MPJE Flashcards
Created law that mandated safety of all drugs
Food Drug Cosmetic FDCA 1938
Created the FDA
Food Drug Cosmetic Act FDCA 1938
Created Rx/OTC
Durham-Humphrey Amendment 1951
Authorized verbal rxs and refills
Durham-Humphrey Amendment 1951
Law that required drugs to be safe AND effective
Kefauver-Harris amendment 1962
Created FDA oversight of drug advertisement
Kefauver-Harris amendment 1962
Increased safety of drugs & created GMPs
Kefauver-Harris amendment 1962
Bans the re-importation of drugs made in the US
PDMA 1987 (prescription drug marketing act)
Bans sale, trade, or purchase of drug samples
PDMA 1987 (prescription drug marketing act)
Mandates storage, handling, and record keeping requirements of samples
PDMA 1987 (prescription drug marketing act)
Only instance where a retail pharmacy may have samples
Pharmacy must be affiliated with a healthcare entity (i.e owned by hospital) (PDMA 1987)
Prohibits the resale of drugs purchased by hospitals and healthcare facilities (acquisition cost lower)
PDMA 1987 (prescription drug marketing act)
Created sterile compounding outsourcing facilities (503B facilities) following cGMPs regulated by FDA
No pt. specific compounding
DQSA - Drug Quality and Security Act 2013
Florida requirement for in-state 503B facility
Must obtain Special Sterile Compounding Permit
Florida requirement for out-of-state 503B facility
Must obtain Nonresident Sterile Compounding Outsourcing Facility Permit
Federally regulated outsourcing sterile facility
non patient specific
503B facility
Compounding (sterile) pharmacies not registered with FDA as outsourcing facility
503A pharmacy/facility
Does a 503A pharmacy need individual prescription to compound a sterile drug?
Yes!
What federal USP statute guides 503A pharmacies?
USP 797 quality standards for sterile compounding
How often must a 503B facility report drugs sold
Initially, then q6months
503B facility must report serious ADE within __ days
15
Law that provides “track and trace” system for drugs as they move through supply chain
Drug Supply Chain Security Act - DSCSA
Law that establishes standards for wholesaler licensure
Drug Supply Chain Security Act - DSCSA
Requires “Transaction data” between wholesalers and pharmacies
Drug Supply Chain Security Act - DSCSA
Requires pharmacies to report/properly handle illegitimate drugs
Drug Supply Chain Security Act - DSCSA
Exceptions to “distribution” (where pharmacy doesn’t need distribution license/pass on transaction data)
Same ownership, dispenser to dispenser for patient specific need, emergency medical reason, “minimal quantities” to licensed practitioner for office use
Adulteration v. Misbranding - Drug contains fility, putrid, or decomposed substance
Adulterated
Adulteration v. Misbranding - Prepared or held under unsanitary conditions
Adulterated
Adulteration v. Misbranding - Drug held in container that is poisonous/deleterious to drug
Adulterated
Adulteration v. Misbranding - Contains unsafe color additive
Adulterated
Adulteration v. Misbranding - Products claims to meet USP standards for strength & quality, but doesn’t
Adulterated
Adulteration v. Misbranding - Drug differs in strength or quality compared to what label states
Adulterated
Adulteration v. Misbranding - Label does not state name of mfr, packer, or distributor
Misbranded
Adulteration v. Misbranding - Label does not state name of drug
Misbranded
Adulteration v. Misbranding - Label does not state quantity
Misbranded
Adulteration v. Misbranding - Label does not state weight of active ingredient
Misbranded
Adulteration v. Misbranding - Label does not state “rx only” if rx only
Misbranded
Adulteration v. Misbranding - Route of admin not stated on label if not for oral use
Misbranded
Adulteration v. Misbranding - Pharmacist dispenses rx w/o authorization
Misbranded
Adulteration v. Misbranding - Pharmacist fills for wrong drug/str/sig
Misbranded
Adulteration v. Misbranding - Pharmacist fill for wrong str
Misbranded AND adulterated
Adulteration v. Misbranding - Pharmacist fills drug w/o REMS requirement
Misbranded
Adulteration v. Misbranding - Pharmacist dispenses expired drug
Adulterated. Also misbranded if pharmacist places a beyond use date that exceeds mfr expiration date
Recall type - reasonable probability of serious ADE/death
Class I
Recall type - May cause temporary/reversible ADE where serious ADE chance is remote
Class II
Recall type - Not likely to cause adverse health consequences
Class III
Patient package insert (lay person level) require for:
Oral contraceptives/estrogen containing products. If hospitalized/institutionalized, initially and every 30 days.
PPPA
Poison Prevention Packaging Act 1970
Law that created mandate for child resistant containers for all drugs and some OTC drugs
Poison Prevention Packaging Act 1970
Exemptions to PPPA (page 44)
Contraceptives, estrogens, medroxyprogesterone, SL NTG, effervescent ASA/APAP, UD potassium, Sodium Fluoride (264mg max/package)
Exemptions to PPPA (page 44)
Cholestyramine, Erythromycin, Prednisone (105mg max/package), Medrol (84 mg max/package)
Exemptions to PPPA (page 44) Prednisone mg
105mg/package
Exemptions to PPPA (page 44) Medrol mg
84mg/package
Exemptions to PPPA (page 44) Sodium Fluoride mg
Sodium Fluoride (264mg max/package)
Authority to schedule controlled substances (federal)
US Attorney General
Authority to schedule controlled substances (Florida)
Florida AG may add/delete/reschedule
Codeine or opium not mixed with other drug is schedule
Schedule II
Codeine solution C-V limit
2mg/1mL (like Robitussin w/codeine = 100mg/10mg/5mL)
Codeine C-III limit (tablet)
90mg/tablet mixed with other drug like apap
Codeine solution C-III limit (liquid)
18mg/1mL
Opium C-V limit
1mg/1ml
Opium C-III limit solution (federal)
5mg/ml
Opium C-III limit solid dosage (federal)
25mg/tablet
Opium C-V limit (Florida)
1mg/ml if greater concentration, CII
Pharmacies and practitioners must register w/DEA every ___ years
3
Form ___ is used to register w/DEA
224
Form ___ is used to renew w/DEA
224a
DEA number for dispensers (pharmacies/practitioners) start with ______
A, B, or F
Mid-level practitioners DEA # starts with _____
M
Verify DEA #
Add 1st, 3rd, 5th #; Add 2nd, 4th, and 6th # & x by 2, add two sums, and last number should be last # DEA
If full amount of CII can’t be filled by wholesaler, the order may be partial and sent to pharmacy within ___
60 days
Theft or significant loss must be reported to DEA within ___
1 business day in writing
Florida law requires theft or significant loss be reported to _____
DEA within 1 business day, BOP within 1 business day (by PDM/CP), and county sheriff within 24 hours
To report theft or significant loss to the DEA, form ___ is used
106
Disposal or destruction of controls uses form ___
41
Form 41 procedure (disposal destruction of controls) other than Class I institutional
Fill and sign. Must be done by PDM or Consultant pharmacist of record and a witness and sent to closest DEA office within 1 business day
To report illegitimate drugs, form ______ is used
Form FDA 3911
Per CMS regs, LTC facilities must have a Medication Regiment Review _____ by a consultant pharmacist
Every 30 days
Irregularities in LTC facility found on Medication Regiment Review must be reported to
Attending MD, Medical Director, DON
Inventory of controls
Exact # for CII, estimated # for CIII-V unless bottle holds more than 1000 doses
Controlled substance records must be kept for ___ years
2
Rx records must be kept for _____
4 years from the last date of fill
Central record-keeping for controls are permitted EXCEPT for _____
Executed 222 forms, prescriptions, or inventories
How many CE hours must a pharmacist take relating to opioids/controls?
2 CE
Every pharmacy must maintain a summary record of control substances dispensed for last ___ days and made available w/in _____ hours
60 days , 72 hours
Summary record of controlled substances includes:
Name of drugs, volume dispensed, specific patients, specific prescribers
Fraudulent controlled substance rxs must be reported to ____ within _______
sheriff/chief law enforcement within 1 business day/24 hours (whatever is later)
Optometrists can only prescribe the following controls:
Ultram, Tylenol w/codeine #3 (max 72 hour supply unless consulting w/md)
PAs can prescribe up to a ___ day supply of CII
7 day
PA can prescribe mental health control to minor?
No!!!!
APRN can prescribe up to a ___ day supply of CII
7 day - does not apply to psychiatric CII written by psychiatric APRN
Can PA/APRN prescribe in pain management clinics?
No!!!
APRN can prescribe mental health control to minor?
No!!! Exception psych specialist
Can a pharmacist fill a control for an out of state doctor?
Only if rx is validated AND is for a chronic/recurrent condition
Can a pharmacist fill and out of state rx for non control?
Yes, but only for chronic/recurrent condition
Is a telehealth rx permitted for controls in Florida?
Yes, but only for A) Psych B) Hospital Inpatient C) Hospice D) Nursing Home
Is E-prescribing mandatory?
Yes!!!
Notable exceptions to e-prescribing
Emergency to pt, hospice/nursing home pt, price shopping
Can a control and non control appear on the same hard copy blank?
No!!!
Refills permitted for CII?
No!!!!
Verbal for CII permitted?
No! Except for emergencies
Verbal for CIII-V permitted?
Yes
Max quantity for a verbal CIII rx?
30 days
Faxes for CIII-V?
Yes, but must bear prescribers original signature
All prescriptions (including CII) must be filled within ____
1 year after issue date or earliest fill date
In general, do quantity limits apply to CII?
No
Max amount of CII PA/APRN can prescribe?
7 days, except for psych APRN for psych CII
Instances where CII may be faxed to pharmacy and function as original rx
Home infusion/IV pain, LTCF, Hospice
A pharmacist may issue up to a ___ supply of CII from a verbal emergency rx
72 hours
A doctor has ____ days to send covering rx for verbal emergency rx
7 days; must state “authorization for emergency dispensing”
CII acute pain max day supply
3 days, with exceptions
Exception to 3 day acute pain CII
7 day max if exception! Permitted if greater than 3 days clinically indicated, “acute pain exception” noted on rx, prescriber documents in pt record
For treatment of non acute pain using CII, prescriber must indicate
“Non-acute pain” on face of rx
Greater than 7 day supply for opioid CII for acute pain?
No, except for Injury Severity Score of >9; prescriber must also write for antagonist (Naloxone)
C-V OTC max codeine per 48 hours
120mg/4oz
C-V OTC max opium per 48 hours
240mg/8oz
Consultant pharmacist course hour requirement
12
Consultant pharmacist requirement initial licensure
Take a course no less than 12 hours, take cognitive test, “intern” w/consultant pharmacist for at least 40 hours for no more than 3 months (no more than 1 year after taking course/test)
Consultant pharmacist preceptor requirement
Must be CPoR (consultant pharmacist of record) at institutional pharmacy & 1 year experience. Max 2 students at a time
CE requirements for pharmacist
30/2 years. 10 must be live. 2 must be in med error. 2 must be in validating controlled substances. 3 must be in vaccines/epi if vaccinator. Initial renewal - 1 hour HIV/AIDS
Consultant pharmacist who wish to monitor and order labs must complete a ___ hour cert course initially
3 hour
PMP not required for patients under ___ years of age
16