Walgreens’ ‘Secret Checklist’ for Pain Meds

An investigation by an Indianapolis television station has uncovered new details about a “secret checklist” used by Walgreens’ pharmacists to screen prescriptions for opioid pain medicines. The mandatory checklist has been in place for several months and has led to many delays or outright denials in getting prescriptions for painkillers filled.


The “National Target Drug Good Faith Dispensing Checklist” requires Walgreens pharmacists to seek additional information from patients and in some cases their physicians if they have a prescription for any drug containing oxycodone, hydromorphone (Dilaudid), methadone, morphine, fentanyl or Opana.

The new policy was implemented after the nation’s largest drug store chain was fined $80 million by the Drug Enforcement Agency for violating its license and the rules for dispensing controlled substances.

The one-page checklist instructs Walgreens pharmacists and pharmacy technicians to copy a government photo ID for each patient and to run their names through a prescription drug monitoring data system.

“Inform the patient that it may take additional time to process the prescription,” the checklist states.

Possible “red flags” that could lead to the prescription being denied include:

  • A pain medication not previously filled at Walgreens
  • A new doctor writing a prescription for the same pain medication
  • A doctor writing a prescription who is not in a “reasonable geographic location” near the pharmacy.
  • A patient paying for a prescription in cash
  • A patient seeking an early refill of a prescription
  • A patient seeking an “excessive” number of pills
  • A patient taking the same pain medication for more than 6 months

Pharmacists are told to call the patient’s physician “if in your professional judgment a call to a prescriber is warranted.”

If such a call is made, pharmacists are instructed to ask the doctor to verify writing the prescription, what the patient’s diagnosis is, their expected length of treatment, and the date of their last office visit.

“Because of the legal requirements placed on pharmacists to verify that controlled substance prescriptions are issued for a legitimate medical purpose, pharmacists may need to gather additional patient information from their prescribing physician’s office.  This diligence may take extra time,” Walgreens said in a statement to National Pain Report.

“Our good faith dispensing policy is intended to be used consistently by our pharmacists for each individual prescription to determine whether the doctor’s office needs to be contacted. Our policy does not require prescriber contact for every prescription.”

Both the American Medical Association and the American Academy of Pain Management have been inundated with complaints from patients and doctors – not only about Walgreens – but about other pharmacies also making it harder for opioid prescriptions to be filled.

“Physicians in more than 20 states tell the AMA that several national pharmacy chains may be inappropriately restricting patients’ access to legitimate pain medication. Such roadblocks are creating serious barriers to patient access to needed medications – including those in hospice,” wrote Dr. Steven Stack, an AMA spokesman and former board chairman in a statement to WTHR-TV.

The American Academy of Pain Management has created an online complaint form for doctors and patients who are having trouble getting prescriptions filled at Walgreens.

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