Coordinating With Pharmacies to Reduce Diversion Risks

Introduction: Closing the Gaps Between Prescriber and Dispenser

The chain of custody for controlled substances doesn’t end when you sign the prescription—it continues through the pharmacy.

Working closely with pharmacists not only improves patient care, it also strengthens diversion prevention.

Think of the pharmacy as your compliance partner, not just a vendor.

Step 1: Build Relationships With Local Pharmacists

• Introduce Yourself – Establish direct contact with the pharmacists who fill your patients’ prescriptions.
  
• Share Your Compliance Philosophy – Let them know you value patient safety and adherence to all regulations.
  
• Encourage Open Communication – Make it clear they can contact you with any concerns about prescriptions.
  

Step 2: Share Relevant Information

While respecting HIPAA:

• Flag high-risk patients or unusual prescribing situations (with patient consent where required).
  
• Confirm patient-specific agreements, such as one-pharmacy rules for controlled substances.
  
• Provide context for atypical dosing or formulations when appropriate.  More communication with your patient’s pharmacist is far better than less.
  

Step 3: Collaborate on Red Flags

Pharmacists often see diversion warning signs first:

• Patients attempting early refills.
  
• Multiple prescriptions from different providers.
  
• Forged or altered prescriptions.
  
• Unusual patterns in medication type or quantity.
  

When alerted:

• Investigate promptly.
  
• Document the communication and outcome.
  
• Adjust patient management plans if needed.
  

Step 4: Leverage Prescription Monitoring Programs (PMPs)

• Encourage pharmacists to check the PMP before dispensing.
  
• Compare your records to PMP data regularly.
  
• Use PMP findings to initiate discussions with the pharmacy about questionable patterns.
  

Step 5: Coordinate on Prescription Logistics

• Use electronic prescribing for controlled substances (EPCS) to reduce forgery risks.
  
• For complex cases, call the pharmacy directly to confirm instructions.
  
• Align refill schedules to minimize surplus medication in the community.
  

Step 6: Participate in Joint Education

• Offer to share your controlled substance policies with pharmacists.
  
• Ask pharmacists to explain any dispensing safeguards they use so you can align your practice’s processes.
  
• Consider co-hosting patient education initiatives on safe use and disposal.
  

Step 7: Create a Feedback Loop

• Ask pharmacists to notify you of patient non-adherence or potential diversion indicators.
  
• Provide feedback when you take corrective actions so they know their input is valued.
  
• Maintain a record of all pharmacist communications related to controlled substances.
  

Common Mistakes to Avoid

• Treating Pharmacists as Outsiders – This limits information sharing and weakens the safety net.
  
• Failure to Communicate Unusual Prescribing Decisions – Leaves room for confusion or suspicion.
  
• Ignoring Pharmacy Concerns – Can damage trust and compliance credibility.
  

Benefits of Coordinated Efforts

• Stronger diversion prevention.
  
• Faster detection of problem behaviors.
  
• Improved patient safety and continuity of care.
  
• Better regulatory defense if prescribing is questioned.
  

Final Thoughts: A Two-Way Street

Pharmacies are your last checkpoint before controlled substances reach the patient.

By treating pharmacists as partners—and maintaining open, respectful communication—you close critical gaps in the diversion prevention process.

When prescribers and pharmacists work together, fewer medications end up where they don’t belong.

About the Author

Douglas J. Jorgensen, DO, CPC, FAAO, FACOFP

Dr. Doug is a physician, consultant, and national educator on healthcare compliance, controlled substance management, and diversion prevention. He helps providers build collaborative systems with pharmacies to protect patients and reduce regulatory risk.