BY
NORMAN J CLEMENT RPH., DDS, NORMAN L. CLEMENT PHARM-TECH, MALACHI F. MACKANDAL PHARMD, JOSEPH SOLVO ESQ., REV. C.T. VIVIAN, JELANI ZIMBABWE CLEMENT, BS., MBA., WILLIE GUINYARD BS., BRAHM FISHER ESQ., JOSEPH WEBSTER MD., ESTHER HYATT PHD., MICHELE ALEXANDER, CUDJOE WILDING BS, MICHELLE LYNN CLARK RPH., DEBRA LYNN SHEPHERD, BERES E. MUSCHETT, STRATEGIC ADVISORS
” WE ARE PHARMACISTS, NOT DRUG DEALERS “
https://www.wesh.com/article/special-report-pharmacies-denying-legitimate-prescriptions/4439866#
THE DARK SIDE OPERATIONS OF THE DEA
The testimony in this article is that of Richard James Alpert, a Diversion Investigator for the United States Drug Enforcement Agency. His title of Diversion Investigator is but a deception because he failed to do the obvious and what is required of an Investigative law enforcement officer: knowing the laws and ignoring the truth:
JUDGE DOWD: “And is it your job, is it part of your investigation in these cases to reach out to the prescribing physicians to determine if there’s a legitimate medical reason to justify the prescription, the opioid or whatever that’s actually prescribed? Is that part of your investigation?“
DI ALBERT: ” That wasn’t part of my investigation. No sir.“
ALL PRESCRIPTIONS ARE VALID
Pronto Pharmacy LLC, At Cost Pharmacy of Fort Myers, FL, Gulf Med Pharmacy of Cape Coral, Florida, and Oak Hill Pharmacy of Oak Hill, West Virginia, to this date, have neither violated nor broken any laws. All control medications in these pharmacies have been dispensed according to CSA guidelines, and licensed medical/dental practitioners legally wrote all prescriptions filled by these pharmacies.
According to Michael Krause, Law Professor at the George Mason University, Scalia Law School, an article on December 27, 2021, in Wall Street Journal titled, A Case Against Walmart Mocks Justice, “The federal government sues the chain for filling valid prescriptions in compliance with state law” (2)
” Under the Constitution’s Supremacy Clause, the former prevails when there’s a contradiction between valid federal and state law. But there’s no federal law requiring that Walmart pharmacists refuse to fill prescriptions that state law requires them to fill. The Controlled Substances Act creates only two circumstances in which pharmacists commit a federal crime by filling facially valid prescriptions for controlled substances.“
” First, if they “knowingly fill” a prescription that wasn’t issued by a doctor “in the usual course of professional treatment”—for instance, if a doctor hands out his entire Rx pad without examining any patient. Second, if they fill a prescription outside the “usual course of” pharmacy practice—for instance, if a “pill mill” dispenses opioids without checking the DEA number of the prescribing doctor. Not only isn’t Walmart being sued for such infractions; it has adopted innovative opioid-stewardship programs and worked with law enforcement agencies including the DEA to root out corrupt doctors.”
As written on December 29, 2020, by the Wall Street Journal Editorial Board which was in a stark rebuke of the United States Department of Justice (DOJ) lawsuit filed in federal court in Delaware, claims that:
” Walmart “failed to detect and report at least hundreds of thousands of suspicious orders” and that as a pharmacy, it “unlawfully filled thousands upon thousands of invalid controlled-substance prescriptions.” These actions enabled opioid abuse and “helped fuel a national crisis,” the feds say. (1)
“The complaint further alleges:
“Violations of the Controlled Substances Act and its accompanying regulations ” is a 160-page exercise in scapegoating a company because it is well-known and has deep pockets. Walmart doesn’t push pills on opioid addicts. Its pharmacists fill valid prescriptions written by doctors who are licensed by their states and registered with the Drug Enforcement Administration (DEA).” (1)
Similarly, in the actions of Pronto Pharmacy LLC, Tampa, Florida, the DOJ/ DEA has shown absolutely NO proof these prescriptions written by licensed practitioners and patients having been diagnosed with a disease condition are illegitimate. Neither the DOJ/DEA found any prescription medications were being diverted for non-medical use.
The Form
Both Walmart and Pronto Pharmacy had implemented internal procedures unique to their specific operations to detect fraudulent prescriptions. The Wall Street Journal Editorial Board further wrote on December 29, 2020:
“When Walmart’s pharmacists catch a prescription that appears fraudulent or forged, they are trained to refuse to fill it and document the incident. Walmart says it has passed tens of thousands of leads about suspicious prescriptions to state and federal law enforcement. It’s the job of the DEA and state medical boards to investigate and revoke doctors’ licenses and prescribing privileges if there’s wrongdoing.”
The Form: A Memorandum For Record
Pronto Pharmacy also had a required “Form” (MEMORANDUM FOR RECORD) in which every patient with any type of prescription had to fill out. The Form was used along with the National Prescription Drug Monitoring Program to screen for suspicious activity of control medications.
The Form was very successful in detecting fraudulent prescriptions and groups engaged in “pharmacy shopping” for diversion purposes. People who were up to “no good” would turn around and leave when they were made aware of the Memorandum For Record “The Form” and the consequences of not being truthful.
Richard James Alpert was knowledgeable of the Pronto Pharmacy “Form” and its purpose. Yet, Mr. Alpert chose not to consider “The Form” as a component of deterring suspicious activity. The dismissal of the purpose of the Pronto Pharmacy “Form” by Mr. Alpert is further indicative of his lack of completing a thorough investigation and failure to get to the truth.
As noted from Mr. Albert’s court testimony, he, in fact, didn’t talk with any prescribing physicians or their patients. Richard James Alpert had been made aware and also had full knowledge that not one person who came to Pronto Pharmacy got any prescriptions filled out without filling out the form, and everyone received a consultation as well as paid a $25 one-time consultation fee.
The Form was evaluated by Pharmacist Daniel Buffington of Tampa, Florida, and he agreed with Pronto Pharmacy’s implementation of this Form as part of their prescription intake procedure. Buffington further felt Pronto Pharmacy should charge for this service as any other health professional would because it is a consultation, a memorandum for record. (5)
The violation of the Pronto Pharmacy Form did cause some people to go prison. More importantly, any suspected fraudulent activity identified and proven by the pharmacist was forwarded to their Attorney who communicated directly with the law enforcement department and/or State Attorney Offices. The Form was part of The Pronto Pharmacy Standard Operation Procedure as a mechanism in place to prevent diversion. The Form is a Memorandum For Record which could be used by any Court to identify the Patients intent.
- Who
- What
- When
- Where
Both the National Prescription Drug Monitoring Program and the Pronto Pharmacy Form were always used together to detect and report suspicious “unlawfully invalid controlled-substance prescriptions.” Both Diversion Investigator Richard James Alpert and so-called Pharmacist diversion expert Donald R. Sullivan were well aware of the Pronto Pharmacy Form and that all patients who came to Pronto Pharmacy were required to complete “The Form.”
FIGURES DON’T LIE, BUT LIARS DO FIGURE
However, Dr. Sullivan was suspicious of the patient questionnaire used by the subject pharmacy. The questionnaire inquired whether the patient lived more than 100 miles from the pharmacy. Dr. Sullivan opined that this reason was insufficient to resolve the red flags.
The questionnaire contained a certification to be made by the patient, certifying that “I am taking all of my medication prescribed.” Dr. Sullivan deemed this certification ineffectual in resolving the red flags of early fills and of diversion. A further statement by the patient that, “I am not selling any of my medication,” did not alleviate any concerns that the patient may have been diverting his medication. (5)
Indeed, Dr. Sullivan suspected the question exposed a subterfuge by the pharmacy, revealing the pharmacy believed patients were selling their medications and the question was designed to relieve the pharmacy of any liability. If a pharmacist believes a patient is selling his/her medications, the pharmacist should not fill any further prescriptions for that patient.
RICHARD JAMES ALBERT AND DONALD SULLIVAN’S TESTIMONY OF BIAS AND FRAUD
Donald Sullivan’s testimony amounted to unsubstantiated fraudulent rubbish and bias. He nor Richard James Alpert took the time to investigate the origins of The Form. The Form was approved by the Pharmacy Attorney.
Dan Buffington, PharmD, MBA of Tampa, Florida, has been selected as President-Elect of the Florida Pharmacy Association for 2020-2021. Dr. Buffington is President and Practice Director of Clinical Pharmacology Services in Tampa and is also on the University of Florida College of Medicine and Pharmacy faculty. (5)
He served for 6 years on the Board of Trustees of the American Pharmacists Association (APhA) and represents pharmacists on the American Medical Association’s Current Procedural Terminology (CPT) Editorial Panel. He served for 5 years as a medication safety expert with the US Centers for Medicare and Medicaid Services on the Healthcare Reform team in the CMS Innovation Center and the Center for Clinical Standards and Quality (CCSQ) focused on improving health outcomes, patient safety, and alternate payment models. (5)
Thus, the testimony of both Donal Sullivan and Richard James Albert demonstrates their gross incompetence and failure to investigate. If these two had been investigated, they would have easily found the people of Pronto Pharmacy LLC always adhered to the rules, regulations, and laws that govern pharmacy.
We demand that the CSA certificate of Pronto Pharmacy LLC. be returned unrestricted and that both Alpert and Sullivan be removed from employment by the Federal Government for fraudulent misrepresentation and abuse of authority.
JUDGE DOWD: And is it your job, is it part of your investigation in these cases to reach out to the prescribing physicians to determine if there’s a legitimate medical reason to justify the prescription, the opioid or whatever that’s actually prescribed? Is that part of your investigation?
DI ALBERT: That wasn’t part of my investigation. No sir.
Mr.Sisco: Okay. So you talked to the patients, right?
DI Albert: Did I talk to the patients?
Mr.Sisco: Yes, sir.
DI Albert: No, sir
Mr.Sisco: You didn’t talk to the patients?
DI Albert: No, sir
CROSS-EXAMINATION
BY MR. SISCO
Q. Good morning, Mr. Albert
A. Good morning.
Q. We’ve met before on a number of occasions, is that right?
A. Yes, sir.
Q. And in the 12 weeks of training that you received as a diversion investigator you were taught to be thorough in your investigation, correct?
A. Yes, sir
Q. And to gather as much information as you can to support an allegation that you were investigating, correct?
A. Yes, sir
Q. And in this case, you followed that training, is that correct?
A. Yes, sir
Q. So it was important for you to make sure that everything that you did that you documented was an accurate reflection of your investigation efforts, right?
A. Yes, sir
Q. All right, And you ran down available leads
A. What are you referring to?
Q. Well, you know, I presume that as part of your investigation, you looked to see whether there was any information that was contrary to other information you’d come up with in the case, right?
A. I’m not sure exactly what you’re referring to.
Q. You would want to know if there was some information that was out there that differed from the conclusions that you’d reached, right?
A. I’m not sure what you’re asking as far as…
Q. Well, let’s make this basic.
A. Okay.
EXPOSING THE DEA’S FRAUDULENT RED FLAG ANALYSIS
DEA Diversion Investigator Richard Albert prepared a warrant based on red flags that Pronto Pharmacy engaged in manufacturing controlled substances. This was an assumption that a crime was committed within the Pronto Pharmacy. Pronto Pharmacy is a licensed pharmaceutical company by law that can compound medications. Yet, through the process of creative deceptive prosecutions, the United States Department of Justice (DOJ) has sidestepped Constitutional issues based on a lack of legal standing.
As further written December 29, 2020, the Wall Street Journal Editorial Board in a stark rebuke of the United States Department of Justice (DOJ) lawsuit filed in federal court in Delaware, claims that: The Walmart DOJ complaint also includes:
” more than 190 mentions of “red flags” about suspicious opioid prescriptions. It claims Walmart often didn’t adequately resolve them and sometimes knowingly filled illegitimate prescriptions despite the warnings. But Walmart notes in its lawsuit that the Controlled Substances Act “and it’s implementing regulations do not include the concept of red flags, let alone identify any particular factors as a red flag.”
“The feds try to side-step this problem by claiming that, under the Controlled Substances Act and regulations, “the pharmacist’s conduct must adhere to the usual course of his or her professional practice as a pharmacist.” The complaint argues that catching and resolving “red flags” for opioid prescriptions is “a well-recognized responsibility of a pharmacist in the professional practice of pharmacy,” so “failing to fulfill this responsibility” is a violation of the federal law.”
However, the Wall Street Journal Editorial Board further points out:
” All of this raises constitutional issues based on a lack of legal standing. A negligence claim like the one alleged here is supposed to have a specific party claiming a specific injury caused by someone specific. Those are typically claims by one private party against another. The government can sue for violations of law, not because someone was negligent. The government’s claims of Controlled Substances Act violations are so general that they seem contrived to add some violation of the law.(1)
” In effect, DOJ is asking the federal court to overrule state law in favor of informal federal guidance and a vague notion of pharmaceutical best practices. This harassment was typical of the Obama era but it’s especially disappointing from the Trump Justice Department. The Biden Administration will be happy to run with this prosecutorial abuse.”(1)
The Six “Rights”
The six medication rights serve as the foundation of safe medication administration. The RIGHT PATIENT must be given the RIGHT MEDICATION in the RIGHT DOSE by the RIGHT ROUTE at the RIGHT TIME. The pharmacist must also ensure that the RIGHT DOCUMENTATION supports the prescription.
This involves cross-checking the prescriber’s order against the patient’s history and medical information to identify potential drug-drug, drug-disease, or drug-allergy interactions. Although electronic prescribing technology can help detect errors in medication names, dosing, and frequency, it is not foolproof. The pharmacist should verify that all elements of the order are correct (Brown, 2016).
Once the medication ordered is verified as appropriate for the patient and appropriately prescribed, the pharmacist must ensure that the correct medication in the right form and dose is provided to the patient at the appropriate time. With the vast array of drugs on the market, a prescriber or a pharmacist can’t be personally familiar with every drug’s uses, dosing, side effects, potential interactions, and other implications.
If a pharmacist is unfamiliar with a medication, he or she must consult a drug reference before dispensing the medication.
These guidelines appear on nearly every State Governing boards of Pharmacist and Pharmacy-Technician throughout the United States of America.
RETURN TO THE CROSS-EXAMINATION
BY MR. SISCO
Q. Okay? What you did was, if there was information that was in your possession that was relevant to this investigation, you wanted to make sure that you investigated that information completely; is that right?
A. Yes.
Q. Okay. So in this case you identified a number of patients whose prescription that you found to be– to raise red flags; right?
A. Correct.
Q. All right. And that’s what caused you to talk to your superiors about, you know, initiating the show cause process and retaining an expert; right?
A. Correct.
Q. Okay. So you talked to the patients, right?
A. Did I talk to the patients?
Q. Yes, sir.
A. No, sir
Q. You didn’t talk to the patients?
A. No, sir
Q. Well, wouldn’t it have been important for you to discuss with the patients whether or not they had an explanation for why they traveled to Pronto Pharmacy, for instance?
A. You could assume that, yes.
Q. Well, but you never attempted to speak with them; correct?
A. No
Q. So specifically the 11 patients that were here, you’ve spoken with them?
A. No, sir
Q. Okay. You had some concerns as a diversion investigator regarding the legitimacy of prescriptions that were issued to those patients; is that true?
A. Not necessarily the legitimacy or the actual prescription.
Q. Okay. So that wasn’t an issue that you were concerned about?
A. I’m not saying that’s not an issue. but I’m saying, not necessarily, that that was just was the main thing.
Q. All right. So you went and you had the prescriptions, right?
A. Correct.
Q. So for those 11 patients that are identified in the orders to show cause, right?
A. Correct.
Q. And that’s part of the information that you reviewed, either in the spreadsheets or by looking at the original prescriptions, you’re very familiar with that; right?
A. Correct.
Q. And so – –
JUDGE DOWD: Let me ask a question.
Mr. Albert, in looking at prescriptions what was your focus? Was it that there was a name on the prescription; that it was facially legitimate, or did you have any interest in looking into the prescription?
THE WITNESS: So when I looked at the prescription, of course I make sure it has all the information on it. What triggered suspicion was is that the prescription was written for tablets, but then on the back it was filled in capsules. So that intrigued my interest on those prescriptions.
JUDGE DOWD: And is it your job, is it part of your investigation in these cases to reach out to the prescribing physicians to determine if there’s a legitimate medical reason to justify the prescription, the opioid or whatever that’s actually prescribed? Is that part of your investigation?
THE WITNESS: That wasn’t part of my investigation. No sir.
JUDGE DOWD: Okay. I’m sorry. Go ahead, Mr. Sisco.
MR. SISCO: Well, Judge, you’re stealing my thunder.
JUDGE DOWD: Sorry. I just want to make that clear, because you asked have you looked into the prescription. And I want to know if it was just facially or if it was the history of the prescriber or whatnot.
BY MR. SISCO:
Q. So Investigator Albert, you did not go and talk to any of the prescribers; is that correct?
A. Correct.
Q. So even though you had a concern about how these prescriptions were filled, capsules as opposed to tablets, you never talked to the prescribers about whether or not the authorized that; is that correct?
A. No, I did not.
Q. That would be important information to have, wouldn’t it?
A. My best answer is yes and no.
JUDGE DOWD: Could you- – that doesn’t help us. Could you explain your answer?
THE WITNESS: Because in my investigation I do not necessarily have to talk to the prescriber based on the investigation that I perform.
BY MR. SISCO:
Q. Well, you don’t have to but you could. There’s nothing preventing you from doing that, right?
A. No. There’s nothing preventing me.
Q. All right. And so if you really j in want to get to the truth of the matter, what you do is you talk to the doctor and say; well, doctor, did you authorize the substitution of capsule for tablets on behalf of tis patient, right?
A. Yes.
Q. That’s kind of a simple, direct and straightforward way to get to the heart of this issue, right?
A. Yes.
Q. And you didn’t do it?
A. Well, I didn’t do it on one particular doctor because he was under investigation already.
Q. Okay. Then you went to Pronto Pharmacy, you observed, starting in September 17, you observed, that they were building out a sterile compounding room?
A. I observed a compounding room, yes sir.
JUDGE DOWD: And what is that? How did you know that was a compounding room? What distinguishes a compounding room from any other room in a pharmacy?
THE WITNESS: So when you go in the pharmacy, this particular pharmacy, and you walk down the hallway and you go around, it’s a whole other room. And they have what appears to be like a laboratory, if you will.
JUDGE DOWD: Like a clean room?
THE WITNESS: Yes. Kind of a clean room. So it’s a big, enclosed area where you have a door to go in then I guess where the pharmacist would do his compounding.
JUDGE DOWD: All right, thank you.
BY MR. SISCO:
Q. And when you walked in the lobby, the entrance area of Pronto Pharmacy there’s a number of signs on the wall; is that correct?
A. Yes.
Q. There’s a sign, for instance, that tells patients that the pharmacist is available for consultations with them, right?
A. I’m not sure, sir.
Q. Okay. And there’s a sign that talks about the substitution of generic equivalents, correct?
A. I’m not sure.
Q. Well, you’re aware that that’s required by Florida statutes, right? Is that part of your training?
A. Thats not part of our training, no sir.
Q. Okay. So you were concerned – _ I think you used the word “suspicious,” because of the distance some of these patients traveled in order to get to Pronto Pharmacy; is that right?
A. Yes, sir
Q. So with regards to that issue, you wanton to Google and tried to figure out how far it was?
A. Yes, Sir.
DOCTORS HAVE BECOME EASY ENFORCEMENT TARGETS BECAUSE THEY DON’T RETURN FIRE WITH ROCKET PROPELLED GRENADES OR M-50 MACHINE GUNS
SIMPLY
YOUR DOCTORS AND PHARMACIST DON’T CARRY ROCKET LAUNCHERS
We are not drug dealers
The DEA has lost the “War on Drugs” with the foreign cartels because these fellows fight back with AK-47’s, Rocket Propelled Grenades, Glock-9 handguns something your physician or pharmacist will never do. So doctors and pharmacists make easier enforcement targets and it is much safer for the agency to attack them.
These health practitioners are not drug dealers but DEA Diversion Investigators like Richard James Albert have the mindset of a serial torturer. They have creatively misinterpreted and manipulated guidelines to target, intimidate, abuse and extort, physicians, pharmacists, drug chain stores, drug manufacturers because healthcare providers don’t shoot back with real armed firepower weaponry like the drug cartels.
pharmacy-blurred-mp4“DEA DAMAGE AND DISABLE SECURITY CAMERAS”
The DEA has learned the rewards are even better against doctors, dentists, pharmacists, manufacturers, or hospitals by the uses of RICCO, through Justice Department intimidations. Further, the DEA specifically has its own Court System ( that Operates as a Kangaroo Court) which does not adhere to Federal Rules of Civil Procedures. Their Judges answer solely to the domain of the DEA Administrator.
MARIJUANA WAS THEIR CASH COW
The prosecution of marijuana (MJ) offenders had been the DEA’s cash cow from its inception which was then used to harvest hundreds of thousands of people, specifically, young black males into the prison system. As states began to allow the legalized use, lift restrictions, and decriminalize MJ the DEA’s cash cow slowly has dried up.
While Geo-politically, the drug cartels, many of whom have cleverly aligned themselves with Government Nations, often whose attitudes are of “turning a blind eye” to illegal euphoric drug medication analogs. Many of the National Governments are allied and major trade partners with the United States, and notwithstanding the facts, these Cartels are better armed.
So, the problem and enforcement of illicit productions of opioid analogs and other illicit euphoric derivatives have become far more complex.
WHY CONGRESS MUST INVESTIGATE THE ABUSES OF THE DEA AND SHUT THEM DOWN
Thus, DEA has been engaged in the practice of extortion and governmental racketeering against healthcare providers, Walmart, CVS Omnicare Inc., Walgreens, Purdue Pharma, Gulf Med Pharmacy, At Cost Pharmacy, George Tenet MD., Oak Hill Hometown Pharmacy, Lincourt Pharmacy in order to promote the good grace of Congress to fund the importance of this agency and its activities.
We Demand hearings from Congress and oversight as the activity of the DEA affects the lives of all of America during this Covid pandemic by creating disparity and shortages and the majority of the time this has been done by race.
CONCLUSION
Mr. Richard James Albert has not done the obvious, which is to investigate as required by any law enforcement investigator. The other more troubling aspects are that he (nor Donald Sullivan) never spoke with the prescribing physicians because his agenda as a Diversion Investigator was to intimidate and to close Pronto Pharmacy LLC by ignoring the truth. Richard James Albert was further angry because the owner of Pronto Pharmacy understood their constitutional rights and knew of the deceptions Alpert was portraying. (3)
There is no finding of facts that supports Pronto Pharmacy as an “imminent danger.” There are no facts to support Pronto Pharmacy as illegally manufacturing, and no facts to support continuing the Immediate Suspension Order (ISO). The DEA’s intent was to exact financial hardship on Pronto Pharmacy and its owners.
The actions of the DEA and DI Albert were clearly malicious and were targeted at shutting Pronto Pharmacy down at whatever the cost. Richard James Albert’s intent was to ignore any rules, laws, standard medical or pharmacy protocols and use his authority to facilitate the Diversion of The Truth. (3),(4),(5)
norm j clement dds______
“…racism wears many masks, it is Jim Crow one decade only to be disguised as voter ID in another century, preventing election fraud, when no fraud ever exists…when wisdom becomes a threat, the knowledgable are deem arrogant and those learned are imprisoned…in healthcare, we must lead the fight for justice by connecting the dots of injustice…uncovering the unique, cleverly designed barriers erected to inhibit people from seeking treatment and preventing those licensed professionally and whom are capable from delivering proper healthcare are required to view them as algorithms seeking care, then waging war upon both their souls and neither affording them dignity and respect…”
Joe Madison_____
” The question is??? What are we going to do about it?”
CONGRESS MUST TAKE ACTION NOW TO STOP THESE DEA ABUSES
https://www.c-span.org/video/?14263-1/jails-prisons-drugs
FOR NOW, YOU ARE WITHIN THE
NORMS
LISTEN TO WBOK 1230 AM
VIDEO THE DEA IS COMING AFTER PHARMACIST
bf966c4e-1f69-45ed-ac15-850dadfeb040-1DEA ” WE ARE GOING TO COME AFTER YOU”
END NOTES
- https://www.wsj.com/articles/scapegoating-walmart-11609285742
- https://www.wsj.com/articles/a-case-against-walmart-mocks-justice-11609103413?mod=searchresults_pos1&page=1
- https://youarewithinthenorms.com/2020/06/18/of-role-models-and-invisible-men-exposing-the-rise-and-mission-of-the-filtered-negroes/
- https://youarewithinthenorms.com/2020/06/20/of-role-models-and-invisible-men-exposing-the-rise-and-mission-of-the-filtered-negroes-part-3-exposing-dea-corruption/
- https://www.floridapharmacy.org/news/488560/Tampa-Pharmacist-Selected-for-Florida-Pharmacy-Association.
- https://www.picmonic.com/pathways/nursing/courses/standard/fundamentals-of-nursing-273/basics-of-medication-administration-1358/6-rights-of-medication-administration_1507
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