I thank Mr McAbee for his comments regarding my editorial on the role of pharmacy in controlled substance take-back programs, including the proper Drug Enforcement Administration (DEA) registration process for pharmacies to accept controlled substances with the intent of destruction.
Pharmacies interested in participating as a site to collect controlled and noncontrolled medication from users (not other DEA registrants) will need to modify their DEA registration to become an authorized collector. As long as the pharmacy is not collecting controlled substances from other DEA registrants, only from ultimate users, the pharmacy will not need to register as a reverse distributor.
This distinction is important not only because it affects which forms need to be filed with the DEA, but also because it results in the reduced fees associated with being an authorized collector. A pharmacy registered as an authorized collector will pay a 3-year fee of $731, versus the annual $1523 fee as a reverse distributor. With an annual fee of less than $250, the financial outlay is considerably less than a reverse distributor. Our hope is that this lessens the barrier for pharmacies considering participation.
Pharmacies will also need to consider new security procedures and training of employees when becoming an authorized collector to take back controlled substances from consumers. To cover certain costs, funding for Southrifty Drug as the first authorized collector was sponsored by the Southampton Business Alliance.
Inside Patient Care: Pharmacy & Clinics always welcomes feedback from readers and will receive submissions pertaining to this topic as well as any other comments from readers regarding other topics published in the issue.
(See "Letter to the Editor: Authorized Collector versus Reverse Distributor.")
