and the state court went on to apply federal court interpretations of a pharmacist s corresponding responsibility. Because corresponding responsibility is so important to daily pharmacy practice, and yet the case law applying this responsibility in the states tends to be sparse, we present this continuing education Question 1: Courts have examined corresponding responsibility as used in the pharmacy profession: a) Sparsely in state courts, such as Ohio s; b) Substantially in federal courts in regards to controlled substance prescriptions; c) Both of the above are true. program. The goal is to help pharmacists, as well as all healthcare providers and especially our pharmacy technicians, better understand this important legal rule under which pharmacists must operate every day. 4 at 37 and at 52. Pharmacy Jurisprudence, L.L.C. and Select CE 2011 All rights reserved. Page 5

6 The DEA Opines on Pharmacists Corresponding Responsibility 6 The Drug Enforcement Administration ( DEA ) is charged with enforcing our nation s laws respecting narcotics and controlled substances. The DEA has more than 5,200 Special Agents and a budget of over $2.6 billion to enforce the federal controlled substance laws. 7 Of special interest to pharmacists and technicians, the DEA recently published a decision that considers the scope of a pharmacist s corresponding responsibility under federal law found at 21 C.F.R (a). The case is an affirmance of a suspension order, and can be found at (Docket No ) (75 Fed. Reg (Oct. 27, 2010), but for purposes of this program we will call the case and the retail pharmacy involved simply The Pharmacy. As background, the Code of Federal Regulations provides that while the responsibility for the proper prescribing and dispensing of controlled substances is upon the prescribing practitioner... a corresponding responsibility rests with the pharmacist who fills the prescription. 21 C.F.R The regulation further states, the person knowingly filling such a purported prescription, as well as the person issuing it [is] subject to the penalties provided for violations of the provisions of law relating to controlled substances. The DEA interprets this regulation to mean that a pharmacist is prohibited from filling a prescription for controlled substances when he either knows of or has reason to know that the prescription was not written for a legitimate purpose Fed. Reg. at Further, the DEA has further stated that when prescriptions are clearly not issued for legitimate medical purposes, a pharmacist may not intentionally close his eyes and thereby avoid [actual] knowledge of the real purpose of the prescription. Id. Pharmacists are well trained and aware of their corresponding responsibility. They must only fill valid prescriptions for controlled substances issued by a legitimate practitioner for a legitimate medical 6 Taken from John Gilbert and Karla Palmer on their law firm s blog at From 75 Fed Reg to 66165, which can be found at Pharmacy Jurisprudence, L.L.C. and Select CE 2011 All rights reserved. Page 6

7 purpose. Nevertheless, the standard for what exactly is and, specifically, what exactly is the extent of -- a pharmacist s corresponding responsibility has been a troublesome concept. Admittedly, the pharmacist in The Pharmacy matter allegedly engaged in misconduct, and the case involved one bad doctor (who the Deputy Administrator called a drug dealer ). And, although this may be a case where over-the-top facts indeed make bad law, pharmacists and those who write controlled substance prescriptions should be mindful of The Question 2: The Drug Enforcement Administration ( DEA ): a) was created by Executive Order of President Carter; b) has enforcement ability over laws respecting narcotics and controlled substances; c) has enforcement ability over laws respecting all prescriptions. Question 3: Under federal regulations: a) the responsibility for the proper prescribing and dispensing of controlled substances is upon the prescribing practitioner... a corresponding responsibility rests with the pharmacist who fills the prescription; b) the person knowingly filling such a purported prescription, as well as the person issuing it [is] subject to the penalties provided for violations of the provisions of law relating to controlled substances; c) both of the above are true. Pharmacy opinion because in it the DEA has taken significant strides to clarify the scope of a pharmacist s corresponding responsibility. First, faced with pharmacist s assertion that the corresponding responsibility standard is vague, unknown and ambiguous, the DEA stated that the standard is constitutional: Federal courts have had little Pharmacy Jurisprudence, L.L.C. and Select CE 2011 All rights reserved. Page 7

8 problem applying the DEA regulation, which gives fair notice that certain conduct is proscribed. Id. The DEA next addressed certain red flags that should have given the respondent pharmacist a reason to know that the prescriptions patients presented to him were not legitimate. Importantly, the DEA did not focus on whether the pharmacist in The Pharmacy had actual knowledge that the prescriptions were not issued for a legitimate medical purpose, but instead whether the pharmacist had reason to know [they] were not issued for a legitimate medical purpose by a practitioner acting in the usual course of professional practice. Id. at DEA s Ten Red Flags The DEA hired an expert to select and review 10% of the prescriptions seized in a DEA raid on The Pharmacy. The expert chose the prescriptions of fifty-five (55) patients filled by the pharmacist at The Pharmacy between September 13 and February 9 of the following year. Id. at In reviewing the pharmacist s conduct, the DEA s expert testified and the DEA Administrator found that the pharmacist ignored several signs that the prescriptions written by a certain physician were not legitimate. These red flags include the following: (1) ample evidence showing that the pharmacist repeatedly dispensed cocktailed prescriptions for oxycodone, hydrocodone, alprazolam, and carisoprodol and finding that this combination of prescriptions is well known in the pharmacy profession as being used by patients abusing prescription drugs. Indeed, the government s expert stated that pharmacists refer the combination of the benzodiazepine, the narcotic * * * pain killer, and the sleeping pill as [t]he triple, and that when Soma (carisoprodol) is added, the combination is known as the homerun. Noting that the prescriber was writing two prescriptions for schedule II narcotics, the government s expert testified that he had never seen two schedule II narcotics prescribed together, other than for treatment of cancer or hospice patients. Id at In his report to the DEA, the expert noted that there were three patients who received three narcotic pain killers on the same Pharmacy Jurisprudence, L.L.C. and Select CE 2011 All rights reserved. Page 8

9 day and that [t]here is no logical reason why the patient would be on two or three narcotic pain killers at the same time. Continuing, he explained that this is a major red flag which is strongly suggestive of abuse and that [n]o reasonable pharmacist would fill two or three of these prescriptions on the same day. (discussing M.C., who on the same day received prescriptions for Percocet 10/325, Norco 10/325, and oxycodone 30 mg.). Id at (2) no individualization of dosing by the prescribing physician. As to the prescriptions for schedule III hydrocodone/apap drugs, the government s expert noted that 100% (89/89) were for the highest strength available, which is 10 mg. of hydrocodone. Id at Observing that it was clinically impossible that all the patients in the sample would always need the highest possible dose of hydrocodone with acetaminophen, the expert thus concluded that there was no individualization of dosing based on pain in these patients, which should have been a major red flag for any pharmacist. Id. Moreover, [a]ny pharmacist would have known that this was a problem and a strong indicator of a doctor operating a controlled substance prescribing mill. Id. And the expert observed that [m]any of the narcotic prescriptions had the words severe LBP on them, which most likely stands for Severe Low Back Pain. Explaining that [l]ower back pain is viewed in the medical field as the biggest scam to obtain controlled substances because it is the hardest to disprove due to the lack of definitive clinical measures, he reported that [i]t is very unusual that all these patients had the same diagnosis and they all had to be on the maximum doses of these controlled substances including Soma. Id at (3) filling multiple prescriptions for the strongest formulations of hydrocodone and alprazolam. With respect to the Xanax (alprazolam) prescriptions, one of the most highly abused benzodiazepines on the market and a drug in high demand on the street, the government s expert observed that all sixty prescriptions were for the maximum strength of the drug. Id at Moreover, ninety-three percent of the prescriptions exceeded the FDA approved maximum daily Pharmacy Jurisprudence, L.L.C. and Select CE 2011 All rights reserved. Page 9

10 dosage of 4 mg. per day and thirty-two percent exceeded the FDA approved dosing schedule of three times a day. Id. At the hearing, the government expert explained that Xanax 2 mg is generally only prescribed to patients with post-traumatic stress disorder. Id. at (4) requests for early dispensing of refills. There were several instances of refill-too-soon cited by the government expert as indicia of the pharmacist s failure to fulfill his corresponding responsibility. These instances were early refills for patient L.B., who on December 28 received a Xanax prescription two weeks early; and S.K., who, on September 13 received a prescription for 240 tablets of oxycodone 15 mg., with eight tablets to be taken per day (thus being a thirty-day supply), and who, one week later, obtained an additional 168 tablets of the same drug. Moreover, patient M.P. filled two prescriptions for Percocet 5/325 on the same day, and patient L.A.T. filled two prescriptions for oxycodone on the same day. Id. at (5) refilling prescriptions of patients or doctors located 100 miles away from the pharmacy. The allegations against The Pharmacy cited the pharmacist for filling prescriptions for controlled substances to persons who were travelling substantial distances to obtain the drugs. More specifically, the Immediate Suspension Order alleged that on October 2, L.D.C., a resident of Portsmouth, Ohio obtained from a physician practicing in Wheelersburg, Ohio, prescriptions for 90 tablets of oxycodone 30 mg and 60 tablets of carisoprodol (a noncontrolled but highly abused drug which metabolizes into meprobamate, a Schedule IV depressant), and that she then travelled approximately 100 miles from Wheelersburg to Columbus and filled the prescriptions at The Pharmacy. The Order alleged that the next morning, L.D.C. was found dead at her residence * * * with a prescription vial identifying [the pharmacist] as the dispensing pharmacy and several scattered oxycodone tablets * * * next to her body, and that the Coroner s Office had preliminarily determined that she died from the * * * probable toxic effects of drugs (oxycodone, carisoprodol and others). Id. at Pharmacy Jurisprudence, L.L.C. and Select CE 2011 All rights reserved. Page 10

11 The Immediate Suspension Order also alleged that on various dates including July 3, September 1, and October 1, the pharmacist had filled various prescriptions for oxycodone issued to S.J.P., of Waverly, Ohio. The Order alleged that Waverly, Ohio is approximately 64 miles from Columbus and that the prescriptions were issued by physicians who practiced in Lees [sic] Summit, Missouri, as well as in Dayton and Portsmouth, Ohio, which are 78 and 92 miles, respectively, from the pharmacist. The Order thus alleged that the pharmacist knew or should have known that the above dispensed controlled substances were likely to be diverted or used for other than legitimate medical purposes and that [b]y dispensing such prescriptions, [the pharmacist] failed to fulfill its corresponding responsibility for the proper dispensing of controlled substances. Id. at (6) a large proportion (75%) of prescriptions filled by the pharmacy were controlled substances prescriptions written by one particular physician, and this particular physician wrote controlled substances 95% of the time. The DEA does not address examine these factors in detail, but includes these factors in its discussion of how some patients drove great distances from their home or from their physician to get their prescriptions filled by the pharmacist. Id at (7) the pharmacist did not reach out to or otherwise contact other pharmacists to determine why they were not filling a particular doctor s prescriptions. This factor was also not discussed at length by the DEA, but there is testimony from the pharmacist that he did not communicate with other pharmacists. Id. at (8) filling prescriptions of patients that travelled to the pharmacist in groups. Again, this factor was not discussed in this case, but it is noted that patients travelled to one particular physician and then to the pharmacist in groups. Id. at (9) filling a larger percentage of cash prescriptions. The government s expert testified that forty of the fifty-five patients Pharmacy Jurisprudence, L.L.C. and Select CE 2011 All rights reserved. Page 11

12 (73%) had paid cash for their prescriptions and that the national average of cash paying customers for prescriptions [was] 11.4% in 2005 and 10% in Explaining that profit margins on cash prescriptions are 30% higher than insurance prescriptions for brandname[] drugs and 100% to 500% higher than insurance prescriptions for generics, he concluded that this is an obvious example of a pharmacy profiting from drugs that are most likely being abused or diverted for sale on the street and that [a]ny reasonable pharmacist knows that a patient that wants to pay cash for a large quantity of controlled substances is immediately suspect. Id. at (10) verification of a prescription as legitimate was not satisfied simply because the practitioner said so and performed MRI s and blood tests on the patients. One federal court of appeals has found that a pharmacist who calls a physician to verify the legitimacy of a prescription almost always, before the call, does not have the knowledge of legitimate medical use. Otherwise, why would the pharmacist make the call? While after the phone call the pharmacist most often does have verification of the prescription s legitimacy, it is not an insurance policy. As the Fifth Circuit has explained, while [v]erification by the issuing practitioner on request of the pharmacist is evidence that the pharmacist lacks knowledge that the prescription was issued outside the scope of professional practice[,] * * * it is not an insurance policy against a fact finder s concluding that the pharmacist had the requisite knowledge despite a purported but false verification. See United States v. Hayes, 595 F.2d at 258, 261 (5 th Circuit 1979). And it was not an insurance policy for this pharmacist either. In an interview with a DEA Investigator, the pharmacist admitted that he had questions about one particular physician but that he was satisfied because the physician told him that he did MRI and blood tests. The pharmacist s employees also testified that some of the physician s patients complained that he was requiring them to undergo blood or urine tests. Still, the DEA found that This sliver of evidence provides no reason to ignore the overwhelming evidence against [the pharmacist]. Id. at Pharmacy Jurisprudence, L.L.C. and Select CE 2011 All rights reserved. Page 12

13 While noting that the pharmacist had called the physician to verify his legitimacy, as well as a local attorney to inquire about [the physician s ] reputation in the community, that he had called other prescribing physicians to verify prescriptions, and that he required customers to show identification prior to dispensing controlled substances the Administrative Law Judge concluded that [the pharmacist s] failure to react to the red flags raised by the conduct of [the physician s] patients and the dispensing patterns the [pharmacist] used for these patients weigh in favor of revocation. Id. at Presented with the above evidence, the DEA stated that even if the pharmacist had verified with the physician each and every prescription, the evidence showed he still violated his corresponding responsibility because many of the prescriptions patently served no legitimate medical purpose. The DEA s opinion at 75 Fed Reg states: In an interview with a DEA Investigator, [the pharmacist] admitted that he had questions about [this particular physician] but that he was satisfied because [the physician] told him that he did an MRI and blood tests. However, as found above, [the pharmacist] repeatedly dispensed drug cocktails for multiple controlled substances including oxycodone, hydrocodone, and alprazolam, as well as carisoprodol, a combination which is widely known in the pharmacy profession as being popular with drug abusers, and it did so in such quantities that any reasonable pharmacist would have asked how the prescriptions could possibly serve a legitimate medical purpose. The Government s Expert also explained that these cocktails would have a synergistic effect on a person s central nervous system and could cause respiratory depression. Accordingly, even if [the physician] told [the pharmacist] that he did blood tests and MRIs, this would not make the prescriptions any more legitimate. This alone supports the conclusion that [the pharmacist] violated Federal law in dispensing the [physician s] prescriptions. 21 CFR (a). The other evidence such as that related to the quantities of the various drugs being Pharmacy Jurisprudence, L.L.C. and Select CE 2011 All rights reserved. Page 13

14 prescribed, the dosing, and lack of individualization of therapy; the distances the patients were travelling and the typical method of payment; the fact that [the pharmacist] knew that other pharmacists had refused to fill [the physician s] prescriptions; the percentage and number of [the physician s] prescriptions that were for controlled substances is simply icing on the cake. Moreover, even after a DEA Investigator had interviewed [the pharmacist] and asked him if he found it suspicious that [the physician s] patients were travelling long distances to fill their prescriptions, [the pharmacist] proceeded to fill numerous oxycodone and alprazolam prescriptions for residents of [one state] who had travelled to [another state] to obtain the prescriptions. Indeed, even one of [the pharmacist s] employees was skeptical as to whether these were legitimate prescriptions. While [the pharmacist] contends that [he] stopped filling prescriptions issued by Florida pain-clinic physicians after he received a state board of pharmacy notice, [the pharmacist] did not testify in this proceeding and so has failed to offer any explanation as to why he filled the prescriptions in the first place. Furthermore, a responsible DEA registrant should be able to make these determinations without the authorities having to provide the information to him on a silver platter. 9 Here we see the DEA stating that the single fact that the pharmacist dispensed high quantities of commonly abused drug cocktails containing oxycodone, hydrocodone, and alprazolam and carisoprodol should have called into question the legitimacy of the prescriptions. Pain experts would certainly argue that in many cases DEA's red flags are in fact the basis for legitimate pain treatment, e.g., the pain cocktail is often prescribed because of the anxiety and muscle tension experienced by pain patients. However, pharmacists must be attentive to these factors, red flags, or signs -- as part of their corresponding responsibility to fill only prescriptions that are issued for a legitimate medical purpose. 9 Id at Pharmacy Jurisprudence, L.L.C. and Select CE 2011 All rights reserved. Page 14

15 Question 4: According to the DEA, red flags that should have given a pharmacist reason to know that a controlled substance prescription is not legitimate include: a) prescription cocktails of controlled substances; b) not reaching out to other pharmacists to see why they were not filling a particular doctor s prescriptions; c) both of the above are true. Question 5: According to the DEA, red flags that should have given a pharmacist reason to know that a controlled substance prescription is not legitimate include: a) requests for refills too soon for controlled substances; b) filling prescriptions for the strongest doses of alprazolam and hydrocodone; c) both of the above are true. Question 6: According to the DEA, red flags that should have given a pharmacist reason to know that a controlled substance prescription is not legitimate include: a) travelling to the pharmacy in groups; b) travelling long distances to the pharmacy from home or the physician s office; c) both of the above are true. Question 7: According to the DEA, even if a pharmacist verifies with a physician each and every prescription, other evidence can show: a) that the pharmacist did not fulfill his duty of corresponding responsibility; b) that many of the prescriptions served no legitimate medical purpose; c) both of the above are true. Pharmacy Jurisprudence, L.L.C. and Select CE 2011 All rights reserved. Page 15

16 Question 8: According to the DEA, red flags should give a pharmacist reason to know that a controlled substance prescription is not legitimate even if the pharmacist: a) notes individualization of dosing by the physician; b) verifies with the practitioner that MRI s and lab tests were being performed on patients; c) fills an overwhelming number of non-controlled substance prescriptions. Question 9: According to the DEA, red flags should give a pharmacist reason to know that a controlled substance prescription is not legitimate even if: a) the pharmacist calls the physician to verify the prescription; b) the prescription is not for a controlled substance. Question 10: According to the DEA, the single fact that a pharmacist dispenses high quantities of commonly abused drug cocktails containing oxycodone, hydrocodone, and alprazolam and carisoprodol should call into question the legitimacy of the prescriptions. a) No, because the single fact of high quantities of some prescriptions can never call into question the legitimacy of other prescriptions; b) Yes, unless the pharmacist stopped dispensing the high quantities to pain clinic patients when he received a notice to do so by the state board of pharmacy; c) Yes, even if the pharmacist stopped dispensing high quantities to pain clinic patients when requested to do so by the state board of pharmacy. Pharmacy Jurisprudence, L.L.C. and Select CE 2011 All rights reserved. Page 16

17 Return this ANSWER SHEET with the $15.00 Program Fee payable to: NAME: ADDRESS: CITY, STATE and ZIP: Pharmacy Jurisprudence, LLC P.O. Box Columbus, Ohio NABP e-profile ID: Month and Day of Birth: ANSWERS: The DEA Opines on Corresponding Responsibility of Pharmacists Expiration Date: May 13, 2013 Circle the answer for each question (questions are imbedded in the program). 1. a b c 6. a b c 2. a b c 7. a b c 3. a b c 8. a b c 4. a b c 9. a b 5. a b c 10. a b c 11. Pharmacists: After completing this program, I am able to list factors found in corresponding responsibility failures according to the DEA. Yes No 11. Technicians: After completing this program, I am able to list factors found in corresponding responsibility failures according to the DEA. Yes No 12. This program was an effective way for me to learn: Yes No 13. I liked the program s format: Yes No 14. This program fostered my mental participation: Yes No 15. This was a user-friendly way for me to learn: Yes No 16. I could sense some commercialism in this program: Yes No If yes, please describe: 17. The faculty quality was: Great OK Needs to Improve 18. The learning material quality was: Great OK Needs to Improve 19. How long did it take to complete this program? 20. What other topics would you like to see? 21. Would you like to receive future publications from us? Yes No Pharmacy Jurisprudence, L.L.C. and Select CE 2011 All rights reserved. Page 17