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Veterans:Prescriptive Authority & Collaboration with Community Hospices FAQ
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 Veterans: Prescriptive Authority & Collaboration with Community Hospices FAQ

 

Can VA physicians prescribe medications for enrolled veterans receiving care from a community hospice program?

VA Handbook 1140.5 states "VA encourages the referring VA staff physician to remain as the primary care physician attending of record during community hospice care. The VA staff physician serving as attending of record for hospice care must, within the limits of ability and authority, sign relevant hospice care orders and forms, and participate with the care plan team. The care plan is controlled by the agency team, not by the physician"

Yes, writing prescriptions for non-VA formulary medications is permissible but local policy should reflect this ability. Payment for the medication may be provided by the Medicare Hospice Benefit when the veteran chooses this payer.

 

Are VA practitioners immune from personal liability when they write for a non-VA formulary medication filled under the Medicare Hospice Benefit?

VA practitioners are immune from personal liability when writing for non-VA formulary medications as long as they are acting within the scope of their employment at the VA. The VA provider writing for these medications may provide these prescriptions for veterans receiving hospice care paid for by the VA or under the Medicare Hospice Benefit depending on the veteran’s choice as outlined in VA Handbook 1140.5.

 

Can prescribers use Drug Enforcement Administration (DEA) registration numbers assigned to VA medical care facilities?

The DEA registration numbers assigned to VA medical care facilities should not be used as practitioner identifiers for the purpose of writing prescriptions to be filled in non-VA pharmacies. Prescribers’ personal DEA numbers are to be used for this purpose if required by the non-VA pharmacy. The good news here is that VA physicians can apply for a fee exempt DEA number after a VA management physician like the COS certifies they are a federal provider and acting solely on VA patients.

 

How can a VA practitioner obtain a DEA number and is there a charge?

Federal employees can register via the DEA website at http://www.deadiversion.usdoj.gov/drugreg/index.html. Fees for personal DEA numbers are waived for federal employees.

 

Can VA practitioners telephone prescriptions to private pharmacies?

This is not desirable in general and not possible for Schedule II (C-II) prescriptions. In most cases pharmacies will not be familiar with the VA providers and given an institutional DEA number, some pharmacies will not fill the prescriptions. Practitioners are, however, permitted to telephone prescriptions to private pharmacies at a VA patient’s requests, if they meet all State requirements for the state in which the prescription is being filled. Telephoning or otherwise transmitting prescriptions to private pharmacies may not be delegated to other clinical staff and must be documented in the medical record.

 

Can VA facilities create their own local prescription blanks? 

           

This is an appropriate option. In cooperation with VHA Forms staff, VA facilities can develop local prescription blanks to write prescriptions to be filled in non-VA pharmacies however these blanks are subject to the same security and control requirements as the VA prescription blanks used for internal Schedule II (C-II) prescribing.

 

What are VA practitioners required to document and how is this done?

 

 

It is an expected part of clinical care for practitioners to obtain and record a complete list of all medications currently used by patients. The Non-VA medication file has been developed and should be used for the purpose of documenting medications obtained outside the VA. It is particularly important that any medications prescribed by VA practitioners for outside fill are documented in this file.

Please contact your local VA hospice and palliative care team should you require further clarification

 

 

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9/20/2017 » 9/21/2017
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