08/28/2014 , 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.”
Be sure to ask the company to disclose how much
money they bill the insurance company (per gram)
for each prescription you will be compounding.
There are only a few PCAB/CQI accredited
pharmacies that do this the right way. Stick with
them and you will not look bad.
3. Co-Pays and Deductibles: Be sure to ask the
company to disclose how they handle collecting co-
pays and deductibles. What do they do for a
patient who has a $100 copay and the patient
cannot afford it. Most companies are waiving co-
pay which is strictly against the insurance
policies. You don’t want to be associated with
this practice. Even though you are not influence
by the pharmacy benefit managers (i.e. ESI/MEDCO),
you are influenced by their clients, the payers
(BC/BC and others). They are the ultimate payers
of all drugs. I do not think it is worth it to
risk your “in-network” status for something like
this.
4. Kick-back Warning: Be aware of the state and
federal laws. This may not be a STARK violation
but it could be a kick-back violation. How do you
know that patient you dispensed to and received
remuneration for was not a post office worker with
insurance paid for by the state? What about
insurance? This is federally backed and
the cards do not make mention of the fact.
Filtering out federal and state programs is not
easy anymore. Who has time to worry about this?
The other pharmacies do. They will be happy to
report things like this and even if everything is
operating by the book. I sure see no benefit
having auditors in my office for things outside my
scope of expertise.
You asked……It is not worth your time. Stay focused
on what you know.
, DPM, St. Louis, MO,
allenthepod@sbcglobal.net
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.”
Be sure to ask the company to disclose how much
money they bill the insurance company (per gram)
for each prescription you will be compounding.
There are only a few PCAB/CQI accredited
pharmacies that do this the right way. Stick with
them and you will not look bad.
3. Co-Pays and Deductibles: Be sure to ask the
company to disclose how they handle collecting co-
pays and deductibles. What do they do for a
patient who has a $100 copay and the patient
cannot afford it. Most companies are waiving co-
pay which is strictly against the insurance
policies. You don’t want to be associated with
this practice. Even though you are not influence
by the pharmacy benefit managers (i.e. ESI/MEDCO),
you are influenced by their clients, the payers
(BC/BC and others). They are the ultimate payers
of all drugs. I do not think it is worth it to
risk your “in-network” status for something like
this.
4. Kick-back Warning: Be aware of the state and
federal laws. This may not be a STARK violation
but it could be a kick-back violation. How do you
know that patient you dispensed to and received
remuneration for was not a post office worker with
insurance paid for by the state? What about
insurance? This is federally backed and
the cards do not make mention of the fact.
Filtering out federal and state programs is not
easy anymore. Who has time to worry about this?
The other pharmacies do. They will be happy to
report things like this and even if everything is
operating by the book. I sure see no benefit
having auditors in my office for things outside my
scope of expertise.
You asked……It is not worth your time. Stay focused
on what you know.
, DPM, St. Louis, MO,
allenthepod@sbcglobal.net
quoted from here
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