Law Flashcards
Cesamet
Nabilone c2
Marinol
Donabinol cap
C3
Syndros
Dronabibol solution
C2
Epidolex
Cannabis derived
CV?
Farm bill
Removed hemp from definition of marijuanna
So cbd can be extracted and added to creams (topicals only)
Gamma hydroxybuyric acid
GHB C1
Sodium oxybate
C3
Zyrtec
Levophanol
C2
Hysingla
Hydrocodone
Zohydro
C2
Hydrocodone
Kadian
Morphine
Nucynta
Tapentadol
C2
Methamphetamine
C2
Tussicaps
Hydrocodone
Cocaine
C2
Codeine
C2
Levo alpha methanol LAAM
C2
Pentobarbital
C2
Secobarbital
C2
Benzphetamine
C3
Butrans
Buprenorphrine
C3
Butabarbital
C3
Fioricet (with codeine) fiorinal,
C3
Codeine/APAP
C3
1.8 g/100 mL codeine is C3 or 90 or less me/dosage unit
Ketamine
C3
Paregoric
C3
Fycompa
Peranpanel
C3
Peranpanel
Fycompa
C3
Phendimetrazine
C3
Testosterone
C3
Sonata
Zaleplon
C4
Adipex
Phentermine
C4
Qsymia
Phentermine/topirimate
C4
Edluar
Zolpidem c4
Intermezzo
Zolpidem
Suvorexant
C4
Nuvigil
Armodafinil
C4
Armodafinil
Nuvigil c4
Butorphanol
Stadol
C4
Stadol
Butorphanol
C4
Difenoxil/atropine
C4
Not more than 1 mg difenox and not less than 25 mcg atropine
***if difenoxil is less than 0.5 is is C5
Modafinil
Provigil
C4
Phenobarbital
C4
Tramadol
C4
Ultracet
Tramadol and apap
C4
Brivaracetam
C5
Epidiolex
Cannabidiol
CV
Codeine cough syrups
C5
Not more than 200 mg/100ml or 100g
Lomitil
Diphenoxylate/atropine
C5
Not more than 2.5 mg and not less than 25 mcg atropine
Lacisamide
Vimpat
C5
224
Requests 222 forms
222 forms
Copy 1 (brown): entity giving drugs Copy 2 (brown): DEA Copy 3 (blue): entity getting drugs
Opioid addiction buprenorphine
Probuphine and sublocade
With naloxone: suboxone, bunavail, zubsolv
Pain buprenorphine
Butrans belbuca, buprenex
Salagen
Pilocarpine
Cholinergic
Increases salivation often for chemo induced dry mouth
Palmar-plantar erythrofyesthesia
Capecitabine and fluoouracil
C2 barbs in combo or as suppository
C3
Diethylpropion
C4
Lorcaserin
C4
Carisoprodol
C4
Eluxadoline
C4
Ezogabine
C5
Meprobomate
C4
Prandin
Rapglinide
Meglitinides
Secretagogues
Before meals
Pure food and drug act
Wiley act
Ingredients meet standards of strength, quality, purity. Label can’t be false or misleading. Must list 11 dangerous ingredients. No adulterated or misbranded drugs can be sent through interstate commerce (FDCA did that too)
Food, drug, and cosmetic act
Must prove safety. Must list ingredients and not have misleading labeling. Birth of FDA
Adulterated
Identity, STRENGTH, quality, purity
Misbranding
Any lack in labeling or warnings, illegible, if ingredients differ from standard in USP monograph (strength, quality, purity), non packaged right according to poison prevention packaging act
Durham-Humphrey
Otc and RX
3 conditions make a drug rx: 1 habit forming 2 unsafe without supervision 3 limited to prescription use under NDA
Otc need adequate directions for use.
Labeling of unit dose
Kefauver Harris
Manufacture must prove safe AND effective
Phase 4 side effect reporting (manufacturer) and retrospective efficacy analysis (FDA 1938-1962). Informed consent. cGMP!
FDA to regular RX advertising and FTC for OTC advertising.
Drug listing act
Manufacturers must register drugs with FDA. Created NDC #
Anti tampering act
Required tamper resistant features for OTCs. Must list features on label. Exempt products include: insulin, lozenges and tooth cleaning powder
Orphan drug act
7 year exclusivity and 50%tax credit of clinical testing costs. Dx of <200,000 people in US. Or products with no reasonable expectation will pay off
Hatch waxman
Drug price competition and patent term restoration act. ANDA (or 505b2-paperNDA) and patent protection for innovators. Prove same API, route, dosage form, strength, and bio equivalent. Made 5 year patent exclusivity for brands.
Prescription drug marketing act
Can no reimport drugs. Sale of drug samples prohibited. Sale of coupons prohibited. Can no bring drug in US unless <90/day, only for pt, no trmt in US, serous condition, no risk. Wholesalers must be licensed. Hospitals can’t resell drugs
Omnibus budgeting act
Prospective DUR, counseling for all Medicaid beneficiaries.
States required to perform retrospective DUR
Dietary supplement and health education act
Considers supplements as food. Adulteration and misbranding still prohibited. FDA requires premarket review of safety data for new ingredients but doesn’t need FDA approval(must say on label). Cant make dx claims. Must say supplement on label. Must have supplement facts and ingredients list
FDA modernization act
Clinical trial registry, extended PDUFA, changed legend sentence to “RX only”, fast track approval of drugs
Drug addiction treatment act (DATA)
Allowed physicians to prescribe CS in office setting to treat opioid addition.
Comprehensive addiction recovery act (CARA)
Amendment of CS act
Allowed NP and PA to treat patients for opioid dependence
Allow partial fills of C2 (30 days)
Authorizes funding and regulatory help in response to opioid epidemic
FDA am me demented act (FDAAA)
FDA more power to ensure safety including REMS program
Biological price competition and innovation act
Abbreviated licensure pathways for biosimilars
Drug quality and security act
Response to NE compounding center incident. It’s an amendment to FDCA that includes: 1. Compounding quality act (traditional compounding vs outsourcing facility), 2. Drug supply chain security act (documentation of transactions through distribution chain-6 YEARS!!
Pregnancy and nursing labeling final rule
June 2020 replace ABCDX with: 1. Pregnancy (includes L&D) 2. Lactation (nursing mothers) 3. Females and males reproductive potential
Form 224
Applying for DEA registration or ordering 222 forms (check box 3) after that can order online (need DEA#, business name, telephone#), or call headquarters or specialist
225
Applying for DEA registration for manufacturer
225a for renewal every year
363
Applying for DEA registration for narcotic treatment programs
363a for renewal every year
Exempt from DEA registration
EMPLOYED BY( need dea reg if working at outside private practice): US Public Health Service, Federal bureau of prison, armed forces, Indian reservations
For administering, dispensing, or prescribing NOT to procure or purchase
Must give service ID number instead
224a
Renewal of DEA registration
224b for chains
Every 3 years
Medpak label
Pt name, serial # for medpak AND each drug, drug name/strength/description/quantity, directions, cautionary statement, storage, MD for EACH drug, prep date, BUD of pak (DNE 60 days), pharmacy name, address, telephone #, DEA # if applicable
Med pak record
Pt name and address, serial #for each drug, manufacturer name and lot #’s, info on design characteristics specs to help recreate it, prep date and BUD, special labeling, RPH initials
Hospice quantities in ADD
Analgesic c2-5: 50, 100, 150
Sedative/ANticonvuls c2-5 30, 60, 90
Ancillary c6: 25, 50, 75
Beds: 21
E-rx req going into effect 1/1/21 exemptions
C6, tech failure, waiver, out of state (or fed facility like veterans or Indians), LTC/nursing home to 1/1/23, compounded drugs, EPT, emergency, urgent public health matters, medical equipment, state/federal law (REMS), veterinarians
LTCF emergency kits
Analgesics c2-5: 45, 60, 75, 90
Sed/anticonvus c2-5: 15, 20, 25, 30
Beds: <50, 51-100, 101-150, >150
3:1
Methaqualone
C1
Sublimaze
Fentanyl
Codeine
Less than or equal to 90 mg per dosage unit is c3 I think-these are combination products
Didrix
Benzphetamine
C3
Oxandrin
Ocandrolone
C3
Propoxyphene
Darvon, darvocet
C4
Darvon
Propoxyphene
C4
TranXene
Clorazepate
223
Duplicate certificate of registration
510
DEA chemical distributor registration
CSR protection act
Federal investigation in robbery if more than 500 taken, interest ate or foreign commerce used, someone hurt or killed….25000 fine and/or 20 years, 35000 and/or 25 years of weapon used, 50000 and/ or life if death
Requires DEA records
222, invoices, POA, inventory, dispensed, distributed, self-certification (pse), 106, 41, DEA registration, transfers of CS
222
Has7 sets of forms, each pharmacy gets 6 books max unless need exceed limits
PSE rules
3.6/day
9/mo
7.5/ mo mail order
PSE amount per 3.6 grams
Ephedrine hcl 25: 175
Ephedrine sulfate 25: 186
Sudafed hcl 30: 146
Sudafed sulfate 30: 155
When can a fax be original for C2
- Compounded narcotic for direct administration parenteral
- LTCF
- Hospice narcotic RX certified and/or paid for by Medicare
Ryan haight
CSA amendment
Online pharmacy consumer protection act
Need a MODIFICATION of DEA registration
Medguides
Antipsyches, NSAIDS, estrogen, antidepressants, anticonvulsants, long acting opioids, amiodarone , ADHD stimulants, atomoxetine, antiarrythmics, REMS drugs
Form 130
When you want to manufacture a new CS that you aren’t register to manufacture
DATA waived patient limits
30, after 1 year 100, after another year 275
If not data waived can administer but not prescribe 1 days worth for up to 3 days til referral is arranged
Online reporting reqs
If over 100 CS rx or 5000+ dosage units
Peanuts/ soy allergy drugs
Cleidipine, propofol, progesterone
Egg allergy drugs
Propofol, clevidipine, yellow fever vaccine.
Flublok is egg free influenza vaccine
Luminal
Phenobarbital
C4
Mebaral
Mephobarbital
C4
Mephobarbital
Mebaral
C4
Brevital
Methohexital
C4
Methohexital
Brevital
C4
Prosom
Estazolam
C4
Dalmane
Flurazepam
C4
Dolene
Dextropropoxyphene
C4
Propocacet
Amobarbital
C2
Amytal
Critical info on med label
Patient name, drug name (brand and generic), strength, directions
Consumer medication information
Leaflet stapled to bag
Required for each NEW rx
Required for first fill
Not reviewed or approved by FDA
Patient package insert
Voluntarily provided by manufacturer
Require FDA approval
Given with new AND refills
LTC/hospital prior to first dose and every 30 days thereafter
Medguide reqs
FDA approved
Drug with serious health concerns- adherence necessary or serious ADR
Supplied by manufacture
Give with new AND refill rx, first time given to provider for outpatient administration, pt asks, medguide revised
REMs
- Communications plans
- Elements to assure safe use
- Implementation systems
- Medguides
Developed by manufacturer and approved by FDA
Who can you share PHI with
Patient, those authorized by patient, other healthcare providing care, for treatment, payment, or operational purposes. Law enforcement: DEA FDA medical board inspectors/pharmacy board inspectors (for public health or abuse concern), limited data for research, public health, or institutional operations
Patient written authorization for PHI disclosure
- Who it’s being shared with
- Purpose
- Expiration
- Patient signature
HIPAA privacy notice
Given in first day of care and whenever there are Changes. Try to get signature acknowledging but can still give care without it. Patient can request privacy disclosures for past 6 years so keep HIPAA signed privacy disclosure form for 6 years.
Contain contact for department of health and human services as well as for someone in pharmacy
Certificate of fitness log book
Date, name and address of person, kind, quantity, price, intended use
Closing pharmacy
14+ days before give board: name, address, phone#, MCSR#, certificate of fitness#, pharmacy permit#, date of closure, procedures, adequate Notice, procedures for disposal/transfer of cs
Transferring CS to different pharmacy
Give to board in 14 days: name/address/phone# (both) pharmacy permit# (both), MCRS# (both), name/RPH registration# of manager(both), date, and intended security procedures. Send copy of inventory over in 10 days(note for manager change inventory doesn’t get sent to board, just sworn statement kept on file)
Transferring rx
CS: void, on back: pharmacy, RPH (receiving), DEA, address- on back
CS/C6: log: pharmacy, RPH transferring, date, RX number
Advertising
NO: safety, efficacy, indications
YES: proprietary name, generic, quantity of API when one API, strength when more than one API, dosage form, price for filling RX
Prospective DUR
Duplication, over/under utilization, drug drug, drug-dx, drug-allergy, abuse, incorrect dose/duration, any changes in drug/dose/directions
Counseling
Name/description, DF dose route duration, instructions for prep/admin/use, missed dose, storage, self monitoring, ADR/CI/interaction/precautions, refills
Nuclear pharmacy record retention
3 years
Form 483
Deficiencies from FDA inspection
RPH vaccines
Flu, TD/Tdap, varicella, HPV, zoster, MMR, PSV23, meningococcal, HepA, HepB, polio
Vaccine class
12 hours self study with assessment
8 hours live with final exam
Hands on
CDC, ACoR approved
Rx can’t change
Pt name, md name, drug, signature, earliest fill date
Note: date written can be changed
And supervising MD can be changed
Rx changes without consultation
DEA#: can add if omitted
Pt address: add if omitted( must consult to change)
“No sub” “pt can request less” if omitted
Can change 30 to 90 days supply if not a PMP drug
Documentation for RX changed
Date, change, MD, RPh
License reactivation reqs
How loss has affected you, activities since loss, remedial activities, plans to resume and measures to ensure following law, have they engaged in pharmacy activity since, document of completion of out of state reqs, reinstatement questionnaire, resume with employment since loss, 3 recs one must be RPH must know you since loss of license. Valid for 90 days. Must send within 90 days. If denied must wait 2 more years
License reactivation after expiration
Documentation of CEs in past 2 years, written statement from each employer since expiration, statement from each state where licensed. retake MPJE. If not been practicing in pharmacy May require personal appearance, retraining, and/or naplex
Fridge/freezer temps
Fridge: 2-8 Celsius
Freezer: -25 to -10
Note for naplex freezer is -50 to -15
Check at least daily
Failure to follow up with c2 HC
Report to DEA, US department of justice, commissioner of public health, Mass department of public health
Date to send plan B report by
8/1 for period of 7/1-6/30 of prior year