newsletter - nabpvendor, prometric; the north american pharmacist licensure examination™...

newsletterNational Association of Boards of Pharmacy®

aid to governmentthe profession

the public1904 to 2007

November-December 2007 / Volume 36 Number 10

Upcoming EventsJanuary 10-13, 2008Multistate Pharmacy Jurisprudence Examination State-Specific Review Renaissance Ft Lauderdale - Plantation HotelPlantation, FL

January 24-25, 2008Committee on Law Enforcement/Legislation MeetingNABP HeadquartersMount Prospect, IL

April 4, 2008Committee on Constitution and Bylaws Meeting(Conference Call)

May 17-20, 2008NABP 104th Annual Meeting Baltimore Marriott Waterfront Baltimore, MD

In This Issue. . . .Legal Briefs:Prescription for Murder

164

Association News:Peer Review Programs Foster Assessment, Revision of Pharmacy Processes

170

Fall Legislative Conference:FDA, DEA Speakers Cite Collaboration with NABP, Boards of Pharmacy

175

Feature News:States Begin to Implement Elec-tronic Tracking of Pseudoephedrine Purchases

176

Professional Affairs Update: Bush OKs Six-Month Delay for Tamper-Resistant Rx Pad Law

183

(continued on page 162)

Combined Efforts Lead to NAPLEX, Georgia MPJE Reinstatement

Through the diligent efforts of the NABP Executive Committee; NABP examination committees; NABP staff; and the NABP testing vendor, Prometric; the North American Pharmacist Licensure Examination™ (NAPLEX®) was reinstated on October 5, 2007, in all Prometric testing centers, several weeks earlier than the originally anticipated date. In addition, with the support of the Georgia Board of Pharmacy, the reinstatement of the Georgia Multistate Pharmacy Jurisprudence Examination® (MPJE®) became effective on December 8.

“NABP maintained a rigorous schedule, working closely with Prometric personnel and NAPLEX Review Committee members to

prepare and analyze items so that the examination meets validity and quality assurance measures required for the NAPLEX,” states NABP President Oren M. Peacock, Jr.

Both reinstated examinations are being offered at Prometric testing centers during regular business hours, Monday through Saturday, and remain in the same computer-adaptive format as in the past. Candidates who have been deemed eligible for the Georgia MPJE or the NAPLEX by their respective state boards of pharmacy may schedule appointments to sit for the examinations. Those candidates who have existing appointments, either selected prior to the suspension of the NAPLEX and MPJE or rescheduled by Prometric during the suspension, are responsible

for rescheduling their appointments if they wish to test at an earlier date and time.

“While the integrity of the NAPLEX remains our top priority,” states Peacock, “NABP understands the importance of this examination for those candidates seeking licensure, and dedicated extensive resources to achieving this reinstatement as quickly as possible.”

NABP applauds the dedication of the Prometric team that made the earlier than anticipated reinstatement of the NAPLEX possible.

nabp newsletter

162

The NABP Newsletter (ISSN 8756-4483) is published 10 times a year by the National

Association of Boards of Pharmacy (NABP)

to educate, to inform, and to communicate the objectives and programs of the Association and its 66 member boards

of pharmacy to the profession and the

public. The opinions and views expressed in this publication do not necessarily reflect the

official views, opinions, or policies of NABP or any board unless

expressly so stated. The subscription rate is

$35 per year.

National Association of Boards of Pharmacy

1600 Feehanville Drive Mount Prospect, IL

60056 847/391-4406 www.nabp.net

[email protected]

Carmen A. Catizone Executive Director/

Secretary

Larissa Doucette Editorial Manager

©2007 National Association of Boards

of Pharmacy. All rights reserved. No part of this publication may be reproduced in any manner without the

written permission of the executive director/

secretary of the National Association of

Boards of Pharmacy.

Association News

Examination SecurityDeveloped to assess

the entry-level skills of candidates and required by all 50 states, the District of Columbia, Guam, Puerto Rico, and the Virgin Islands as part of the specifications for pharmacist licensure, the NAPLEX consists of 185 multiple-choice questions, including both profile-based and stand-alone items.

Since NABP f irst began development of the standardized pharmacy competence examination, NABP has been vigilant in maintaining the security of the NAPLEX and its other examinations. In order to uphold and ensure

the utmost integrity of its examinations, NABP follows strict security measures during all stages of the examinations, including both the development and testing phase.

While in the examination development phase the items undergo rigorous evaluation including pretesting and statistical analysis. NABP utilizes these psychometric evaluations and the statistical support to ensure that the examination items are not overexposed to any one segment of candidates. Further, NABP copyrights all of its examinations using a secure test procedure developed by the United States copyright off ice.

During the testing phase of the examinations,

NAPLEX Reinstatement(continued from page 161)

candidates must, among other things, show two forms of identif ication, are not allowed to bring any materials into the testing room, must agree to a non-disclosure statement, and are continuously monitored by testing center staff and video cameras.

With these security procedures, as well as several additional measures, NABP is dedicated to providing candidates with secure and valid examinations and will continue to ensure that the NAPLEX, as well as all other examinations, meets and maintains examination standards set by the pharmacy profession.

For additional information regarding NABP examination programs, please visit the NABP Web site at www.nabp.net.

Deadline Set for Proposed Amendments to NABP Constitution and Bylaws

Proposed amendments to the NABP Constitution and Bylaws must be

submitted between Monday, February 18, 2008, and Thursday, April 3, 2008,

to be considered during the NABP 104th Annual Meeting, May 17-20, 2008,

at the Baltimore Marriott Waterfront, Baltimore, MD. Amendments must

be submitted in writing to NABP Executive Director/Secretary Carmen A.

Catizone at NABP Headquarters, 1600 Feehanville Dr, Mount Prospect, IL

60056. Submission dates are established by the NABP Constitution and Bylaws,

which specifies that proposed amendments may be accepted no earlier than 90

days and no later than 45 days before the first business session of the Annual

Meeting.

november-december 2007

163

DEA Calls on Pharmacies, Regulators, Others to Help Curb Illegal Sale of Controlled Substances via Internet

Drug Enforcement Ad-ministration (DEA) is call-ing on the cooperative effort of pharmacies, practitioners, distributors, state and local law enforcement, and regu-latory agencies to help curb the illegal sale of controlled substances via the Internet. DEA distributed an infor-mational notice regarding recent trends in the Internet trafficking of pharmaceuti-cal controlled substances on August 13, 2007, to guide stakeholders in preventing the illegal diversion of these medications.

In its “Notice: Diversion Trends via the Internet,” DEA cites the Code of Federal Regulations (Title 21, §1306.04), which requires prescriptions for controlled substance medications to be “issued for a legitimate medical purpose by an individual practitioner acting in the usual course of his professional practice.” DEA states that, “[u]nder Federal and state law, for a practitioner to be acting in the usual course of professional practice, there must be a bona fide doctor-patient relationship.”

In the notice, DEA lists the elements that medical authorities generally accept as indications of a bona fide doctor-patient relationship:

a patient has a medical •complaint;a medical history has •been taken;

a physical examination •has been performed; andsome logical connection •exists between the medical complaint, the medical history, the physical examination, and the drug prescribed.DEA describes the typi-

cal illicit Internet opera-tions as those that skirt this relationship by having cus-tomers complete medical questionnaires online and possibly fax recent medical records to the Web sites, which generally charge con-sultation fees. Payment is generally accepted by credit card only; no insurance. A prescribing practitioner affiliated with the Web site may contact customers by phone for consultation and then authorize prescrip-tions via the Web site. An Internet pharmacy affili-ated with the Web site then receives the prescription and ships the medication to the customer.

DEA stresses that an individual completing an online questionnaire that is reviewed by a practi-tioner hired by a Web site operator does not establish a legitimate doctor-patient relationship and, thus, a prescription based solely on an online questionnaire is illegal.

A few states already incorporate this distinction in their laws. (See “States Begin to Define What Con-stitutes Legitimate Patient-

Prescriber Relationships” in the September 2007 issue of the NABP Newsletter, avail-able on the NABP Web site at www.nabp.net.)

Arkansas prohibits dispensing medications for prescriptions writ-ten based on an Internet questionnaire or a cyber or telephonic consultation without a “proper relation-ship” with a practitioner, which includes a physi-cal examination. North Carolina prohibits filling Internet-based prescrip-tions generated without a physical examination or a prior patient-prescriber relationship. West Virginia specifically prohibits online or telephonic evaluations by questionnaire to estab-lish a patient-practitioner relationship.

The NABP Verified Internet Pharmacy Practice Sites™ (VIPPS®) program, which accredits Internet pharmacies meeting a stringent set of professional practice criteria, requires pharmacies displaying the VIPPS seal to maintain and enforce policies and procedures to ensure that prescription medications are not prescribed or dis-pensed based on telephonic, electronic, or online medi-cal consultations without a pre-existing patient-prescriber relationship that has included an in-person physical examination. Ken-tucky and North Carolina


Executive CommitteeLawrence H. “Larry” MokhiberChairpersonOne-year term

Oren M. Peacock, JrPresidentOne-year term

Richard A. “Rich” PalomboPresident-electOne-year term

Gary A. Schnabel TreasurerOne-year term

Karen M. RyleMember, District 1Serving first year of a three-year term

Elizabeth Scott “Scotti” RussellMember, District 2Serving first year of a three-year term

Reginald B. “Reggie” DilliardMember, District 3Serving third year of a three-year term

William T. “Bill” WinsleyMember, District 4Serving third year of a three-year term

Lloyd K. JessenMember, District 5Serving first year of a three-year term

Malcolm J. BroussardMember, District 6Serving second year of a three-year term

Cathryn J. LewMember, District 7Serving first year of a two-year term

Patricia F. HarrisMember, District 8Serving third year of a three-year term

The NABP Executive Committee is elected each year at the Association’s Annual Meeting.

Feature News

nabp newsletter

164

Prescription for MurderBy Dale J. Atkinson, JD

Boards of pharmacy are likely empowered to administratively

sanction a licensee based upon a criminal conviction. Generally, such authority will be found in the practice act, perhaps specifically under the grounds for discipline. The language within the practice act may be important in determining the basis for relying upon the criminal conviction (as opposed to the acts that lead to such conviction). Sometimes, reference to and citation of the facts contained in judicial holding are the best learning tools. Consider the following:

A physician held a duly issued license to practice medicine in Texas. He prac-ticed industrial medicine involving worker’s compen-sation claims. Regarding one particular patient and presumably based upon the physician’s assessment, a claimant was found by the worker’s compensation commission to have a 4% impairment. This finding resulted in a reduction of benefits paid to the patient. Angered at the physician, the patient confronted the licensee and threatened to kill him, his family, his staff, and their families. Later that evening, the patient appeared at a social event at the physician’s home and again threatened to kill the physician and his family. The patient empha-sized that he knew where the physician lived and

other descriptive details about the physician and his family.

A guest of the physician at the social event, a chiro-practor, voiced eagerness to physically step in and assist the physician. The chiro-practor also later loaned a shotgun to the physician and put him in contact with a local police officer. At a meeting with the police officer, (precisely what was said is in dispute), the phy-sician identified the issues with the patient. The officer explained the process for filing a complaint and indi-cated that the police would investigate. During this in-terview, the physician also mentioned he had a brother who was an officer with the Mexican federal police and that in Mexico “one could pay a Federale to ‘take care’ of the likes of [patient].”

The physician also alluded to drinking beer on the patient’s grave.

The officer, confused by what the physician was requesting, asked what the physician would like the police to do. The physician responded by suggesting that the officer get a gun and (holding his hand up like a gun) said “boom, boom, boom.” The officer interpreted these remarks to mean that the physician wanted the patient killed. The officer was “shocked” and “surprised” and won-dered if he was being set up. He told the physician that “he had to think about it.” The officer later testified that there was no doubt in his mind that the physician was asking the officer to kill the patient.

Many factors within the meeting between the of-ficer and the physician are in dispute as to who said what and what may have been meant. The physician denied that he pointed his finger like a gun and said “boom, boom, boom.” The physician believed that the officer stated that he would help him (the physician) out and “help him take care of the problem.”

Based upon the officer’s report to his superiors in the police force, the officer continued to investigate the physician, including the use of surveillance and recording devices. Several conversations between the


165

officer and physician were recorded during this investi-gative period. The meanings of the recorded conversations were in dispute. However, it was not in dispute that the physician paid $8,000 to the officer so that the officer could acquire an unregistered handgun.

Additional meetings took place between the officer and the physician, including the establishment of an alibi for the physician and that a price would be paid by the physician to the officer for the allegedly agreed upon “act.” Eventually, the officer reported to the physician that the matter had been taken care of and the physician inquired as to whether he had pictures. The payment of monies was discussed and the meeting ended. Upon leaving the meeting, the physician was arrested and charged with solicitation of capital murder. The physician pled nolo contendre to the charge and an order of deferred adjudication was entered whereby the physician was sentenced to 10 years com-munity supervision, a $5,000 fine, forfeiture of the $8,000 paid to the officer, and 500 hours of community service.

Thereafter, the board initiated a formal complaint against the physician alleg-ing a felony conviction and unprofessional conduct that is likely to deceive, defraud, or injure the public. After a hearing, the administrative law judge (ALJ) determined

that the order of deferred adjudication was not a “con-viction” that would support an administrative sanction against the license. The ALJ also determined that the unprofessional conduct al-legation at the administrative level, claiming the conduct would deceive or defraud the public, must be related to the practice of medicine. Thus the ALJ concluded that the board must establish “not only that [physician’s] re-marks were ‘connected with’ his practice of medicine, but were undertaken ‘while in the practice of medicine or under the guise of practicing medicine.’”

However, the ALJ did conclude that the board could sanction the physician for unprofessional conduct that “could likely injure the public.” He held that the phy-sician’s actions constituted acts that would likely injure the public, providing a basis for administrative discipline. The board adopted the find-ings of the ALJ, except for the conclusion of law that found that the solicitation of mur-der did not occur while the physician was engaged in the practice of medicine, stating that such was not alleged and need not be determined by the board. Additional conclu-sions of law were also not ad-opted as the board held such were not conclusions, but merely recommendations. In the end, the recommended sanctions of revocation, $5,000 fine, and payment of

$1,480 in transcripts costs were adopted.

The physician sought judicial review of the board’s order, which was affirmed by the district court. Thereafter, the physician appealed the matter to the appellate court.

The physician argued two sets of issues. The first set addressed questions of the admission of the taped conversations and transcrip-tions into the administrative record, as well as the applica-tion of the preponderance of the evidence standard, rather than the higher supported-by-substantial-evidence standard. The second set of issues addressed the ques-tions of whether the findings of fact determined by the ALJ and adopted by the board supported the disciplinary grounds that the physician committed unprofessional conduct likely to injure the public without a finding that the acts were commit-ted within the practice of medicine.

The court held that the tapes of the conversations, although not necessarily clearly identified by the offi-cer in testimony as accurately reflecting their conversations, were admissible. It also noted that testimony established that the transcriptions accu-rately reflected the contents of the tape giving credence to their admissibility. Regarding the burden of proof, the court held that the Texas courts have consistently held that administrative proceedings

Legal Briefs

Attorney Dale J. Atkinson is a partner in the law firm of Atkinson & Atkinson, counsel for NABP.


nabp newsletter

166

Legal Briefs(continued from page 165)

are “civil in nature” and that “no doctrine is more firmly established than that issues of fact are resolved by a pre-ponderance of the evidence.”

Interestingly, the physi-cian argued that the analogy to a civil proceeding neces-sitated the implication of Texas law that prohibits the use of a nolo contendre plea in a civil suit based upon or growing out of the act upon which the criminal pros-ecution is based. The court noted that the ALJ agreed and found that the plea was not admissible. However, the actual order of deferred

adjudication was admissible, and the court presumed that the ALJ relied upon that order rather than the nolo plea.

The court also rejected the physician’s arguments that the factual findings were not supported by substantial evidence. The court held that board find-ings were reasonable in light of the evidence from which they are purported to infer, satisfying the test followed by the judiciary. In addi-tion, the court recognized the authority of the board and held that the medical practice act, construed as a whole, is not meant to limit the prohibited practices to

acts or conduct committed solely within or in the guise of medical practice. It noted prohibited practices include fraudulent acts commit-ted in the application for licensure process, as well as criminal convictions involv-ing moral turpitude, and a mental or physical condition rendering a person unable to practice medicine with reasonable skill and safety. Thus, the court held that the board acted consistent with the legislative intent in finding that conduct likely to injure the public need not be directly related to the practice of medicine.

In short, the court up-held the actions of the board

in disciplining the physician based upon the order of the deferred adjudication and the fact that the actions were likely to injure the public.

The use of criminal convictions can present interesting issues for boards of pharmacy in subsequent administrative proceedings. Many examples of judicial decisions exist whereby the conviction (or acts) must be linked to the practice. For-tunately, the solicitation to commit capital murder was found to implicate actions likely to injure the public.

Sanchez v Texas State Board of Medical Examiners, 2007 WL 1853371 (App Ct TX 2007)

Association News

NAPLEX and MPJE Test Vendor to Change Effective January 2, 2008,

NABP will utilize a new vendor for administration of the North American Pharma-cist Licensure Examination™ (NAPLEX®) and the Multi-state Pharmacy Jurisprudence Examination® (MPJE®). Pearson VUE, the new vendor, offers a professional testing environment for candidates through its network of Pear-son VUE owned and operated testing centers in the United States and its territories.

“Pearson VUE has a record of solid customer ser-vice combined with a secure and consistent test center network to efficiently deliver and safeguard examinations such as the NAPLEX and MPJE,” says NABP President Oren M. Peacock, Jr.

NABP has been working closely with Pearson VUE

to structure testing admin-istration services for NABP examinations, and to facili-tate a seamless transition to Pearson VUE. As with the current process, a candidate submits an application to sit for the NAPLEX and/or MPJE on the NABP Web site; once accepted, an Authorization to Test (ATT) number is issued. Upon receiving the ATT, a candidate may schedule a date to sit for the examination by visiting the Pearson VUE Web site. Registration for Pearson VUE test sites will begin on January 2, 2008; candidates who wish to sit for an exami-nation prior to that date will register through the Associa-tion’s current test vendor.

“Pearson VUE is com-mitted to providing excellent customer service on behalf of the NABP examination

programs,” says Robert Whelan, president of Pearson VUE. “Testing programs choose Pearson VUE because we deliver on our promise to provide solid performance, outstanding customer service, and reliable examination delivery. We look forward to providing a professional test-ing environment for NABP examination candidates.”

The NAPLEX is the standardized examina-tion utilized by all 50 state boards of pharmacy, the District of Columbia, Guam, Puerto Rico, and the Virgin Islands as part of their assessment of com-petence to practice phar-macy. NABP also offers the Pre-NAPLEX®, the only NAPLEX practice examina-tion written and developed by NABP, through Pearson

VUE. The MPJE combines federal and state specific law items to serve as the state law examination in 46 participating jurisdictions and is one condition of licensure in those states.

As the transition pro-gresses, information will be posted to the NAPLEX/MPJE section of the NABP Web site in order to inform candidates of any pertinent information. The Asso-ciation anticipates that the



167

Association News

Task Force Seeks to Safeguard Prescription Medication Supply Chain against Threat Posed by Cargo Theft

The states have taken great strides to safeguard the nation’s medication supply chain against counterfeiting and diversion. Recently enacted laws and regulations in some states tighten licensing requirements for wholesale drug distributors and establish controls over mail-order pharmacies and Internet distributors selling medications across state lines.

Some NABP members have pointed out, however, that a significant weakness in the supply chain remains all-too-often unheeded. Potentially millions of dollars worth of prescription medications enter the black market with every incident of pharmaceutical cargo theft.

“Most of these drugs end up on the streets,” says William Harvey, executive director/chief drug inspector for the New Mexico Board of Pharmacy. “It’s our responsibility to prevent that from happening.”

Harvey served as ex officio member of the NABP Task Force on Prescription Drug Diversion from Common Carriers, which met November 8-9, 2007, at NABP Headquarters. The task force was created as a result of a resolution passed at the

103rd Annual Meeting in May 2007, which notes (1) that the diversion of prescription medication from common carriers presents a threat to the public health, and (2) that “regulations regarding the distribution and delivery of prescription drugs vary by state and often do not include accountability provisions for common carriers that distribute and deliver prescription drugs.”

The charge of the task force is to study issues surrounding the diversion of prescription drugs from common carriers or their agents during interstate and intrastate distribution and delivery to wholesalers, pharmacies, patients, and patients’ agents and to recommend possible solutions.

Complicating the problem, pharmaceutical cargo thefts often go unreported, Harvey says. If a pharmacy receives an incomplete order, pharmacy personnel likely assume an error on the part of the wholesaler, who in turn typically provides the pharmacy with the missing units, attributes the error to the courier, and/or files an insurance claim for the lost inventory. The courier might report the theft to local police, but it is not clear how often these instances are reported to the state

board of pharmacy or Drug Enforcement Administration (DEA), as required of entities registered to handle controlled substances, Harvey says.

Title 21 of the Code of Federal Regulations (CFR) holds suppliers

use ground couriers, who might then subcontract other couriers of varying sizes and standards of professionalism to deliver the pharmaceutical cargo to various destinations after they leave the wholesaler’s warehouse.

DEA holds registrants accountable for checking the backgrounds of couriers and warehouse personnel handling controlled substances. “When shipping controlled substances, a registrant is responsible for selecting common or contract carriers which provide adequate security to guard against in-transit losses,” CFR states. “. . . In addition, the registrant shall employ precautions (eg, assuring that shipping containers do not indicate that contents are controlled substances) to guard against storage or in-transit losses.”

Shipping trade maga-zine Northeast Export lists pharmaceuticals among the top 10 targets of cargo theft, largely be-cause of their aftermarket sales value. Harvey notes that most pharmaceuti-cal cargo thieves target controlled substances and so-called lifestyle medications.

In most cases, law enforcement officials say, cargo thefts are inside jobs. The Crime Prevention Service for Business, of Rutgers


“Most of these drugs end up on the streets. It's our responsibility to prevent that from happening.”

William Harvey, Executive Director/

Chief Drug Inspector New Mexico Board

of Pharmacy

responsible for “reporting [to DEA] in-transit losses of controlled substances by the common or contract carrier selected pursuant to Sec. 1301.74(e), upon discovery of such theft or loss. . . . Thefts must be reported whether or not the controlled substances are subsequently recovered and/or the responsible parties are identified and action taken against them.”

A wholesale drug distributor might be legitimately licensed and operating within the law, but many wholesalers

nabp newsletter

168

Association News

University, New Jersey, notes that cargo theft occurs most commonly in trucking and is often committed by a truck driver and a warehouse employee working together, and that cargo is at its greatest risk when it is being loaded and unloaded.

Thefts also commonly occur when trucks are left unattended, notes Barbara Goodson, senior criminal financial analyst of the Florida Law Enforcement Analyst Academy, in a June 2007 report on counterfeit prescription drugs. “These trucks have been hijacked, broken into while the driver is at lunch or dinner, the trailer has been unhitched from the cab while parked at an overnight stop, or stolen from a pharmaceutical facility warehouse,” she says. “. . . People’s health is at stake and there needs to be more security for these trucks delivering what could be life-saving medication.”

In June 2007, DEA notified the boards of pharmacy of the theft of more than 16 million doses of hydrocodone combination products. A tractor-trailer traveling from Watson Pharmaceuticals, Inc manufacturing plant in Corona, CA, to its distributor in Gurnee, IL,

was stolen from a truck stop in Troy, IL.

New Mexico news source KOB.com reported in July 2007 that a Neb Ark Courier van containing 2,000 tablets of hydrocodone and approximately 200 tablets of oxycodone was stolen from outside the Lovelace Healthcare Clinic in Albuquerque, NM, while the driver was inside delivering the freight. These tablets reportedly carry a typical street value of $10 apiece. This latest heist is the third theft of prescription pain medication the courier has encountered this year, KOB reports, noting that investigators think the thefts are an inside job.

The online news publication e-Week reported that police apprehended a theft ring in July 2006 near Chicago, found to have pilfered some $2.2 million in various merchandise, including prescription medications, from courier trucks. “Thieves often follow trailers from the time they exit a plant until the driver stops for the night and then make off with the entire vehicle,” e-Week reports. Steve Grover, director of communications at Knight Transportation in Phoenix, AZ, says in the article that the ready availability of unattended cargoes to potential thieves points to an efficiency problem in the shipping business. In the process of coordinating

manufacturer, trucker, and retail store schedules, he notes, cargoes often sit for hours or days until the store has the capacity to receive the load or the manpower to empty it.

Chris Swecker, assistant director of the Criminal Investigative Division of the Federal Bureau of Investigation (FBI), addressed the House Judiciary Committee’s Subcommittee on Crime, Terrorism, and Homeland Security in March 2005 regarding FBI’s efforts to curb the “nationwide problem posed by criminal enterprises involved in the theft, diversion, repackaging, and ultimate resale of consumer products,” including prescription and over-the-counter medications. “The unsuspecting consumer also faces potential health and safety risks from legitimate products which may have been mishandled by the criminal enterprises who stole them for resale to consumers,” Swecker states. If medications are not stored under proper conditions or are adulterated, they pose a significant health hazard to consumers when reintroduced into the retail market.

Food and Drug Administration and some drug makers are looking to radio-frequency identification of prescription medication containers to help track stolen medications, weed out counterfeits, and

maintain the integrity of the supply chain. Others point to increased security measures and uniformly enforced employee background checks to address the problem.

These and other potential remedies, as well as related regulation and enforcement issues, were the subject at hand for the NABP Task Force on Prescription Drug Diversion from Common Carriers.

The following individuals, listed here with their state boards of pharmacy, have been appointed to serve on the task force: Howard C. Anderson, Jr, RPh, chairperson, North Dakota; Wendy L. Anderson, RPh, Colorado; Jack William “Jay” Campbell IV, RPh, JD, North Carolina; John R. Dorvee, Jr, PharmD, Vermont; Edith G. “Edie” Goodmaster, Connecticut; Edward G. McGinley, RPh, New Jersey; Peter J. Orzali, Jr, RPh, Kentucky; and Frank A. Whitchurch, RPh, Kansas; William C. Harvey, RPh, ex officio member, New Mexico; and Lloyd K. Jessen, RPh, JD, Executive Committee liaison, Iowa.

The task force is now in the process of developing a report outlining its recommendations. The NABP Executive Committee will then review the task force report, which, once approved, is distributed to all member boards and posted on the NABP Web site.

Threat Posed by Cargo Theft(continued from page 167)


169

Association News

require Internet pharma-cies conducting business in those states to be VIPPS-accredited.

In addition, during the NABP 103rd Annual Meet-ing in May 2007, NABP member boards passed a resolution to encourage regulators to explicitly prohibit the dispensing of medications based on prescriptions generated solely from Internet-based questionnaires or otherwise invalid patient-prescriber relationships.

In response to the esca-lating use of the Internet to illegally obtain controlled substance medications, DEA has suspended or revoked the DEA regis-trations of pharmacies, practitioners, and distribu-tors who were involved in the illegal distribution of controlled substances via

the Internet. Additionally, DEA has instigated criminal investigations leading to the arrest of doctors, pharma-cists, and Web site operators involved in the illegal sale of controlled substances over the Internet.

Some NABP members question whether DEA is acting aggressively enough to crack down on illegal ac-tivities involving controlled substances. They cite DEA’s responsibility and author-ity to impose and enforce legal controls on scheduled substances. The law enforce-ment arm of some boards of pharmacy, by contrast, has a more limited reach.

For its part, DEA aims to keep the boards and other stakeholders abreast of criminal practices as it becomes aware of them. For instance, DEA notes a recent trend in the illegal sale of controlled substance medi-cations over the Internet that often skirts traditional

means of detection. Some illicit Internet operations now offer “Direct Script” programs, in which illegal prescriptions for controlled substances are either faxed to the customer’s local phar-macy or sent directly to the customer to present at a lo-cal pharmacy. The Web site’s consultation fee is typically higher, but customers in this scenario can now use insur-ance to pay for the medica-tions. (For more on DEA’s activities, see “FDA, DEA Speakers Cite Collaboration with NABP, Boards of Phar-macy as Key to Protection of Public Health” on page 175 of this Newsletter.)

Controlled substance medications most frequently sought after by illegal means include hydrocodone combination products, benzodiazepines, and phentermine, DEA states in the notice.

DEA urges pharmacies to be vigilant for indications

that a controlled substance prescription may have been obtained illegally. The agency advises pharmacy personnel to verify the authenticity of controlled substance prescriptions received via fax or in person bearing the address of a practitioner in another state, written by a practitioner unfamiliar to the pharmacist, or presented by a patient unfamiliar to the pharmacist.

If a prescription is suspected of originating from an illegal Internet operation, DEA requests that the pharmacist contact the DEA office in their local area; contact information is available on the DEA Web site at www.DEAdiversion .usdoj.gov. Alternatively, pharmacists can report suspicious Internet activities directly via the DEA Web site or by calling the DEA drug abuse hot line toll-free at 877/792-2873.

DEA Calls(continued from page 163)

NABPLAW Online Provides Valuable Research Results With the addition of

state controlled substance and wholesale distribu-tor laws and regulations, NABPLAW® Online continues to offer subscrib-ers comprehensive and complete research results. NABPLAW Online, a valu-able and robust research tool, consists of the phar-macy practice acts and board of pharmacy regula-tions for all 50 states and the District of Columbia, and is constantly updated and maintained by NABP

staff to ensure that the databank remains thorough and complete.

With its powerful search capabilities, NABPLAW Online allows subscribers to adapt their searches to meet their specific require-ments as well as search by individual state, several states, or all 51 jurisdic-tions. Convenient and user-friendly search options are especially beneficial to state boards of pharmacy wish-ing to perform comprehen-sive queries of the laws and

regulations implemented and/or amended by other states, providing a stream-lined research process conducive to side-by-side comparisons of research findings.

In addition to the state boards of pharmacy, NABPLAW Online is utilized as a valuable tool by attorneys, chain drug store headquarters, schools and colleges of pharmacy, health care marketing research companies,

pharmaceutical companies, and state and national pharmacy associations.

For a free demonstra-tion or to subscribe to NABPLAW Online, visit the Publications section of the NABP Web site at www.nabp.net.

nabp newsletter

170

Association News

Peer Review Programs Foster Assessment, Revision of Pharmacy Processes, and Prevention of Future Adverse Events

Traditionally, regulatory bodies have been left little latitude but to take

the approach that when medication errors occur, the response is to discipline the responsible entity, as required by statutes and rules. Presently, many argue that such a punitive system is not the best way to prevent similar errors from recurring.

NABP understands and supports the “systems” ap-proach to identifying and preventing future medica-tion errors. NABP President Oren M. Peacock, Jr, RPh, is a strong supporter of such an approach, as well as peer review programs that evaluate errors to identify weaknesses in the system and modify practices to prevent similar errors from occurring in the future. An approach that identifies and seeks to prevent future errors and uses discipline only when necessary, he says, encourages the report-ing, open discussion, and prevention of future medi-cation errors.

Speaking at the NABP 103rd Annual Meeting in May 2007, President Peacock announced that, during his term as presi-dent, his focus is to assess the current status of quality outcome and peer review legislation and regulations in the states and the appli-cability of model language included in the Model State

Pharmacy Act and Model Rules of the National Asso-ciation of Boards of Phar-macy (Model Act).

Member boards of pharmacy echoed his com-mitment when they passed Resolution No. 103-5-07, “Medication Error Report-ing,” at the Annual Meet-ing. The resolution includes a commitment to “review and revise, if necessary, the Model Act regarding the im-plementation of continuous quality improvement [CQI] and peer review programs and best practice recom-mendations, in accordance with non-discovery provi-sions that allow appropriate access by the state boards of pharmacy and regulatory agencies, with the ultimate goal of enhancing patient safety and quality of care.”

To bring about this objec-tive, NABP convened the Task Force on Continuous Quality Improvement, Peer Review, and Inspecting for Patient Safety December 6-7, 2007, at NABP Headquarters in Mount Prospect, IL.

The charge of this task force is threefold: (1) to review current language in the Model Act addressing CQI, peer review, and free-dom from discovery and, if necessary, recommend amendments to accom-modate the present practice environment; (2) to develop an implementation plan and educational program to assist states with developing and implementing quality improvement programs and peer review processes; and (3) to evaluate the need for a tool for use by boards of pharmacy to evaluate pharmacies in the area for patient safety. If indicated, the task force will also develop such a tool.

The Model Act currently includes language recommending that each pharmacy establish a CQI program that includes periodic pharmacy staff meetings to consider the effects of staffing levels, workflow, and technological support on the quality of the pharmacy system. It advises that these meetings should include a review of data showing evidence of the quality of care for patients served by the pharmacy, and the development of plans to improve the system of pharmacy practice to increase good outcomes for patients.

The Model Act further recommends that the


171

Association News


boards require pharmacists to report medication errors to a designated error re-porting program. Such pro-grams monitor error trends and recommend safety measures where needed. The Model Act qualifies, however, that error re-ports should be considered “privileged and confidential . . . and shall not be public records nor be available for court subpoena or for discovery proceedings.”

The state boards of pharmacy and NABP previously have come out in favor of a nonpunitive system of error reporting. The 2004-2005 NABP Task Force to Develop Recom-mendations to Best Reduce Medication Errors in Com-munity Pharmacy Practice noted that “pharmacists are often hesitant to report errors because of fear that such information may be used against them in court proceedings or hearings” and that “NABP should continue to work with the state boards to encourage regulations and legislation that provide certain protec-tions of error data submit-ted by pharmacists and pharmacies.” Additionally, the task force identified the need to provide protection for peer review materials from legal discovery.

In certain situations, however, disciplinary ac-tion is the only appropriate

response of the boards of pharmacy. For instance, if the pharmacy has a pro-cedure in place to prevent medication errors, and an error occurs because the pharmacist does not fol-low the procedure, some argue that the appropriate response is not to change the system, but to discipline the pharmacist.

According to the 2007 NABP Survey of Pharmacy Law, 14 state boards of pharmacy require phar-macies to maintain a CQI program to monitor and prevent quality-related events.

During his talk at the Annual Meeting, Presi-dent Peacock commended the Quality Improvement Program and Peer Review System established by the legislature in his home state of Texas. In implementing the legislation, the Texas State Board of Pharmacy worked with other patient safety and pharmacy stake-holders to establish guide-lines on how best to imple-ment quality improvement programs and peer review systems.

“The pharmacy peer review process goes beyond traditional personnel evalu-ations, risk management activities, or supervisory reviews in that it provides for outcome-based, con-tinuous quality improve-ment processes,” he ex-

plained. “Through a peer review process, partici-pants are able to identify quality-related events that are below set standards; evaluate processes and determine the reasons why events occurred; and make recommendations to lessen future occurrences of the events and work with the individuals to implement recommendations. Most of all, peer review programs provide a platform for con-tinually assessing pharmacy processes to prevent future occurrences of adverse quality-related events.”

Other states recently have implemented or are in the process of imple-menting similar programs. California, Florida, and Massachusetts, for instance, require each pharmacy in those states to establish a CQI program including standards and procedures to identify and evaluate quality-related events and improve patient care. These programs require the docu-mentation and evaluation of quality-related events to determine possible causes and prevent future occur-rences.

In New Jersey, the Pharmacy Quality Improve-ment and Error Prevention Act (Senate Bill 1752), as introduced in 2006, calls for the establishment of a New Jersey Task Force on Medica-tion Error Prevention. The

nabp newsletter

172

Association News

act would require pharma-cies to establish a CQI pro-gram to assess medication errors and to determine and implement appropriate processes to prevent their recurrence. The act would further require all informa-tion regarding medication errors to be considered privileged and confidential.

In North Carolina, the Pharmacy Quality Assur-ance Protection Act, which became effective January 1, 2006, requires each phar-macy to implement a quality assurance program that includes evaluation of (1) the quality of the practice of pharmacy, (2) the causes of alleged medication errors and incidents, (3) pharma-ceutical care outcomes, (4)

possible improvements for the practice of pharmacy, and (5) methods to reduce alleged medication errors and incidents.

The New Hampshire Board of Pharmacy recently implemented a patient safety initiative that includes a nonpunitive approach to the voluntary and anony-mous reporting of medica-tion errors. It is expected that anonymous reporting will provide the Board with additional information and data for review, analysis, and sharing with pharma-cies in that state. The goal of the initiative is educational; its primary aim is to reduce medication errors. The Board plans to post information gained through this initiative on its Web site.

In Tennessee, Senate Bill 3107, as introduced in 2006,

Peer Review(continued from page 171)

encourages pharmacists to implement CQI programs and quality assurance pro-grams “to identify and evalu-ate quality-related events, reduce medication-related errors, generate data useful to studying the causes of medi-cation errors and improve patient care.” The bill further states, “confidentiality is essential to effective func-tioning of peer review com-mittees, continuous quality improvement programs and quality assurance programs, and to continued improve-ment in patient safety and patient care.”

The Task Force on Continuous Quality Improvement, Peer Review, and Inspecting for Patient Safety examined ways in which NABP can provide further guidance to assist the state boards

in implementing or, if necessary, fine-tuning their peer review and CQI programs.

The following individuals, listed here with their state boards of pharmacy, served on the task force: Kim A. Caldwell, RPh, chairperson, Texas; Joseph L. Adams, RPh, Louisiana; Vernon H. Benjamin, RPh, Iowa; Amy S. Buesing, RPh, New Mexico; James T. DeVita, RPh, Massachusetts; Paul N. Limberis, RPh, Colorado; Alice G. Mendoza, RPh, Texas; Kevin J. Mitchell, RPh, Ohio; Rebecca Poston, RPh, Florida; Charles R. Young, RPh, CFE, ex officio member; and NABP President-elect Richard A. “Rich” Palombo, RPh, Executive Committee liaison, New Jersey.

NABP Survey of Pharmacy Law Updated for 2008The NABP 2008 Survey

of Pharmacy Law CD-ROM, which provides a state-by-state overview of organi-zational law, licensing law, drug law, and census data, is now available.

The updated Survey includes the following changes:1. Section IV, formerly

titled “Practical Experi-ence: Internship Hours,” has been renamed “Pharmacy Practice Ex-perience Hour Require-ments” to reflect the ter-minology recommended by the 2006-2007 NABP Task Force on Standard-izing Student Pharmacist Experiential Require-

ments. For the same rea-son, section VI, “Foreign Pharmacist Licensure,” is also revised to change the title of subcategory “Practical Experience” to “Pharmacy Practice Ex-perience Hour Require-ments.”

2. Section XVI, “Phar-macy Licensure Require-ments,” is amended to include a subcategory indicating which states recognize Verified Inter-net Pharmacy Practice Sites™ accreditation.

3. Section XXVII, “Pos-session of Controlled Substances,” is amended to delete the subcategory indicating which states

allow pharmacists to dis-pense emergency contra-ception pursuant to an established collaborative practice agreement or protocol. This subcatego-ry was removed in light of the change in status of emergency contraception from legend to over-the-counter for patients 18 years of age and older.

4. Section XXIX, “Mini-mum Standards of Care,” is amended to in-clude a new subcategory indicating which state boards require compli-ance with United States Pharmacopeia Chapter 797, “Pharmaceutical Compounding – Sterile

Preparations.”The Survey is available for

purchase for $20. To order your 2008 Survey, complete the publications order form, which can be downloaded from the NABP Web site at www.nabp.net, and mail it with your payment to NABP Headquarters. Payment is accepted via check or money order made payable to NABP. The CD-ROM is provided free of charge to all final-year pharmacy students through a sponsorship from Purdue Pharma LP.

More information on the Survey is available by e-mailing NABP at [email protected].


173

Feature News

A Regulatory Tangle: Who Oversees Tribal Pharmacies?Most state boards of

pharmacy don’t spend much time thinking about tribal pharmacies, most of which serve Native Americans and are located on Indian reservations. However, tribal nations’ efforts at economic development, combined with the changing face of health care and the related increased popularity of Internet and mail-order pharmacies, have led to increased activity by tribes in the area of com-mercial pharmacy operations. This activity can create areas of conflict, as state pharmacy laws and regulations often remain silent on the issue, and the tangled strands of the federal-state-tribal jurisdic-tional web make for a murky legal climate.

Which Laws Apply?In general, federally

recognized tribes, located on federal land, even though they are considered in some ways to be sovereign nations, are also subject to federal ju-risdiction. For example, “The [Food and Drug Administra-tion (FDA)] considers Indian Reservations to be possessions of the United States within the meaning of section 201(a)(2) of the Federal Food, Drug, and Cosmetic Act,” states the Indian Health Service (IHS) in its summary of FDA jurisdiction on reservations. “Under the Food, Drug, and Cosmetic Act, the FDA has the same authority on a res-ervation as it does anywhere else, to inspect, to take official samples, and to initiate regu-latory actions.” Likewise, the Drug Enforcement Adminis-

tration (DEA) has jurisdiction in cases involving controlled substances or illegal drugs. If a pharmacy is “compacted” or “contracted” with the IHS – as is true in the majority of cases – that pharmacy must abide by IHS regulations, says Rear Admiral Robert Pittman, principal pharmacy consultant for the IHS, and, he notes, the Office of the In-spector General can monitor compliance.

Historically, IHS com-pacted/contracted facilities providing health care and pharmacy services to enrolled tribal members (of federally recognized tribes) and their descendants have been the face of tribal pharmacies. Ac-cording to Pittman, the IHS employs approximately 500 pharmacists who are federal employees and licensed to work at IHS and tribal facili-ties in any state; tribes may also hire their own pharma-cists who, depending on state law, may or may not need to be licensed by the state in which the reservation (and the pharmacy) is located. To fulfill their contract/com-pact with IHS, tribal nations may purchase prescrip-tion medications at feder-ally discounted pricing from wholesalers at the Federal Supply Schedule (FSS) price or from the Department of Veterans Affairs Pharmaceu-tical Prime Vendor contract or the Health Resources and Services Administration 340 Drug Program. These drug discount programs save ap-proximately 40% compared to the average manufacturer price.

In this self-contained world of tribal pharmacies run in conjunction with IHS, state jurisdiction tends not to apply. In the compli-cated arena of health care, however, very little remains self-contained or simple.

Enter third-party pay-ers. As IHS’s Pittman points out, even though registered tribal members may receive free medical care, including prescription drugs, from the federal government through IHS, Congress considers the program to be “discretion-ary” rather than an entitle-ment, and provides money to cover only approximately 40% to 50% of the program’s expected costs. According to Pittman, IHS and its associat-ed pharmacies are required to bill potential third-party pay-ers, such as health insurance, for services before remaining costs are covered by the IHS budget. To facilitate reim-bursement from third-party payers, tribes may require their pharmacies to obtain a state license.


In this self-contained world of tribal pharmacies run in conjunction with IHS, state jurisdiction tends not to apply. In the complicated arena of health care, however, very little remains self-contained or simple.

The Fond du Lac Band of Lake Superior Chippewa ap-pears to have been particular-ly successful in this area. The group operated two pharma-cies on its tribal lands for many years before opening a third earlier this year – in Minneapolis. The tribe’s di-rector of human resources on the reservation, Phil Norrgard, told the Associated Press in August 2007 that the Min-neapolis site would be the first pharmacy operated by a tribal government outside its reservation boundaries. Norrgard noted that the phar-macies’ books come close to balancing most years, aided by the FSS drug purchase discount and the Fond du Lac Band’s strategy of aggres-sively seeking reimbursement from those patients who do have health insurance. (The group has been lauded for its development of a computer-ized billing system that was subsequently adopted by a number of other tribes, and its pharmacy-based disease state management clin-ics.) The Minnesota Board of Pharmacy approved the tribe’s application for its Min-neapolis site in June 2006.

Third-party payers, however, are not the only force pushing tribal pharma-cies to seek state licenses. In Oklahoma, for example, Oklahoma State Board of Pharmacy Executive Director Bryan Potter points to two major reasons that almost all tribal pharmacies there hold state licenses: first, because IHS facilities in Oklahoma are often used as (highly regarded) preceptor sites for

nabp newsletter

174

the local colleges of pharmacy and therefore, by state law, must be licensed; and second, because the state’s Bureau of Narcotics and Dangerous Drugs requires pharmacies to hold a state license to handle controlled substances, and DEA in turn requires phar-macies to be licensed by the Bureau of Narcotics before the pharmacy can receive a license from DEA.

Potter notes that one state’s regulations can indi-rectly affect another’s. He gives the example of a tribal pharmacy located in Nebras-ka that wished to dispense prescriptions to patients in Oklahoma. Oklahoma law requires a nonresident phar-macy license for that purpose, and also requires that the pharmacy produce a local license when applying for the nonresident status. The tribal pharmacy obtained a Nebraska license to comply.

Problem AreasIn recent years, some

tribal nations have considered turning to commercial phar-macy ventures – dispensing prescription medications to non-tribal members, as a re-tail outlet, a mail-order outfit, or a wholesaler – as an avenue to economic development.

In these cases, the word-ing of federal and state laws becomes important in de-termining jurisdiction and regulatory requirements.

Disciplinary action brought by the Maine Board of Pharmacy against a tribal-

owned commercial pharmacy provides a prime example. Two years after Maine voters rejected efforts by the Penob-scot Indian Nation to estab-lish a $600 million casino project, the tribe worked with the state to establish a mail-order pharmacy program that would, in theory, provide the tribe with much-needed eco-nomic development and save the state money by providing lower-cost medications to residents on Medicaid.

During the process lead-ing up to the establishment of the pharmacy, the question of licensure was raised. A phar-macy located on federal land (a military base, for example) providing pharmacy services and medications to federal employees and dependents located on the base would not need a state license, according to Geraldine L. Betts, board administra-tor for the Maine Board of Pharmacy. But a pharmacy dispensing medications to Maine citizens would need to obtain a license. In addi-tion, a pharmacy dispensing medications through the mail to Maine citizens would not be regarded as a mail- order pharmacy, but as a retail drug outlet.

The Board consulted with its legal counsel on the matter. Citing a 1983 case in which the Penobscot nation was held to be subject to state law when the tribe was engaged in economic activities that were not an internal tribal matter (in that case, establishment of a beano game), the legal counsel determined that the pharmacy had to obtain a state license. In 2005, PIN Rx, duly licensed by the Board

and partially funded by state grants, opened for business and began filling prescrip-tions. Within a short period of time, however, while the state was saving money on Medicaid prescriptions, the pharmacy was losing money and in danger of closing its doors.

In 2006, the Maine Board began an investigation into alleged illegal activities by the pharmacy, culminating in revocation of the pharmacy’s license in May 2007 and a $500,000 fine. The Board found several violations of law as PIN Rx dispensed 183,303 orders placed over the Internet, many for controlled substances, most without evidence of a legitimate practitioner-patient relation-ship. The Board also revoked the license of PIN Rx’s pharmacist-in-charge at the time of the investigation, and levied a fine totaling more than $300,000; a previous pharmacist-in-charge was also disciplined. The Board was only empowered to make the investigation, however, because the pharmacy held a state license. Had the phar-macy been unlicensed, says Betts, in Maine the state attorney general would then have jurisdiction.

A different issue, with different jurisdiction, arose in Connecticut, between the IHS and the Mashantucket Pequot Tribal Nation. The tribe, which runs a successful casino operation that is the largest employer in the state, was offering health benefits, including drug benefits, to its employees through a tribal-run pharmacy net-work that operated under an

Indian Self-Determination Act (ISDA) contract with the IHS. The tribe argued that, for legal purposes, tribe members and their families (about 1,000 people), and the employees of the tribe and their families (about 23,000 people, non-Indians) were qualified to receive medica-tions that had been purchased at the tribe’s FSS rate. A judge for the United States Department of Health and Human Services’ Depart-mental Appeals Board made a final decision rejecting this argument, and agreeing with the IHS’s position that the non-Indian employees and their families did not qualify in this instance, although the tribe would be permitted to provide pharmacy benefits with drugs purchased at a standard managed-care price.

In other cases, tribes at various times have indicated their interest in using their status as sovereign nations to import drugs from Canada for resale in the United States. (Indeed, Maine gov-ernor John Baldacci initially wished the PIN Rx opera-tion to act as an importer, to supply cheaper medica-tions to state residents. Federal permission was not forthcoming, and the plan was abandoned.) FDA has maintained its position that selling or importing foreign drugs for profit is illegal.

In these cases, the regu-latory structure, no matter how complex, succeeded in addressing areas of con-cern. Sometimes, however, questionable activities can slip through the cracks.

In Oklahoma, for ex-ample, one tribe’s pharmacy-

A Regulatory Tangle(continued from page 173)


Feature News


175

Fall Legislative Conference

FDA, DEA Speakers Cite Collaboration with NABP, Boards of Pharmacy as Key to Protection of Public Health

Food and Drug Administration (FDA) Commissioner Andrew C. von Eschenbach and Drug Enforcement Administration (DEA) Administrator Karen Tandy stressed the importance of collaboration between their agencies, the boards of pharmacy, and NABP on key issues such as diversion and counterfeit drugs. In their remarks at the NABP Fall Legislative Conference, held in September 2007, both von Eschenbach and Tandy spoke of the challenges regulators face in protecting the public, and they asserted their agencies’ commitment to strong partnerships with the boards of pharmacy and NABP to overcome these challenges.

FDA RemarksDuring his remarks, von

Eschenbach noted that il-legal imports and counter-feit drug products, patient information, and pharmacy compounding are issues of particular importance to both FDA and the boards of pharmacy.

FDA’s opposition to importation has not waned over the years, and von Eschenbach reiterated that illegal importation of drugs presents a significant threat to patients’ safety, while of-fering insignificant savings to patients. Legalization of drug importation would do more harm than good

by adversely affecting new drug development, creat-ing liability concerns, and creating an environment in which FDA is unable to ensure the safety and integrity of imported drugs. “Many imported drugs are unapproved, mislabeled, and of dubious origin,” von Eshenbach stated. “And frequently they are unsafe, ineffective, and sometimes more expensive than prod-ucts available in the United States.”

According to von Eschenbach, FDA’s sampling shows that up to 85% of drugs that patients thought were coming from Canada actually came from 27 other countries including China, India, and Turkey. Also, some of these drugs are being sold via the Internet without prescriptions – a risky proposition, von Eschenbach stated.

He emphasized the importance of pedigrees and radio frequency identification and other technologies to combat counterfeits. He added that while known cases of counterfeiting were down slightly to 54 in 2006, these numbers in no way represent the prevalence of counterfeit drugs in the United States and worldwide. He added that FDA continues to work with countries around the world and regulatory agencies in the US to fight counterfeiters.

Also important to FDA is providing information to patients for the safe and effective use of medications. Currently NABP is helping FDA determine if the congressional requirement to provide 95% of people getting new prescriptions with useful information by 2006 is being met.

Recently FDA made three significant decisions regarding patient information as a result of public input:

FDA will address internal •improvements in the development and approval of Medication Guides and will provide access to them on the Internet.FDA will explore what •kind of regulatory guidance might be necessary not only for their content and format, but also electronic distribution and access.FDA will work with •NABP, state boards of pharmacy, and other groups to develop a better strategy for educating pharmacists about

Medication Guides and their requirements.In regard to pharmacy

compounding, von Eschenbach asserted that FDA respects the states’ roles in overseeing the practice of pharmacy. He remarked that the states are essential to the issue and that FDA generally defers to the states in compounding matters. He expressed this with the caveat that FDA regards certain compounding practices as unacceptable. Such situations include using compounding as a front for drug manufacturing and practices that cause a public health hazard, for example, drug contamination.

Concluding his remarks, von Eschenbach asserted that FDA wants to improve its communications with the state boards of pharmacy and pharmacists regarding important information about drugs. In addition, FDA will be meeting with NABP to discuss the boards’ information needs, identify

FDA Commissioner Andrew C. von Eschenbach

DEA Administrator Karen Tandy


nabp newsletter

176

Feature News

States Begin to Implement Electronic Tracking of Pseudoephedrine Purchases

Since the Combat Methamphetamine Epidemic Act of 2005 went into effect

March 9, 2006, some states are going a step further in tracking purchases of over-the-counter products containing pseudoephedrine (PSE), ephedrine, and/or phenylpropanolamine – they are going digital.

Fifteen pharmacies in southeastern Kentucky be-came the first in the country to use MethCheck technol-ogy to electronically track purchases of PSE-containing products, used all too fre-quently in the illicit produc-tion of methamphetamine. Based on the success of this pilot program, Kentucky en-acted legislation earlier this year to begin implement-ing a central database to track the purchase of these products statewide. Effective June 25, 2007, Senate Bill 88 states that pharmacies may be required to implement electronic record keeping of PSE sales if the funds to establish and maintain the technology are provided by the state.

Funding will be provided in stages and is in place for the first year, says Branch Manager for Compliance Van Ingram of the Kentucky Office of Drug Control Policy (ODCP). He says he expects the administra-tive regulatory process to be in place by the end of 2007. Implementation of the program will begin soon after, he says, with all 1,290

pharmacies in the state ex-pected to be up and running by mid-2008.

Developed by Appriss, Inc, a Louisville, KY-based provider of government technology services, the MethCheck system makes it easier for pharmacies to comply with the Combat Methamphetamine Epidem-ic Act – which, among other things, requires pharmacy personnel to record custom-er and purchase information for each PSE product sale – and for law enforcement to identify suspicious activity.

The system replaces individual paper logbooks with a single, networked computer database and automatically records the customer’s name, address, and age by swiping a driver’s license or state-issued iden-tification card. If a customer has reached the purchasing limit or attempts to skirt the law by purchasing less than the maximum from mul-tiple pharmacies, the system automatically alerts police departments.

Without the technology, manually scanning indi-vidual paper logs looking for

violations makes for pains-taking work for law enforce-ment. Similarly, entering the handwritten information from multiple pharmacies into one database takes more personnel hours than law enforcement in most jurisdictions are able to al-locate.

MethCheck and other electronic tracking systems, such as LeadsOnLabs by Dallas, TX-based LeadsOn-line, on the other hand, allow pharmacies to keep a real-time electronic log of customers’ purchases of PSE-containing products. The electronic database allows pharmacy personnel to instantly see a customer’s purchasing history – at the point of purchase and at all other stores connected to the database. The elec-tronic programs analyze the data coming in from several sources, allowing law enforcement to track sales, observe suspicious buying patterns, and watch those who are going over the legal limit of PSE purchases. Kentucky’s ODCP main-tains that connecting all pharmacies to a common database, in the end, helps curb the illicit manufacture of methamphetamine from these products.

Case in point: Kentucky’s MethCheck pilot program, launched in 2005 in Laurel County, identified questionable buying patterns that led to the shutdown of 16 methamphetamine


177

Feature News

laboratories, the arrest of 28 people on methamphetamine-related charges, and the investigation of another 54 cases.

In April 2007, three counties in Arkansas joined pharmacies in Kentucky, Oklahoma, and West Virginia in using electronic tracking systems to identify potential illegal activity involving PSE. With pending federal and state legislation calling for tightening PSE laws and/or requiring electronic monitoring, the need is greater than ever for technology to efficiently track purchases of PSE-containing medications. State and local laws vary regarding PSE purchases, which can complicate compliance issues, especially for national chains operating pharmacies in multiple states.

With electronic tracking of PSE purchases the wave of the future, the American Society for Automation in Pharmacy (ASAP) convened a task force to develop technical standards to enable the various systems to “talk” to each other. Consisting of pharmacists, retailers, software developers, and law enforcement, the group announced the standards on its Web site in September 2007. By using a common technical standard, each state or jurisdiction will no longer have to use time and money developing their own systems to electronically

track PSE purchases. The ASAP standards do not tell jurisdictions what information to gather; rather, they facilitate dissemination of the information they do collect.

The ASAP standards will work with current and future legislative directives such as:

Sending law enforcement •purchase data regarding PSE productsStopping above-limit •purchases of PSE products through the use of real-time dataAllowing reports of PSE •purchase data through Web portals, servers, and company point-of-sale systemsASAP Executive Director

Bill Lockwood stresses that the standards are voluntary; however, he states that common platforms will expedite information sharing, which is a significant incentive for implementing technical standards.

Seeking to expand pharmacy access to tracking technology, Senator Richard Durbin of Illinois introduced the Methamphetamine Production Prevention Act of 2007 on May 3, 2007. The bill (S 1276) amends the Controlled Substances Act to expand electronic logbook requirements applicable to sellers and purchasers of listed chemicals (eg, legal substances used in the production of metham-phetamine). Among other things, the bill provides for

three-year grants to state and local governments through the US Attorney General’s office for the purpose of developing, implementing, or enhancing electronic track-ing systems of PSE purchases. Higher consideration is given to grant applications that provide for state-wide track-ing, the ability to transmit real-time information to law enforcement, and the sharing of information across law enforcement jurisdictions. As of September 2007, this bill is referred to the Senate Judi-ciary Committee. An identi-cal bill was introduced in the House of Representatives by Representative Keith Ellison of Minnesota and is currently in the Judiciary Committee of the House.

Although electronic tracking of PSE-containing medications has been a success from a law enforce-ment standpoint, civil rights activists are uneasy about the government tracking purchases of legal over-the-counter products. There is concern the laws violate due process and give law en-forcement access to private medical records without warrant or subpoena. In response to these concerns, law enforcement has stressed that information gathered through electronic tracking systems is only one tool used in the fight against illicit methamphetamine labs. The information is used to detect patterns and pursue leads, not as the sole basis for an arrest.

nabp newsletter

178

104th Annual Meeting

Sponsorship/Educational Grant Opportunities Available for 104th Annual Meeting Programming

Organizations have an opportunity to gain expo-sure through numerous sponsorship and educa-tional grant opportunities available at the NABP 104th Annual Meeting to be held May 17-20, 2008, at the Bal-timore Marriott Waterfront in Baltimore, MD. Organi-zations that contribute help

NABP provide quality pro-gramming designed to assist board members, executive officers, and compliance staff to meet their responsi-bilities for safeguarding the public health while creating visibility for the sponsoring organization.

All contributing organi-zations will be recognized

by session or event, and will also be identified in meeting program materi-als, the NABP Newsletter, on meeting signage, and on the NABP Web site at www.nabp.net. In addition, sponsoring organizations contributing $5,000 or more to the meeting are entitled to two compli-

mentary meeting registrations valued at $575 each. Contributions of $1,000 to $4,999 entitle the donors to one compli-mentary meeting registra-tion. For more details on sponsorship and grant opportunities, organiza-tions can e-mail [email protected].

May 17-20, 2008 Baltimore Marriott Waterfront Baltimore, MD

The NABP 104th Annual Meeting provides pharmacy profes-sionals with an opportunity to take an active role in protecting the public health. The Annual Meeting is designed for the state boards of pharmacy – including executive officers and board staff, pharmacist and public members, compliance staff, and board counsel – as well as other pharmacy professionals. Attend-ees will help to define the direction of NABP by participating

Charting the Course –New Passages to Protecting the Public Health

in business sessions during which officers and members of the NABP Executive Committee will be elected, and resolutions will be voted upon. In addition, the Annual Meeting offers timely and informative continuing pharmacy education (CPE) sessions led by educators, regulators, and others who will share their knowledge, experience, and insight of the pharmacy profession. Advance registration for CPE sessions is not required.


179

104th Annual Meeting

Travel Grant Available for NABP 104th Annual Meeting NABP is once again

offering the Annual Meet-ing Travel Grant Program to qualified state board of pharmacy voting delegates. This year, delegates may receive up to $1,200 in grant monies to attend the NABP 104th Annual Meet-ing, scheduled for May 17-20, 2008, at the Balti-more Marriott Waterfront in Baltimore, MD.

Attendance at NABP Annual Meetings is of

high importance to the boards of pharmacy, as these meetings provide the forum in which members vote upon resolutions, elect Executive Committee members and officers, and attend educational sessions regarding current issues facing pharmacy regulators. NABP realizes that budget limitations can prevent state boards of pharmacy from sending representatives

to meetings; therefore, the Annual Meeting Travel Grant Program was created to defray costs for designated voting delegates by providing funds for travel expenses, including airfare, hotel rooms, meals, taxis, parking, and tips. The Grant does not include Annual Meeting registration fees.

Twenty-seven state boards of pharmacy utilized the Grant to attend

the NABP 103rd Annual Meeting in May 2007.

Grant applications may be obtained from NABP upon the direct requests of executive officers of the state boards of pharmacy. NABP requests that applications be submitted to NABP Headquarters prior to the Annual Meeting; NABP will inform applicants whether or not they have qualified for the grant.

Educational Poster Session Offers Boards Opportunity to Earn CPE Credit, Chance to Network

State boards of pharma-cy and schools and colleges of pharmacy are invited to participate in the Sixth Annual Educational Poster Session, themed “Protect-ing the Public Health,” which will take place dur-ing the NABP 104th Annual Meeting to be held May 17-20, in Baltimore, MD. The Poster Session will be held for one day only, Sunday, May 18, from 8 to 11:30 am and will offer at-tendees the chance to net-work with their colleagues and view educational post-ers displayed by member boards of pharmacy and schools and colleges of pharmacy.

In addition, by attend-ing the poster session par-ticipants have the oppor-tunity to earn one contact hour (0.1 CEU) of Accredi-tation Council for Phar-macy Education-approved continuing pharmacy

education (CPE) credit. To earn CPE, attendees will need to spend a minimum of 50 minutes in the Poster Session area discussing the poster displays with presenters.

Submitting a PosterFor presenters, the

Poster Session affords the opportunity to share information about the latest legislative issues, technol-ogy, policy development, and/or disciplinary cases as they relate to protecting the public health, as well as for networking with other pharmacy professionals in-terested in the poster topics. Encore presentations are accepted and encouraged; posters will not be judged.

For those interested in participating, the following is a list of tips on preparing a poster:

Limit text and utilize •graphics; double-check

that all items on the poster are necessary for presentation.Prepare handouts to •provide an overview of the poster and/or additional information including contact names, should attendees have questions.Keep the poster title •short, highlighting the topic.Make the font size •at least 14 point and double-space paragraph lines to ensure readability from two to four feet.Lay out the sections of the •poster in a logical order so that the poster is easy to follow. Rather than affixing documents to one large piece of poster board, break materials into three or four sections. Enlist the help of •students and/or interns

on rotation in your office to prepare the poster.Each participating

board or school/college of pharmacy will be provided with one four-foot by six-foot bulletin board, which should be manned by a representative during display times. Posters must coincide with the Poster Session theme “Protecting the Public Health.” Pharmacy school students who submit a poster for display will receive a complimentary voucher valued at $50 to take the Pre-NAPLEX®, a practice examination for students preparing for the North American Pharmacist Licensure Examination™.

To participate, those who are interested should contact NABP Professional Affairs Manager Eileen Lewalski via e-mail at elewalski@nabp .net by Monday, March 3, 2008.

nabp newsletter

180

Association News

Around the AssociationExecutive Director Changes

Mark D. Johnston, RPh, was hired as the executive director of the Idaho Board of Pharmacy effective September 24, 2007. Prior to his position as executive director, he was a division pharmacy manager for Albertson’s. He also served four years as a member of the Idaho State Pharmacy Asso-ciation and was recently elected to serve as presi-dent. Johnston received the McKesson Leadership Award and the National Community Pharmacists Association’s Pharmacy Leadership Award. He ob-tained a bachelor of science degree in pharmacy from the Virginia Common-wealth University Medical College of Virginia with a minor in psychology.

James D. “JD” Coffey, RPh, assumed the position of director of the Massa-chusetts Board of Registra-tion in Pharmacy on June 10, 2007. Prior to his posi-tion as director, he served as the associate director and investigator for the Board since 1996. Coffey has also been a member of the Multistate Pharmacy Jurisprudence Examina-tion® Review Commit-tee since 2001. Coffey obtained his bachelor of science degree in pharma-cy from the Massachusetts College of Pharmacy and Allied Health Sciences.

Nominations Now Being Accepted for 2008 NABP Recognition Awards

Do you know a colleague or a board of pharmacy that exemplifies the Association’s mission and is deserving of recognition for their dedication to the protection of the public health? If so, nominate him or her for an NABP award to be presented at the 104th Annual Meeting, May 17-20, 2008, in Baltimore, MD. Nominations are currently being accepted for the following awards: 2008 Lester E. Hosto Distinguished Service Award (DSA), 2008 Lester E. Hosto Inspector DSA, 2008 Fred T. Mahaffey Award, and the NABP 2008 Honorary President.

Lester E. Hosto DSAsNamed in memory

of the 1990-1991 NABP President Lester E. Hosto, this award is the highest honor bestowed by the Association. The DSA is awarded in recognition of exemplary service in protecting the public health and significant involvement with NABP. Any individual who meets these criteria may be nominated for the DSA, regardless of his or her member affiliation with NABP.

The Inspector DSA is awarded to an individual employed by or affiliated with a member board of pharmacy as an inspector or compliance officer. As with the DSA, this award is given in recognition of exemplary service in

protecting the public health and significant involvement with NABP.

During the NABP Annual Meeting, recipients of the DSA and Inspector DSA are presented with distinguished plaques and pins acknowledging the Association’s recognition of the recipients’ meritorious efforts.

Fred T. Mahaffey Award

Named in honor of the late NABP executive director emeritus, the Fred T. Mahaffey Award recognizes a member board of pharmacy that has made substantial contributions to the regulation of the pharmacy profession during the past year. The nominated board’s efforts must have contributed to the protection of the public health and welfare through the enforcement of state and federal laws and regulations, and to the advancement of NABP goals and objectives as specified in the Association’s Constitution and Bylaws.

Honorary PresidentNABP is also accepting

nominations for the 2008 Honorary President. Nominees for Honorary President must meet the following criteria:

service on one or more •NABP committees or task forces;participation in district •and Annual Meetings;

exemplary services for, or •on behalf of, NABPstrong commitment to •NABP, the mission of the Association to protect the public health, and the profession of pharmacy; andaffiliation (either •current or past) as a board member or as an administrative officer of an active or associate member board.NABP President-

elect Richard A. “Rich” Palombo, RPh, will present the awards during the 104th Annual Awards Dinner.

Nominations for these awards must be received at NABP Headquarters no later than December 31, 2007. Letters of nomination, along with a brief biography and current resume, or curriculum vitae of the nominee, must include an account explaining why the nominee should be considered for an award.

The NABP Executive Committee will review the nominations and select the award recipients and Honorary President. Please submit your nomination to NABP Executive Director/Secretary Carmen A. Catizone at NABP Headquarters, 1600 Feehanville Dr, Mount Prospect, IL 60056. For more information, please contact Chris Siwik in Executive Office via e-mail at [email protected]. (continued on page 183)


181

Association News

Training Session Provides Board Staff with Program Overview, Networking Opportunity

Eager to further familiar-ize themselves with NABP programs and services, 17 staff members from 15 state boards of pharmacy attended the Annual Program Review and Training Session, held in Au-gust, at NABP Headquarters in Mount Prospect, IL. This interactive session, specifi-cally geared towards board of pharmacy staff, provided an overview of the policies and procedures of NABP programs and services as well as offered participants the opportunity to network.

“The purpose of offering these annual training sessions is to provide the boards of pharmacy with the opportuni-ty to learn more about NABP programs and services as well as the Association’s mission and structure. In addition, the session allows board staff to network with other boards,” says NABP President Oren M. Peacock Jr, RPh.

The Program Review and Training Session included hands-on training with Lotus

Notes software provided by NABP to the boards and focused on items including accessing licensure transfer ap-plication status; viewing and printing score retrieval/score transfer reports; and confirm-ing examination eligibility re-ports, which NABP e-mails to the boards on a weekly basis.

Fannie Yorkman, a licensure analyst/pharmacy technician from the Maryland Board of Pharmacy, provided positive feedback regarding her overall experience with the Program Review and Training. “The session was very organized and well planned. The staff was great, helpful, and accommo-dating,” states Yorkman.

Additional topics covered in the Program Review and Training Session included:

licensure transfer, licensure •verification, e-mail, and data transfer functions;Healthcare Integrity and •Protection Data Bank reporting and NABP Disciplinary Clearinghouse reporting;

Staff members from 15 state boards of pharmacy learned about the policies and procedures of NABP programs and services and had the opportunity to network during the Annual Program Review and Training Session, held in late August at NABP Headquarters. Pictured above at left: Annette Gearhart, Oregon State Board of Pharmacy. Pictured at right from top to bottom: Sarah Trujillo, New Mexico Board of Pharmacy; Annette Scheinost, Nebraska Board of Pharmacy; Donald Walker, Missouri Board of Pharmacy; Fannie Yorkman, Maryland Board of Pharmacy; Elizabeth Ranne, Florida Board of Pharmacy; Nancy Fields, Delaware State Board of Pharmacy; Judy Letterman, Delaware State Board of Pharmacy; Karin Barron, District of Columbia Board of Pharmacy; and Tia Johnson, Colorado State Board of Pharmacy.

North American •Pharmacist Licensure Examination™ and Multistate Pharmacy Jurisprudence Examination® score replication and views as well as state and pharmacy school roster reports and retrieval procedures;application, examination, •and certification process for the Foreign Pharmacy Graduate Examination Committee™ (FPGEC®) certification program; Verified Internet Pharmacy •Practice Sites™, Verified-Accredited Wholesale Distributors®, and durable medical equipment, prosthetics, orthotics, and supplies accreditation programs; and an overview of NABP •departments including Board Services, Communications, Meetings, and Customer Service. Elizabeth Ranne, regu-

latory specialist II for the

Florida Board of Pharmacy, expressed the importance of the information provided during the Program Review and Training. “This training was extremely valuable to me. Overall it was a great experi-ence and I especially enjoyed the FPGEC session,” says Ranne.

Held concurrently with the Program Review and Training, the New Executive Officer Orientation Program was chaired by the 2007-2008 NABP President-elect Richard A. “Rich” Palombo, RPh. The orientation, designed to acquaint attendees with NABP membership and governance as well as the programs and services, welcomed six recently named state board of pharmacy executive officers including Wendy L. Anderson, RPh, program director, Colorado State Board of Pharmacy; Herbert “Herb” Bobo, RPh, executive secretary, Alabama State Board of Pharmacy; deLinda Brown-Jagne, board administrator, Connecticut Commission of Pharmacy; Lisa Durden, MA, executive director, Georgia State Board of Pharmacy; David E. Potters, JD, executive director and general counsel, West Virginia Board of Pharmacy; and Debra C. Ringgenberg, RPh, executive director, Missouri Board of Pharmacy.

For more information about future training ses-sions or to obtain training materials provided at the session, please contact NABP at [email protected].

nabp newsletter

182

Association News

First Round of DMEPOS Accreditation CompleteWith the passing of the

October 31, 2007 dead-line for the first round of durable medical equipment prosthetics, orthotics, and supplies (DMEPOS) com-petitive bidding, NABP has accredited approximately 30 independent phar-macies and three chain pharmacies representing more than 11,000 phar-macies. The majority of the pharmacies to which NABP awarded DMEPOS accreditation were seeking the accreditation primar-ily for mail-order diabetic supplies.

This first deadline for DMEPOS accreditation was set by the Centers for Medi-care and Medicaid Services (CMS) for those suppliers located or serving beneficia-ries in the first 10 Metropol-itan Statistical Areas (MSA) that wish to participate in the competitive acquisition program. CMS requires that all suppliers falling into this category must have been DMEPOS accredited prior to the October 31 deadline in order to be considered for a contract for competitive bidding, thereby qualifying the pharmacy for reim-bursement from Medicare.

Understanding the imperativeness of accredi-tation for the suppliers in the top 10 MSAs, NABP granted priority to these applications and worked rapidly to complete the accreditation process by October 31, while ensur-ing that pharmacies met the quality standards set by CMS. In determining

eligibility for accreditation, NABP evaluates the phar-macy’s submitted applica-tion and documents against CMS quality standards, meanwhile communicat-ing with the applicant, throughout the process, any deficiencies in documenta-tion or operations. If all documentation meets the standards, NABP proceeds in conducting an unan-nounced, on-site survey.

What’s Next?NABP eagerly awaits

CMS’s announcement of the next 70 MSAs, which are ex-pected to be included in the second phase of the com-petitive bidding program and to coincide with the release of the next accredita-tion deadline set by CMS. Although not mandated at this time, CMS strongly recommends that all sup-pliers seek accreditation in anticipation that eventually DMEPOS accreditation will be mandatory for all sup-pliers. With this in mind, NABP continues to accept DMEPOS applications from those suppliers seeking ac-creditation voluntarily.

For additional informa-tion on DMEPOS accredita-tion, program updates and deadlines, and access to the online application, please visit the NABP Web site at www.nabp.net. Information regarding the competitive bidding process and upcom-ing deadlines may also be found on the CMS Durable Medical Equipment Center Web page at www.cms.hhs .gov/center/dme.asp.

Absolute Pharmacy, IncNorth Canton, OHAccredited October 8, 2007

Alternacare Infusion PharmacyOlathe, KSAccredited October 9, 2007

Avenue PharmacyDayton, KYAccredited Ocotber 15, 2007

Benet’s Pharmacies, IncCincinnati, OHAccredited October 19, 2007

BioScrip Pharmacy, IncEden Prairie, MNAccredited October 23, 2007

CVS/Caremark CorporationWoonsocket, RIAccredited September 10, 2007

Dominguez PharmacyPerris, CAAccredited October 8, 2007

Good’s PharmacyTyler, TXAccredited October 29, 2007

Kindred CareLawrence, KSAccredited October 8, 2007

Langley Drug CompanyLangley, SCAccredited October 8, 2007

MedEx Direct, LLCWarren, MI Accredited October 29, 2007

Medicap Pharmacy #8334York, SCAccredited October 2, 2007

Medicine Shoppe #188Kansas City, KSOctober 2, 2007

Medicine Shoppe #0483Munhall, PAAccredited October 2, 2007

Medicine Shoppe #1101Springboro, OHAccredited October 2, 2007

Medicine Shoppe #1114Greensburg, PAAccredited October 2, 2007

Nipro HealthcareMiramar, FLAccredited October 1, 2007

North Coast Medical SupplyCarlsbad, CAAccredited May 2, 2007

Parkview Medical Plaza PharmacyRiverside, CAAccredited October 8, 2007

Parkview PharmacyRancho Cucamonga, CA Accredited October 29, 2007

Patient CareInfusion, LLCTempe, AZAccredited May 24, 2007

Pharmacy Concepts, LTDArlington, TX Accredited October 29, 2007

Prescription Care PharmacyHollywood, FL Accredited October 19, 2007

Prescription SolutionsCarlsbad, CAOverland Park, KSAccredited June 26, 2007

Queens PharmacyVictorville, CA Accredited October 29, 2007

Sav-a-lot PharmacyDelray Beach, FL Accredited October 31, 2007

Swillings DeAnza Pharmacy Inc, dba Royal Oak PharmacyOntario, CAAccredited October 1, 2007

Tru-Valu Drugs of Sanford, IncSanford, FL Accredited October 29, 2007

Walgreen CoDeerfield, ILAccredited October 8, 2007

Wellcare Specialty PharmacyTampa, FL Accredited October 19, 2007

NEWLY ACCREDITED DMEPOS FACILITIES


183

Professional Affairs Update

Bush OKs Six-Month Delay for Tamper-Resistant Rx Pad Law

President Bush signed HR 3668 into law on Sep-tember 29, 2007, delaying by six months the effec-tive date of a law requiring Medicaid prescriptions to be written on tamper-re-sistant prescription paper.

The president’s approval follows quickly on the heels of congressional action on this issue. The Senate unanimously approved the bill, which includes delay-ing the tamper-resistant prescription paper require-ment, as part of a larger Medicare and Medicaid relief package, on Septem-ber 25. The House passed a similar measure to delay the requirement as a stand-alone bill (S 2085) on September 26.

In addition to many pharmacy stakeholders who appealed to lawmak-ers and the Centers for Medicare and Medicaid Services (CMS), NABP asked CMS in a July 27 letter to delay implementa-tion of the measure. The requirement is included as Section 7002(b) of the US Troop Readiness, Veterans’ Care, Katrina Recovery, and Iraq Accountabil-ity Appropriations Act of 2007, which was passed in May.

CMS has posted an-swers to frequently asked questions related to the new guidelines on its Web site at www.cms.hhs .gov/DeficitReductionAct/Downloads/MIPTRPFAQs 9122007.pdf.

Governments to Propose Regulations for Pharmacy Technicians” in the May 2007 issue of the NABP Newsletter, accessible at www.nabp.net.)

Bush Signs FDA Re-form Bill, Clears Way for Tracking Standards

President Bush signed HR 3580, the Food and Drug Administration Amendments Act of 2007, into law on September 27, 2007. Among other provi-sions, the law reauthorizes and expands the Prescrip-tion Drug User Fee Act and the Medical Device User Fee and Modernization Act.

The legislation expands Food and Drug Adminis-tration (FDA) authority to regulate marketed drugs, establish a surveillance sys-tem to monitor and assess the safety profile of drugs on the market, reauthorize and modify programs that evaluate the use of drugs and devices by children, and expand federal databases that track information on certain clinical trials.

The law also requires the Department of Health and Human Services to establish a standardized numerical identifier that must be applied to pre-scription medications at the point of manufacture, and to develop standards to serve as guidelines in the implementation of track-and-trace and package-level identification technology to monitor prescription medications through the supply chain.


Ohio Pharmacist In-dicted for Manslaugh-ter after Lethal Error

Ohio pharmacist Eric Cropp was responsible for reviewing the work of the technician whose medica-tion error claimed the life of a 2-year-old girl in February 2006. As a result, an Ohio grand jury indicted him on August 9, 2007, for involun-tary manslaughter and reck-less homicide. Both charges carry penalties of up to five years in prison. The techni-cian, Katie Dudash, was not indicted.

The medication error occurred at Rainbow Babies and Children’s Hospital in Cleveland, OH, where Emily Jerry was undergoing chemotherapy. The intrave-nous medication that Emily received should have been mixed in a standard bag of 0.9% saline. Instead, Du-dash reportedly mixed the drug with a 23.41% concen-tration of sodium chloride.

Cropp, the supervising pharmacist, was responsible for reviewing her work; nonetheless, the mistake was overlooked, and the lethal dose was administered. The patient died three days later.

Dudash was fired after the incident. The Ohio Board of Pharmacy revoked Cropp’s license in April 2007 for this mistake and 14 other errors he committed since Emily’s death while working at three retail pharmacies. As the Board has no jurisdiction over technicians, Dudash did not face any disciplinary action.

(See “Child’s Death Prompts State and Federal

Around the Association (continued from page 180)

Ronald J. Klein, RPh, was appointed executive director for the Mon-tana Board of Pharmacy effective September 24, 2007. Prior to his posi-tion with the Board, Klein was inspector and chief inspector for the Nebraska Board of Pharmacy. Klein obtained his bachelor of science degree in phar-macy from the Creighton University School of Pharmacy and earned his master of science degree in pharmacy institution administration from St John’s University in New York.

Kevin K. Eidson, PharmD, was named as the executive director of the Tennessee Board of Pharmacy effective Octo-ber 1, 2007. He has been employed by the Tennes-see Department of Health since 2002, serving in various capacities includ-ing as the strategic national stockpile coordinator for the department and as the director of pharmacy for the Bureau of Health Services Administration. Eidson obtained his doctor of pharmacy degree from Mercer University South-ern School of Pharmacy.

Board Member Appointments

Lynette Bradley-Baker, PhD, was appointed a member of the Mary-land Board of Pharmacy,


nabp newsletter

184

Professional Affairs Update

FDA Cracks Down on Firms Marketing Unapproved Hydrocodone Products

FDA will take enforce-ment action against compa-nies marketing unapproved prescription drug products containing hydrocodone, the agency announced on Sep-tember 28, 2007. The action does not affect other hydro-codone formulations, which have FDA approval.

FDA told companies marketing unapproved hydro-codone products labeled for use in children younger than 6 years of age to cease manufac-ture and distribution of the products by October 31, 2007. Those marketing any other unapproved hydrocodone drug products must stop manufacturing such products by December 31, 2007, and must cease further shipment in interstate commerce by March 31, 2008. FDA warns that failure to meet these deadlines could subject viola-tors to legal action.

More information is avail-able on the FDA Web site at www.fda.gov/cder/drug/ unapproved_drugs/default.htm.

Coumadin Labeling Updated to Explain Genetic Considerations

FDA recently approved up-dated labeling for Coumadin® and the generic warfarin to explain that patients’ genetic makeup may influence how

they respond to the medica-tion. The labeling change highlights the opportunity for health care providers to use genetic tests to improve their initial estimate of what is a reasonable warfarin dose for individual patients.

Testing may help optimize the use of warfarin and lower the risk of bleeding complica-tions. Warfarin is the second most common drug – after insulin – implicated in emer-gency room visits for adverse drug events.

FDA’s “personalized medi-cine” initiative makes use of pharmacogenomics – the sci-ence that predicts a response to drugs based upon a person’ genetic makeup.

More information is available on the FDA Web site at www.fda.gov/cder/drug/ infopage/warfarin/ default.htm.

Bill Calls for More Effective Pain Management

The proposed National Pain Care Policy Act of 2007 seeks to eliminate barriers to

pain medications for patients who legitimately need them.

Introduced by Representa-tives Lois Capps of California and Mike Rogers of Michigan on July 11, 2007, the bill calls on the secretary of Health and Human Services to work with the Institute of Medicine to convene a Conference on Pain Care to increase the recognition of pain as a significant public health problem in the United States; to evaluate the adequacy of assessment, diagnosis, treat-ment, and management of pain in the general population; and to identify barriers to appropri-ate pain care.

The bill also calls for the establishment of a Pain Consor-tium at the National Institutes of Health to further research on the causes and treatment of pain, along with a National Pain Care Research Advisory Committee. In addition, the bill provides for comprehensive pain care education and train-ing for health care professionals, and a public awareness cam-paign on pain management.

The bill is posted on the Library of Congress Web site at http://thomas.loc.gov.

Professional Affairs (continued from page 183)

Around the Association (continued from page 183)

replacing Mark Levi. Her appointment expires May 31, 2011.

Lenna Israbian-Jamgochian, BS, was appointed a member of the Maryland Board of Pharmacy, replacing Joseph DeMino. Her appointment expires April 30, 2011.

Reid A. Zimmer, BS Pharm, was appointed a member of the Maryland Board of Pharmacy, replacing Jeanne Gilligan Furman. Zimmer’s appointment expires May 1, 2011.

Richard F. Kolezyn-ski, RPh, was appointed a member of the Ohio State Board of Pharmacy, replacing Suzanne East-man. His appointment expires June 30, 2011.

Jerome J. Wiesen-hahn, RPh, was appoint-ed a member of the Ohio State Board of Pharmacy, replacing Robert Gia-calone. His appointment expires June 30, 2011.

Jeffery L. Nielsen, RPh, was appointed a member of the South Dakota State Board of Pharmacy. His appoint-ment expires October 1, 2010.

Derek D. Garn, RPh, was appointed a mem-ber of the Utah Board of Pharmacy, replacing Shawna Hanson. His ap-pointment expires June 30, 2011.

Test Vendor(continued from page 166)

transition will be seamless for candidates and that there will be little to no dis-ruption in testing services.

Pearson VUE is the global leader in electronic testing services for academic admissions, certification, and licensure programs. Pearson VUE offers examinations through the world’s largest network of test centers in 151 countries, providing test-ing services for information

technology, regulatory and certification boards, academ-ic, government, and corporate clients. Its innovative technol-ogy offers the security and control required by academic, licensure, and certification programs while its commit-ment to service provides cus-tomers with an unmatched testing experience. Pearson acquired Promissor, which is now a business of Pearson VUE, extending its leadership in the testing and certifica-tion industry.


185

Association News

Updated Model Act Reflects Amendments Recommended by NABP Task Forces, Committee, FDA

NABP recently released its amended Model State Phar-macy Act and Model Rules of the National Association of Boards of Pharmacy (Model Act). The revised Model Act includes amendments recom-mended by the 2006-2007 NABP Task Force on Stan-dardizing Student Pharmacist Experiential Requirements (Experiential Requirements Task Force); the 2006-2007 Task Force on Emergency Preparedness, Response, and the US Drug Distribu-tion System (Emergency Preparedness Task Force); the 2006-2007 Committee on Law Enforcement/Legislation, and proposed revisions sub-mitted by the Food and Drug Administration (FDA).

Amendments resulting from recommendations of the Emergency Preparedness Task Force include a provision (described in Article II, §201) giving the board of phar-macy leeway in the event of a declared state of emergency to waive the requirements of the Model Act “in order to protect the public health, safety, or welfare of its citizens and to facilitate the provi-sion of Drugs, Devices, and Pharmacist Care services to the public.”

For instance, as described in the newly added comments, those states where centralized prescription filling or process-ing is not permitted “may consider allowing the perfor-mance of such activities” in an emergency.

Duties and responsi-bilities of the pharmacist-in-

charge also were amended to include developing or adopting, implementing, and maintaining:

a “procedure for the opera-•tion of the Pharmacy, to the extent that the Phar-macy can be safely and effectively operated and the Drugs contained therein can be safely stored and Dispensed, in the event of a fire, flood, pandemic, or other natural or manmade disaster or emergency; and “policies and procedures •for reporting to the Board the occurrence of any fire, flood, or other natural or man-made disaster or emergency within 10 days of such occurrence” (Model Rules for the Practice of Pharmacy, §2.A.(2),(a),(vii-viii)).The revised Model Act also

includes a new section, “Mod-el Rules for Public Health Emergencies,” to “enable Pharmacists and Pharmacies to assist in the management and containment of a Public Health Emergency or similar crisis within the confines of a regulatory framework that serves to protect the welfare and health of the public.” Subsections address emergen-cy prescription drug orders, public health emergency refill dispensing, temporary recognition of nonresident licensure, and temporary pharmacy facilities or mobile pharmacies.

Amendments recom-mended by the Experiential Requirements Task Force include changes to bring

about consistency with the Accreditation Council for Pharmacy Education Accredita-tion Standards and Guidelines for the Professional Program in Pharmacy Leading to the Doctor of Pharmacy Degree (effective as of July 1, 2007).

For instance, changes to the “Model Rules for Phar-macy Interns” section provide that a license to practice pharmacy as a pharmacy intern will be granted only to applicants who meet the fol-lowing criteria: a. “are enrolled in a profes-

sional degree program of a school or college of pharmacy that has been approved by the Board and satisfactorily progressing toward meeting the re-quirements for licensure as a Pharmacist; or

b. “are graduates of an ap-proved professional degree program of a school or college of pharmacy or a graduate who has estab-lished educational equiva-lency by obtaining a For-eign Pharmacy Graduate Examination Committee™

(FPGEC®) Certificate, who are currently licensed by the Board of Pharmacy for the purpose of obtaining practical experience as a requirement for licensure as a Pharmacist; or

c. “are qualified applicants awaiting examination for licensure or meeting Board requirements for relicen-sure; or

d. “are participating in a residency or fellowship program.”

The following revisions to the Model Rules for Sterile Pharmaceuticals, §3, “Policy and Procedure Manual,” stem from proposed revisions submitted by FDA.

The policy and procedure manual, to be prepared and maintained for the com-pounding, dispensing, deliv-ery, administration, storage, and use of sterile pharma-ceutical prescription drugs, shall include the following additional components:

a plan designed to •prevent microbiological contamination of sterile drug products and procedures concerning the validation of any sterilization process;training and other •requirements for pharmacy compounding personnel involved in aseptic manipulations to ensure adherence to the basic principles of aseptic technique;address the management •and proper disposal of cytotoxic and/or infectious waste, if applicable; andaddress how supervisory •personnel will monitor the ongoing adherence to procedures and sound practices.The Model Act also has

been modified to remove Appendix B, “Computerized Compliance Reports,” which was determined to be outdated and of limited value.

The updated Model Act is available in the Publications section of the NABP Web site at www.nabp.net.

nabp newsletter

186

strategies, and develop communication channels.

DEA RemarksDEA Administrator

Tandy informed Fall Legis-lative Conference attendees of the agency’s increased efforts in combating the abuse of pain killers, particularly hydrocodone combinations, which is sky rocketing – most notably among teenagers. She noted that the No. 1 prescribed drug in the United States is hydrocodone/acetamino-phen combinations, with the greatest volume of this drug being sold via the Internet. Between the years of 2005 and 2006, there was a 7.9% increase in the number of hydrocodone prescriptions sold in the US, she said.

In conjunction with the increase of prescriptions, there has been an explosion of prescription drug abusers rising from 2.4 million to 7 million since 2004. Cur-rently, 80% of all overdose deaths are attributed to hydrocodone drugs. Tandy noted that the high rate of overdoses for hydrocodone is due to the perception by patients that hydrocodone drugs are less harmful be-cause they are prescription drugs. In addition, teenag-ers are accessing prescrip-tions drugs more frequently with one in 10 high school seniors having admitted to abusing hydrocodone in 2006. Shockingly, while US citizens represent only 4% of the world’s population,

Fall Legislative Conference

FDA & DEA(continued from page 175)

99% of the world’s supply of hydrocodone was con-sumed by the US in 2004.

As the proliferation of illegal drug sales on the Internet continues to skyrocket, DEA is looking to establish new initiatives to eliminate these online sales. One of the ways that DEA has been successful in stopping rogue pharma-cies is by finding the “choke point,” Tandy stated. This choke point is the wholesale distributors and the manu-facturers.

Tandy explained that with more than 64,000 brick-and-mortar pharmacies and nearly one million practitio-ners to monitor, the best way to get a handle on those who are illicitly supplying drugs is to go after the manufacturers who are supplying them. It is significantly easier for DEA to monitor the 1,300 drug manufacturers. Any drug manufacturer or distributor engaging in illegal activities will be shut down, and, as a result, this will prevent rogue pharmacies from being sup-plied with drugs and in turn providing those drugs to patients.

Tandy also expressed the need for boards of pharmacy, state police, and other local regulatory agencies to notify DEA of overdose deaths, drug arrests, and other inci-dents. By providing this local view to DEA, the agency can use the information to track rogue pharmacies that may relocate to another state after being shut down. An example of how sharing local information with DEA can dismantle a large organiza-tion is the case of a Miami,

FL-based retail pharmacy that was closed by DEA and later reestablished itself in Queens, NY. Information provided to DEA regard-ing hydrocodone drugs that were found on a Connecti-cut youth and an Alaskan woman enabled the agency to track down the relocated mail-order drug store. As a result, DEA shut down the illegal mail-order facility and confiscated $20 million in assets.

Because of the high abuse of hydrocodone in recent years, DEA is cur-rently reviewing a peti-tion to move hydrocodone combination products from Schedule III to Schedule II.

For more information on DEA’s activities in preventing illegal sales of controlled substances on the Internet, see “DEA Calls on Pharmacies, Regulators, Others to Help Curb Illegal Sale of Controlled Substances via Internet” on page 163 of this issue.

NABP encourages member boards of pharmacy to work with FDA and DEA regarding the matters discussed by von Eschenbach and Tandy. With collaboration, NABP, the boards of pharmacy, FDA, and DEA can continue to be a strong force in protecting public health.

Participants Discuss Regulatory Issues during Roundtable Session at NABP Fall Legislative ConferenceAttendees had the opportunity to discuss pharmacy regulatory issues during “Roundtable Discussion: Political Platforms Meet Current Issues in Pharmacy Regulation,” at the NABP 2007 Fall Legislative Conference, in Arlington, VA. Choosing from four 2008 presidential candidates, participants discussed their candidate’s position on health care regulation and the potential challenges and issues the state boards of pharmacy may face in their mission to protect the public should that candidate win the election. Participants then presented their findings and solutions to these challenges to the rest of the attendees. Pictured above from left to right: Daniel F. Luce, RPh, MBA, Walgreen Co; Marcia Wooden, RPh, District of Columbia Board of Pharmacy; and Leo H. Ross, MBA, RPh, Virginia Board of Pharmacy.


187

NEWLY ACCREDITED VAWD FACILITIESThe following facilities were recently accredited through the NABP Verified-Accredited Wholesale Distributors® (VAWD®) program:

Association News

AmerisourceBergen Drug CorporationOrlando, FLAccredited September 20, 2007

AmerisourceBergen Drug Corporation dba Oncology Supply CompanyDothan, ALAccredited September 5, 2007

BioPartners In Care, IncLenexa, KSAccredited August 29, 2007

BioPharm Distribution, IncAltamonte Springs, FLAccredited October 9, 2007

Cardinal Health 200, Inc dba Cardinal HealthGrand Prairie, TXAccredited September 5, 2007Fife, WAAccredited September 13, 2007

Chapin Drug Company dba Chapin Specialty HealthcareAnaheim, CA Accredited October 1, 2007

Columbus Serum CompanyColumbus, OHAccredited September 4, 2007

Columbus Serum CompanyIndianapolis, INAccredited October 9, 2007

Cook, IncBloomington, INAccredited September 21, 2007

Cook Medical, IncBloomington, INAccredited September 21, 2007

Dubin Medical, IncSan Diego, CAAccredited September 20, 2007

Exel, IncMechanicsburg, PAAccredited August 29, 2007

Guerbet, LLCBloomington, INAccredited August 29, 2007

Harco, Inc dba Rite Aid Tuscaloosa Distribution Center (#35)Tuscaloosa, ALAccredited August 29, 2007

Hawkins, IncMinneapolis, MNAccredited October 2, 2007

Heartland Repack Services, LLCToledo, OHAccredited October 2, 2007

Heritage Labs International, LLC dba Heritage LabsOlathe, KSAccredited October 1, 2007

McKesson Medical-Surgical, IncLivonia, MIAccredited October 9, 2007

Methapharm, IncCoral Springs, FLAccredited September 21, 2007

Novis Pharmaceuticals, LLCElk Grove Village, ILAccredited September 4, 2007

Owens & Minor Distribution, Inc dba Owens & MinorIndianapolis, INAccredited October 1, 2007

Owens & Minor Distribution, Inc dba Owens & MinorHebron, KYAccredited October 1, 2007

Patterson Logistics Services, IncCamby, INAccredited September 5, 2007

Patterson Logistics Services, IncSouth Bend, INAccredited September 5, 2007

Promotech Research Associate, Inc dba PromotechLouisville, COAccredited October 2, 2007

Publicis Selling Solutions dba PharmagisticsSomerset, NJAccredited September 13, 2007

Returns R Us, Inc dba Pharma LogisticsMundelein, ILAccredited October 8, 2007

Sage Products, IncCary, ILAccredited September 13, 2007

Thrifty Payless, Inc dba Rite Aid Woodland Distribution Center (#81)Woodland, CAAccredited August 29, 2007

Tri-anim Health Services, IncFort Wayne, INAccredited October 8, 2007

UPS Supply Chain Solutions, IncRancho Cucamonga, CA Newark, DE Decatur, GA Louisville, KY Stead, NV Harrisburg, PA Memphis, TN Fort Worth, TX Accredited September 5, 2007Louisville, KY Accredited September 13, 2007

Walgreen CompanyPerrysburg, OHAccredited October 2, 2007

Webster Veterinary Supply, IncSterling, MAAccredited September 5, 2007

Wyeth Pharmaceuticals Division of WyethVonore, TNAccredited September 12, 2007

related activities seemed to fall in something of a jurisdictional no-man’s-land. According to Potter, of the Oklahoma Board, the tribe issued itself a tribal license to be a drug

wholesaler. The tribe would purchase medications at a discount, and resell them at a profit to a wholesaler in Tennessee. The state did not have clear jurisdiction. Eventually, FDA was able to require them to close.

Know the LawThe long and convo-

luted history of state and

federal relations with Native Americans has led to an at times confusing regulatory atmosphere when it comes to tribal pharmacies.

Nonetheless, state boards of pharmacy may find that some analysis of the situation in their state can prove valuable, in either knowing what legal tools are available should a

problem arise, or averting problems in the first place. “A lot of people want to say, ‘We don’t have juris-diction,’ and ignore the issue,” says Potter. But he sees an advantage in stay-ing engaged and working for cooperation. “We try to get along,” he says. And, he notes with satisfaction, “We generally do.”

A Regulatory Tangle(continued from page 174)

nabp newsletter

188 *SI = Special Issue

Index Volume 36

2007 NABP Newsletter Index – Volume 36103rd Annual Meeting103rd Annual Meeting Educational Poster

Session, Table Top Displays Invite Dis-cussion (SI, pg 12)

103rd Annual Meeting Educational Ses-sions Address Pharmacy Practice Regu-lation Issues (SI, pg 14)

2006 Honorary President Kendall Lynch Honored at Past President’s Dinner (SI, pg 11)

2007-2008 NABP Executive Committee Inaugurated at Final Business Session (SI, pg 16)

A Glimpse of Portland – Site of NABP’s 103rd Annual Meeting (No. 2, pg 27)

Annual Meeting Program (No. 3, pg 47; No. 4, pg 63; No. 5, pg 80)

Attendees May Earn up to Seven Hours of Continuing Education Credit Dur-ing the NABP 103rd Annual Meeting (No. 4, pg 62)

Annual Meeting Educational Grants and Sponsors (SI, pg 13)

Annual Meeting Officer Reports Online (SI, pg 2)

Author and Former Vietnam POW Captain Gerald Coffee to Offer Inspiration Dur-ing Keynote Address (No. 2, pg 27)

Boards of Pharmacy Come Together at the 103rd Annual Meeting to Make a Difference (SI, pg 1)

Contenders Vie for Executive Committee Seats; Updates Posted on NABP Web site (No. 3, pg 34)

Delegates Adopt Seven Resolutions (SI, pg 4)

Fifth Annual Poster Session Provides Boards and Schools of Pharmacy Opportunity to Share Experiences (No. 2, pg 23)

Keynote Address (SI, pg 16)NABP 103rd Annual Meeting Speakers to

Present on Current Issues Affecting Regu-lation in Pharmacy (No. 5, pg 81)

NABP Honors Leaders in Public Health Protection at Annual Awards Dinner (SI, pg 8)

New Officers, Members Inaugurated During 103rd Annual Meeting to Serve on NABP 2007-2008 Executive Com-mittee (SI, pg 3)

Optional Events Offer Meeting Attendees Additional Opportunities to Share In-formation and Network (No. 3, pg 46)

Portland: A Naturally Perfect Location for 103rd Annual Meeting Attendees to Unite (No. 1, pg 8)

Portland Attractions (No. 1, pg 10)President’s Welcome Reception Kicks off

Events (SI, pg 11)Register Now for the NABP 103rd Annual

Meeting to Take Advantage of Early Registration Rates (No. 4, pg 64)

Travel Grant Applications Still Being Ac-cepted for NABP’s 103rd Annual Meet-ing (No. 2, pg 19)

104th Annual MeetingDeadline Set for Proposed Amendments

to NABP Constitution and Bylaws (No. 10, pg 162)

Educational Poster Session and Hospital-ity Brunch Provides Boards, Schools of Pharmacy Opportunity to Share Expertise, Network (No. 10, pg 179)

Nominations Now Being Accepted for 2008 NABP Recognition Awards (No. 10, pg 180)

Save the Date (No. 9, pg 160)Sponsorship/Educational Grant Opportu-

nities Available for 104th Annual Meet-ing Programming (No. 10, pg 178)

Travel Grant Available for 104th NABP Annual Meeting (No. 10, pg 179)

Around the AssociationACE Member Honored (No. 8, pg 142)Alabama Board Names New Executive Di-

rector (No. 2, pg 31)Former Missouri Executive Director Wins

Award (No. 1, pg 12)History of Women in Pharmacy (No. 5,

pg 87)Massachusetts Board and Former Execu-

tive Director Honored (No. 3, pg 50)Board Member Appointments Anderson, Cynthia (No. 9, pg 157)Bary, Andrew (No. 3, pg 51)Bergrud, Karen (No. 7, pg 127)Bilek, Barbara A. (No. 8, pg 143)Bonar, David (No. 3, pg 51)Boudreaux, Barry (No. 1, pg 14)Bradley-Baker, Lynette (No. 10, pg 183)Braman, Karen S. (No. 7, pg 127)Christ, Geoffrey (No. 3, pg 51)Crump, Keith (No. 3, pg 51)Fanning, Del T. (No. 1, pg 14)Finke, Harry, Jr (No. 9, pg 157)Garn, Derek D. (No. 10, pg 184)Goertzel, Carol (No.1, pg 14)Ham-Burr, Arlene (No. 4, pg 66)Hamilton, Sebastian (No. 3, pg 51)Israbian-Jamgochian, Lenna (No. 10, pg

184)

Kirk, Nancy A. (No. 7, pg 127)Kolezynski, Richard F. (No. 10, pg 184)Leandre, Alland (No. 9, pg 157)Marshall, Robert (No. 6, pg 111)Mickleson, Jo (No. 3, pg 51)Nielsen, Jeffrey L. (No. 10, pg 184)Palombo, Richard A. “Rich” (No. 6, pg 111)Riddle, James D. (No. 8, pg 143)Robinson, Sandy (No. 3, pg 51)Simpson, Sandra M. (No. 6, pg 106)Spreier, Mitchell P. (No. 3, pg 50Tocco, Michael (No. 6, pg 111)Walsh, Thomas Richard (No. 6, pg 111)Wedemeyer-Oleson, DeeAnn (No. 8, pg

143)Whitchurch, Frank A. (No. 7, pg 127)White, Dirk (No. 6, pg 106)Whitworth, Margaret “Peggy” (No. 8, pg

143)Wiesenhahn, Jerome J. (No. 10, pg 184)Zimmer, Reid A. (No. 10, pg 184)Board Member ReappointmentsBrown, Willie (No. 2, pg 31)Fitzpatrick, Roger B. (No. 1, pg 15)Genovese, Kristina (No.1, pg 15)Gregg, Elizabeth I. (No. 1, pg 15)Ison, Bobby J. (No. 2, pg 31)Keans, Sandra (No. 1, pg 15)Navarra, John P. (No. 1, pg 15)McManus, Alison Kay (No. 7, pg 127)Petrin, Ronald L. (No. 1, pg 15)Ross, Leo H. (No. 2, pg 31)Spoon, James O. (No. 1, pg 15)St Angelo, Sara (No. 1, pg 14)Stredler, Michael E. (No. 2, pg 31)Tran, Hao “Jimmy” (No. 1, pg 15)Villa, Daniel (No. 1, pg 15)Zeitoun, Richard (No. 1, pg 15)Board Officer ChangesAbramowitz, Paul (No. 8, pg 143)Bach, David S. (No. 8, pg 143)Beckner, John O. (No. 4, pg 67)Bender, Thomas F.X., Jr (No. 4, pg 67)Berry, Zina S. (No. 8, pg 143)Borcher, Kevin (No. 8, pg 143)Braylock, Gregory (No. 4, pg 67)Bueler, Cindy (No. 8, pg 143)Chason, David (No. 9, pg 157)Chater, Rebecca W. (No. 4, pg 67)Chiari, Angelo (No. 4, pg 67)Conroy, Ruth M. (No. 8, pg 143)Dazé, Timothy D. (No. 8, pg 143)Doyle, Richard J. (No. 2, pg 31)Edelblut, E. Katherine (No. 2, pg 31)Givens, Gary (No. 8, pg 143)


189*SI = Special Issue

Index Volume 36

Holst, Donald E. “Don” (No. 4, pg 67)Ison, Bobby J. (No. 4, pg 67)Johnson, Betty L. (No. 8, pg 143)Kaczmarek, Roger (No. 8, pg 143)Marshall, Pamela L. (No. 4, pg 67)McGinley, Edward G. (No. 4, pg 67)McKeown, Lori (No. 8, pg 143)Mundell, Mary (No. 8, pg 143)Nelson, Wallace E. (No. 4, pg 67)Olson, Leman (No. 8, pg 143)Powers, William (No. 8, pg 143)Schneider, Gary S. (No. 8, pg 143)Shaw, Laura A. (No. 8, pg 143)Sobocinski, Gary (No. 8, pg 143)Souranis, Michael (No. 9, pg 157)Taylor, Donald (No. 9, pg 157)Turner, James (No. 4, pg 67)Vanhassel, Thomas J. (No. 8, pg 143)Wolzak, Elaina (No. 8, pg 143)Wuest, J. David (No. 4, pg 67)Executive Director ChangesBobo, Herbert “Herb” (No. 2, pg 31)Brown-Jagne, deLinda (No. 4, pg 66)Coffey, James D. “JD” (No. 10, pg 180)Durden, Lisa (No. 1, pg 12)Eidson, Kevin K. (No. 10, pg 183)Klein, Ronald J. (No. 10, pg 183)Herold, Virginia “Giny” (No. 5, pg 82)Johnston, Mark D. (No. 10, pg 180)Potters, David E. (No. 8, pg 142)Ringgenberg, Debra C. (No. 5, pg 82)Wooden, Marcia (No. 6, pg 106)Posts in Transition Coffey, James D. (No. 1, pg 14)Ellenburg, Mitzi (No. 1, pg 13)Herold, Virginia “Ginny” (No. 1, pg 13)Salmi, Lisa (No. 1, pg 13)RemembranceD’Angelo, Salvatore J. “Sal” (No. 4, pg 66)

Competency Assessment ProgramsCombined Efforts Lead to NAPLEX Re-

instatement (No. 10, pg 161)Continuing Professional Development

Pilot Program Moves into Part Two; PSAM Utilized (No. 3, pg 45)

Date and Locations Announced for De-cember FPGEE Administration (No. 8, pg 142)

Introducing the Members of the 2007-2008 NAPLEX Review Commit-tee (No. 4, pg 55)

June FPGEE Administration Numbers Reported (No. 6, pg 91)

NABP Seeks Item Writers for all Exami-nations (No. 7, pg 124)

NABP Thanks Outgoing Ace Members for Service, Welcomes New Members

to the Committee (No. 6, pg 107)NAPLEX Administrations Continue to

Climb (No. 3, pg 35)NAPLEX and MPJE School Pass Rate

Statistical Analysis Now Available on NABP Web Site (No. 6, pg 108)

NAPLEX and MPJE Test Vendor to Change Effective January 2008 (No. 10, pg 166)

Newly Appointed Review Committee An-nounced; June 2007 FPGEE Adminis-tration Approaching (No. 5, pg 86)

Opportunity for Appointment to ACE (No. 9, pg 147)

The 2007-2008 MPJE Review Committee (No 3, pg 50)

Updated FPGEE Blueprint to be Imple-mented for June 2007 Administration (No. 2, pg 17)

DMEPOS ProgramDMEPOS Accreditation Process Involves

Three Steps (No. 3, pg 41)First Round of DMEPOS Accreditation

Complete (No. 10, pg 182)NABP Awards First DMEPOS Accredita-

tion; CMS Opens Competitive Bidding (No. 6, pg 89)

NABP Wins CMS Approval to Accredit Suppliers of Durable Medical Equip-ment (No. 1, pg 1)

NABP’s Mission to Protect Public Health Fuels DMEPOS Accreditation Pro-gram (No. 3, pg 33)

Newly Accredited DMEPOS Facilities (No. 10, pg 182)

Fall Legislative Conference2007 Fall Legislative Conference Online

Registration Available (No. 8, pg 137)Fall Legislative Conference Program (No.

7, pg 120; No. 8, pg 136)FDA, DEA Speakers Cite Collaboration

with NABP, Boards of Pharmacy as Key to Protection of Public Health (No 10, pg 175)

NABP Fall Legislative Conference Pre-pares Attendees to Meet with US Con-gressional Legislators (No. 7, pg 121)

Legal Briefs103rd Annual Meeting Report of Counsel

(No. 6, pg 92)Attorneys’ Frees (No. 1, pg 4)Board Not Deterred By Lapsed License

(No. 5, pg 72)From Soho Down to Brighton . . . (No.

7, pg 116)IA Confidential (No. 8, pg 132)

Import[ant] Decision (No. 3, pg 36)Licensure Renewal: A Taxing Situation

(No. 4, pg 56)Pharmacy: A Hands-off Profession? (No.

9, pg 148)Prescription for Murder (No. 10, pg 164)Tap Dance (No. 2, pg 20)

Licensure Transfer ProgramNumber of Licensure Transfer Requests

Sets Eighth Consecutive Record as Grad-uating Classes Grow (No. 3, pg 38)

NABP – GeneralCall for Committee and Task Force Vol-

unteers (No. 1, pg 14)Boards Favor Inspector Training to En-

sure Pharmacy Compliance with Com-pounding Standards (No. 2, pg 29)

Electronic Prescriptions, Networked Medical Records Aid in Patient Care; Uniformity and Security Concerns Remain (No. 9, pg 145)

NABP/AACP District Meetings Address Cur-rent Issues, Future Goals (No. 6, pg 94)

NABP and FDA Meet to Address Public Health Concerns (No. 4, pg 59)

NABP Comments on Proposed Federal Regulation Compounding (No. 6, pg 96)

NABP Honors Executive Director Emeri-tus with Dedication of Fred T. Ma-haffey Boardroom (No. 4, pg 53)

NABP President Announces Appoint-ments to 2007-2008 Standing Com-mittees and Single-Issue Task Forces (No. 9 pg 152)

NABP Seeks Representative to Serve on ACPE Board (No. 5, pg 78)

NABP Survey of Pharmacy Law Updated for 2008 (No. 10, pg 172)

NABPLAW Online Provides Valuable Re-search Results (No. 10, pg 169)

Nonresident Licensing Helps Protect States from Illegal Internet Pharmacies (No. 5, pg 71)

OIG Exclusion List Raises Concerns for State Boards of Pharmacy (No. 8, pg 138)

Open Member and Officer Positions Announced for 2007-2008 Executive Committee (No. 2, pg 18)

Peer Review Programs Foster Assessment, Revision of Pharmacy Processes, and Prevention of Future Adverse Events (No. 10, pg 170)

Podcasts on NABP Web Site Provide Expert Commentary on Counterfeit Drugs (No. 1, pg 3)

nabp newsletter

190 *SI = Special Issue

Index Volume 36

State Board Roster (No. 7, pg 125)Task Force Addresses Gaps between State

Boards’ Experiential Training Require-ments (No. 3, pg 48)

Task Force Offers Recommendations and Guidebook to Help Boards Prepare for Emergencies (No. 5, pg 69)

Task Force Recommends Standards for Pharmacy Practice Experience Pro-grams (No. 5, pg 77)

Task Force Seeks to Safeguard Prescrip-tion Medication Supply Chain against Threat Posed by Cargo Theft (No. 10, pg 167)

Timely Reporting to NABP Clearing-house Key to Professional Account-ability System (No. 4, pg 60)

Training Session Provides Board Staff with Program Overview, Networking Opportunity (No. 10, pg 181)

Two New Executive Committee Members Inaugurated at NABP 103rd Annual Meeting (No. 6, pg 90)

Updated Model Act Reflects Amend-ments Recommended by NABP Task Forces, Committee, FDA (No. 10, pg 185)

VAWD and VIPPS Applications Now On-line (No. 9, pg 147)

Pharmacy – GeneralA Regulatory Tangle: Who Oversees

Tribal Pharmacies? (No. 10, pg 173)ACPE Continued Recognition Hinges on

Resolving Compliance Issues in Ac-creditation Review Process (No. 2, pg 30)

Child’s Death Prompts State and Federal Governments to Propose Regulations for Pharmacy Technicians (No. 5, pg 83)

CMS Offers NPI Compliance Contingen-cy Plan (No. 5, pg 85)

Continuing Education for the Profession of Pharmacy Revised to Better Reflect Lifelong Learning (No. 5, pg 74)

Controversy Over Conscience Clauses, Must-Fill Laws Fueled by Plan B Deci-sion (No. 7, pg 113)

Court Decision Again Delays Implemen-tation of PDMA Rule (No. 3, pg 44)

DEA Calls on Pharmacies, Regulators, Others to Help Curb Illegal Sale of Controlled Substances via Internet (No. 10, pg 163)

Democratic Majority Brings Pharmacy Issues to Congressional Table (No. 3, pg 42)

Higher Expectations for Pharmacists

Fuel Demand for Quality Practice Ex-perience (No. 6, pg 102)

Lifestyle Medications for Pets on the In-crease (No. 9, pg 155)

More States Adopt Pedigree Laws to Pro-tect Medication Supply Chain from Counterfeiters (No. 7, pg 118)

NCC MERP Wins APhA Pinnacle Award for Contributions to Health Care Quality through Medication Use Pro-cess (No. 7, pg 123)

North Carolina Supreme Court Says Board May Regulate Pharmacist Working Conditions (No. 2, pg 24)

Pharmacy Council Maps New Route for US Pharmacists to Practice in New Zealand (No. 2, pg 19)

Pharmacy Groups Respond to News Me-dia Portrayal of Medication Error ‘Epi-dimic’ (No. 6, pg 100)

Pharmacies, State Boards, Others Take Steps to Lessen Impact of Avian Influ-enza Pandemic (No. 8, pg 134)

PPSG Report Shows Improved State Poli-cies on Medical Use of Opioids (No. 1, pg 14)

States Begin to Define What Constitutes Legitimate Patient-Prescriber Rela-tionships (No. 8, pg 129)

States Begin to Implement Electronic Tracking of Pseudoephedrine Pur-chases (No. 10, pg 176)

States Implement Disposal, Recycling Programs to Reduce Diversion and Pollution Resulting from Unused Medications (No. 9, pg 150)

PhotosAnagnostiadis, Eleni Z. (SI, pg 14)Aron, Carl (No 1, pg 16)Beltz, Roger (SI, pg 13)Bess, David Todd (No. 1, pg 11)Brimberry Michael (No 1, pg 16)Broussard, Malcolm J. (No. 4, pg 68; SI,

pg 7, 14, 16)Campbell, Jay (No. 2, pg 25)Cannon, Brad (No. 1, pg 11)Coffee, Gerald (No. 2, pg 27; SI, pg 16)Cohen, Michael R. (SI, pg 15)Conroy, Ruth (No 1, pg 16)Cover, William (No 1, pg 16)Darvey, Diane, (No. 10, pg 186)DeLander, Gary E. (SI, pg 12)Dilliard, Reginald B. “Reggie” (No. 4, pg

68; SI, pg 6, 15, 16)Dodson, Gay (No. 1, pg 11; SI, pg 9)Donato, Patricia F. (No. 1, pg 11)Dorvee, John R., Jr (No. 4, pg 68)

Dryden, David W. (SI, pg 12)Duteau, Michael (No 1, pg 16)Eaton, Julia (No. 6, pg 112)Fitzpatrick, Cynthia P. (SI, pg 13)Flashover, David (No 1, pg 16)Flynn, Arlene (No. 1, pg 11)Frank, Denise M. (No. 6, pg 112)Fry, Benjamin (No. 1, pg 11)Fulton, Elaine (SI, pg 9)Gallagher, Cathy A. (SI, pg 13)Gardner, Judy (No 1, pg 16)Giacalone, Robert (No 1, pg 16)Gibbons, Moira (SI, pg 14)Harris, Patricia F. (SI, pg 7)Herold, Virginia “Giny” (SI, pg 12)Hilbert, Sarah (SI, pg 12)Howrey, Linda D. (SI, pg 12)Ingram, Van L. (SI, pg 15)Jessen, Lloyd K. (No. 4, pg 68; SI, pg 7,

14, 16)Johnson, Jeane (No. 6, pg 112)Jones, Dennis (No 1, pg 16)Jones, Richard A. (No. 1, pg 11)Kastango, Eric S. (SI, pg 14)Lew, Cathryn J. (SI pg 7, 11, 16; No. 6, pg

90)Lieberman, Mary Ann (No. 4, pg 53; No.

4, pg 68)Ling, Louis (SI, pg 15)Lloyd, Llyn A. (SI, pg 12)Luce, Daniel F. (No. 10, pg 186)Lynch, Kendall M. (SI, pg 11)Macdonald, Keith W. (SI, pg 15)Madigan, Melissa A. (SI, pg 14)Mahaffey, Chris (No. 4, pg 53; No. 4, pg 68)Mathison, Judy (SI, pg 11)McAllister, Dennis K. (No. 4, pg 53; No.

4, pg 68; SI, pg 11)McGinley, Edward (No. 1, pg 11)Mitchell, Kevin (No. 1, pg 11)Mokhiber, Lawrence H. “Larry” (No. 4,

pg 53; No. 4, pg 68; SI, pg 3, 8, 11, 16)Murer-Corrigan, Melissa (SI, pg 13)Nurse, Judi (SI, pg 15)Osman, Jeffrey (SI, pg 9)Palombo, Richard A. “Rich” (No 1, pg 16;

No. 4, pg 68; SI, pg 3, 16)Peachey, Karen (SI, pg 15)Peacock, Oren M., Jr (No. 4, pg 53; No. 4, pg

68; SI, pg 3, 8, 9, 16)Pease, Earl W. (SI, pg 12)Pinson, Larry L. (SI, pg 15)Robin, Lisa (No 1, pg 16)Ross, Leo (No. 10, pg 186)Rothholz, Mitch (No 1, pg 16)Rouse, Michael (No. 1, pg 11)Russell, Elizabeth Scott “Scotti” (No. 1,

pg 11; SI, pg 6, 16; No. 6, pg 90)


191*SI = Special Issue

Index Volume 36

Ryle, Karen M. (No. 1, pg 11; No. 4, pg 68; SI, pg 6, 15, 16)

Schnabel, Gary A. (No. 4, pg 68; SI, pg 6, 11, 16)

Schnabel, Joe (SI, pg 11)Slijepcevich, Walt (No 1, pg 16)Spunt, Avery L. (No. 1, pg 11)St Angelo, Sara (No 1, pg 16)Sutcliffe, Sandra (No. 3, pg 34)Taylor, Donald (No 1, pg 16)Turner, James E. (No. 1, pg 11)Vlasses, Peter H. (No. 1, pg 11)Whaley, Joseph (No 1, pg 16)Wiberg, Cody C. (No. 6, pg 112)Winsley, William T. “Bill” (No. 4, pg 68;

SI, pg 6, 15, 16)Wooden, Marcia (No. 10, pg 186)Wright, Dean (No. 3, pg 34)Wright, Sister Margaret (SI, pg 12)Young, Charles R. “Chuck” (SI, pg 8, 15)

Professional Affairs UpdateADHD Drug Firms Told to Provide

Guides on Cardiovascular, Psychiatric Risks (No. 5, pg 84)

Bill Calls for More Effective Pain Man-agement (No. 10, pg 184)

Bush OKs Six-Month Delay for Tamper-Resistant Rx Pad Law (No. 10, pg 183)

Bush Signs FDA Reform Bill, Clears Way for Tracking Standards (No. 10, pg 183)

Canadian Internet Pharmacy Sales to US Drop Nearly 50% in 2006 (No. 6, pg 110)

Canadian Pharmacist Groups Call for Ban on Drug Exports (No. 4, pg 65)

Canadian Researchers Seeking Input from US Pharmacists (No. 8, pg 142)

Canadian Restrictions on Unapproved Drugs Extend to Foreign Trade (No. 1, pg 13)

Coumadin Labeling Updated to Explain Genetic Considerations (No. 10, pg 184)

CMS Issues Guidance on Implementing Tamper-resistant Rx Pad Require-ments (No. 9, pg 156)

DATA 2000 Increases Patient Limit for Authorized Physicians (No. 5, pg 87)

DEA Announces New Letter Assignments (No. 2, pg 28)

DEA Releases Updated Practitioner’s Manual (No. 2, pg 28)

DEA Rule Controls Chemical Used in Il-licit Manufacture of Fentanyl (No. 6, pg 110)

Deadline Approaches for Pharmacists to Use NPI Numbers (No. 4, pg 67)

Death in Canada Tied to Counterfeit Drugs Bought via Internet (No. 8, pg 141)

Drugs Purchased via Internet Found to Contain Wrong Active Ingredient (No. 5, pg 84)

FDA Advises Glycerin Testing to Prevent DEG Poisoning (No. 7, pg 127)

FDA Asks for Warnings on Sleep Disor-der Drug Labels (No. 6, pg 110)

FDA Calls Halt on Unapproved Supposi-tory Drugs (No. 6, pg 110)

FDA Cracks Down on Firms Marketing Unapproved Hydrocodone Products (No. 10, pg 184)

FDA Cracks Down on Marketing of Un-approved Timed-Release Guaifenesin (No. 7, pg 124)

FDA, EC, EMEA to Expand Regulatory Cooperation (No. 8, pg 141)

FDA Evaluates Creating BTC Class of Drugs (No. 6, pg 109)

FDA Implements Strategy for Phony Di-etary Supplement Claims (No. 2, pg 28)

FDA Initiatives Address IOM Recom-mendations (No. 4, pg 65)

FDA Launches CDERLearn Educational Tutorial on MedWatch and Offers Other Free ACPE-Accredited CE (No. 4, pg 65)

FDA Nabs Tainted Toothpaste Shipment, Issues Import Alert (No. 7, pg 127)

FDA Sets Standards for Dietary Supple-ments (No. 8, pg 141)

FD&C Act Holds Manufacturers Ac-countable for Medication Guides (No. 5, pg 84)

International Agencies Crack Down on Diabetes Treatment Scams (No. 1, pg 12)

iPledge Loosens Prescribing Restrictions for Isotretinoin (No. 1, pg 13)

New FDA Web Page Warns of Buying Isotretinoin Online (No. 6, pg 109)

Ohio Pharmacist Indicted for Man-slaughter after Lethal Error (No. 10, pg 183)

Partnership for Safe Medicines Launch-es Anti-counterfeiting Guide (No. 1, pg 13)

Pergolide Ban Worries Veterinarians, Horse Owners (No. 7, pg 124)

Public Hearing Garners Recommenda-tions on Med Guides (No. 9, pg 156)

Purdue Pleads Guilty to Misbranding OxyContin (No. 6, pg 109)

Sellers of Pseudoephedrine Products

Now Need DEA Self-Certification (No 1, pg 12)

Tampering Results in Misbranding of Ziagen as Combivir (No. 6, pg 110)

State Board NewsAlaska Board Reviews Wholesale Dis-

tributor Regulations (No. 3, pg 51)Improperly Compounded Colchicine

Blamed for Deaths (No. 6, pg 106)Kansas Board Issues Warning of Internet

Prescriptions (No. 3, pg 51)North Carolina Board Investigates Com-

pounding Violations (No. 8, pg 140)North Carolina Board Requires VIPPS

Accreditation for Internet Pharmacies (No. 8, pg 140)

Oregon Board Receives Awards for Meth Work (No. 3, pg 51)

Oregon Board Requires Wholesaler Ac-creditation (No. 4, pg 66)

Oregon Patient Safety Commission Be-gins Safety and Quality Effort (No 1, pg 15)

Pharmacists Sue State over Mandate (No. 9, pg 157)

States Adopt Legislation to Tighten Li-censing Requirements for Wholesalers (No. 8, pg 140)

States Tighten Wholesaler Licensure Re-quirements (No 6, pg 106)

‘The Legislature Giveth, and the Legisla-ture Can Taketh Away’ (No. 5, pg 87)

Vermont Law Allows Emergency Contra-ception Collaborative Practice (No. 9, pg 157)

Washington Pharmacies Must Fill EC Prescriptions (No. 6, pg 106)

Washington Program Facilitates Safe Disposal of Drugs (No. 4, pg 66)

VAWD ProgramAccredited Facilities Increase Steadily as

Wholesale Distributors Continue to Sub-mit VAWD Applications (No. 1, pg 6)

Henry Schein Exceeds Indiana Require-ments by Obtaining VAWD Accredi-tation for Entire Distribution System (No. 4, pg 58)

Newly Accredited VAWD Facilities (No. 1, pg 6; No. 2, pg 32; No. 3, pg 52; No. 4, pg 58; No. 5, pg 88; No. 6, pg 105; No. 7, pg 122; No. 8, pg 144; No. 9, pg 156; No. 10, pg 187)

States Recognize VAWD in Efforts to Unify Regulations and Thwart Pre-scription Drug Counterfeiters (No. 1, pg 7)

november-december 2007nabp newsletter

National Association of Boards of Pharmacy

1600 Feehanville Drive

Mount Prospect, IL 60056

nabp newsletter

Association Highlights

from NABP

newsletter - nabpvendor, prometric; the north american pharmacist licensure examination™...

Documents