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V CVSHealth Ms . Florido March 8, 2019 Page 7 credit determination, Genco handles the pharmaceutical in accordance with manufacturer instruction . Conversely, where pharmaceuticals are inherently waste - like at the store , such as leaking items , dropped pills or dispensed medications (not on recall) , the pharmaceuticals are deemed non- creditworthy and are managed by CVS stores as hazardous waste ( see the attached flowchart, which illustrates the logic used at all CVS Pharmacies to determine whether an item is returnable to Genco) . Non- creditworthy prescription pharmaceuticals are shipped via a licensed hazardous waste transporter, and ultimately disposed at a licensed facility . Importantly, at the store - level , store colleagues are unaware of whether specific non- dispensable pharmaceuticals will ultimately receive manufacturer credit . IT systems used to process pharmaceuticals for return to reverse distributors also vary among retailers and, as a result, visibility to records varies at the pharmacy level . Whether a manufacturer issues credit for a given non-dispensable pharmaceutical varies depending on various criteria, and thus the same pharmaceutical may be issued manufacturer credit for one shipment and denied credit for the same pharmaceutical the following shipment. This highlights the benefit of using a third-party pharmaceutical reverse distributor. Retailers contract with reverse distributors to handle this tedious , ever- changing process of working with manufacturers regarding credit and handling the pharmaceuticals in accordance with manufacturer instruction. The process is simply too complex to manage at the retail store level . EPA Support : Pharm Rule As you know, U . S . EPA recently finalized its final hazardous waste pharmaceuticals rule ("Pharm Rule") , in which EPA codifies regulations affirming that "healthcare facilities , " including retail pharmacies , may use the reverse distribution process . The Pharm Rule reiterates that healthcare facilities are not required to know for certain whether they will ultimately receive credit for a particular pharmaceutical sent to the reverse distributor . We highlight key quotes from EPA ' s preamble below, which emphasizes this point : • [W] e added the phrase [to the definition of "potentially creditable hazardous waste pharmaceutical "] to clarify that the healthcare facility does not have to definitively know whether something will receive manufacturer credit but rather indicates that they should have a reasonable expectation that it will . 84 Fed . Reg . 5846 . • [W] e also note that EPA could have proposed to use the term " creditable hazardous waste pharmaceuticals , " but chose to use the term "potentially creditable hazardous waste pharmaceutical " to convey the same concept (i . e . , that a healthcare facility does not have to definitively know whether a specific item will receive manufacturer credit . ) 84 Fed . Reg . 5846 . C;" pharmacy / caremark / minute clinic / specialty