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Law 2
Law 2
43
Law
Professional
02/03/2009

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Cards

Term
Drug Efficacy Study Implementation (DESI)
Definition
Allows generic competitors of approved brand name drugs to submit an abbreviated new drug application (ANDA) showing proof of bioavailability, bioequivalence and information on manufacturing and controls
Term
Who controls OTC advertising?
Definition
FTC
Term
Who controls Rx drug advertising?
Definition
FDA
Term
Advertising to Health Care Professionals by Manufacturers
Definition
True statement which provides information related to name of drug, active ingredients, and summary of information regarding side effects, contraindications, and clinical effectiveness
Term
When ddvertising to Health Care Professionals by Manufacturers does not apply:
Definition
Reminder advertisements with no indications or dose recommendations;
Ads for bulk sale of drugs;
Ads by pharmacists regarding compounding
Term
Where is labeling found?
Definition
Brochures, booklets, mailing pieces price lists, references, etc provided by manufacturer for use by health care professionals
Term
PhRMA Code on Interactions with Healthcare Professionals
Definition
Voluntary attempt by manufacturers to reduce undue influence of manufacturers on prescribing habits;
Resulted in companies spending less on marketing and programming;
Focus on ensuring fair and balanced information from pharmaceutical companies
Term
Direct to Consumer Advertising
Definition
Must contain true statement, a brief summary, and be fair and balanced;
Must contain adequate provisions to provide consumers with information regarding medication, uses and side effects
Term
FDA Adequate Provision Requirements
Definition
Summary of risks in audio/visual format as long as it provides adequate provision for obtaining complete prescribing information from:
Toll free number,
Website,
Print advertisement in a concurrently running publication and,
Referral to a health care provider--”Ask your doctor or pharmacist”
Term
Product specific
Definition
must provide summary of side effects, etc and adequate provisions to obtain further information
Term
Non-product specific
Definition
does not name product and directs consumers to health care professional
Term
Off-Label Drug Use
Definition
Governmental agencies
Must provide peer-reviewed journal information;
Sales force generally must refer to medical science staff to provide this type of information;
FDA must approve content
Term
VA Definition: Proprietary Drugs
Definition
Drugs that meet FDA requirements for OTC medications;
Cannot be a controlled substance or require a label indicating that it might be habit-forming;
Cannot be a product that must be administered by a licensed practitioner or dispensed by a pharmacy
Term
Does NOT include transportation of mixed, diluted, or reconstituted products for the purpose of administration by a practitioner in an office setting directly to patients
Definition
Dispensing; only includes delivery of a drug and prescribing and administering, packaging, labeling or compounding
Term
What is it called when physicians and other providers inject or provide medications in their office?
Definition
Administration
Term
Dispensing pharmacists and pharmacies exempt from extensive labeling requirements so long as the label:
Definition
Meets the requirements established by the state;
Is not false or misleading;
Packaging and labeling conform to official compendia standards;
Drugs packaged and labeled appropriately;
Drug is packaged in conformance with the Poison Prevention Packaging Act when required;
Term
Dispensed prescriptions must contain:
Definition
Name and address of dispenser (pharmacy);
Serial number of rx (pharmacy’s assigned number);
Date of rx or filling;
Name of prescriber (not address);
Name of patient (not address);
Directions for use and cautionary statements if necessary
Term
Poison Prevention Packaging Act of 1970 (PPPA)
Definition
Designed to protect children from accidental poisonings with household substances, including prescription drugs;
Delegates authority to the Consumer Products Safety Commission to regulate and ensure compliance with requirements
Term
PPPA Requirements for Pharmacy
Definition
Requires use of child-resistant containers for most OTC drugs and for all prescription drugs dispensed directly to consumers;
Containers meeting these requirements will be proven by manufacturer such that 80% of children less than 5 years of age cannot open them but at least 90% of adults can open them
Term
Do drug packaging for residents of long-term care facilities apply to the PPPA requirements?
Definition
Prescription drugs packaged for residents of long-term care facilities and other institutional settings exempt if the facility personnel will administer the medications to the patient
Term
PPPA exemptions for drugs that can be dispensed in vials without safety caps
Definition
OTC products marketed specifically for elderly or disabled individuals with proper notation that the packaging is not child-resistant;
Exceptions for certain drugs dispensed in special containers or for certain uses;
Request could be oral but should be documented;
VA requirements under Special Packaging -
May post a sign near pharmacy department outlining policy;
Pharmacy must maintain a release of such request form the patient or authorized agent and be maintained for at least 2 years from dispensing date
Term
Who governs pharmamacist compounding?
Definition
States
Term
Actions that require pharmacists to register as manufacturers
Definition
Actions by pharmacists that result in changing the container, wrapper or labeling of products
Term
Compounding Nonprescription Products
Definition
Must be labeled according to FDA provisions as any other OTC agent;
Cannot be prepared with any prescription ingredients
Term
Reconstitution
Definition
Involves mixing drug products for use by a patient pursuant to manufacturer’s instructions;
Not considered compounding
Term
VA Compounding Provisions
Definition
Combining 2 or more ingredients into a single preparation and
Includes mixing, assembling, packaging or labeling of a drug or device; Prescribers that mix, dilute, or reconstitute a manufacturer’s product for the purpose of administration to a patient not compounding
Term
Labeling for Compounding Rx must include:
Definition
Conform with VA standards for prescription label;
Name and strength of medications or list of active ingredients and strengths;
Pharmacy must number the prescription consistent with the compounding record;
Beyond use date determined by the pharmacist in compliance with USP-NF standards for pharmacy compounding;
Quantity
Term
Record-keeping for compounding
Definition
May be maintained electronically or manually so long as the information is readily retrievable
Term
When products compounded in advance of dispensing, use of bulk drug substances used:
Definition
Generic name and quantity;
Name of manufacturer;
Manufacturer’s lot number and expiration date for each component or if unknown, the source of acquisition of each component;
Assigned lot number if subdivided;
Unit or package size and number of units prepared;
Beyond use date
Term
Drug Repackagers
Definition
FDA-registered facilities that must comply with GMPs, including all labeling requirements and product integrity requirements;
Repackages drugs from manufacturers and places them into new packaging; Repackaging different from prepackaging where pharmacy packages drugs from manufacturer’s container to a customized unit dose or other type of unique dispensing systems for direct patient use
Term
NDC
Definition
3 segment unique code identifying drug product and packaging type;
First 4 numbers: manufacturer or distributor;
Second 4 numbers: drug;
2 final numbers: package type
Term
Repackagers
Definition
placing any drug from a manufacturer’s original container into different packaging
Term
Requirements for Drug Repackagers
Definition
Applies to bulk reconstitution, bulk compounding, or repackaging;
Records must be maintained for one year or until the expiration date of the product, whichever is greater; MUST INCLUDE THE EXPIRATION DATE (Current guidelines: 6 months or one year if packaged in containers “better than PVC”)
Term
Requirements for Drugs Placed into Automated Counting Devices or Dispensers
Definition
Must maintain filing record either manually or in a computerized record that is readily retrievable; Manufacturer’s control or lot number for all lots placed into bin at time of filling
Term
Pharmaceutical equivalent
Definition
Contains the exact same product and the same salts as the original, brand name drug
Term
Pharmaceutical equivalent
Definition
Contains the exact same product and the same salts as the original, brand name drug
Term
Pharmaceutical alternative
Definition
exact product but different salts or excipient ingredients
Term
Bioavailability
Definition
Rate and extent of absorption of product;
Includes the requirements for the composition of the product
Term
FDA Requirements for Generic Substitution
Definition
Compares bioavailability of the drug in 24-36 healthy volunteers;
Examines the AUC and peak drug concentrations (CMax);
Looks for a variation of AUC and CMax of between 20%-25% above or below brand name product
Term
generic substitution
Definition
allowed unless physician specifically requires drug dispensed as written
Term
Therapeutic substitution
Definition
requires provider authorization
Term
Dispensing of therapeutically equivalent drug products
Definition
Permits pharmacists (not requires) dispensing of a therapeutically equivalent product written for a brand name product unless:
Prescriber indicates “brand medically necessary” OR
Patient insists on brand name drug
Term
Reference for therapeutic equivalence
Definition
Orange book
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