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Law 3
Law 3
47
Law
Professional
02/10/2009

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Term
prepackaging
Definition
pharmacy packages drugs from manufacturer’s container to a customized unit dose or other type of unique dispensing systems for direct patient use
Term
repackaging
Definition
placing any drug from a manufacturer’s original container into different packaging
Term
Time length for repackaging records
Definition
Records must be maintained for one year or until the expiration date of the product, whichever is greater
Term
Requirements for determining expiration date
Definition
Current guidelines: 6 months or one year if packaged in containers “better than PVC”
Term
FDA Risk Evaluation & Management Strategies (REMS)
Definition
implemented by FDA in 2008 to establish formal protocols to communicate information about safety and efficacy concerns with certain medications
Term
REMS include at least one of the following elements designed to ensure safety of use:
Definition
Practitioners must be certified or have training to prescribe medication;
Pharmacies and other dispensers or those who administer must have special certification;
Drug distribution is limited to only certain settings such as clinics or hospitals;
Patients who receive the medication must receive special information regarding safe use, including required lab testing;
Patients must be monitored when using the medication;
Patients must be enrolled in a registry to use drug
Term
closed distribution system
Definition
System for regulating controlled drugs
Term
Attorney General of the United States(Dept of Justice)
Definition
has authority under CSA to classify drugs into Schedules I-V
Term
Controlled Substances Act (CSA)
Definition
defines drugs necessary for control based upon narcotic and nonnarcotic; schedule I-V
Term
narcotic
Definition
natural or synthetic opium or opiate derivative including poppy straw, coca leaves, cocaine
Term
nonnarcotic
Definition
has a high potential for abuse and addiction based on studies and or chemical properties but does not contain a narcotic substance
Term
Schedule I
Definition
no currently accepted medical use in US
Term
Schedule II
Definition
Commonly prescribed drugs include: Ritalin and other amphetamines for ADHD; Percocet and its generic equivalents; Oxycodone and generic equivalents; Dilaudid and generic equivalents; cocaine
Term
Schedule III
Definition
abuse may lead to moderate or low physical dependence or high psychological dependence; Categories include: barbiturates; APAP/ASA with codeine; weight loss agents with amphetamine; anabolic steroids; GHB; paregoric
Term
Schedule IV
Definition
Categories include: drugs with NMT 1 mg difenoxin and not less than 25 mcg of atropine sulfate per dosage unit; benzodiazepines; barbital; chloral hydrate; certain stimulants such as diethylpropion and phentermine
Term
Schedule V
Definition
In many states, including VA, SV drugs can be sold by a pharmacist without a prescription *** (however, limits; pharmacist has the right to reject);
Common agents include Robitussin with codeine and generic versions
Term
Exclusions from Federal Scheduling
Definition
A manufacturer or other entity (FDA) may petition DEA for exclusion of a substance under any of the federal schedules; DEA must issue a public notice with details of the final order in the Federal Register open for public comment for at least 60 days
Term
Who has authority to Add or Deschedule Controlled Substances?
Definition
Virginia Board of Pharmacy
Term
Timeline for federal controlled substance provisions
Definition
Any change in federal controlled substance scheduling provisions may be enacted by state Board after 120 days of the final publication in the Federal Register without public notice
Term
Schedule VI
Definition
Virginia officially classifies prescription drugs not otherwise deemed controlled by DEA into this category (va law - cannot make otc into controlled)
Term
Schedule V exception
Definition
Schedule V controlled substance considered may be dispensed by a pharmacist without a prescription
Term
Manufacturer Labeling & Packing Requirements
Definition
Commercial containers of controlled substances must be labeled with the designated schedule by placing the C-I, C-II, C-III, C-IV, C-V or;
Symbol may be a C with the schedule number inside of it
Term
Closed Loop Distribution Process
Definition
Every entity involved in DEA manufacture, distribution, purchase or dispensing must be registered with DEA except ultimate consumer; Not every INDIVIDUAL health care practitioner must be registered but employer or affiliated health care setting must be registered
Term
Activities Requiring Registration
Definition
Manufacturing, dispensing, researching, narcotic treatment programs, chemical analysis, and import and export of controlled substances;
Each entity must provide separate registrations for each site where it conducts business
Term
Registration and Reregistration Procedures
Definition
DEA issues renewal notices 60 days prior to expiration;
Registrants not receiving renewal notices must notify DEA within 45 days of expiration
Term
Registration Forms
Definition
Dispensers: Form 224;
Manufacturers, distributors, and narcotic treatment programs: Form 225
Term
Distribution of Controlled Substances on Discontinuance of Business
Definition
Must return the Certificate of Registration and executed 222 Forms to the Washington, DC office***
Term
Pharmacy closings; going out of business; change of ownership
Definition
Must notify Board of Pharmacy at least 14 days in advance of closure or change in ownership;
Must provide the Board with information related to the disposition of all controlled substances in SII-VI
Term
Registration Time Frames
Definition
Manufacturers and distributors (wholesalers) register each year at the end of the month assigned by DEA for the registration year (21 CFR 1301.13©);
Pharmacies, hospitals/clinics, teaching institutions must register once every three years in the month assigned by DEA (21 CFR 1301.13(d));
Most entities can reapply for reregistration within 60 days of expiration except importers/exporters that permits 120 day timeframe (21 CFR 1301.13(b))
Term
VA practitioners authorized to prescribe for controlled substances
Definition
MD, OD, podiatrists, dentists, veterinarians, licensed nurse practitioner --II-VI; Licensed physician assistant (CIII-VI only); TPA-certified optometrist may only prescribe oral analgesics listed in Schedules III-VI appropriate to relieve ocular pain
Term
DEA Rule for Multiple CII Prescriptions
Definition
Allows prescribers to issue multiple prescriptions for CII controlled substances for up to a 90 day supply
Term
Label for CII Controlled Substance Prescriptions in VA
Definition
Serial number or name of drug
Date of initial filling
Name and address of pharmacy or pharmacist (no phone number required)
Name of patient (address not required)
Name of prescriber
Directions for use
Term
VA Requirements for Drug Repackagers
Definition
Drug name;
Strength;
Date repackaged;
Quantity prepared;
Initials of pharmacist verifying process;
Assigned lot or control number;
Manufacturer or distributor’s name and lot or control number;
Expiration date
Term
VA Requirements for Drugs Placed into Automated Counting Devices or Dispensers
Definition
Drug name and strength;
Name of manufacturer or distributor;
Manufacturer’s control or lot number for all lots placed into bin at time of filling;
Expiration date
Term
FDA Requirements for Generic Substitution
Definition
Compares bioavailability of the drug in 24-36 healthy volunteers;
Looks for a variation of AUC and CMax of between 20%-25% above or below brand name product
Term
Therapeutic substitution
Definition
substitution of different drug, same class
Term
Therapeutic substitution
Definition
substitution of different drug, same class
Term
Who develops and approves REMs?
Definition
by manufacturers and the FDA
Term
Only entities and persons registered with DEA may dispense, administer, manufacture, purchase, sell, or otherwise acquire controlled substances including
Definition
Pharmacies but not pharmacists;
Prescribers;
Manufacturers;
Distributors/wholesalers;
Researchers;
Hospitals but not long-term care facilities
Term
Who must consult with the Department of Health and Human Services for a clinical and medical evaluation of the drug?
Definition
Attorney General
Term
Virginia Definition: Controlled Substance
Definition
Drug, substance or immediate precursor to substances listed in SI-V by the CSA or by the state Board of Pharmacy;
Excludes distilled spirits, wine, malt beverages, or tobacco
Term
Where should transfer proposals be sent when going out of business?
Definition
DEA requires transfer proposal to be sent by registered or certified mail to the special agent in charge of the DEA region*** of the registrant
Term
DEA Definition of Dispensing
Definition
Delivering a controlled substance to an ultimate user or research subject or
Pursuant to the lawful order of a practitioner including:
Prescribing and administration of a controlled substance and the packaging, labeling, or compounding necessary to prepare the substance for such delivery;
Dispenser is the entity that delivers the controlled substance to the ultimately user or research subject;
Under this section, a pharmacy is a practitioner;
DEA recognizes pharmacists as individual practitioners if authorized by state law;
A hospital is also a practitioner
Term
Dispensing CII Controlled Substance Prescriptions in VA
Definition
Written prescription from prescriber
Meets minimum DEA requirements of drug name, strength, dosage form, quantity prescribed, and directions for use AND Dated and signed by practitioner/prescriber on date written--post dated or undated prescriptions not acceptable; Full name and address of patient or owner of animal for vet rxes (may be added by pharmacist);
Full name, address, and DEA number of prescriber
Term
Dispensing CIII-VI Controlled Substance Prescriptions in VA
Definition
Written prescription from prescriber;
Meets minimum DEA requirements of drug name, strength, dosage form, quantity prescribed, and directions for use (21 CFR 1306.05);
May also be filled pursuant to an oral prescription;
Dated and signed by practitioner/prescriber on date written--post dated or undated prescriptions not acceptable;
Oral prescriptions must contain the same information except no prescriber signature required
Term
Which schedule does not require an address?
Definition
For SVI drugs: no address needed if the information is readily-retrievable in the pharmacy’s records
Term
Label for CII Controlled Substance Prescriptions in VA
Definition
Serial number or name of drug;
Date of initial filling;
Name and address of pharmacy or pharmacist (no phone number required);
Name of patient (address not required);
Name of prescriber;
Directions for use
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