STATE OF OHIO
BOARD OF PHARMACY
Delivery by Opioid Treatment Programs
Updated 3/18/2020
To address patient access to medication assisted treatment during the COVID-19 outbreak, the State of Ohio Board of Pharmacy has adopted the following guidance regarding delivery of patient medications by an opioid treatment program (OTP).
This guidance is being issued in accordance with a Board resolution adopted on March 2, 2020.
In the event an OTP patient is quarantined due to coronavirus or suspicion of coronavirus (including those who have household members under quarantine), the Board authorizes an OTP to deliver take-home medication. Deliveries must comply with the following requirements:
1. Must be conducted by any of the following authorized delivery personnel:
a. Two employees of the OTP;
b. A physician, pharmacist, or nurse employed/contracted by the OTP; or
c. A law enforcement officer or national guard member.
2. Any medication taken off the premises of the OTP for delivery must be in a substantially constructed lock box to prevent unauthorized access.
3. The OTP should always communicate with the patient prior to delivery to reduce risk of diversion, including:
a. Call placed to the patient prior to staff delivery departure ensuring that the patient or their approved designee is available to receive the medication at the address provided by the patient. The address for delivery must be the same as that which is recorded in the patient's OTP medical record.
b. Upon arrival, medication is delivered to the patient's residence door and another call is made to the patient/designee notifying that the medications are at the door.
c. The authorized delivery personnel are to retreat a minimum of 6 feet to observe that the medications are picked up by the patient or the designated person to receive the medications.
i. Delivery personnel must ask the person who is retrieving the medication to identify themselves.
ii. Delivery personnel should determine that the person appearing to retrieve the medication is the patient or the person named by the patient as having permission to do so.
iii. Delivery personnel who deliver the medication should remain until retrieval of the medication by the designated person has been observed.
iv. Delivery personnel must expressly document, using positive identification (i.e. signature or initial of the delivery personnel), that medications were received by the individual identified as permitted to pick up the medication.
d. Do not leave medication in an unsecured area. Delivery personnel must remain with the medication until the designated individual arrives and retrieves the medication.
e. If the person who is to receive the medication is not at the designated location, an attempt should be made to reach the person. If the person does not arrive in timely manner (this wait period will need to be determined by OTP policy), then the delivery personnel must bring the medication back to the OTP where it will be stored in the dispensing area until a determination is made by the OTP as to whether another attempt will be made to deliver medication.
i. Any medication returned to the OTP must be logged in.
ii. The medication delivery and pick up by the designated person or return of medications to the OTP must be documented in the patient's OTP record and appropriate pharmacy records.
For additional federal guidance on home delivery visit: https://www.deadiversion.usdoj.gov/GDP/(DEA-DC-015)%20SAMHSA%20Exemption%20NTP%20Deliveries%20(CoronaVirus).pdf
This guidance, as is authorized by the Drug Enforcement Administration, shall remain in effect until the Secretary of Health and Human Services (HHS) rescinds the declared public health emergency.
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