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pure food and drug act
adulteration of food and drugs
misbranding
food, drug cosmetic act
safe before marketing
direction of use
warning of habit-forming drugs
durham-humphrey amendment
distinction between prescription and OTC medications
kefauver-harris amendment
safe and effective
good manufacturing practices (GMP)
waxman-hatch amendment
streamline generic drug approval process
prescription drug marketing act
hospitals and healthcare entities prohibited from re-selling drugs
federal anti-tampering act
tylenol contamination event
tamper-resistant
REMS for NDA
patient package insert
communication plan
ETASU
implementation system
REMS for ANDA
package insert
ETASU
implementation system
ETASU requirements
special certifications
specially certified
dispensed certain healthcare settings
dispensed with evidence of safe-use conditions
pt monitoring
pt registry
patient protection and affordable care act
patient access
FDA safety and innovation act
FDA collect fees for NDA, medical devices, generics, biosimilar
adulteration
whole or partly filthy, putrid or decomposed substance
misbranding
distinction between rx and OTC medications
use by date
after drug is moved from original container
product recalls
class i
serious
product recalls
class ii
reversible consequences
product recalls
class iii
not likely to cause adverse consequences
product recalls
voluntary
not determined to cause health issue but manufacturer is urged to recall
pregnancy category x
contraindicated
pregnancy category c
risk can’t be ruled out
pregnancy category a
Human studies show no risk
pregnancy category d
Known fetal risk
pregnancy category b
No demonstrated human fetal risk
medical device
class i
least potential harm
scissors, needles, gloves, toothbrushes
medical device
class ii
moderate - FDA performance standards for safety
insulin syringes, infusion pumps, thermometers
medical devices
class iii
highest - potential injury
pacemakers, heart valve, soft contact lens
lanham trademark act
prohibits false description
allows civil law suits
FDA guidance policy
education separate from drug promotion
manufacturer involvement limited
department of health and human services - office of inspector general
manufacturers no control educational programs or use payments to reward
product claim ads
Drug + Disease + Benefit
Drug X treats hypertension and helps lower blood pressure
Reminder ad
Drug Only
Ask your doctor about Drug X
Help-seeking ad
Disease Only
Do you experience persistent migraines? Talk to your doctor about treatment options
what does FTC and FDA collaborate on?
OTC products and claims regarding food product
INDA
phase i
adverse effects
INDA
phase ii
efficacy and dosage
INDA
phase iii
safety and efficacy in large populations
supplemental new drug application changes
production
manufacturing
labeling
all trail phases must have patient written consent and explain…
risk
benefits
alt courses of therapy
OTC
category i
Safe and effective
OTC
category ii
not safe or effective
OTC
category iii
Not enough information
how should the patient name, brand/generic, directions should appear?
larger font
different color
bolded
expiration date
manufacter date
beyond use date
compounding dispenser
use by date
dispensing pharmacy
sale of emergency contraception
17+ yr → OK
rx: 16yr and younger
do pharmacist have the right to refuse dispensed prescriptions?
yes but needs to give pt alternative
orange book
A: equivalent
B: problems
AB: thought was a problem → is good now
purple book
biosimilars
prescription drug marketing act
No selling drug samples + control of drug distribution + prevention of drug diversion
can you deny drug insepection from…
FDA: NO
BOARD: NO
DEA: YES unless administrative inspection warrant or search warrant
patient records
everything kept 5 years
4 yr retrieve - 2 weeks
1 yr retrieve - 1 day
what kind of rx can be filled in nj?
any U.S territory
puerto rico
virgin island
VA hospital
what should community pharmacies be registered with to used tax paid ethyl alcohol?
ATF
IRS
tax-free alcohol exemptions are generally reserved for..
Hospitals
research laboratories
authorized institutions
Who can request non-child-resistant packaging under the Poison Prevention Packaging Act (PPPA)?
prescriber/pt for individual prescriptions
patients may make blanket requests
computer system downtime
enter within 72 hrs
what happens to pt information after you close the pharmacy?
1 yr store records
differences between label in retail & hospital
retail pharmacy - name of prescriber , prescription #
hospital pharmacy - name of person who prepared the sterile compound
CI
dihydromorphine
marijuana
diethylamide (LSD)
psilocybin
morphine methylbromide
THC
CII
morphine
codeine
fentanyl
levorphanol
hydromorphone
oxycodone
methadone
cocaine
methylphenidate
pentobartibal
CIII
APAP w codiene
chlorphentermine
ketamine
narcotics in CIII may not contain more than
Narcotic | Maximum amount |
|---|---|
Codeine or dihydrocodeine | 1.8 g per 100 mL or 100 g |
Hydrocodone (dihydrocodeinone) | 300 mg per 100 mL or 100 g |
Ethylmorphine | 300 mg per 100 mL or 100 g |
Opium | 500 mg per 100 mL or 100 g |
Morphine | 50 mg per 100 mL or 100 g |
CIV
tramadol
benzos
DEA registration - midlevel practitioners
CDS prescriptive authorities
animal shelters
certified nurse anesthetists
certified nurse midwives
nurse practitioners
optometrist
PA
new application for registering pharmacy
DEA form 224
renewal application for registered pharmacy
DEA form 224a
who can have the key to the pharmacy?
pharmacist/pharmacist in charge
where should diprenorphine and etorphine HCL be stored?
safe or steel cabinet that is CV container
theft, diversion or loss
notify DEA within 1 business day of significant loss or theft
DEA 106 form → forward copy to NJBOP, record amendment key #
opioid treatment program must be reaccredited and recertified every…
3 years
who is the opioid treatment program enforced by?
substance abuse and mental health services administration
opioid treatment program
maintenance tx
opioid agonist >21 days
combatting methamphetamine epidemic
pseudoephedrine or phenylpropanolamine - behind the counter
purchaser: 18 yr+ and gov ID
quantity limits of
pseudoephedrine or phenylpropanolamine
no > 3.6 gm/day
no > 9 gm/month
no > 7.5gm/month if mail order
CDS DEA registration #
practitioners letter starts with
A,B,F
CDS DEA registration #
mid-level practitioners start with the letter
M
CDS DEA registration #
distributors start with the letter
P or R
CDS DEA registration #
second letter
first letter of PERSON’S last name
if business name begins with a #, the second character of its DEA registration number may be the digit
confirming DEA registration #
add 1st,3rd,5th= x
add 2nd,4th,6th= y
multiply yx2= z
add x+z= D
last digit should be the DEA #
what can’t pharmacist do when correcting a CDS prescription?
pt name
CDS prescribed
prescriber signature
can a pharmacist dispense emergency verbal or faxed CII?
yes only covering emergency period, NO REFILLS
prescriber must send written copy to pharmacist within 7 days
post 7 days - report to DEA office
what if pharmacist is unable to fill partial CII?
notify prescriber after 72 hrs
must fill balance within 72 or new rx is needed
CII partial refill
long term care facility
up to 60 days for terminally ill
dispensing CIII,CIV,CV
refills
no >6m or 5 refills from original date of issue
dispensing CIII,CIV,CV
partial refills
no dispensing occurs after 6m of original issue
CDS inventory record
biennial
CII and CIII-CV must be on separate reports
CI and CII must have separate counts
DEA 222 form
sale or transfer of CDS to another pharmacy (reverse distributor)
DEA form 106
theft
DEA form 41
CDS disposal
DEA 222 form
brown page (page 1)
supplier keeps for records
DEA 222 form
green (page 2)
sent to DEA at the end of the month
DEA 222 form
blue (page 3)
purchaser keeps for records
how long to keep DEA 222 form
state - 5yrs
CSA/DEA - 2 yrs
what happens when DEA 222 forms are lost?
notify DEA and provide serial number of forms
electronic DEA 222 FORM
control substances ordering system
submit to DEA
must have power of attorney to order CDS
when should you report diversion, loss, and theft?
within 24 hrs of discovery
Omnibus Budget Reconciliation Act
patient counseling
drug utilization review (DUR)
patient profiles
HIPPA
4 aspects
Transactions = Standardized billing
NPI = Provider identification
Security = Protect electronic information
Privacy = Protect patient confidentiality