Senior Medicare Fraud Patrol Recovers $5.9M

Senior Medicare Fraud Patrol Recovers $5.9M

Louisana Board of Pharmacy July 2014 Newsletter

read it here

Sixth Question of the Day June 28, 2014 Aren't compounding pharmacies, pharmacists and organizations that represent them makeing a very good argument that the FDA should be given total authority over all compounding so that there will be no confusion as they claim still exist? Concurrent jurisdiction with state boards of pharmacy just as criminal illegal drugs are now regulated?

Texas Board of Pharmacy Proposed Rules--Still time to Comment by July 31, 2014

Proposed Rules by the Texas State Board of PharmacyOn June 13, the Texas State Board of Pharmacy proposed rules in seven areas of regulations which, if adopted, will impact pharmacies, pharmacists and pharmacy technicians. Below are excerpts of the rules along with page references from the Texas Register. Click here if you wish to access the actual, detailed set of the proposed rules as published in the Register. TPA will be submitting a comment letter on these proposed rules and will provide the Association’s membership with an analysis of the rules in the next two weeks prior to the July 31 comment deadline.

ØConcerning pharmacy license fees. The rule will decrease pharmacist license fees based on expected expenses. (page 39 TexReg 4596)

ØConcerning definitions; personnel; operational standards; and records for Class A (community) pharmacies. The rules update the reference to advance practice registered nurses; clarify that the requirements for dispensing a prescription are the same for a pharmacist and for an intern and eliminate references to sterile compounding that are no longer necessary. The rules also eliminate the requirement for the pharmacist to notify the prescriber of a substitution of dosage form.(page 39 TexReg 4597)

ØConcerning Class C (institutional) pharmacies located in a freestanding ambulatory surgical center. The rules clarify the labeling requirements for medications provided by ASC pharmacies; remove references to sterile compounding that are no longer necessary; and add tramadol to the record keeping requirements to be consistent with other sections.(page 39 TexReg 4602)

ØConcerning pharmacies compounding sterile preparations. The proposed rules clarify the training requirements for pharmacy technicians in American Society of Health-System Pharmacists accredited programs. (page 39 TexReg 4604)

ØConcerning Class F pharmacies, which are pharmacies located in a freestanding emergency medical care center. The rules clarify the labeling requirements for medications provided by Class F pharmacies; remove references to sterile compounding that are no longer necessary; and add tramadol to the record keeping requirements to be consistent with other sections.(page 39 TexReg 4605)

ØConcerning pharmacist license or renewal fees. The rules will decrease pharmacist license fees based on expected expenses.(page 39 TexReg 4607)

ØConcerning fees. The rules will decrease pharmacy technician and pharmacy technician trainee fees based on expected expenses.(page 39 TexReg 4608)

Comments on these proposed rules should be submitted to Allison Benz, R.Ph., M.S., Director of Professional Services, Texas State Board of Pharmacy, 333 Guadalupe Street, Suite 3-600, Austin, Texas 78701, fax (512) 305-8008. Comments must be received by 5:00 p.m., July 31, 2014.

Click Here to View Proposed Rules
Comments on these proposed rules should be submitted to Allison Benz, R.Ph., M.S., Director of Professional Services, Texas State Board of Pharmacy, 333 Guadalupe Street, Suite 3-600, Austin, Texas 78701, fax (512) 305-8008. Comments must be received by 5:00 p.m., July 31, 2014.

Texas Pharmacy Association Conference and Expo June 30--

LAST CHANCE for Advance Registration: Cut-off for the 2014 TPA Conference & Expo is June 30th

Top Stories An Opportunity to Share Your Medicaid Managed Care Concerns A special opportunity to participate in a Town Hall discussion for YOU to air your questions and concerns with Medicaid Managed Care and PBMs. It is open to all interested pharmacist. There is no charge and Conference registration is not required.READ MORE Proposed Rules by the Texas State Board of Pharmacy On June 13, the Texas State Board of Pharmacy proposed rules in seven areas of regulations which, if adopted, will impact pharmacies, pharmacists and pharmacy technicians. READ MORE Sunset Commission Focuses on State Health Services The Texas Sunset Advisory Commission, met on June 24 and 25 to review Commission staff reports on a number of state health agencies. More than 150 individuals testified during the two day hearing. READ MORE National Community Pharmacy 2014 Cost of Dispensing Study Needs Input Before July 9 The Texas Sunset Advisory Commission, met on June 24 and 25 to review Commission staff reports on a number of state health agencies. More than 150 individuals testified during the two day hearing. READ MORE Member Spotlight: Gay Dodson, Executive Director, Texas State Board of Pharmacy If you grew up in the Dallas area in the 70’s or 80’s you may remember the Texas chain of drug stores called Skillern’s. And if you were a customer there, you might have been helped by Gay Dodson. READ MORE

Fifth Question of the Day June 28, 2014 If OTC acne medications are causing heath problems and risks, what about all the compounded acne treatments and skin care products that compounding pharmacies are making? And why aren't companies with patents bringing patent infringements?

This is a photo of a Blemish Blaster Acne Wash that a local compounding pharmacy makes.  Interestingly, a pharmacy tech mixed it up in less than 30 minutes and promised it was the equivalent to what Proactive makes and includes the same ingredients.  In fact, the compounding pharmacy has an entire line of acne products it compounds.   The first question is what about Proactive's patent.  The second question is with the recent FDA alert regarding acne treatments what is the harm being done by all the compounded skin care treatments, especially acne treatments.

Fourth Question of the Day June 28, 2014 Who will be the first bring a qui tam action against compounding pharmacies who have overcharged for compounded medications? Insurance Companies? Doctors? Sales Reps? Other employees of the compounding pharmacies?

Third Question of the Day June 28, 2014 Will there be an insurance company bring a class action against compounding pharmacies to recover the money they have paid out for illegal compounded medications?

The Drug Shortage Report: Shortage of Saline Has Hospitals on Edge --Salty Water Harder to Make Than One Might Think

Hospitals across the country are struggling to deal with a shortage of one of their essential medical supplies. Manufacturers are rationing saline -- a product used all over the hospital to clean wounds, mix medications, and treat dehydration. Now drug companies say they won't be able to catch up with demand until next year.

That leaves San Francisco General Hospital's materials manager, Reid Kennedy, in a fix. Kennedy is in charge of managing all the gloves, bandages, bedpans, and IV solutions for all the medical floors, emergency room, and operating room.

He first got a call last year from his vendor telling him they might not be able to deliver his full order.

"We were put on notice that it was going to be tight," he said.

Then things got worse in January. The flu season hit much harder than expected, and sick people flooded into hospitals. Saline bags flew off the shelves to treat dehydration, and demand far outstripped supply.

"The flu season knocked us out as an industry," Kennedy said. Though hospital administrators say the shortage hasn't affected the quality of patient care, Kennedy uses the word "crisis" to describe the shortage.

It's Harder to Make Than You Think

But can salty water really be that hard to come by? Kennedy pays $1.57 per bag. Why can't drug companies just whip up some more?

continue to read here

Second Question of the Day June 28, 2014 How many doctors and pharmacies or pharmacists have arrangements like this: "Compounding Medications can become the cash based 'annuity concession' that many health care providers have been looking for."

USP Compounded Preparation Monograph Title Revisions Coming Soon

Compounded Preparation Monograph Title Revisions

Posting Date

1-July-2014

Coming Soon:

Repost With Link: Must Read This 2005 Report from IACP-- especially all their actions to stop regulations and enforcement. The BHRT litigation and the CHASM fight!!

A must read!!! This 2005 Report from IACP-- especially all their actions to stop regulations and enforcement. The BHRT litigation and the CHASM fight!!

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Question of the Day June 28, 2014 When will more doctors and those in the know speak the truth about compounded medications so that the fraud and greed can be removed so that those who do legitimately need compounded medications can receive them?

This is the Problem with Most Compounded Pain Creams and Gels. Well said Dr. Kenneth Woliner:

The sooner that insurance companies stop reimbursing compounding pharmacies (and their sales reps) based on grossly inflated "Average Wholesale Price" lists that have nothing to do with the average wholesale price pharmacies pay to buy the raw active ingredients in these pain creams, the better. Reimbursement should be based upon the ACTUAL cost for providing services, or the ACTUAL value of the services provided. These pain creams are dispensed in buckets to patients, much of it not being used because it isn't as effective as touted. Why it had to take 5-10 years before insurance companies realized and reacted to being raped by rogue pharmacies abusing the system, is beyond me.

Here is a prediction on cafepharma board about sales reps and transdermal creams....

05-31-2014, 07:08 AM

Anonymous   Posts: n/a

Enough of the compounding To all you "sales reps" selling the "transdermal creams, be ready for the harsh reality of a new reimbursement. The insurance companies are well aware of what's happening and are already changing the reimbursement rates. It's over!

Anonymous

#2   06-16-2014, 11:33 AM

Anonymous   Posts: n/a

Re: Enough of the compounding http://www.protectmycompounds.com/ex...-announcement/ Yeah its going down soon

Absolute Must Read as I have Suggested Before--Cafepharma-- a lot of the legal and practice issues are discussed--for example here is discussion regarding how much 1099 sales reps get paid and a disagreement as to whether 1099 commissions violate the law

1099 Compounding Commissions?

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What is the norm commission rate for these companies? I will be 1099 and this will be an addition to my 1099 medical device position. Pharmacy looks to be very reputable. They have a realtime RX tracking software that shows all reimbursements. Lots of transparency and shows the billing pathways for pt. tracking.

Anonymous

#2   05-28-2013, 07:17 PM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Commission ranges from 15%-20% with some companies offering money for entertaining and travel. The money can be quite lucrative with refills etc...do your research on the pharmacy. There are plenty of pharmacies but only a handful are doing it right. Who is the pharmacy you are considering?

Anonymous

#3   05-30-2013, 12:49 AM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Im not the OP but had a similar question. I am looking at Focused Pain Solutions out of NY. Their comission seems to be quite a bit higher - $90 for any script over $225

Anonymous

#4   05-30-2013, 08:27 AM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Quote: Originally Posted by Anonymous Im not the OP but had a similar question. I am looking at Focused Pain Solutions out of NY. Their comission seems to be quite a bit higher - $90 for any script over $225 OP here, pretty sure 20% is higher than $90. I don't want to give name just yet, but they are in the Carolinas and seem to be very legit.

Anonymous

#5   05-30-2013, 08:58 AM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? $90 per script isn't bad if the creams were billing out at $225 but they typically bill between $500 and $2500 per script. I believe the $90 is a flat commission. Do the math and you can do considerably higher.

Anonymous

#6   05-30-2013, 11:47 PM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Dude this is fad not long term. Insurances are figuring out overpriced pain creams are a rip off. I give it a year!

Anonymous

#7   05-31-2013, 06:09 AM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Quote: Originally Posted by Anonymous Dude this is fad not long term. Insurances are figuring out overpriced pain creams are a rip off. I give it a year! Okay by me, I love something easy in my bag that is highly profitable. Make hay.

Anonymous

#8   06-01-2013, 05:15 PM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Quote: Originally Posted by Anonymous Dude this is fad not long term. Insurances are figuring out overpriced pain creams are a rip off. I give it a year! You sound like the guy that said cars were just a fad and that people would get tired of them breaking down and running out of fuel and would come back to horses. The creams are cheap compared to the pain pills that physically and mentally impair the patients in addition to getting them addicted. The opioids cause such common problems as low testosterone and constipation just to name a few. How many people die every day from drug overdose that got their start from legal pain pills. What's the cost in human lives? What's the cost for all the accidents caused by people who are driving impaired that end up crippled all their lives or in the hospital for months or even just a few weeks? Have the reimbursement rates dropped for the opioid medications except when a generic has come out? No? Then why would the insurance companies want to discourage physicians from prescribing the pain creams that in the long run are much cheaper to the bottom line? The pain creams have been going on for years and years so why now? No answer? No, I didn't think so.

Anonymous

#9   06-01-2013, 05:30 PM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Quote: Originally Posted by Anonymous Im not the OP but had a similar question. I am looking at Focused Pain Solutions out of NY. Their comission seems to be quite a bit higher - $90 for any script over $225 You can take that $90 offer if you want or earn 20% to 24% from Supreme Medical Solutions. Since most scripts go for $1,000 or more We represent a PCAB accredited pharmacy that is licensed in all 50 states, has a pharmacist available 24/7 and unlike all the competition we offer you some additional product lines that are a perfect fit and compliment each other and they also pay you a residual income. There are only about 132 PCAB accredited pharmacies in the US out of about 7,000 compounding pharmacies and a ton of those are only licensed in their own state or don't take insurance or don't sell pain creams.

Anonymous

#10   06-05-2013, 12:31 PM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? I have some snake oil that cures all ailments too and will only charge you 2k

Anonymous

#11   06-06-2013, 07:52 AM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Quote: Originally Posted by Anonymous I have some snake oil that cures all ailments too and will only charge you 2k OP here, I don't care if it is snake oil or not. Have you ever tried a compounded cream? I have several years ago and it worked well for my shoulder pain. I'm not asking providers who don't already write these scripts. I am just having my providers write them with me.

Anonymous

#12   06-06-2013, 02:27 PM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Quote: Originally Posted by Anonymous I have some snake oil that cures all ailments too and will only charge you 2k Tell us how you would defend big pharma when they came out with Voltaren Gel when all it is really consists of is a NSAID in a transdermal cream and yet they charged big bucks. They took a generic product and put it in a transdermal cream and yet they have charged the medical field a ton of money. At least the compounding pharmacies put additional ingredients in their medication to further reduce pain. There is a ton more to producing a transdermal medication with 5-6 active ingredients than mass producing a ton of Voltaren Gel that the Novartis & Endo reps are selling. If your loved one was suffering in pain which of these two products would you want to help make the pain go away?

Anonymous

#13   07-02-2013, 12:44 AM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Quote: Originally Posted by Anonymous You can take that $90 offer if you want or earn 20% to 24% from Supreme Medical Solutions. Since most scripts go for $1,000 or more We represent a PCAB accredited pharmacy that is licensed in all 50 states, has a pharmacist available 24/7 and unlike all the competition we offer you some additional product lines that are a perfect fit and compliment each other and they also pay you a residual income. There are only about 132 PCAB accredited pharmacies in the US out of about 7,000 compounding pharmacies and a ton of those are only licensed in their own state or don't take insurance or don't sell pain creams. Uh.... Didn't Supreme Medical Just run into issues with waiving of copays and sever ties to the compounding pharmacy they represented? It won't be long until insurance companies figure out they are being billed huge sums of money for these creams and the compounding companies are pocketing a ton of money. Let's be real, how long until insurance companies put amstopmto this high priced practice?

Anonymous

#14   07-17-2013, 09:22 PM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Quote: Originally Posted by Anonymous Uh.... Didn't Supreme Medical Just run into issues with waiving of copays and sever ties to the compounding pharmacy they represented? It won't be long until insurance companies figure out they are being billed huge sums of money for these creams and the compounding companies are pocketing a ton of money. Let's be real, how long until insurance companies put amstopmto this high priced practice? They will just pay less. The payments are based on known generic quantities and concentrations. The higher the concentration and volume, the higher the price. Many insurance companies such as BCBS still reimburse, but instead of 120g and more at a time, they will only approve 30g or a weeks supply. There is nothing magical about the compounds or underhanded about the pharmacies (if they are billing appropriately). Happy hunting.

Anonymous

#15   11-14-2013, 12:51 PM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Just to set the story straight, Florida Board of Pharmacy requires or recommends strongly that all sales people are employees because of pharmacy compliance issues. Most legit companies are contracting their employee sales team. Commissions ranges are factored as salary not a per transaction basis. Figure up to 20-25%

Anonymous

#16   03-21-2014, 11:41 PM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Medimix only paying 15%. Suxs

Anonymous

#17   03-24-2014, 06:26 PM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? I pay 25% for all pain, scar, wound care, and sinus formulations. Awesome pharmacy, ships nationally in 48 hours. I'm looking for seriously motivated reps.

Anonymous

#18   03-24-2014, 10:58 PM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Quote: Originally Posted by Anonymous I pay 25% for all pain, scar, wound care, and sinus formulations. Awesome pharmacy, ships nationally in 48 hours. I'm looking for seriously motivated reps. I'm sure you won't tell the name of the company, but what state are you in?

Anonymous

#19   03-26-2014, 08:34 AM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Quote: Originally Posted by Anonymous Medimix only paying 15%. Suxs Yes, but MediMix is here to stay. Many have gotten tempted with smaller pharmacies but want to come back. At least there is transparency and great customer service.

Anonymous

#20   04-16-2014, 02:45 PM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Quote: Originally Posted by Anonymous I'm sure you won't tell the name of the company, but what state are you in? In Texas with 3 pharmacies.

Anonymous

#21   04-28-2014, 01:41 PM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Any well paying and reputable companies in NJ?

Anonymous

#22   04-29-2014, 09:27 AM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Quote: Originally Posted by Anonymous I pay 25% for all pain, scar, wound care, and sinus formulations. Awesome pharmacy, ships nationally in 48 hours. I'm looking for seriously motivated reps. How do I get in touch with you????

Anonymous

#23   05-02-2014, 12:49 AM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Commissions aren't everything, but 15-20% is pretty standard. Service, efficacy, quality, are all very important for sustained business. These docs don't want to get patient complaints about anything. Sometimes the companies try to lure away reps with higher %, but you'll make less when you lose credibility with the product. Find a leader, a good % and quality product, and you'll make money. Some companies like to bonus reps over and above their performance when deserved. Lots of ways to incentivize sales performance.

Anonymous

#24   05-02-2014, 07:31 AM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Quote: Originally Posted by Anonymous Commissions aren't everything, but 15-20% is pretty standard. Service, efficacy, quality, are all very important for sustained business. These docs don't want to get patient complaints about anything. Sometimes the companies try to lure away reps with higher %, but you'll make less when you lose credibility with the product. Find a leader, a good % and quality product, and you'll make money. Some companies like to bonus reps over and above their performance when deserved. Lots of ways to incentivize sales performance. Agree with this comment 100%..spot on. Look for good pharmacy and good support with sales transparency. The fly by night start up pharmacies trying to throw out high commissions to lure reps away would be a very bad move. Do your homework, ask to speak to several reps.

Anonymous

#25   05-02-2014, 11:42 AM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Quote: Originally Posted by Anonymous Commissions aren't everything, but 15-20% is pretty standard. Service, efficacy, quality, are all very important for sustained business. These docs don't want to get patient complaints about anything. Sometimes the companies try to lure away reps with higher %, but you'll make less when you lose credibility with the product. Find a leader, a good % and quality product, and you'll make money. Some companies like to bonus reps over and above their performance when deserved. Lots of ways to incentivize sales performance. Right on. Stay away from the small pharmacies who will most likely be out of the compound biz, soon. Make sure you have a good lead manager who provides accurate information and a pharmacy who has a data system portal. Also look for those who have credentials and are licensed in most states. All you need are a few prescribers who believe in the product and who prescribe often. This has been a great opportunity for many in adding great, additional income.

Anonymous

#26   05-19-2014, 02:47 PM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? any pharmacy or rep working on a 1099 commission only basis is violating federal and state anti-kickback laws. If your doing get ready for a major legal issue. large fines and possible jail

Anonymous

#27   05-19-2014, 07:43 PM

Anonymous   Posts: n/a

Re: 1099 Compounding Commissions? Quote: Originally Posted by Anonymous any pharmacy or rep working on a 1099 commission only basis is violating federal and state anti-kickback laws. If your doing get ready for a major legal issue. large fines and possible jail So all distributors who sell Ortho products as 1099 are violating anti-kickback laws as well according to your logic. The law you are referring to that you think compounders are violating would apply to every medical rep selling 1099. You are wrong.   read more at http://www.cafepharma.com/boards/showthread.php?t=532111