Monday, May 7, 2012

Two Key Things Regarding Compounding: Follow the Applicable State Law and Price Should Not Be A Factor

An article written by Scott Karolchyk, MS, RPh, FIACP, entitled Pharmaceticual Compounding, The Right and Responsibility fo Pharmacists to Compound , appearing in the American Journal of Mesotherapy can be read by clicking here.  Karolchyk makes two very good points: 

1.  follow the applicable state law relating to pharmacy and compounding and

2. price is not a factor; and advertisements or marketing promoting the price of compounded preparations should not be used.  If price is advertised, the FDA may view that the company is a manufacturer or wholesaler.

Here is Karolchyk's entire list of factors to remember:

The Responsibilities of Pharmacists to the Profession Patients, and Colleague

1. Operate in conformance with applicable state law regulating the practice of pharmacy

2. Ensure that your professional conduct is above reproach.
3. Practice the art and skill of compounding pharmacy to the best of your ability.
4. Know the limits of your expertise and refer to colleague on issues beyond your knowledge and skill.

5. Continue self-education to improve your standard of compounding practice.
6. When possible, accept responsibility to advance the profession of pharmacy and the practice of compounding by participating in properly developed programs,research projects, seminars, teaching opportunities, lectures, and publications.
7. When possible, accept responsibility to advance the profession of pharmacy and practice of compounding by taking leadership positions with the state association, licensing authority, college of pharmacy, national pharmacy organization, or other organizations that have as their objective the betterment of the profession of pharmacy.
8. Willingly accept responsibility to advance the professionof pharmacy and the practice of compounding by representing to lawmakers at the state and national level the policies and agendas that have as their objective the betterment of the profession of pharmacy.
9. Ensure that marketing practices, fee structures, and overall promotion of your practice are implemented in the best interest of the profession and the treatment of patients.
10. Share ideas and information with colleagues and assist them in their professional development.
11. Give credit to the contributions of your colleagues.
12. Be responsible when placing an appropriate value on your services, and consider the time, skill, experience, and any special circumstances involved in the performance of that service when determining any fee.
13. Do not deny services on the basis of race, religion, gender, disability, age, or national origin.
14. Do not dispense medications to a third entity for resale.
15. Uphold the triad relationship of patient, physician, and pharmacist as the basis for pharmacy practice.
16. Know the details of and adhere to the National Association of Boards of Pharmacy Good Compounding Practices Applicable to State-Licensed Pharmacies or other international standards.
17. Do not engage in marketing or promotional practices that:
       a. Utilize manufacturers’ names or the names of patented products
       b. Create misinformation with claims of therapeutic equivalence
       c. Create misinformation by perception that compounded products are generic products
       d. Base such promotion and advertising solely on price

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