July 7, 2021 New Medication Disposal Regulations Can Help Long-Term Care Communities Lower Costs With many long-term care (LTC) communities already struggling with staff shortages, rising salaries, declining resident census, and other challenges, new government regulations can seem like just one more burden. However, changes to federal medication disposal regulations can actually help assisted living facilities, skilled nursing facilities, memory care facilities, and other providers realize significant savings. If your facility would like to save money on medication disposal, including hazardous waste pharmaceuticals (HWP) and labor costs, review our recent white paper: Cost-Saving Solutions for Compliant Medication Disposal in Long-Term Care Communities We explain how key provisions of the following laws and regulations apply to LTCs: Secure and Responsible Drug Disposal Act of 2010 2014 Disposal of Controlled Substances, Final Rule Management Standards for Hazardous Waste Pharmaceuticals and Amendment to the P075 Listing for Nicotine (EPA Pharma Management Rule) You’ll learn how LTCs can lower costs by using on-site medication collection or mailback options for unused pharmaceuticals, including HWPs. Many facilities may realize significant cost savings. For example: Labor costs: LTCs utilizing on-site pharmaceutical collection receptacles could save as much as $10,000 annually, per community, in salary expenses for the time it takes two RNs to prepare medications for disposal via a multi-step process, as opposed to the simple solution of placing medication wastes into a collection receptacle. Disposal costs: Communities utilizing drug disposal receptacles or mailback packages could potentially realize a savings of nearly $12,000 annually, per community, by consolidating all their medication disposal options into a single solution. Would your facility like to reduce costs without cutting staff or patient services? Download our white paper to learn how Sharps Compliance can help you manage your pharmaceutical waste disposal. Read More
September 22, 2020 Disposal of Controlled and Non-Controlled Medications in Long-Term Care Communities Last updated on June 14, 2021 This is an update of the article originally published on October 9, 2014. Regulations change frequently. That’s why Sharps Compliance monitors updates and communicates any changes to its customers. On September 9, 2014, the Drug Enforcement Agency published the Disposal of Controlled Substances Final Rule, which went into effect on October 9, 2014. This new rule allowed registered collectors to place DEA-compliant drug collection receptacles in long-term care facilities (LTCFs) for the collection and disposal of ultimate-user controlled substances (Schedules II-V). “Best Practices” for Medication Disposal Have Changed Many people aren’t aware that EPA guidelines and state/local environmental regulations strongly discourage many common medication disposal methods, including: Flushing medications: In addition to the EPA’s new rule, the sewering of hazardous waste pharmaceuticals is explicitly forbidden. The DEA also states that the flushing of controlled substances does not meet their non-retrievable standard for disposal. A 2013 EPA study estimated over 46 million Americans could be potentially exposed to up to 4.4 daily doses of an active pharmaceutical ingredient from their wastewater treatment plants. Other studies have shown changes in aquatic life such as gender changes in fish, due to pharmaceuticals in the water. Mixing medications with kitty litter or coffee grounds: The purpose of mixing medications with kitty litter or coffee grounds is to mask the medications, but eventually, the mixture ends up in a landfill where the pharmaceuticals can cycle back into the water. Additionally, the process is time-consuming and often messy — not the best use of a community’s best resource: nurses. Like flushing, this form of disposal likely does not meet the DEA’s non-retrievable standard of disposal. To learn more about how landfilling of medications harms both people and the environment alike, read our article on this topic. Chemical Solutions May Increase Disposal Costs Chemical solutions that break down the compounds on-site are relatively new options. These solutions are messy, release a foul odor, require nurses to remove, or “pop,” pills one at a time from blister packs or other packaging. Additionally, these methods of destruction do not meet the DEA’s non-retrievable standard, given the medication does not fully dissolve or takes days to dissolve. Anyone who has ever struggled to remove a single pill from a blister pack knows that this can be a difficult and time-consuming task. In fact, this type of disposal solution can cost a community upwards of $10,000 annually in nursing salary alone.1,2 Figure 1: After seven days, medications treated with a chemical solution were emptied into a plastic bag. The pills were removed from the plastic bag and rinsed off, but the pills were still not liquefied. Nurses must also take time to completely block out Personal Health Information on the packaging to comply with HIPAA before placing that packaging into the trash — overall, consuming even more valuable staff hours and increasing potential facility liability. Lastly, if chemical solutions are used for the disposal of hazardous waste, controlled, and non-controlled medications, then they must be disposed of by a hazardous waste provider, given the presence of hazardous waste pharmaceuticals and the unknown resulting conglomeration of waste. It causes the customer to “double pay” for disposal: once to purchase the pouch and then a second time to dispose of it by a hazardous waste provider. Sharps Compliance Offers Safe Medication Disposal Options for LTCFs Long-term care facilities can now utilize a DEA compliant drug collection receptacle or provide mailback solutions to residents for safe disposal of their medications, including controlled and non-controlled medications. Sharps Compliance has been at the forefront of safe mailback and on-site pharmaceutical collection options. We can help LTCFs safely dispose of unused/unwanted medications and stay compliant with the DEA. LTCFs have two options for the disposal of comingled controlled and non-controlled substances: collection receptacles or mailback envelopes/boxes. We offer both a collection receptacle program (MedSafe™) and a mailback solution (TakeAway Medication Return System™). As the DEA has stated, “the DEA has considered the diversion risks and determined that the installation and maintenance of collection receptacles by authorized hospitals/clinics and retail pharmacies is the most secure and responsible means by which registrants may collect and dispose of LTCF residents’ pharmaceutical controlled substances.” Collection Receptacles for Medication Disposal As outlined in § 1317.60 of the Disposal of Controlled Substances Regulations, a collection receptacle is a substantially constructed container with a permanent outer container and a removable inner liner. Collection receptacles must be securely fastened to a permanent structure, and the outer container shall include a small opening that allows contents to be added to the inner liner but does not allow removal of the inner liner’s contents. LTCFs can utilize a collection receptacle for medication disposal, provided that an authorized collector manages the program. A collector is a DEA registrant that has been approved to administer drug collection programs at an LTCF. The collector for the community is the managing pharmacy that provides medication for the residents (retail, closed-door, or hospital/clinic with an on-site pharmacy). While the collection receptacle is physically located within the community, the authorized collector will manage the program. Program management includes inserting inner liners into the collection receptacle, removing and sealing inner liners for disposal, and documenting a step log of the procedures. Note: No LTCF can operate a collection receptacle program without an authorized collector managing the program. The removable inner liners, once sealed by the authorized collector, can be stored on-site at the community for up to three business days per the DEA regulations. The inner liners are returned via common carrier to a registered treatment facility for proper destruction. With the goal of diversion as a main concern of the DEA, all steps outlined above are conducted by two people — either two employees from the authorized collector pharmacy or one employee from the authorized collector pharmacy and a second supervisory-level employee from the LTCF. Mailback Medication Disposal For LTCFs where residents manage their own medications, specially-designed mailbacks can be used for disposing of controlled substances. The resident places their medication into the mailback, seals it, and gives it to USPS for direct return shipping to the registered collector for destruction. Our 10- and 20-Gallon TakeAway Environmental Return Systems™ are optimal mailback solutions for communities where residents are managing the disposal of their own non-controlled, non-hazardous medications. To learn more about the 2014 Disposal of Controlled Substances Final Rule and options for a collection receptacle or mailback program for your communities, please contact Sharps Compliance at 800.772.5657 or visit our MedSafe website. Additionally, Sharps Compliance continues to offer both medical and hazardous waste management services. For more information on medication disposal in LTCFs, read our other articles: This white paper was co-written by Sharps Compliance and Senior Housing News: “Medication Disposal in Senior Living: Understanding New Regulations.” Our white paper, “Requirements for Long-Term Care Facilities Under the EPA’s Pharmaceutical Rule,” describes in detail how the new EPA rule affects LTCFs. In this video interview, Sharps Compliance’s Director of Regulatory Compliance discusses new EPA regulations and their implications for LTCFs. 1 Working hours per year = 2087 based on Policy, Data, Oversight. Fact Sheet: Computing Hourly Rates of Pay Using the 2,087-Hour Divisor. The U.S. Office of Personnel Management. 2 Salary estimates based on Salary Guide: Nurses 2018 & 2020 Salary Survey Results: An Elite Healthcare Resource Guide. (2018, 2020). Elite Healthcare. Read More
January 22, 2020 Cost-Effective Medication Disposal in Long-Term Care This is an update of the article originally published on November 3, 2015. Regulations change frequently. That’s why Sharps Compliance monitors updates and communicates any changes to its customers. Nurses practicing in senior care have very busy work schedules. From caring for residents to distributing medications and updating records, their days can become overwhelming. One of the most important tasks is the disposal of unused medication. When a resident’s medication is permanently discontinued, per the 2014 Drug Enforcement Agency’s (DEA) Disposal of Controlled Substances Final Rule, it must be properly disposed of within three business days. Prior to the 2014 DEA regulation updates, the most common ways to dispose of a resident’s medication was either flushing medications down the sink or toilet (sewering) or placing them into a drug disposal pouch and placing it into the trash. However, these options are costly, inefficient, and unsafe for the environment. Reducing costs is key to the success of any business. So, paying Clinical Directors, Directors of Nursing, and nurses up to $50/hour to pop pills out of blister packs to flush them down sinks or toilets or place them into disposal pouches is certainly not the best use of their time, skill set, and salary expense. This practice can cost a community upwards of $14,000 annually in nursing salary alone. Additionally, the ability to streamline disposal options for multiple medication waste streams can reduce the expense of managing multiple disposal solutions by over $2,700 annually. This action reduces disposal solutions from four or five solutions down to only two. Secondly, sewering drugs or placing them into disposal pouches are an inefficient use of the highest-paid staff’s time and efforts. Nursing Directors, Clinical Directors, and nurses in the long-term care setting are spending, on average, 4 hours a week removing pills from their packaging in order to prepare them for disposal, which takes significant time away from direct resident care. Also, after disposing of the pills, the staff is still responsible for disposing of the medication packaging in a HIPAA compliant manner to protect the resident’s protected health information, further contributing to time away from residents in need. Lastly, neither sewering nor disposal pouches are environmentally friendly disposal options. In August 2019, the EPA Management Standards for Hazardous Waste Pharmaceuticals and Amendment to the P075 Listing for Nicotine made it illegal to sewer hazardous waste pharmaceuticals in all 50 states due to the environmental hazards. Plus, there have been several studies published on the fact that medications are showing up in our water streams and that water treatment facilities are not equipped to remove pharmaceuticals as part of their treatment processes. Furthermore, though used drug disposal pouches are designed to be placed directly into the trash, many states have outlawed businesses from landfilling such waste since there is no way to verify the sludge contents within the pouch, which has implications for leachate and its impact on the environment. So, businesses not only pay for the pouches themselves but then must pay a second time to dispose of the pouches as regulated or hazardous waste, which is extremely costly. Fortunately, thanks to the promulgation of both the DEA and EPA rules, there are more efficient, environmentally safe, and cost-effective methods to dispose of controlled, non-controlled, and hazardous waste pharmaceuticals (HWPs) upon adoption of the new EPA rule by each state. The first is the use of a DEA-compliant drug collection receptacle like our MedSafe. With MedSafe, there is no need for your highest-paid employees to spend their time popping pills for disposal. Rather, you simply dispose of the blister pack or pill bottle full of controlled, non-controlled, or HWPs (once the state has adopted the new EPA rule) into the securely locked collection receptacle, which provides the extra benefit of reducing the possibility of diversion. Once the inner liner is full, it is sent directly to our treatment facility via prepaid postage by common carrier. Upon receipt, all liners are incinerated, meeting the DEA and EPA disposal standards. Plus, since all contents are incinerated, the resident’s protected health information is destroyed in a HIPAA compliant manner. Like MedSafe, the DEA also allows for individuals to utilize mail-back envelopes, like our TakeAway Medication Recovery System Envelopes, in their home to dispose of their unwanted medications, controlled and non-controlled, via USPS. An individual simply takes the nondescript envelope, fills it with their unwanted medication bottles and blister packs, seals the envelope, and places it in the mailbox or gives it to the mail carrier. With the prepaid postage, the envelope is sent directly to our treatment facility, where it is incinerated – again, meeting the DEA and EPA destruction standards as well as HIPAA. By using MedSafe or TakeAway Medication Recovery System Envelopes, communities will not only remain compliant with DEA, EPA, and HIPAA, but they also save long-term care communities money, potentially as much as $17,000 annually, with the reduction in the various expenses related to medication disposal. Additionally, these easy, efficient, and time-saving methods of disposal will give nursing staff their valuable time back to care for residents rather than spending their time popping pills out of blister packs. Contact us today at 800.772.5657 to learn more about how we can help your community save money on medication disposal. Read More
November 20, 2019 New Video Puts the Spotlight on Medication Disposal in Long-Term Care Facilities Last updated on April 13, 2021 The EPA’s new rule regarding pharmaceutical waste disposal means that many long-term care (LTC) facilities will have to change their current practices and train employees on the new regulations. In an interview with McKnight’s Long Term Care News, Sharps Compliance’s Director of Regulatory Compliance, Wanda Lingner, explains how the new EPA rule will affect senior living facilities. “Long-term care currently has a myriad of different disposal options. Flushing used to be the way that LTCs could easily dispose of unused medications, but that no longer is allowable per the EPA’s new rule. Now the question is: how do they manage the different types of pharmaceutical waste in the most compliant manner?” How indeed? Lingner answers common questions and concerns that LTC facilities have about compliance under the new rule and how the changes will affect their operations. What are the different methods for medication disposal in long-term care facilities? How does MedSafe save long-term care communities money and staff time? How does the EPA’s new pharmaceutical rule affect medication disposal in long-term care? Watch the interview to learn how it can help your facility streamline medication disposal while making the process safer for residents, the community, and the environment. Get more detailed information about the EPA’s new pharmaceutical rule in these articles: Better options for safe medication disposal in senior living facilities Read our white paper on the EPA’s new hazardous waste pharmaceutical rule EPA’s new pharmaceutical rule: reasons and origins EPA’s new pharmaceutical rule takes effect 8/12/2019 Read More
October 23, 2019 No More Flushing: Better Options for Safe Medication Disposal in Senior Living Facilities Last updated on April 13, 2021 Many senior living providers aren’t aware that some common medication disposal methods may actually be putting them at risk from a compliance standpoint while reducing operational efficiency and eroding the bottom line. A new white paper published by Sharps Compliance and Senior Housing News explains how “best practices” in medication disposal are changing and how senior living providers can benefit from new, safer pharmaceutical disposal options. The new white paper discusses: Proper medication management disposal in senior living communities The latest disposal regulations from the EPA and DEA Cost-saving methods Environmental considerations In particular, the paper addresses the common practice of “sewering,” or flushing medications down the toilet. This disposal method does not meet the Drug Enforcement Agency’s “non-retrievable” standard for destruction of controlled substances. In February 2019, the EPA issued a rule titled “Management Standards for Hazardous Waste Pharmaceuticals and Amendment to the P075 Listing for Nicotine,” which explicitly urged all senior living facilities to stop flushing all medications. There are better medication disposal options that are safe, compliant, and affordable. Learn more about them when you download our free white paper. Read More
