PRP Insights: Documentation Requirements for Emergency Prescription Refills
In our Practice Review Program, Compliance Officers have come across questions from pharmacists regarding documentation requirements for emergency prescription refills (“emergency supplies”). As per Professional Practice Policy 31: Emergency Prescription Refills:
- Pharmacists must use their CPBC pharmacist registration numbers in the PharmaNet practitioner ID field to identify the responsible decision-maker when providing an emergency supply of a drug to a patient
- Pharmacists must document in the client’s record any emergency refill of the prescription, the rationale for the decision, and any appropriate follow-up plan
Confusion has occurred around what is sufficient documentation for a rationale and follow-up plan:
Rationale: This refers to the reasoning behind your decision. Simply stating “continuity of care” alone is insufficient because that is already an assumed requirement of an emergency prescription refill and does not give any additional information about the scenario or why you made the decision. Every scenario is different and the details affect whether it’s appropriate to provide an emergency supply at all, and if so how much to give. For example, the patient may have run out of medication, or the patient goes to the pharmacy for an authorized refill of a valid prescription but PharmaNet returns the message “101 Prescriber not found”.
*Example of rationale documentation: “Patient ran out of medication, her doctor is away this weekend. The dose is stable and the drug is currently effective with no issues”
Follow-up plan: This refers to the need of documenting what happens after the emergency supply is used up. Lacking a documented follow-up plan leaves the situation open-ended, where there’s no resolution or plan of action for patient care and continuity of therapy. For example, is the patient going to see the doctor for a new prescription? Does the patient have an appointment with the doctor or knows to make one before the emergency supply is used up? Or is the patient expecting the pharmacy to contact the doctor for a refill? Documentation of a follow-up plan removes ambiguity and serves to reinforce the rationale and appropriate course of action.
*Example of follow-up plan documentation: “Patient will make an appointment to see her doctor next week for a new prescription”
*The above documentation examples are for illustrative purposes only. The level of detail expected varies with each scenario and is based on professional judgement.