Friday, July 4, 2014

Question of the Day July 4, 2014 If you leave office use under state board of pharmacy authority don't you violate the entire intent and purpose of the DQSA? Are state boards of pharmacy willing to actually enforce laws and rules Don't compounding pharmacies make a lot more money from "office use" compounding than patient-specific compounding? Where is there greater potential for fraud, waste and abuse?


1 comment:

Kenneth Woliner, MD said...

Honestly, I wish state legislatures wrote laws that said:

(1) all office-use compounding must be made by FDA-registered outsourcing facilities;

(2) if a health care provider (physician, dentist, veterinarian, nurse practitioner, etc.) administers (not dispenses or distributes or resells) a compounded drug that was obtained from an FDA-registered outsourcing facility, that physician/clinic is statutorily immune from lawsuits that relate to the drug be defective (adulterated, misbranded or contaminated);

And

(3) the further dispensing or distribution of a compounded drug through physician (or veterinary) offices, is strictly prohibited. Furthermore, physician office cannot "act as an agent of the patient" and have compounded medications mailed to their offices for patients to pick up, nor tacan they use their physician accounts to pay the pharmacy for the medication (with the patient then paying the physician for the drugs).