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Let’s face it, the day to day operations of working in a dental practice can get crazy! The dentist can be pulled in three different directions and, as dental team members, we try our best to keep them on track. There’s times when a patient needs a prescription for medication and the dentist needs the office staff to help facilitate that process. Did you know that not just any ol’ staff member can help with this process? Have you ever heard of a Designated Agent?
A Designated Agent is “an authorized person who acts on behalf of or at the direction of a manufacturer, distributor, or dispenser or prescriber.” The dentist, also known as the Registered Agent, cannot appoint the Designated Agent until they complete the proper screen, train and document their designated team members. Let’s explore this!
First, potential Designated Agents must be properly screened by the Registered Agent (dentist). The DEA recommends not using staff that has been convicted of a felony offense related to controlled substances, someone that has been denied a DEA registration, has ever had a DEA registration revoked or has surrendered a DEA registration. If the candidate passes this screening, a Designated Agent form needs to be filled out by the Registered Agent (dentist) and Designated Agent (dental team member). This form includes information such as the Registered Agent’s name, DEA number, practice name, date, Designated Agent’s information, witness signatures, and signatures of the Registered Agent and the Designated Agent. The last part of this form states that revocation can happen at any time or upon separation of employment.
Next, it is recommended that the Designated Agent have controlled substance training and that the Registered Agent create/maintain records of the training. Designated Agents are allowed to prepare a written prescription for the signature of the practitioner as long as the practitioner has determined the legitimate medical purpose and has also given the Designated Agent the patient of record’s name, date, address, drug name, drug strength, quantity, directions for use and the name, address and DEA number of the issuing practitioner. The practitioner must sign, not stamp the completed prescription after review.
Designated Agents are also allowed to:
- call the pharmacy and give information regarding a Schedule III-V controlled substance prescription after the practitioner has made a valid oral prescription by conveying all of the information required.
- fax a Schedule III-V controlled substance to a pharmacy with the practitioner’s valid, completed and signed prescription.
Designated Agents are NOT allowed to:
- determine who gets a prescription or why. Only the registered practitioner can make this diagnosis.
- sign a prescription, only to prepare one for a signature for the prescribing practitioner.
- call in a Schedule II controlled substance on behalf of a practitioner even during an emergency situation.
Having one or more Designated Agents in your dental practice can be an asset. However, it’s a big responsibility and one that should not be taken lightly. With the proper training staff members can communicate with pharmacies to make the prescription process more efficient for both the practitioner and the patient.
In the words of former President Ronald Reagan, “Trust, but monitor.” Trust your staff, but monitor your state’s Prescription Monitoring Program to verify that no improper prescriptions are processed using your controlled substance authority.