Since the new United States Pharmacopeia (USP) guidelines went into effect on November 1, 2023, I have been receiving many inquiries regarding their impact on compounders. Because the changes are fairly recent, compounders want to know how and when they must be fully compliant, what enforcement vehicles are in the government arsenals, and what types
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Pharmacy & Healthcare legal updates, news, and industry trends
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Tips on dealing with double DIR fees
Due to the new Medicare Part D requirements effective the next year, direct and indirect remunerations (DIR) fees – that are so favored by PBMs – must be included and deducted from reimbursements at point-of-sale. In other words, starting with 2024 (still unclear when exactly), there will be no more retroactive DIR fees. Currently PBMs…
Sustainability in Pharmacy. Possible?
“Climate change is the single biggest threat to our world and health.”The International Pharmaceutical Federation’s address to the WHO
A recent episode of “The Business of Pharmacy” podcast made me think about the environmental impact and sustainability of a pharmacy. In the episode, Mike Koelzer interviewed Melinda Su-En Lee – a co-founder of Phill Box…
You are invited: ASPL Pharmacy Law Conference
This year the American Society for Pharmacy Law (ASPL) is organizing its annual conference in San Antonio November 2-5. To register or to check out the schedule, please go to the conference website. Some of the highlights of the conference:
- a discussion of the impact of Rutledge v PCMA by Arkansas Lieutenant Governor Leslie
…
Rescheduling Cannabis? More possible than ever…
As many of you know, the U.S. Department of Health and Human Services (HHS) has recently recommended rescheduling marijuana from Schedule I to Schedule III under federal law.
The DEA has the final say here but a review of healthcare news shows that most commentators believe that the DEA will follow the recommendation and will…
Changes in reporting loss/theft of controlled substances
DEA regulations require DEA registrants to notify their local Field Division Office, in writing, of any theft or significant loss of any controlled substances within one business day of discovery of such. Registrants must complete and submit to their local DEA Field Division a DEA Form 106 regarding the theft or loss.
Prior to July…
Who needs to sign refill authorization? A lesson from a recent PBM audit
I recently assisted a pharmacy in a PBM audit where we had to address unauthorized refills. The PBM was recouping a substantial amount of money because a medical assistant was signing refill authorizations. While medical assistants often sign for refills, they need do so with their supervising prescriber’s credentials.
California law defines medical assistants as…
Upcoming Changes to the DSCSA – what do pharmacies need to start doing now?
The Drug Supply Chain Security Act (“DSCSA”) was enacted in 2013 with the goal of creating an interoperable electronic system to trace certain prescription drugs as they are distributed in the United States.
The DSCSA’s requires[1]:
- Product identification (such as a bar code)
- Product tracing (trading partners, such as manufacturers, wholesalers, and pharmacies
…
Pharmacies are facing increased scrutiny when filling ADHD meds
The DEA’s administrative action against Truepill is what first prompted me to write this blog post. Initially, I thought “interesting,” but I deal with over-dispensing allegations on a daily basis, so I didn’t think of writing about it. Then I started digging into the bedrock of this case. And the Truepill case has morphed into…