Tuesday, March 15, 2016

Second Question of the Day March 15, 2016 How many compounding pharmacies have violated this five percent rule? What legal action will we see against those violators?

"Pharmacies can register with the DEA as a manufacturer/distributor. It is a criminal violation of the law when a DEA-registered pharmacy knowingly and intentionally delivers opiates to any person other than the patient or a member of the patient’s household. However, a DEA-registered manufacturer/distributor may distribute controlled substances to providers under conditions outlined by the DEA. For pharmacies that register as a distributor, a “5 percent rule” specifies that they can supply no more than 5% of their dosage units to physicians’ offices. This does not apply if a drug must be compounded from bulk chemicals.
Logan Davis says:
Generally, if pharmacies dispensing these preparations were to distribute the preparations to physicians, their distribution would exceed 5% of all of the controlled substances they dispense in a calendar year. Since these preparations are unique, high-risk sterile compounds, rather than a bottle of pills, a registration with the DEA as a distributor would not suffice. To distribute these controlled substances, a pharmacy would have to register with the DEA as a manufacturer, and this registration would have implications related to pharmacy registration with the FDA and most state Boards of Pharmacy."

quoted from  http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3628171/

No comments: