Human Medications, Human Drugs, Animal Medications, Animal Drugs, Pharmacy law, Pharmaceutical law, Compounding law, Sterile and Non Sterile Compounding 797 Compliance, Veterinary law, Veterinary Compounding Law; Health Care; Awareness of all Types of Compounding Issues; Pharmacy Benefit Managers (PBMs), Outsourcing Facilities Food and Drug Administration and Compliance Issues
Wednesday, September 19, 2012
Tuesday, September 18, 2012
DEA Crackdown May Be Coming Down on Prescription and Compounded Controlled Substances
Pharmacies Ill-Prepared For Potential DEA Crackdown
By Rachel Slajda
Law360, New York (September 18, 2012, 8:38 PM ET) -- Many pharmacies' day-to-day operations appear to violate the U.S. Drug Enforcement Administration's policies on controlled substances, and the pharmacies are risking their DEA registrations if the agency cracks down — a not-implausible scenario as the DEA battles widespread prescription drug abuse.At issue is whether retail and compounding pharmacies can give controlled substances to doctors, rather than directly to patients. A prime example, pointed to by the industry and supportive lawmakers, is intrathecal pain medications that must be injected directly into a patient's spinal fluid....
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Louisiana Board of Veterinary Medicine Rules and Regulations Relating to Prescriptions
Louisiana's Principles of Veterinary Medical Ethics of the American Veterinary Medical Association (AVMA)
III. THE VETERINARIAN - CLIENT – PATIENT
RELATIONSHIP
A. The
veterinarian - client - patient relationship (VCPR) is the basis for
interaction among veterinarians, their clients, and their patients. A VCPR exists when all of the following
conditions have been met:
(1) The
veterinarian has assumed responsibility for making clinical judgments regarding
the health of the animal(s) and the need for medical treatment, and the client
has agreed to follow the veterinarian’s instructions.
(2) The
veterinarian has sufficient knowledge of the animal(s) to initiate at least a
general or preliminary diagnosis of the medical condition of the
animal(s). This means that the
veterinarian has recently seen and is personally acquainted with the keeping
and care of the animal(s) by virtue of an examination of the animal(s), or by
medically appropriate and timely visits to the premises where the animal(s) are
kept.
Kansas Veterinary Rules Regarding Prescriptions
KANSAS ADMINISTRATIVE REGULATIONS
PUBLISHED APRIL 1997
Kansas Board Veterinary Examiners
Amendment/Addendum to the Kansas Administration Regulations
Article 7.--STANDARDS OF VETERINARY PRACTICE
70-7-1 The practice of veterinary medicine. Each veterinarian shall meet the following minimum standards in the practice of veterinary medicine.
***
(j) Controlled drugs. The veterinarian shall ensure that a separate written ledger is maintained when a controlled
drug is administered or dispensed.
(k) Locked area. If controlled drugs are used, the veterinarian shall ensure that a locked area for the storage
of controlled substances is provided.
(l) Dispensation of medications for companion animals.
(1) All prescription drugs to be dispensed for use by a companion animal may be dispensed only on the order of a licensed veterinarian who has an existing veterinary client-patient relationship as defined by the Kansas veterinary practice act. The veterinarian shall ensure that labels will be affixed to any unlabeled container containing any medication dispensed and to each factory-labeled container that contains prescription drugs or controlled substances dispensed for companion animals. The label shall be affixed to the immediate container and shall include the following information:
(A) The name and address of the veterinarian and, if the drug is a controlled substance, the veterinarian’s telephone number;
(B) the date of delivery or dispensing;
(C) the name of the patient, the client’s name, and, if the drug is a controlled substance, the client’s address;
(D) the species of the animal;
(E) the name, active ingredient, strength, and quantity of the drug dispensed;(F) directions for use specified by the practitioner including dosage, frequency, route of administration, and duration of therapy; and
(G) any cautionary statements required by law, including statements indicating that the drug is not for human consumption, is poisonous, or has withdrawal periods associated with the drug. If the size of the immediate container is insufficient to be labeled, the container shall be enclosed within another container large enough to be labeled.
(2) The term ‘‘companion animal’’ shall have the meaning specified in K.S.A. 47-816 and amendments thereto.
(m) Dispensation of medications for food or commercial animals. All prescription drugs to be dispensed for
food used by a food animal or used by a commercial animal may be dispensed only on a written order of a licensed veterinarian with an existing veterinary-client-patient relationship as defined by the Kansas veterinary practice act. That veterinarian shall maintain the original written order on file in the veterinarian’s office. A copy of the written order shall be on file with the distributor, and a second copy shall be maintained on the premises of the patient-client. The written order shall include the following information:
(1) The name and address of the veterinarian and, if the drug is a controlled substance, the veterinarian’s telephone number;
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