American Epilepsy Society Comment on
Therapeutic Substitution of Medications
April 3, 2020
Several governors have issued or are considering emergency proclamations that
permit a pharmacist to make therapeutic substitution of medications without
physician approval, should medication shortages occur.
The American Epilepsy Society (AES) strongly encourages pharmacists to make
every effort to keep patients with epilepsy on their current regimen of antiseizure
medications (ASM). Pharmacists should consult with the patient’s
prescriber/healthcare provider prior to making any therapeutic substitution of ASM.
Generic substitution of ASM has been shown to be safe and is appropriate for
patients with epilepsy. While the AES appreciates efforts to ensure patients receive
medications during the COVID-19 crisis, there are important concerns for
individuals with epilepsy that make therapeutic substitutions of ASM less than
optimal and possibly harmful. For many patients with epilepsy, it is very difficult to
balance seizure control with adverse effects and drug-drug interactions of ASM.
Additionally, ASM have a wide range of mechanisms of action, pharmacokinetics,
adverse effect profiles, and drug interactions. While almost all ASM have similar
FDA approved indications, individual patients with the same seizure classification
may have very different clinical responses to the same medication. In addition,
many patients require multiple adjustments of ASM, particularly when given in
combination, to achieve optimal outcomes.
AES shared this comment with the following organizations with requests for consideration of
dissemination to members: American College of Clinical Pharmacy (ACCP); American Pharmacists
Association (AphA); American Society of Consultant Pharmacists (ASCP); American Society of
Health-System Pharmacists (ASHP); College of Psychiatric and Neurologic Pharmacists (CPNP);
National Alliance of State Pharmacy Associations (NASPA); National Association of Boards of
Pharmacy (NABP); National Community Pharmacists Association (NCPA); National
Pharmaceutical Association (NPhA); and Pediatric Pharmacy Association (PPA).