This is a short, non inclusive and non specific (for the most part I have not included specific statutes) list of potential crimes that a compounding pharmacy or pharmacist may face if the applicable facts present themselves. Note this list does not include such things as forfeiture, fines and restitution that a pharmacy or pharmacist may also face.
1. Health Care Fraud
2. Tax Evasion or tax related crimes
3. Violations of Controlled Dangerous Substances statute
4. Violation of Drug Statutes
5, False Statements 18 U.S.C 1001(federal crime); some states may have equivalent statutes
6. Murder/Manslaughter/negligent homicide
7. Federal Conspiracy Law
1. Health Care Fraud
2. Tax Evasion or tax related crimes
3. Violations of Controlled Dangerous Substances statute
4. Violation of Drug Statutes
5, False Statements 18 U.S.C 1001(federal crime); some states may have equivalent statutes
6. Murder/Manslaughter/negligent homicide
7. Federal Conspiracy Law
2 comments:
You forgot:
- patient brokering (for restricting patients' choice of pharmacy)
- fee-splitting / illegal kickbacks (offering to sell compounded drugs wholesale to physicians/veterinarians for further resale/distribution/dispensing at a retail price)
- Florida Deceptive and Unfair Trade Practices Act (for false advertisements touting compounded drugs as "safe and effective" for conditions not approved by the FDA) - this is also a violation of the Federal Food Drug and Cosmetic Act
Kenneth Woliner, MD
www.holisticfamilymed.com
Thank you for adding to the list. There are many more that could still be added.
Post a Comment