tag:blogger.com,1999:blog-28450497.post-35366617689066559212007-11-30T18:59:00.000-05:002007-11-30T18:59:00.000-05:00"It shouldn't take much experience to realize Horen's Drug Store is an unlikely candidate for your 'largest purchaser of hydrocodone.'"<BR/><BR/>You may be right, but since when (in any industry) is it the wholesaler's job to police its customers?<BR/><BR/>It seems like a very slippery slope to say, "Horen's drug store purchased x number of units of controlled substances, which accounts for x% of its total purchase and, therefore, is a drug diverter." What if the pharmacy is only using that wholesaler for a few products, all controlled substances? Does the wholesaler notify the DEA of abnormal purchasing patterns? Does the wholesaler stop conducting business with one of its customers because of abnormal purchasing patterns?<BR/><BR/>Long ago I worked for a small independent pharmacy (not an internet pharmacy) in rural Southeast Missouri. Hydrocodone was by far the top drug dispensed in units. Was there drug diversion? Maybe. If there was, it was at a very small scale. The vast majority of the utilization was valid, legal, and fully auditable. The patient population was 95% Medicaid recipients (and, due to the demographics of that region, most people were far below the federal poverty level) and, as is typical with that population, they take A LOT of drugs. In particular, A LOT of hydrocodone. The pharmacy easily dispensed 9,000+ units per day of legitimate (written by a DEA licensed MD) hydrocodone scripts. (Average ~300 scripts per day, 3 scripts per patient, ~75% of the population on hydrocodone, average quantity per Rx of 120 [1 qid x30 days]).<BR/><BR/>The “small independent“ pharmacy I worked for could have dispensed 605,000 units in 67 business days, almost 3 times the volume of Horen’s in a like period. Does that make it a candidate for contract suspension or termination? Does the volume of a particular controlled substance indicate the incidence of drug diversion? Even if there is a “pain clinic” involved in possible illegal prescribing activity, is it the pharmacy wholesalers’ responsibility to identify and/or control the dispensing pharmacies? (Rhetorical)<BR/><BR/>Without specific laws on the books, or even guidance from any given federal, state, or local government agency, department, or branch, how can a wholesaler investigate and determine “at risk” status of a customer? If that kind of policing begins, I can see hundreds of class action suits alleging unfair treatment and discrimination of pharmacy customers and patients. That is a slippery slope.PBMguruhttp://www.blogger.com/profile/00546076413892779491noreply@blogger.com