psm interchange 2014 panel 3: todd brown: non-fda approved foreign drugs are being provided to...
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Non-FDA approved foreign drugs are being provided to vulnerable patients in
MassachusettsTodd BrownMassachusetts Independent Pharmacists Association
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• Lack of active ingredient.• Expired medication
repackaged with fake expiration dates.
• Toxic fillers such as roach poison, road paint, etc.
• Lack of safety information that endangers the patient.
What is the Danger?
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Why is this occurring?
• Ignorance
• Unaware of the dangers
• Sold a tale of lies
+
Mostly greed
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• Patients are told they are receiving medication from countries that have FDA-approved facilities.
• Marketing materials claim “The FDA and Health Canada (FDA equivalent) have had a Memorandum Of Understanding for decades regarding safety standards for Rx medications.”
• Medications come from “Tier 1 Countries.”
Vague statements mislead patients to think the medications are from “safe” countries
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• Pharmacist/Pharmacy License cannot be reviewed. No recourse if a problem occurs.
Even if these were “safe” countries
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• Pharmacist/Pharmacy License cannot be reviewed. No recourse if a problem occurs.
• No or limited access to patient records to prevent drug interactions (“Does this medication interact with another condition I have or another medication I’m taking?”).
Even if these were “safe” countries
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• Pharmacist/Pharmacy License cannot be reviewed. No recourse if a problem occurs.
• No or limited access to patient records to prevent drug interactions (“Does this medication interact with another condition I have or another medication I’m taking?”).
• No ability to talk with a pharmacist (“should alcohol or OTC medications be avoided?”) and no safety packaging (childproof caps).
Even if these were “safe” countries
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• Self-funded insurers (cities, towns, school districts, etc) organize into larger groups to purchase a variety of services.
• Those that purchase various healthcare services for employees and retirees are known as health groups or trusts.
• Health care services include insurance, dental, vision and prescription drug coverage.
How it works - Overview
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• The health groups contract with Group Benefit Strategies (GBS) a health care consulting firm located in MA. GBS uses Prescription Benefit Services, Inc. (PBS) a for profit insurance advisor located MA (same ownership) to provide pharmacy benefit management services.
• PBS directs customers to use a web-based tool (myMedication Advisor) developed by a for-profit company, Abucus Group located in Rhode Island.
How it works in MA – Rx Medications
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• Patients provide prescription information through the web tool myMedication Advisor.
• This information is reviewed by a pharmacist to determine if it can be purchased for less outside the US. If so the patient is directed to the Canadian Mail Order Pharmacy “CanaRx.”
• CanaRx obtains the medications from wholesalers and retailers in Canada, United Kingdom, Australia, and New Zealand.
How it works in MA – Rx Medications
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• The medication from the wholesaler or retailer is shipped to the patient at no charge.
• CanaRx bills the health care group or trust for the cost of the medication. Each self-funded insurer is then billed for the medications used by their employees/retirees.
How it works – Financial Incentives
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How it worksGBS PBS
myMedication Advisor
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How it worksmyMedication Advisor CanaRx - meds from
wholesaler or retailer
Financial incentives for the patient and self-funded insurer
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• Cape Cod Municipal Health Group - fifty-three (53) participating governmental units on the Cape & Martha’s Vineyard with 10,662 health plan contracts and 20,818 members.
• West Suburban Health Group - seventeen (17) participating governmental employers with 12,092 health plan contracts and over 22,632 covered members.
Participating Health Groups & Trusts
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• Minuteman Nashoba Health Group - seventeen (17) participating governmental employers plus one affiliated member with 3,966 health plan contracts and over 7,678 covered members.
• Scantic Valley Regional Health Trust – four (4) towns and two (2) school districts.
• Amherst Pelham Regional Health Insurance Trust - two (2) towns and one school district.
Health Groups & Trusts (continued)
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How big is the problem?
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Does the problem exist elsewhere?
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• Over the last nine months, the Massachusetts Independent Pharmacists Association (MIPA) has used Freedom of Information Act (FOIA) requests to obtain documents and contracts about these programs.
Documents available
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• Food and Drug Administration• Department of Labor• Massachusetts Attorney General• Massachusetts Board of Registration in
Pharmacy• Individual Health groups/trusts
Next Steps – Avenues for Intervention