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
Saturday, November 29, 2014
Louisiana Board of Pharmacy Application for Renewal of Non-Resident Pharmacy Permit Contains a Survey Regarding Compounding and ask Pertient Disciplinary History Questions
Application for Renewal of Non-Resident Pharmacy Permit ...
Friday, November 28, 2014
Essendon supplements saga: Hearing to discuss evidence
Essendon supplements saga: Hearing to discuss evidence ...
www.northweststar.com.au/.../essendon-supplements-saga-hearing-to-discus...
Essential Read: FDA Panel Warns Against Certain Back Pain Injections
FDA Panel Warns Against Certain Back Pain Injections
Originally, the question put to the panel was, "Do you recommend FDA add a contraindication to the labeling of injectable corticosteroids for the use of these ...
Review Shows that Licensing Boards Voted Improperly: For instance, after initially voting at a legal board meeting to shut down a Webster compounding pharmacy that gave a teenager medicine that was 1,000 times too potent, triggering a heart attack, a handful of board members voted to reverse the action at a meeting a week later without a legal quorum. The pharmacy has since closed on its own, and DPH is continuing to investigate the matter
read entire article here
Reminder: There are more than just the state and federal pharmacies rules to comply with; Here is an example of what veterinarians in Texas must also comply with relating to labels, use, controlled substances, extra and off-label use and compounded drugs--Make sure your legal counsel is advising you on the full umbrella of laws that may impact your specific practice
Texas Administrative Code
|
TITLE 22 | EXAMINING BOARDS |
---|---|
PART 24 | TEXAS BOARD OF VETERINARY MEDICAL EXAMINERS |
CHAPTER 573 | RULES OF PROFESSIONAL CONDUCT |
SUBCHAPTER E | PRESCRIBING AND/OR DISPENSING MEDICATION |
Rules
§573.40 | Labeling of Medications Dispensed |
§573.41 | Use of Prescription Drugs |
§573.42 | Use of Scheduled Drugs in Training and/or Racing |
§573.43 | Controlled Substances Registration |
§573.44 | Compounding Drugs |
§573.45 | Extra-Label or Off-Label Use of Drugs |
Veterinarians in Texas: Are you ready for an inspection? Texas Board Notes there are still issues with controlled substances and prescription labels; Great Compliance Inspection List to help you get ready for no-notice inspections in Texas
ARE YOU READY FOR A COMPLIANCE INSPECTION?
We continue to document chronic problems that exist in the areas of Continuing Education (CE), controlled substances, and Prescription Labels. Licensees are subject to no-notice inspections at anytime. Veterinarians are strongly encouraged to keep their CE records in the facility where they are practicing. Under rule 573.64, CE records must be maintained for the last 3 renewal cycles and be provided to the Board investigators for inspection upon request. When practicing veterinary medicine, relief and mobile veterinarians are requested to keep with them copies of their CE records, current renewal certificate and DEA/DPS Controlled Substances Registrations Certificates Controlled substances logs must maintain balance on hand at all times. The log book must also contain the proper information concerning the purchase, identification and use of controlled substances. For more information on controlled substances and record keeping, please review rule 573.50. Prescription labels must contain the species being treated. For further information on labeling, please review rule 573.40.
Click here to view a Compliance Inspection List.
Clinic Postings
Compliance visits have revealed that some licensees are not posting the required Complaint Information Notice " . . . in an effective way to inform his/her consumers . . . about how to file complaints . . ." as required by rule 573.29.
Also, many practitioners are under the impression that DEA and DPS Drug registration Certificates must be posted. These notices do not need to be posted and in fact we discourage posting them. The registrant's drug license number is shown on these certificates and if the wrong client got these numbers, drugs could be ordered under the practitioner's registration number.
Patient Record Keeping
Rule 573.52 of the Rules of Professional Conduct, addresses patient records and what should be included in each record. Section (a)(12) of this rule states ". . . Each entry in the patient record shall identify the veterinarian who performed or supervised the procedure recorded." When reviewing the patient records involved in consumer complaints, we continue to have difficulty identifying the DVM that performed a given procedure. Please remember each entry on the record should include at least the initials of the licensee that performed the procedure.
quoted from Texas State Board of Veterinary Medical Examiners
Significant Guidance Documents of DEA office of Diversion Control that Pharmacist and their Legal Counsel Should be Aware of
List of Significant Guidance Documents of the Drug Enforcement Administration Office of Diversion Control
- Practitioner’s Manual: A Guideline to the Practitioner’s Responsibilities under the Controlled Substances Act of 1970 (August, 2006)
- Mid-Level Practitioner’s Manual: An Informational Outline of the Controlled Substances Act of 1970 (January, 1993) (Under Revision - Refer to the Pharmacist's Manual for general guidance. If you have a specific question, contact your local DEA Office for assistance).
- Pharmacist’s Manual: An Informational Outline of the Controlled Substances Act of 1970 (2010)
- Narcotic Treatment Programs: Best Practice Guideline (April, 2000)
- Chemical Handler’s Manual: A Guide to Chemical Control Regulations (April 2013)
- ARCOS Registrant Handbook (1997)
- A Security Outline of the Controlled Substances Act of 1970 (May, 1991)
- Policy Statement: Dispensing Controlled Substances for the Treatment of Pain [71 FR 52716; September 6, 2006] (Docket No. DEA-286)
Second Question of the Day November 28, 2014 How many are aware that it is a federal criminal offense to make a threat toward a federal employee? You may want to read 18 U.S.C. 115(a)(2) before you speak words with intent to impeded, intimidate or interfere with a federal employees job whether it be FDA, DEA, FBI, etc.
Section 115(a)(2) of Title 18 covers threats against all Federal employees, including those covered by § 351, when such threat is done "with intent to impede, intimidate, or interfere with" such Federal employee "while engaged in the performance of official duties, or with intent to retaliate against" such Federal employee.
Overview of Texas Employees Group Benefits Program for Fiscal Year 2015: HealthSelect of Texas Benefits for Compounded Medication Coverage
Pharmacy Benefit Management Update
Compound Prescription Drugs
Compound drugs products refers to a prescription medication product that requires
compounding by a pharmacist.
Compound Drugs consist of two or more solid, semi-solid or liquid ingredients, at least one
of which is a Prescription Drug.
Effective July 1, 2014, the coverage of compound drugs under the HealthSelect plan
administered by Caremark and the HealthSelect Medicare Rx plan administered by
SilverScript will entail a 2-step process.
All Compound Medications with a cost greater than $300 will require a pre-authorization to
insure that it is being prescribed for a “medically accepted indication”; and
Compounded prescription drug product may be covered if it contains at least one FDA
approved drug component, although reimbursement is limited to the compounding fees and
FDA approved component(s) only. Bulk chemicals are not FDA approved drug products.
Agenda item 5g - Meeting book dated May 20,2014
Compound Prescription Drugs
Compound drugs products refers to a prescription medication product that requires
compounding by a pharmacist.
Compound Drugs consist of two or more solid, semi-solid or liquid ingredients, at least one
of which is a Prescription Drug.
Effective July 1, 2014, the coverage of compound drugs under the HealthSelect plan
administered by Caremark and the HealthSelect Medicare Rx plan administered by
SilverScript will entail a 2-step process.
All Compound Medications with a cost greater than $300 will require a pre-authorization to
insure that it is being prescribed for a “medically accepted indication”; and
Compounded prescription drug product may be covered if it contains at least one FDA
approved drug component, although reimbursement is limited to the compounding fees and
FDA approved component(s) only. Bulk chemicals are not FDA approved drug products.
Agenda item 5g - Meeting book dated May 20,2014
Powerpoint: FDA Progress, Trends and Compliance at the AFDO in Denver
FDA – Progress, Trends, and Compliance - Denver - AFDO
FDA Animal Drug Users FDA to Present ADUFA III Process Enhancements Live Webinar and 60-Day NF Qualifying (A)NADA Labeling Supplements ( Q and A/submit your questions prior to the second seminar)
60-Day NF Qualifying (A)NADA Labeling Supplements
The first part of the two-part webinar series entitled “60-Day NF Qualifying (A)NADA Labeling Supplements (QLS)” provides a pre-recorded update on the ADUFA III process enhancement regarding shortened review time of 60 days for a specific subset of labeling supplements requiring pre-approval by CVM. Regulatory citations defining which supplements qualify and which do not are discussed, as are the specific requirements supporting submission of a 60-day QLS. Viewers are encouraged to also attend the second webinar (on January 26, 2015), which provides a live Q and A session to address any questions. Questions should be submitted prior to the second webinar, if available, to Linda.Wilmot@fda.hhs.gov in order to provide CVM time to adequately answer them.
Part One - https://collaboration.fda.gov/p3a1h6p24ft/
Part Two - Live Q&A Session scheduled for January 26, 2015 from 12:00 pm to 1:00 pm EST.
View webinar at https://collaboration.fda.gov/cvm_qls_live_webinar/
FDA to Present ADUFA III Process Enhancements Live Webinar
November 24, 2014
The Food and Drug Administration's Center for Veterinary Medicine (CVM) announces Part Two of the “60-Day NF Qualifying (A)NADA Labeling Supplements (QLS)” webinar, featuring a live Q and A session, to take place on: Monday, January 26, 2015 from 12:00 noon to 1:00 pm. Questions should be submitted to Linda.Wilmot@fda.hhs.gov prior to the webinar so that CVM has time to adequately prepare the answers to the questions to present at the webinar.
This live Q and A follows the first webinar of the two-part webinar series. Part I, a pre-recorded update on the ADUFA III process enhancement regarding shortened review time of 60 days for a specific subset of labeling supplements requiring pre-approval by CVM, can be viewed at https://collaboration.fda.gov/p3a1h6p24ft/.
Part One is a discussion of the regulatory citations defining which supplements qualify and which do not, and the specific requirements supporting submission of a 60-day QLS.
The live webinar can be viewed at https://collaboration.fda.gov/cvm_qls_live_webinar/.
Additional Information
Thursday, November 27, 2014
Wednesday, November 26, 2014
Question of the Day November 26, 2014 Who is the largest and most powerful human compounding pharmacy? Who is the largest and most powerful animal compounding pharmacy? Are they owned by pharmacist or corporations/companies? How long before the biggest and most powerful compounders buy out or force the shut down or bankruptcy of the smaller less powerful compounding pharmacies? Have the buy outs already in process?
Patient Sues Hospital and Pharmacy for Allegedly Giving Contaminated Medications POSTED ON NOVEMBER 25, 2014
Belleville, IL - A Belleville (IL) hospital, along with a local pharmacy, is being sued by a patient for allegedly giving him contaminated medication following a heart surgery, causing her to contract an infection. Melissa Owens has filed a 3-count complaint against defendants Dr. John D. Sadoff, St. Elizabeth’s Hospital, and New England Compounding Pharmacy Incorporated on 27th October in the Saint Clair County Court.
The complaint says Owens underwent an open heart surgery at defendant St. Elizabeth’s Hospital on 27th August, 2012. The coronary bypass surgery was performed by Sadoff. Subsequent to the heart operation, Owens developed a very severe infection, the suit says. On 26th October, 2012, she came to know that her infection was a result of taking contaminated drugs produced by the New England Compounding Pharmacy, according to the complaint. The plaintiff says the medications weren’t sterile.
Updated 2014 FDA Pharmacy Inspections and Related Records Released as of November 26, 2014
2014 Pharmacy Inspections and Related Records
Advanced Pharma Inc., Houston, TX, 483 Issued 3/17/2014 (PDF - 638KB)Alexander Infusion, LLC dba Avanti Health Care Services, New Hyde Park, NY, 483 Issued 7/9/2014 (PDF - 1.4MB)- ALK-Abello, Inc., Port Washington, NY, 483 Issued 02/25/14 (PDF - 1.3MB)
AnazaoHealth Corporation, Tampa, FL, Referral Letter to FL BOP Issued 2/21/2014 (PDF - 375KB)Browns Compounding Center, Inc., Englewood, CO, 483 Issued 8/11/2014 (PDF - 580KB)- California Pharmacy and Compounding Center, Newport Beach, CA, 483 Issued 8/25/2014 (PDF - 2.8MB)
Central Admixture Pharmacy Services, Inc. (CAPS), San Diego, CA, 483 Issued 8/8/2014 (PDF - 1.5MB)Central Admixture Pharmacy Services, Inc. (CAPS), Livonia, MI, 483 Issued 6/25/2014 (PDF - 928KB)Central Admixture Pharmacy Services, Inc. (CAPS), Allentown, PA, 483 Issued 6/11/2014 (PDF - 2.1MB)Central Admixture Pharmacy Services, Inc. (CAPS), Woburn, MA, 483 Issued 2/20/2014 (PDF - 1.9MB)- Complete Pharmacy and Medical Solutions, LLC, Miami Lakes, FL, 483 Issued 8/12/2014 (PDF - 1.4MB)
Custom Compounding Centers, LLC, Los Alamitos, CA, 483 Issued 8/28/2014 (PDF - 457KB)Custom RX LLC, dba Custom RX Compounding Pharmacy, Richfield, MN, 483 Issued 8/28/2014 (PDF - 775KB)DNA Pharmacy Services Inc dba Palm Beach Compounding, Jupiter, FL, 483 Issued 8/13/2014 (PDF - 251KB)Downing Labs, LLC (formerly NuVision Pharmacy, Inc.), Dallas, TX, 483 Response Dated 8/20/2014 (PDF - 4.2MB)Downing Labs, LLC (formerly NuVision Pharmacy, Inc.), Dallas, TX, 483 Response Dated 8/6/2014 (PDF - 4MB)Downing Labs, LLC (formerly NuVision Pharmacy, Inc), Dallas, TX, FDA Requested Recall Letter Issued 9/9/2014 (PDF - 941KB)Downing Labs, LLC (formerly NuVision Pharmacy, Inc), Dallas, TX, 483 Issued 7/16/2014 (PDF - 2.1MB)Eastern Pharmacy, Inc., Ocala, FL, 483 Issued 2/4/2014 (PDF - 516KB)Edge Pharmacy Services, LLC, Colchester, VT, 483 Issued 8/20/2014 (PDF - 923KB)Foundation Care, LLC, Earth City, MO, Referral Letter to MO Board of Pharmacy Issued 2/26/2014 (PDF - 396KB)Franck's Lab Inc dba Trinity Care Solutions, Ocala, FL, 483 Issued 5/23/2014 (PDF - 856KB)Healix Infusion Therapy, Inc., Sugar Land, TX, 483 Issued 5/16/2014 (PDF - 628KB)Health Dimensions, Inc., Farmington Hills, MI, 483 Response Dated 8/29/2014 (PDF - 1.5MB)Health Dimensions Inc., Farmington Hills, MI, 483 Issued 8/8/2014 (PDF - 613KB)HHCS Pharmacy, Inc. dba Freedom Pharmacy, Orlando, FL, 483 Issued 7/28/2014 (PDF - 1.7MB)Hopewell Pharmacy, Hopewell, NJ, Referral Letter to NJ Board of Pharmacy Issued 2/21/2014 (PDF - 1.3MB)Infusion Options, Inc., Brooklyn, NY, 483 Issued 4/23/2014 (PDF - 2.3MB)I.V. Specialty Ltd., Austin, TX, 483 Issued 7/22/2014 (PDF - 1019KB)Johnson Memorial Cancer Center, Enfield CT, 483 Issued 8/5/2014 (PDF - 916KB)John W. Hollis Inc dba John Hollis Pharmacy, Nashville, TN, 483 Issued 3/21/2014 (PDF - 1.3MB)- Jubilant HollisterStier, LLC, Spokane, WA, 483 Issued 4/15/14 (PDF - 18MB)
Kings Park Slope, Inc., Brooklyn, NY, 483 Issued 3/14/2014 (PDF - 3.2MB)KRS Global Biotechnology, Inc., Boca Raton, FL, 483 Issued 3/17/2014 (PDF - 735KB)LeeSar, Inc., Fort Myers, FL, 483 Issued 8/8/2014 (PDF - 541KB)Leiter's Cambrian Park Drugs, Inc., dba Leiter's Pharmacy, San Jose, CA, 483 Issued 3/6/2014 (PDF - 1.3MB)Leiter's Compounding Pharmacy, San Jose, CA, 483 Response Dated 3/26/2014 (PDF - 3.6MB)Lowlyn Pharmacies, Inc., d/b/a Red Cross Drug, Blanchard, OK, Referral Letter to OK Board of Pharmacy Issued 2/25/2014 (PDF - 2.4MB)Martin Avenue Pharmacy, Inc., Naperville, IL, 483 Issued 7/21/2014 (PDF - 1.8MB)Medi-Fare Drug and Home Health Center, Inc., Blacksburg, SC, 483 Issued 9/12/2014 (PDF - 371KB)Nebraska Methodist Hospital, Omaha, NE, 483 Issued 7/14/2014 (PDF - 772KB)Nora Apothecary and Alternative Therapies, Inc., Indianapolis, IN, 483 Issued 8/21/2014 (PDF - 422KB)One Way Drug, LLC dba Partell Specialty Pharmacy, Las Vegas, NV, 483 Issued 5/30/2014 (PDF - 1.3MB)Oregon Compounding Centers, Inc., dba Creative Compounds, Wilsonville, OR, Amended 483 Issued 9/12/2014 (PDF - 1.9MB)Oregon Compounding Centers, Inc., dba Creative Compounds, Wilsonville, OR, 483 Issued 8/28/2014 (PDF - 1.7MB)People’s Pharmacy, Inc. #2, Austin, TX, 483 Issued 7/28/2014 (PDF - 560KB)Perry Drug Inc., Overland Park, KS, 483 Issued 9/9/2014 (PDF - 821KB)Pharmakon Pharmaceuticals, Inc. Noblesville, IN, 483 Issued 3/13/2014 (PDF - 1.9MB)Pharmakon Pharmaceuticals, Noblesville, IN, 483 Issued 4/8/2014 (PDF - 350KB)Portage Pharmacy Inc., Portage, MI, Referral Letter to MI Board of Pharmacy Issued 2/25/2014 (PDF - 357KB)Premier Pharmacy Labs, Inc., Weeki Wachee, FL, 483 Issued 5/9/2014 (PDF - 2.5MB)Region Care, Inc., Great Neck, NY, 483 Issued 3/20/2014 (PDF - 922KB)RX South LLC DBA RX3 Pharmacy, Chester, VA, 483 Issued 2/21/2014 (PDF - 5MB)SCA Pharmaceuticals, LLC, Little Rock, AR, 483 Issued 4/1/2014 (PDF - 1.7MB)Sina LLC, dba OncoMed (Onco 360), Great Neck, NY, 483 Issued 8/22/2014 (PDF - 936KB)South Coast Specialty Compounding, Inc. (Park Pharmacy and Compounding), Irvine, CA, 483 Issued 7/2/2014 (PDF - 708KB)SSM Health Care St. Louis dba SSM St. Clare Health Center, Fenton, MO, 483 Issued 8/14/2014 (PDF - 711KB)Stewart Compounding Pharmacy, Fayetteville, NC, 483 Issued 2/26/2014 (PDF - 1.4MB)Transdermal Therapeutics, Inc., Birmingham, AL, 483 Response Dated 10/14/2014 (PDF - 952KB)Transdermal Therapeutics, Inc, Birmingham, AL, 483 Issued 6/27/2014 (PDF - 413KB)UCSF Home Therapy Services, San Francisco, CA, 483 Issued 9/12/2014 (PDF - 893KB)Unique Pharmaceuticals, Ltd. FDA Requested Recall Letter Issued 7/11/2014 (PDF - 754KB)Unique Pharmaceuticals Ltd., Temple, TX, 483 Issued 6/20/2014 (PDF - 1MB)Unique Pharmaceutical, Ltd., Temple, TX, Amended 483 Issued 4/4/2014 (PDF - 4.3MB)Unique Pharmaceutical, Ltd., Temple, TX, 483 Issued 4/2/2014 (PDF - 748KB)University Pharmacy, Inc., Salt Lake City, UT, Referral Letter to UT Board of Pharmacy Issued 2/20/2014 (PDF - 240KB)US Compounding Inc., Conway, AR, 483 Issued 3/27/2014 (PDF - 1.1MB)Wells Pharmacy Network LLC, Ocala, FL, 483 Issued 6/19/2014 (PDF - 1MB)Wells Pharmacy Network LLC, Ocala, FL, 483 Issued 3/7/2014 (PDF - 1.2MB)Wickliffe Pharmaceutical, Inc., Lexington, KY, 483 Issued 5/22/2014 (PDF - 206KB)Zions RX Formulations Services LLC dba Rx Formulation Serv., Mesa, AZ, 483 Issued 1/9/2014 (PDF - 1MB)
FDA 2014 Records Relating to Downing Labs, LLC (formerly NuVision Pharmacy)
Downing Labs, LLC (formerly NuVision Pharmacy, Inc.), Dallas, TX, 483 Response Dated 8/20/2014 (PDF - 4.2MB)Downing Labs, LLC (formerly NuVision Pharmacy, Inc.), Dallas, TX, 483 Response Dated 8/6/2014 (PDF - 4MB)Downing Labs, LLC (formerly NuVision Pharmacy, Inc), Dallas, TX, FDA Requested Recall Letter Issued 9/9/2014 (PDF - 941KB)Downing Labs, LLC (formerly NuVision Pharmacy, Inc), Dallas, TX, 483 Issued 7/16/2014 (PDF - 2.1MB)
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