Some More Great Comments Posted from Dr. Woliner especially about office use, physican dispensing, and pay per prescription/patient brokering!

It appears that Allergan wants to distribute through physician and optician offices, Latisse (a drug used to make eyelashes grow longer), glycolic acid peels (drugs used to remove wrinkles), acne creams, and creams used to treat age spots. By doing so, Allergan and the physician (optician) both make a heck of a lot of money, more than if the physician just wrote a prescription for appropriate patients, and let a licensed pharmacy actually dispense the drug. This is the nose under the camel' stent. In other states, including Florida where I practice, this has gone terribly wrong. Physician dispensing isn't about "making it more convenient for the patient". It is about giving the physician a financial incentive to push product, even if it isn't the most appropriate therapy for the patient. on Texas Board of Pharmacy Held an Open Forum July 2, 2014 to discuss Physican Dispensing Remove content | Delete | Spam	Kenneth Woliner, MD	at 12:00 PM
	Honestly, I wish state legislatures wrote laws that said: (1) all office-use compounding must be made by FDA-registered outsourcing facilities; (2) if a health care provider (physician, dentist, veterinarian, nurse practitioner, etc.) administers (not dispenses or distributes or resells) a compounded drug that was obtained from an FDA-registered outsourcing facility, that physician/clinic is statutorily immune from lawsuits that relate to the drug be defective (adulterated, misbranded or contaminated); And (3) the further dispensing or distribution of a compounded drug through physician (or veterinary) offices, is strictly prohibited. Furthermore, physician office cannot "act as an agent of the patient" and have compounded medications mailed to their offices for patients to pick up, nor tacan they use their physician accounts to pay the pharmacy for the medication (with the patient then paying the physician for the drugs). on Question of the Day July 4, 2014 If you leave office use under state board of pharmacy authority don't you violate the entire intent and purpose of the DQSA? Are state boards of pharmacy willing to actually enforce laws and rules Don't compounding pharmacies make a lot more money from "office use" compounding than patient-specific compounding? Where is there greater potential for fraud, waste and abuse? Remove content | Delete | Spam	Kenneth Woliner, MD	at 11:46 AM
	Anyone can say that they only distribute 5% or less of their compounded drugs through physician offices, but no one is checking! and I am sure that there are plenty of pharmacies doing more than that! but not admitting to it. Plus, what if a "mega-pharmacy" that has a national sales force has over $10 million in business per year? $500,000 of drugs (5%) is a heck of a lot of drugs shipped. on Third Question of the Day July 4, 2014 NCPA strongly supports this letter as it stresses the importance of allowing traditional pharmacies to continue to be allowed to compound small amounts of medications for office use. What does the NCPA consider to be a "small amount?" Some compounders argue about the 5% rule but it has to be a measurable amount? Remove content | Delete | Spam	Kenneth Woliner, MD	at 11:39 AM
	Pay per prescription seems so inherently wrong. It feels like "patient brokering". Especially when a sales rep is a "1099 independent contractor" vs. a "W-2 employee". Isn't this an element of patient-brokering ans a split-fee arrangement? on Those Compounding Pharmacy Representative/Marketing Representative Jobs Keep Being Announced--pay per prescription with tiered bonus payout Remove content | Delete | Spam	Kenneth Woliner, MD	at 11:32 AM
	Autocorrect makes it hard to catch typos. Sorry about that ... on Eighth Question of the Day July 4, 2014 Which state has passed the most aggressive compounding pharmacy legislation in an attempt to clean up an industry gone bad? Michigan? Florida? Which state has done the best job of stepping up enforcement of the compounding pharmacy laws? Which states have made no attempt to pass new, better legislation? Which states have drug their heals on enforcing compounding phamacy regulations? Remove content | Delete | Spam	Kenneth Woliner, MD	at 11:29 AM
	Not Florida. They might say, "compounding pharmacies cannot distribute compounding drugs to physician offices for further resale/distribution/dispensing", nut they do not enforce it. I am registered as a dispensing practitioner, but once have they inspected my office. And myself, as a patient, was offered, by both my family doctor and dermatologist, compounded prescriptions dispensed directly from their offices. No enforcement, no protection of patients. Now, due to some pretty vigorous complaining about the lack of enforcement and the lack of protection of patients,there has been a shakeup at the Florida Department of Health Bureau of Enforcement. Over the last two (2) years, several DOH employees have been replaced. Gone are Susie Love (Chief, Bureau of Enforcement ); Amie Rice (Chief, Consumer Services Unit); Jeanne Clyne (Chief, Investigative Services Unit); and Renne Alsobrook (Chief, Prosecution Services Unit). Does this mean that the Department of Health will start enforcing on Eighth Question of the Day July 4, 2014 Which state has passed the most aggressive compounding pharmacy legislation in an attempt to clean up an industry gone bad? Michigan? Florida? Which state has done the best job of stepping up enforcement of the compounding pharmacy laws? Which states have made no attempt to pass new, better legislation? Which states have drug their heals on enforcing compounding phamacy regulations?