Supply Chain and Inventory Management Flashcards
CE Impact and PowerPack put together all Modules
Prescription Drug
Rx or legend drug; need a presription
Over the Counter
May be purchased w/o a prescription
Compounding
Mixing, combining, altering of ingredients to make specific product dosage form or strength nor commercially available
Dispense
Supply drug to patient pursuant to a RX or drug order from a practitioner or prescriber
Distribute
Supply a drug to entity for sale, resale, dispensing, or administration
Supply Chain
Path drug takes from manufacturer to patient. Includes: Manufacturer, wholesale distributer, 3PL, 503B Outsourcing Facility, Reverse Distributor, etc..
Pharmacy
Obtains RX product and dispenses to patients pursuant to patient-specific RX or order. Hospital, Community, outpatient, mail order, nuclear, specialty, LTC, other
Wholesaler
Obtains product from manufacturer to distribute (sell) to other wholesalers, pharmacies, practitioners, health systems, and others appropriately registered.
Manufacturer
Makes drug from active ingredients, excipients and other components. May have own facility or virtual manufacturer.
may offer health care providers product education, patient support programs, and support with navigating insurance reimbursement
Third Party logistics Provider
3PL. Possesses but not owns. Act as warehouse, recieves product sent by manufacturer distributing orders directed by manufacturer
Product
Per “DSCSA” human Rx product in finished dosage form.. Some exceptions to definition
Transaction
Product transfer between persons in which a change of ownership occurs
Inventory
What is on hand to dispense
Group Purchasing Organization
Organization joins together several facilities to purchase products at a larger volume than each could on their own generating cost savings
Virtual Manufacturer
Owns drug but not possess drug. Outsources manufacturing to a contract manufacturing organization (CMO) utilized a 3PL for distribution. Includes repackager and relabeler
FDA
ensures the safety, efficacy, and security of food, drugs, biologics (e.g., therapeutic proteins, monoclonal antibodies, vaccines), radioactive products (e.g., sodium iodide, radium), medical devices, and cosmetics. Regulating the manufacturing, marketing, and distribution of tobacco products also falls under FDA’s purview. Also plays a role in the nation’s counterterrorism capability by ensuring food supply security and fostering medical product development to respond to public health threats
1906 Food and Drugs Act
passed to protect the consumer against dangerous and mislabeled drugs) allowed for the establishment of FDA.
DEA
regulates Controlled Substances, who sells and prescribes as well
Established 1973 to enforce CSA
Controlled Substance Registration Certificate
Form 223. Renew Q 3 years. Makes so you can handle Controls
CI
No medical approved use. High abuse potential.
CII
High abuse potential. May lead to severe psych or physical dependence.
CIII
potential for abuse less than CII. may lead to moderate or low physical dependence or high psych dependence
CIV
low abuse potential compared to CIII
CV
low abuse potential compared to CIV.
Combat Meth Epidemic Act 2005
CMEA put restriction on daily and monthly purchase of certain OTCs. Required to self certify.
State Board of Pharmacy
License or register those working in pharmacy, dispensing to patients, may posess RX drugs, supply chain entities, responds to complaints
FD&C Act 1938
authorized FDA to demand safety evidence for new drugs, issue standards for food, and conduct factory inspections
Kefauver-Harris Amendments of 1962
mandated efficacy and safety data before a drug could be marketed; established stricter FDA control over drug trials; allowed FDA to regulate prescription drug advertising; established good manufacturing practices by the drug industry; granted FDA greater power to access manufacturer’s records to verify those practices
Clinical Trial Phase 1
20-100 healthy volunteers or people with the disease/condition, Several months, Safety and dosage
PDMA 1987
Ensure drugs safe and effective, avoid unacceptable risk to consumers from
counterfeit misbranded adulterated subpotent or expired drugs. added restrictions on sale of RX and samples. Required wholesalers be registered in the state meet uniform standards
DCSCA
Title II of Drug Quality and Security Act 2013 Further protects patients from counterfit, stolen, contaminated or otherwise harmful drugs. Requires interoperable package level tracing. required FDA to establish national licensure standards for wholesalers and 3PL reporting requirements
Track and Trace Exemption
Veterinary drug products; Blood or blood components intended for transfusion; Radioactive drugs or radioactive biological products; Imaging drugs; Intravenous products intended for the replenishment of fluids and electrolytes (such as sodium, chloride, and potassium) or calories (such as dextrose and amino acids); Intravenous products used to maintain the equilibrium of water and minerals in the body, such as dialysis solutions; Products intended for irrigation, or sterile water, whether intended for such purposes or for injection; Any medical gas; Homeopathic drugs; Active pharmaceutical ingredients (APIs) used in compounding; Preparations compounded by a 503A Compounding Pharmacy or a 503B Outsourcing Facility
Active Pharmacutical Ingredient Repaker
API Repacker takes bulk powder APIs from the original manufacturer and packages it into smaller containers to distribute to drug manufacturers, outsourcing facilities, and compounding pharmacies.
Reverse Distributor
unsaleable products from dispensers such as damaged products or expired products.
A reverse distributor does not sell or distribute products to wholesale drug distributors or dispensers. The reverse distributor may obtain credit for unsaleable products from the manufacturer and destroy the unsaleable products or send unsaleable products for destruction.
503A Compounder
preparations for patient-specific prescriptions and is not allowed to compound commercially available products unless there is a clinically significant difference required.
503B Outsourcing Facility
compounds preparations for office use. An outsourcing facility may NOT compound any commercially available product unless the product is documented as being in short supply. This is to alleviate shortages. An outsourcing facility must compound at least one sterile product but is allowed to compound both sterile and nonsterile products. The outsourcing facility must comply with CGMP
Compounding Quality Act
CQA Title I of the Drug Quality and Security Act (DQSA) of 2013. The CQA separates out compounding for patient-specific prescriptions from compounding for office use or administration.
current Good Manufacturing Practices
a standard required of manufacturers and much more stringent than USP sterile and nonsterile compounding standards.
Transaction Data
T3 Transaction Information, History, Statements
Transaction Information
Product name, strength, dosage form, NDC number, container size, number of containers, lot number, transaction date, shipment date (if >24 hours after the transaction date), business name and address of the original and new owner
Transaction History
Statement including the transaction information for each prior transaction which can be traced back to the manufacturer
Transaction Statement
States that the entity transferring ownership received the product, received transaction information and a transaction statement from the product’s prior owner, did not knowingly ship a suspect or illegitimate product, had systems and processes in place to comply with verification requirements, and did not knowingly provide false transaction information or alter transaction history
Exemptions from Transaction Data
Intracompany distribution of products; Distribution of products among healthcare entities under common control; Distribution of products for emergency medical reasons or public health emergencies (does not include drug shortages); eDispensing a product to a patient; Distribution of product samples; Distribution of minimal quantities of product from a pharmacy to a practitioner for office use. “Minimal” is interpreted as less than or equal to 5% and may not be allowed by a state board of pharmacy. Pharmacies distributing larger quantities may also require licensure as a wholesaler and then transaction data requirements will apply.; Certain charitable organizations; Sale or merger of trading partners for the actual transfer of product ownership (transaction data received for those products originally must still be kept); Certain kits or devices that may include products
Clinical Trial Phase 2
Up to several hundred people with the disease/condition, Several months to 2 years, Efficacy and adverse effects
Clinical Trial Phse 3
300-3,000 volunteers with the disease/condition, 1-4 years, Efficacy and monitoring of adverse effects
Clinical Trial Phase 4
Several thousand volunteers with the disease/condition, Post Marketing, Safety and efficacy
New Drug Application
If early tests and preclinical and clinical research indicate that a drug is safe and effective for its intended use, This is filed with results from pre-clinical and Phase 1-3 clinical trials, Mist include: proposed labeling, safety updates, drug abuse information, patent information, any data from studies conducted outside the U.S., Institutional Review Board, compliance information, directions for use
abbreviated new drug application
ANDA contains data which is submitted to FDA for the review and potential approval of a generic drug product. generally not required to include preclinical (animal) and clinical (human) data to establish safety and effectiveness. Instead, generic applicants must scientifically demonstrate that their product performs in the same manner as the innovator drug . To be approved, must demonstrate bioequivalence.
Medical Product Safety Network
(MedSun) monitors medical device safety and effectiveness. requires hospitals, nursing homes, and outpatient treatment and diagnostic centers to report medical device problems that result in serious illness, injury, or death. Once an individual reports a problem, MedSun researchers work with each facility’s representatives to clarify and understand the problem. Each month, FDA publishes the MedSun newsletter to share information about medical device safety so clinicians can take preventive actions
FDA Adverse Event Reporting System
(FAERS) is a database that contains adverse event reports, medication error reports, and product quality complaints resulting in adverse events that were submitted to the FDA. The database is designed to support the FDA’s post-marketing safety surveillance program for drug products. Based on an evaluation of the potential safety concern, the FDA may take regulatory action(s) to improve product safety (e.g., updating labeling information, restricting the use of a drug, communicating new safety information to the public, removing a product from the market). Health care professionals and consumers can submit electronic reports on a voluntarily basis, while manufacturers are required to report to FAERS
Sentinel Initiative
launched in 2008, FDA is developing a new national system to identify possible safety issues more quickly. The system uses large existing electronic health databases (e.g., electronic health records, insurance claims databases) to monitor the safety of approved medical products in real time. will add to, not replace, FDA’s existing post-market safety assessment tools.
MedWatch
medical product safety and adverse event reporting program to promote public safety.
publishes safety alerts for FDA-regulated products including OTC and prescription medications, biologics, combination products, medical devices, nutritional products, cosmetics, and food. website allows reports for serious adverse events, product quality problems, product use/medication errors, or therapeutic inequivalence/failures. Manufacturers are mandated to report adverse events through MedWatch; reporting by consumers, patients, and health care professionals is voluntary but strongly encouraged by FDA. Individuals can file reports online or by mail
Controlled Substances Act of 1970
CSA bring those involved in the illegal growing, manufacturing, or distribution of controlled substances to the criminal and civil justice systems. DEA also recommends and supports programs aimed at reducing the availability of illicit controlled substances on the domestic and international markets
Form 224
To register with DEA
Form 223
Certificate of Registration
Form 224A
Used to renew reg with DEA q 3 years
renewal notifications via email to registrants approximately 60 calendar days prior to their registration expiration date.
Form 224b
Same as 224a but for chains
Resource Conservation and Recovery Act in 1976
address increasing problems the nation faced from the growing volume of municipal and industrial waste
EPA
authority to control the generation, transportation, treatment, storage, and disposal of hazardous waste by imposing strict standards through tracking and permitting. EPA authorizes states to operate their own hazardous waste programs when those programs are at least equal to and consistent with federal standards.
Procedures for Non-Creditable Hazardous Waste
waste that is sent to a facility for incineration instead of a reverse distributor
place its hazardous waste pharmaceuticals in containers that are structurally sound, compatible with the contents, and prevent any leaks or spills.
If incompatible hazardous waste pharmaceuticals are commingled in a container, must manage the container so it doesn’t: have the potential to generate dangerous heat and/or pressure; emit any toxic or flammable substances; damage the container’s structural integrity; otherwise endanger human health and/or the environment
must be protected from unauthorized access and marked with the phrase “Hazardous Waste Pharmaceuticals.”
must ship hazardous waste to a designated facility via a hazardous waste transporter. EPA and DOT require all shipments accompanied by a manifest form.
Hazardous Waste Manifest form
form is designed to track hazardous waste from the time it leaves the health care facility until it reaches the off-site waste management facility where it will be disposed of.
If signed copy of the shipping document from the owner of the facility within 60 days, must notify EPA. must provide a copy of the manifest along with an explanation of efforts taken to locate the hazardous waste and the results of those efforts.
must keep a copy of the signed shipping document for 3 years when hazardous waste is removed from the premises.
Procedures for Creditable Hazardous Waste
waste that is unopened, undispensed, and unexpired or within 1 year of expiration and has a reasonable expectation of receiving manufacturer credit
EPA does not impose specific standards for how containers of creditable waste must be managed or labeled because they are in the original manufacturer packaging which is already labeled.
EPA believes that the risk of environmental release of creditable hazardous waste pharmaceuticals during transport is relatively low because of the form and packaging
Country of Manufacture
FDA, the country where the final formulation of a drug occurs, including where it is packaged, is the drug’s country of manufacture
Country of Origin
CBP, the country in which the active pharmaceutical ingredient is made is the country of origin
FDCA
Requires only that a manufacturer’s drug label bear the name of the manufacturer and any address associated with the company
The address does not have to be where the drug was made (eg, the address can be a manufacturer’s corporate headquarters instead of the country of the factory where the drug was made)
Tariff Act
Requires imported products to be labeled with the country of manufacture
A drug manufacturer cannot list a US address alone without including the country of manufacture for a drug with a foreign made active pharmaceutical ingredient
A drug labeled solely with a US address would be considered, by the FDA and the CBP, to be manufactured domestically
FTC Act
Stipulated it was illegal to market a product with the phrase “Made in the USA,” unless “all or virtually all” the contents of the product are domestically manufactured
A drug with a domestically manufactured active pharmaceutical ingredient, labeled only with a US address, cannot make the claim “Made in the USA’’ if any of its inactive ingredients are imported
Trade Agreement Act
TAA limits the US Government procurement to domestic products or products made in designated countries. Such products are called TAA compliant. Examples of designated countries that are not TAA approved are China, India, Indonesia, Iran, Iraq, Malaysia, Pakistan, and Russia
Red Flags
Purchasing from a source new to the trading partner
Receiving unsolicited sales offers from an unknown source (eg, receiving emails, telephone calls, or in-person sales calls from an unsolicited source)
An internet purchase from an unknown source that offers a product their usual source cannot provide or a better price
Purchasing from a source that a trading partner knows or has reason to believe has engaged in questionable business practices that could increase the risk of suspect product entering the supply chain, such as:
Previous business transactions where the trading partner sold or delivered illegitimate product
A trading partner with a history of problematic or potentially false transaction histories (eg, contains misspelled words or is incomplete)
A trading partner that is reluctant to provide a transaction history or does not do so in a timely manner
A trading partner that provides transaction information, a transaction statement, and/or transaction history that appears to be incomplete or questionable
Product that is generally in high demand in the US market
Product that is in higher demand because of its potential or perceived relationship to a public health or other emergency (eg, antiviral drugs)
Product that has a high sales volume or price
Product offered at a price that is “too good to be true”
Product that has been previously or is currently being counterfeited or diverted (eg, HIV, antipsychotic, or cancer drugs)
Product that has been previously or is currently the subject of a drug shortage (current and resolved drug shortages can be accessed at https://www.accessdata.fda.gov/scripts/drugshortages/default.cfm)
Product that has been or is the subject of a public alert or announcement related to drug quality
Product that has been or is the subject of an FDA counterfeit or cargo theft
Drug Diversion
act of changing the intended course of a drug: at some point in the supply chain, it is passed along into the wrong hands.
Authenticating Trading Partners
check directly with the state licensing agency in the state in which the wholesaler is located, AND the pharmacy’s state (the state they are shipping into),
Check if license is current.
Specialty or biologic check manufacturer for authorized distributor
Drug Counterfeiting
act of selling a product that has packaging for one drug but contains a different drug, OTC product, or placebo.