The voice for pharmacy compounding │ 27 October 2023

 

This edition is sponsored by PCAB

The Pharmacy Compounding Accreditation Board offers the most comprehensive compliance solution in the industry, with standards based on U.S. Pharmacopeia requirements. Achieving PCAB Accreditation demonstrates your commitment to meeting the highest industry standards for quality and safety. Learn more here.

 

From our CEO

 

A righteous rant

When it comes to tutoring reporters about pharmacy compounding in the media, I feel sometimes like I’m in one of those old Tom & Jerry cartoons in which the mouse tries to persuade the cat that as dinner goes, mouse is just not all that tasty.

 

Reporters are almost never persuaded, and in real life the mouse is almost always roasted. Why do reporters rely so unquestioningly on FDA’s statements about the risks of compounding (with no recognition of nuance, much less that there are rewards) or on the attestations of “experts” who neither prescribe nor have expertise in compounded medications?

 

Think about the last time you saw a media report on compounding in which the reporter interviewed and quoted a prescriber of compounded medications along with the non-prescriber opponents. I’ll wait.

 

…

By the standards of “good journalism”, the lack of balance, the lack of interest in even talking with pro-compounding prescribers or pharmacists, is appalling.

 

You’re thinking: “This ain’t a new problem. What set you off?”

 

Well, I’ll tell you. It was this sentence in a health.com piece this week on FDA’s recent warning about compounded ketamine nasal spray:

 

The drug [Spravato] is the only FDA-approved ketamine-based nasal spray, but compounding pharmacies are creating their own, unregulated versions of ketamine nasal spray and selling them to people who can use them without the requirement of going to an approved healthcare provider.

 

Unregulated? Seriously?

 

A licensed prescriber — almost certainly one with expertise in treating psychological disorders – makes the judgment that an FDA-approved therapy is not right for his or her patient — perhaps after the patient has been through the litany of FDA-approved therapies already — and so he or she writes a prescription for compounded ketamine – there’s obviously some research suggesting it may help the patient when nothing else has, even though it’s off-label — and sends it to a licensed pharmacy where a licensed pharmacist with expertise in prescription drugs collaborates on dosing, and then operating within state and federal law and rigid USP standards, dispenses the medication to the patient with the understanding that the physician-patient relationship is such that monitoring of administration of the drug and follow-up is being provided by that physician.

 

What is unregulated about any of that?!

 

Pardon the rant. It’s just the final straw in a year in which I’ve seen otherwise intelligent reporters refer to compounded medications as “knock-offs” or “concoctions” or worse; or lump compounding in with sketchy non-pharmacy direct-to-consumer providers of research-grade API; or simply swallow what opponents of compounding tell them without bothering to dig a little – you know, just in case there may be another side to the story.

 

The point is, words matter. Precision matters. Compounded drugs are not knock-offs. Compounded drugs are not unregulated. Far from it. But you wouldn’t know that from what you read in the news.

 

As with Tom and Jerry, the mouse never gets a fair shake, does he?


—Scott


Scott Brunner, CAE is APC’s ranter-in-chief. Contact him at scott@a4pc.org.

 

ICYMI

 

This week’s news

 

APC requests transparency on new Cat 2 substances

In a letter this week to Gail Bormel, director of FDA’s Office of Compounding Quality and Compliance, APC called for transparency regarding the recent addition of substances to Category 2.


APC wants clarification on the process behind the FDA’s decision to include new substances in Category 2. The agency had cited “significant safety risks” as the basis for this categorization, but has not disclosed the methodology or, more importantly, specifics about the identified risks.


“More detail about FDA’s substance-specific safety concerns can assist APC and other groups in educating pharmacists, technicians, and other stakeholders about why the substances were added to Category 2 and the risks the agency sees as inherent in compounding with them,” the letter states.

 

Mark your calendar (doggone it!)

2024 is coming fast, and before you know, your calendar will fill up. That’s what we’re telling you now to mark your calendar and hold the dates for a couple of important APC events in 2024.


Here they are:

APC’s Compounding Pharmacy Owner Summit, April 4–6, La Jolla, CA ⤵

 

EduCon Virtual: The Ethical Compounding Conference, June 20–21


Compounders on Capitol Hill (CCH), September 17–18, Washington, DC

Medisca is APC’s first $100k Patron

Pharma Source Direct bumps up its support for 2024, too

Long-time APC supporter Medisca has notified APC that it will increase its support for the organization in 2024, becoming our first $100,000 Diamond-level corporate patron.

“We treasure our relationship with the Medisca folks and are grateful for this increased support,” said APC’s Scott Brunner. “We take it as a strong vote of confidence in the work we’re doing to elevate pharmacy compounding and protect patient access to compounded medications. A lot of that work is supported not just by funding but also by expertise Medisca’s team provides us.”

 

2024 is the first year in which APC has offered a Diamond-level Corporate Patron package.

In addition to Medisca’s commitment, Pharma Source Direct has indicated it will increase its support for APC in 2024 from a Bronze-level $10,000 sponsorship to at $25,000 Silver-level sponsorship.


“We appreciate Matt Johnson and his team at Pharma Source Direct,” said Brunner. “They’ve done a super job sharing our news and social media posts so that more compounders see and know what we’re doing for their profession.”

 
 

Short takes

 

APC (and many of its members) in Houston. APC’s Jen Petska and Scott Brunner are staffing a booth at PCCA’s International Seminar this week, meeting with members and arm-twisting prospective members. Shown here, APCs Jen Petska, second from left, caught up with APC members Jen Burch, Sue Horton, and Angie Svoboda on Wednesday evening.

CCH 2023 presenter featured in NPR story. Angels for Change founder Laura Bray, who was featured at Compounders on Capitol Hill last month, was featured in an NPR story this past week for the work she’s done in confronting pediatric chemotherapy drug shortages.


APhA, ASHP, NABP unveil strategies to bolster pharmacy workforce.A new report includes recommended solutions to improve pharmacy workplace conditions. Workplace problems are leading to high stress levels and occupational burnout across various pharmacy practice settings, the report says.

 

Save these dates

 

October 26–28: PCCA's International Seminar 2023 in Houston.

November 2: OutcomeMD Express Lunch & Learn for existing users. Free but registration is required.

November 9: An APC webinar, Automation and USP 797 Don't Mix

November 10: PCF Pharmacy Technician Education Grant deadline.

December 12: An APC webinar, Quality assurance programs for compounding pharmacies: A medication safety survival guide for the compounding pharmacy. Registration coming soon.

December 14–16: A4M Longevity Fest 2023 in Las Vegas


2024

January 28: An APC webinar, Survey of State Compounding Law Changes 2024. More details coming soon.

April 4–6: Owner Summit, La Jolla, CA

June 20–21: EduCon Virtual: The Ethical Compounding Conference

September 17–18: Compounders on Capitol Hill (CCH) in Washington, DC


On demand


Now available: The FDA Compounding Quality Center of Excellence is announcing the availability of these self-guided, online courses:

 

Quick links

 

APC Career Center

• Job seekers

• Employers


APC's Code of Ethics


Compounding Connections archive


Compounders on Capitol Hill


Continuing education

• Live webinars

• On-demand webinars


Current issues:

• GFI #256 on animal compounding

• Urgent-use compounding (HR 167)

• Adverse events reporting framework 

• Saving compounded hormones


EduCon


Owner Summit


Prescriber Briefing Resources


Invest in APC efforts

• CompPAC

• Campaign to save cBHT

• OneFund


Membership

• Renew

• Pharmacy/Facility Membership (PFM)

• APC Logo agreement for PFMs

• APC Logo agreement for individual members


Affinity service providers

• Accounting & Tax Services: Rx Advisors

• Audible Sunshine

• Office Equipment: TUI Solutions

• Online Payments Platform: HealNow

• Patient-Reported Outcomes: OutcomeMD

• Pharmacy Technician Certification Board

• Shipment Trackers, a shipping costs auditor 

• TUI Total Solutions

• TxtSquad


 
 

Alliance for Pharmacy Compounding | A4PC.org

APC is committed to addressing any concerns or complaints within one business day.

Please send them — and, of course, any compliments — to info@a4pc.org.

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