Pharmaceutical Distribution Supply Chain Pilot Projects; Request for Information Docket No. FDA-2016-N-1114



Similar documents
September 13, Division of Dockets Management (HFA 305) Food and Drug Administration 5630 Fishers Lane, Rm.1061 Rockville, MD 20852

Standards for the Interoperable Exchange of Information for Tracing of Human, Finished,

The Drug Supply Chain Security Act: Readiness and Implementation Update

Guidance for Industry DRAFT GUIDANCE

DSCSA Updates and Readiness Check: Requirements for Dispensers and other Trading Partners

Statement of the American Pharmacists Association Thomas E. Menighan, BSPharm, MBA, ScD (Hon), FAPhA Executive Vice President and CEO.

Guidance for Industry Drug Supply Chain Security Act Implementation: Identification of Suspect Product and Notification

On May 8 and 9, 2014, FDA held a public workshop on the development of initial standards for

March 7, [Submitted electronically to

Drug Supply Chain Security Act (Title II of the Drug Quality and Security Act) Overview and Implementation

California E-Pedigree Update. August 2013

Re: Guidance for Industry Fees for Human Drug Compounding Outsourcing Facilities Under The Federal Food, Drug and Cosmetic Act

RE: Medication Assisted Treatment for Opioid Use Disorders RIN 0930-AA22

Pharmaceutical Distribution Security Alliance (PDSA)

DSCSA Implementation: Annual Reporting by Prescription Drug Wholesale Distributors and Third-Party Logistics Providers

Re: Docket No. FDA 2014 N 0339: Proposed Risk-Based Regulatory Framework and Strategy for Health Information Technology Report; Request for Comments

116th Annual Convention

The opinions expressed herein are our own and do not necessarily reflect the views of The Johns Hopkins University.

CMS Proposed Electronic Health Record Incentive Program For Physicians

55364 Federal Register / Vol. 80, No. 178 / Tuesday, September 15, 2015 / Notices

U.S. Department of Health and Human Services Food and Drug Administration Center for Drug Evaluation and Research (CDER) March 2006 Compliance

Suspect and Illegitimate Products. Francis B. Palumbo, PhD, Esq. University of MD School of Pharmacy Center on Drugs & Public policy

Statement Of. For. U.S. House of Representatives Energy and Commerce Committee Subcommittee on Oversight and Investigations.

ID: FDA-2015-N :

February 21, Regina Benjamin, MD, MBA U.S. Surgeon General Office of the Surgeon General 5600 Fishers Lane, Room Rockville, MD 20857

IBM Solution for Pharmaceutical Track & Trace

Evaluating the impact of REMS on burden and patient access

Re: Docket No. DEA-218, Electronic Prescriptions for Controlled Substances

Submitted via September 12, 2013

DRAFT GUIDANCE. This guidance document is being distributed for comment purposes only.

IBM Solution for Pharmaceutical Track & Trace: Supply chain visibility drives overall performance

Karen DeSalvo, M.D., M.P.H., M.Sc. May 29, 2015 Page 2 of 7

VIA Electronic Submission to: June 26, 2013

October 27, Attention: RIN 0906-AB08. RE: 340B Drug Pricing Program Omnibus Guidance. Dear Captain Pedley:

Guidance for Industry

May 7, Dear Dr. Mostashari:

Guidance for Industry

FDA Advisory Committee Hearing on Potential Rescheduling of Hydrocodone: Pharmacist and Pharmacy Issues to Consider

(RIN) 0906-AB08; 340-B

Use of Electronic Health Record Data in Clinical Investigations

The statements made herein are our own and do not necessarily reflect the views of the Johns Hopkins University.

Re: FDASIA Health IT Report: Proposed Strategy and Recommendations for a Risk-Based Framework.

Guidance for Industry. Further Amendments to General Regulations of the Food and Drug Administration to Incorporate Tobacco Products

April 3, Re: Request for Comment: ONC Interoperability Roadmap. Dear Dr. DeSalvo:

Guidance for Industry

Medical Device Data Systems, Medical Image Storage Devices, and Medical Image Communications Devices

April 28, Submitted electronically via

RECOMMENDATIONS FOR DEFINING AND DEMONSTRATING MEANINGFUL USE OF CERTIFIED ELECTRONIC HEALTH RECORDS (EHRs)

Dear Honorable Members of the Health information Technology (HIT) Policy Committee:

Comments to Notice of Proposed Amendments to Federal Sentencing Guidelines Federal Register: F.R. Doc. E F.R. Publication Date: January 28, 2008

GS1 Healthcare Discussion paper on Mobile Applications and Services in Healthcare

10 Steps to Establishing an Effective Retention Policy

Medical Device Data Systems, Medical Image Storage Devices, and Medical Image

2014, That Was The Year That Was Greg Baran, RPh, MA, FMPA Baran Consulting LLC

December 31, comments to the Office of Dietary Supplements (ODS) at the National Institutes of Health on the

DUKE UNIVERSITY MEDICAL CENTER

DEPARTMENT OF HEALTH AND HUMAN SERVICES. Medicare Program; Changes to the Electronic Prescribing (erx) Incentive Program

Re: Occupational Injury and Illness Recording and Reporting Requirements; Docket No. OSHA

Re: Docket No. DEA-218, Electronic Prescriptions for Controlled Substances, Interim Final Rule with Request for Comment

Submitted via Federal erulemaking Portal

Table of Contents. Preface CPSA Position How EMRs and Alberta Netcare are Changing Practice Evolving Standards of Care...

FDA 2014 N 0339; 79 FR

Risk Evaluation and Mitigation Strategies: Modifications and Revisions Guidance for Industry

Five Challenges of Serialization in Pharmaceutical Supply Chains

Drug Pedigree Requirements for Pharmacies and Wholesalers. State Statutes

Re: CMS 3323 NC, Request for Information (RFI): Certification Frequency and Requirements for the Reporting of Quality Measures Under CMS Programs

April 22, Re: Advancing Interoperability and Health Information Exchange. Dear Dr. Mostashari,

Pursuant to the authority vested in the Commissioner of Health by Article 33 of the

APTA and Meaningful Use of HIT

White Paper. Trust Hi-Speed to show you the way. A Guide to Pharmaceutical Serialization Choosing the Right Equipment Supplier

New Law Extends Federal Oversight of Compounding Pharmacies, Establishes National Drug Track-and-Trace Requirements

ooo- I542 (314 Brlngrng tnnovation to patient care worldwide April 23,2003

Guidance for Industry. IRB Review of Stand-Alone HIPAA Authorizations Under FDA Regulations

Statement BAR CODE LABEL REQUIREMENTS FOR HUMAN DRUG AND BIOLOGIC PRODUCTS

EDUCATING, MOTIVATING, and EMPOWERING PATIENTS to SAVE MONEY

Contains Nonbinding Recommendations

Guidance for Industry

Statement of the Federation of State Medical Boards of the United States

GE Healthcare Healthcare IT

Guidance for Industry Tablet Scoring: Nomenclature, Labeling, and Data for Evaluation

American Kidney Fund 6110 Executive Boulevard Suite 1010 Rockville, Maryland 20852

State Advocacy Guide to Prescription Drug Monitoring Program Legislation and Regulations

Defining Larger Participants of the International Money Transfer Market Docket No. CFPB /RIN 3170-AA25

DEPARTMENT OF HEALTH AND HUMAN SERVICES. Medicare, Medicaid, Children's Health Insurance Programs; Transparency Reports

Information Governance and Management Standards for the Health Identifiers Operator in Ireland

To: FSHP Award Nominations Committee From: Robert A. Besser, R.Ph., M.S. Date: April 30, 2015 RE: NOMINATION MEDICATION SAFETY AWARD

Guidance for Industry

RE: CMS 1621 P, Medicare Clinical Diagnostic Laboratory Tests Payment System Proposed Rule; (Vol. 80, No.190), October 1, 2015.

Re: Comments on Proposed Establishment of Certification Programs for Health Information Technology (Health IT); Proposed Rule

Division. Impact. Before the. Pensions

Guidance for Industry

RE: HIPAA Privacy Rule Accounting for Disclosures, RIN 0991-AB62

105 CMR: DEPARTMENT OF PUBLIC HEALTH 105 CMR : THE ADMINISTRATION OF PRESCRIPTION MEDICATIONS IN PUBLIC AND PRIVATE SCHOOLS

340B Drug Discount Program Overview and Emerging Issues

Guidance for Industry

Guidance for Sponsors, Institutional Review Boards, Clinical Investigators and FDA Staff

The Children s Hospital

THE STATE EDUCATION DEPARTMENT / THE UNIVERSITY OF THE STATE OF NEW YORK / ALBANY, NY 12234

Step 1: Analyze Data. 1.1 Organize

The Drug Quality and Security Act (the DQSA), enacted. Complying with the Authorized Trading Partner Requirements of the DQSA.

Transcription:

May 16, 2016 [Submitted electronically to http://www.regulations.gov] Division of Dockets Management (HFA-305) Food and Drug Administration 5630 Fishers Lane, Rm. 1061 Rockville MD, 20852 RE: Pharmaceutical Distribution Supply Chain Pilot Projects; Request for Information Docket No. FDA-2016-N-1114 Dear Sir/Madam: The American Pharmacists Association ( APhA ) appreciates the opportunity to provide a response to the Food & Drug Administration s ( FDA ) Pharmaceutical Distribution Supply Chain Pilot Projects; Request for Information ( RFI ). APhA, founded in 1852 as the American Pharmaceutical Association, represents more than 62,000 pharmacists, pharmaceutical scientists, student pharmacists, pharmacy technicians, and others interested in improving medication use and advancing patient care. APhA members provide care in all practice settings, including community pharmacies, physicians offices, hospitals, long-term care facilities, community health centers, managed care organizations, hospice settings and the uniformed services. APhA is committed to working with FDA and other health professionals and stakeholders to enhance the safety and security of the pharmaceutical distribution supply chain. APhA appreciates the Agency s efforts to seek stakeholder input, including hosting the April 2016 Public Workshop. Because of the size of and variability amongst pharmacies, especially compared to other supply chain entities, APhA advocates that any new requirement stemming from these pilot project(s) should be able to be easily incorporated into existing pharmacy operating systems and workflow, and at a minimal cost so as not to negatively impact patient care and services. In addition, APhA urges FDA to strengthen education efforts that target pharmacies to improve compliance efforts and limit vulnerabilities within the supply chain. I. Pharmacist education As FDA moves forward in implementing DSCSA, APhA urges the Agency to increase educational outreach efforts to pharmacies. Despite efforts by APhA and other pharmacy organizations to inform pharmacists about DSCSA requirements and compliance, APhA remains concerned that there needs to be better awareness. Unlike most of the other participants in the supply

chain, pharmacies are smaller and do not have the legal resources to devote to DSCSA implementation and therefore, are more likely to need and rely upon government informational materials and education. Moreover, for outreach targeted to pharmacies and pharmacists to be successful, it needs to be robust due to the fact that the number of pharmacists and pharmacies far exceeds that of other categories of supply chain entities (e.g. manufacturers). Many of our members indicated that they rely on wholesalers for DSCSA compliance and education because there is a lack of FDA-developed DSCSA-related resources targeted to pharmacies. In fact, APhA members indicated that they were unaware that FDA is exploring pilot projects and stated that their participation in such projects highly unlikely, often because of resource constraints or concern over interrupted workflow. While APhA will continue to educate its pharmacist members on DSCSA implementation, we believe that FDA involvement would increase awareness and improve message consistency, ultimately advancing compliance and the safety and security of the supply chain. APhA is willing to help FDA s outreach efforts to pharmacies by reviewing and disseminating dispenser-specific materials FDA develops. II. Variability amongst pharmacies As the member of the supply chain who most frequently dispenses medications to patients, the pharmacist plays a vital role in protecting patients from illegitimate products. While it may be clear that there are substantial variances between pharmacies and other members of the supply chain, other differences, such as size, resources, patients and business practices, including DSCSA compliance methods, exist amongst pharmacies. When designing pilot project(s), APhA encourages FDA to consider the diversity between pharmacies, the majority of which are small businesses, and other supply chain stakeholders, such as manufacturers and wholesalers. Pilot project(s) should include a wide range of pharmacies and evaluate projects with consideration of the pharmacy s characteristics. As APhA noted earlier this year 1, pharmacy participation could be limited because pilots may require technological capabilities beyond or in advance of DSCSA requirements. New or earlier technology requirements can be particularly onerous on smaller pharmacies. It is important that pilots include a wide range of pharmacy practices to test the variability amongst pharmacies, including differing business practices and technology capabilities. APhA recommends FDA notify and educate potential participants as early as possible and well in advance of implementation to gain meaningful pharmacy participation that is representative of the current supply chain environment. Many pharmacies have contracted with third parties or rely on wholesalers to comply with DSCSA and thus, may not have direct control over the software and/ or hardware used. Therefore, a pharmacy may not possess or be able to purchase or implement the technology to utilize the product identifier an anticipated component of the pilot project(s). In order to provide a comprehensive view of existing strengths, weaknesses, opportunities and threats, APhA recommends that pilot project(s) include pharmacies using different compliance methods. APhA believes this will improve the applicability of the results and provide FDA with better data to inform decision-making, including those pertaining to resource allocation and supply chain security. APhA also has concerns regarding the timeline for the pilot project(s). DSCSA compliance dates are staggered and because pharmacies are at the end of the supply chain, their compliance dates are later than those of other trading partners. For example, manufacturers and repackagers are required to place a unique identifier on certain prescription drug packages by 2017 and 2018, respectively, 1 See American Pharmacists Association comment letter submitted to Docket No. FDA-N-0407. 2

while wholesalers and dispensers have until 2019 and 2020, respectively, to meet the requirement to only accept products with identifiers. Consequently, dispensers may not have systems in place to participate in pilot project(s) involving product identifiers if pilots are implemented prior to 2020, and to do so would likely be burdensome and costly. Furthermore, since several deadlines have already been delayed, FDA may consider re-evaluating the enforcement of current DSCSA deadlines and the impact delays would have on the timelines of the pilot project(s). a. Interoperability Like other members of the supply chain, APhA believes that interoperable systems are essential to effectively tracking and tracing medications. A vulnerability in the supply chain may exist when systems are not interoperable. Pilot project(s) should consider existing technology capabilities, and the costs and time associated with implementing new systems or making changes for the varied supply chain stakeholders. While APhA s membership has not expressed a preference for systems that enable serialized data exchange, such as the Electronic Product Code Information System (EPCIS), testing such systems is an inevitable component to securing the drug supply chain. As these systems are tested, we urge FDA to evaluate costs to dispensers, especially small and independent pharmacies that may find implementation more challenging or cost-prohibitive. APhA is concerned that if systems are implemented that are not interoperable with existing pharmacy systems, then trading partners will stop or limit transactions with pharmacies that cannot readily adopt serialized data exchange systems, increasing costs, limiting patient access and potentially driving dispensers out of business. Rural pharmacies that lack or have slow internet connections are especially vulnerable to such exclusion from trading partners. Therefore, FDA s pilot project(s) also need to consider pharmacies ability to achieve interoperability and mechanisms to optimize communication between stakeholders. b. Identifying suspect / illegitimate products Although pharmacists are on alert for fraudulent medicines, little training or information is available to pharmacists to help them detect such products. We appreciate FDA s draft guidance regarding identification of suspect products 2 ; however, our members have expressed the need for more education on the identification and determination of illegitimate products in order to best protect the integrity of the supply chain. Thus, APhA encourages FDA to educate pharmacists on the identification and reporting of illegitimate products. In addition to increased education, APhA suggests that FDA s pilot project(s) include a standardized electronic process that simultaneously notifies both FDA and immediate trading partners. We believe that FDA Form 3911 could be enhanced to allow notifying through a streamlined and standardized electronic process, all necessary stakeholders, including the FDA. FDA s development of this single standardized form could decrease the time it takes trading partners to notify, thus minimizing interruptions in the delivery of patient care and facilitating compliance with the 24-hour notification time mandate. 2 See, Food and Drug Administration (2014). Guidance for industry: Drug Supply Chain Security Act Implementation: Identification of Suspect Product and Notification (Draft Guidance), available at: http://www.fda.gov/downloads/drugs/guidancecomplianceregulatoryinformation/guidances/ucm400470.pdf, last accessed: April 20, 2016. 3

The RFI seeks information about the use of aggregation and inference. Because inference allows for the replacement of item-level tracking with aggregate-level tracking, it limits the need to open and scan pallets, totes, and cases manually as they move through the supply chain until individually scanned by the pharmacist. APhA believes FDA needs to test the impact of aggregation and inference on safety and security in the pilot project(s). Additionally, error or validation methods, including suspect / illegitimate product identification, should be easy to incorporate into the pharmacist s work flow without excessive cost or resources. III. Inclusion of varied stakeholders APhA members participating in track and trace projects administered by private entities have noted that such projects have limited the pharmacy s choice of secondary wholesalers because some wholesalers cannot meet the system requirements of the pilot. In addition, pharmacists have noted that their choice of wholesalers is further narrowed because some pharmacies have to select wholesalers who have additional services related to DSCSA compliance. As a result of both pilot projects and compliance practices, dispensers have fewer buying options which ultimately affects costs to patients and their health care system generally. Thus, APhA suggests that FDA s pilot project(s) consider existing stakeholder capabilities and whether DSCSA is unnecessarily restricting buying options. In addition, APhA members noted that many independent pharmacies participate in cooperative buying groups which, among other benefits, have helped pharmacies comply with DSCSA. APhA encourages FDA to gain additional feedback from these stakeholders that appeared underrepresented at the workshop and include these entities in pilot project(s) as they may be better positioned to engage in pilot project(s) with small or independent pharmacies. IV. Returns and drop shipments As with many other supply chain stakeholders, APhA agrees that FDA s pilot project(s) should examine the safety and security of drop shipments and returns. V. Use of information Given the type and amount of data that is being transferred through DSCSA and the proposed pilot project(s), our members believe that this data could be useful in assessing pharmacy services and making improvements to benefit patients. APhA supports pilot project(s) that evaluate how to best capture and access DSCSA-related data. VI. Dispenser transfers without a wholesale distribution license There is significant confusion regarding whether a dispenser requires a wholesale distribution license for transfers between pharmacies without a specific patient need under FDA s existing guidance and regulations. Numerous pharmacies, especially independent pharmacies, rely on dispenser-to-dispenser transfers to provide patient access to medications. Given the importance of these transfers to patients and pharmacies, APhA urges FDA to consider pilot project(s) that test different dispenser-to-dispenser transfers to assess the scope, frequency and actual risk these transfers pose to the safety and security of the supply chain. 4

Thank you for your leadership and work on this issue. We look forward to supporting FDA s efforts and working to improve the safety and security of the drug supply chain using practical and feasible implementation approaches. If you have any questions please contact, Jenna Ventresca, Associate Director for Health Policy, by email jventresca@aphanet.org or phone (202) 558-2727. Sincerely, Thomas E. Menighan, BSPharm, MBA, ScD (Hon), FAPhA Executive Vice President and CEO 5