view complaint here. A copy of the Request for Temporary Restraining Order and Memorandum in Support can be found in PACER filed in the Eastern District of Missouri. The court has not set a hearing yet.
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
Thursday, August 28, 2014
Breaking News: Concierge Compounding Pharmaceuticals Inc. v. Express Scripts Inc.: A Lawsuit seeking to Stop Express Script from Terminating a Compounding Pharmacy from its Network-hearing set for tomorrow August 29, 2014
View Motion
View Memo of Law in Support of Motion
View Complaint for Injunctive Relief
Great Read: One Doctor's Answer to Office Use Compounded Medications--Questions to Consider
08/28/2014 Allen Jacobs, DPM
In-Office Compounding
In-Office Compounding
In-office compounding has been around a long time.
There is nothing wrong with compounding selected
pharmaceutical ingredients in your office for
patient treatment. The issue your question raises
is not about Stark Law. It should be about medical
liability, kick-back laws, ethics, and not
jeopardizing your in-network medical status with
payers.
1. Liability is a major issue. When a pharmacist
dispenses a drug to a patient, they hold 100% all
patient liability for safety around allergies,
drug to drug interactions, contraindications and
side effect profile. The pain creams sound pretty
simple but most of them have 5-8 active
ingredients (including CII and CIII drugs) and the
bases contain over 25-30 ingredients.
Although the systemic exposure is less than oral,
there is still exposure and it varies depending on
skin type (elderly and children). When there is an
issue with the medication you dispensed, you are
the one the patient calls for immediate solution.
Due to this, you will also need to have a 24 hour
hot line to field non-911 issues. The companies
that are doing this shell game are passing all
liability on to you so be sure to increase your
liability coverage with the money you gained from
playing pharmacist. This is not worth my time.
2. Price gouging: The company is charging
insurance companies ridiculous amounts of money
and passing a fraction of that revenue to you.
Just remember that when a patient’s insurance gets
billed thousands for the pain cream, you will be
the one the patient comes running to. It usually
presents itself as a patient carrying an EOB
yelling, “you charged my insurance $3,500 for that
cream.”
There is nothing wrong with compounding selected
pharmaceutical ingredients in your office for
patient treatment. The issue your question raises
is not about Stark Law. It should be about medical
liability, kick-back laws, ethics, and not
jeopardizing your in-network medical status with
payers.
1. Liability is a major issue. When a pharmacist
dispenses a drug to a patient, they hold 100% all
patient liability for safety around allergies,
drug to drug interactions, contraindications and
side effect profile. The pain creams sound pretty
simple but most of them have 5-8 active
ingredients (including CII and CIII drugs) and the
bases contain over 25-30 ingredients.
Although the systemic exposure is less than oral,
there is still exposure and it varies depending on
skin type (elderly and children). When there is an
issue with the medication you dispensed, you are
the one the patient calls for immediate solution.
Due to this, you will also need to have a 24 hour
hot line to field non-911 issues. The companies
that are doing this shell game are passing all
liability on to you so be sure to increase your
liability coverage with the money you gained from
playing pharmacist. This is not worth my time.
2. Price gouging: The company is charging
insurance companies ridiculous amounts of money
and passing a fraction of that revenue to you.
Just remember that when a patient’s insurance gets
billed thousands for the pain cream, you will be
the one the patient comes running to. It usually
presents itself as a patient carrying an EOB
yelling, “you charged my insurance $3,500 for that
cream.”
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