Arlington, VA – National Association of Chain Drug Stores (NACDS) President and CEO Steven C. Anderson, IOM, CAE, submitted official comments to the President’s Commission on Combating Drug Addiction and the Opioid Crisis, which is chaired by New Jersey Governor Chris Christie. President Donald Trump signed an Executive Order on March 29, 2017, establishing the Commission. The comments reflect NACDS’ long-standing and ongoing commitment to help address prescription drug abuse, addiction and proper access.
Anderson described chain pharmacies’ “zero tolerance for prescription drug diversion” and extensive efforts to prevent it – including regulatory compliance, company-specific measures and collaboration with law enforcement and other authorities. He also noted challenges involved in pharmacists’ ethical duty to serve patients’ medical needs while meeting requirements of the Drug Enforcement Administration (DEA) to evaluate the legitimacy of the use of controlled substances.
“The ongoing opioid abuse problem concerns both legal and illicit substances; that is, prescription opioids as well as heroin and illegal fentanyl analogs. NACDS and the chain pharmacy industry are committed to partnering with law enforcement agencies, policymakers, and others to work on viable strategies to prevent prescription drug diversion and abuse, including prescription opioids. One encouraging statistic is the decrease in the number of opioid prescriptions dispensed annually over the past few years. The number of opioid prescriptions dispensed at retail pharmacies declined almost 15% from 2013-2016 (Xponent, QuintilesIMS, 2017). Chain pharmacies engage daily in activities with the goal of preventing drug diversion and abuse. Since chain pharmacies operate in almost every community in the U.S., we support policies and initiatives to combat the prescription drug abuse problem nationwide. We believe that holistic approaches must be implemented at the federal level. We are pleased that we are helping to solve the opioid abuse problem.
“Pharmacists take their role in helping to ensure safe use of medications very seriously—but they cannot do it alone. We support a collaborative approach to curb prescription drug abuse and preserve patient access to their medically-necessary pain medications. We believe that there are a variety of ways to help curb prescription drug diversion, and chain pharmacies actively work on many initiatives to reduce this problem.”
Anderson also advised the Commission on opportunities to enhance existing strategies to curb opioid abuse, including in the following areas:
- Patient and Provider Education: “NACDS supports prescriber education initiatives. NACDS also supports education efforts targeted at the general public…We have encouraged collaboration among FDA [the Food and Drug Administration]; the Institute of Medicine (IOM), and other agencies and stakeholders to identify further opportunities and develop prescriber education tools for other controlled substances. Additionally, we have encouraged collaboration among ONDCP [the Office of National Drug Control Policy] and state boards of medicine to ensure enhanced training for prescribers on the legitimate use of controlled substances…We have encouraged FDA to expedite implementation of the one-document solution, as doing so could help to ensure that patients who are prescribed controlled substances better understand appropriate use of these medications.”
- Controlled Substance Prescription Drug Monitoring Programs (PDMP): “Unfortunately, there is great variability among state PDMPs…There exist no nationwide standards for the data that these programs collect, maintain, or provide; nor are there any nationwide standards for who may access the data among health care providers such as prescribers and pharmacists, health plans and Medicaid, or law enforcement officials; and there is no nationwide interconnectivity among the programs, which hinders regional surveillance of patients at risk and potential criminals. NACDS supports initiatives to establish a robust, national database with timely, reliable information and a standard set of requirements.”
- Role of Electronic Prescribing: “NACDS is supporting draft federal legislation that would require prescriptions for controlled substances in the Medicare Part D program to be issued electronically. In addition, NACDS recently developed model state legislative language to pursue mandatory electronic prescribing for all prescriptions…We urge that the Administration finalize the DEA interim final rule (IFR) that allows for the electronic prescribing of controlled substances. The current limitations in the IFR serve as barriers to more widespread adoption of electronic prescribing technologies. Finally, we urge CMS to move to the latest version of the National Council for Prescription Drug Programs (NCPDP) SCRIPT Standard so that prescribers and pharmacies may take full advantage of current electronic prescribing technologies.”
- Limiting Initial Fills of Controlled Substance Prescriptions: “Several states have enacted laws or rules to establish limits on the maximum day supply that prescribers can authorize on initial prescriptions for certain controlled substances. A growing number of states are considering legislation that would enact similar limits… Notably, there is variation across states with respect to the scope of these policies, especially concerning the pending legislative proposals…NACDS advocates for standardized policies that ease implementation challenges so that patient care is not adversely impacted. We believe that the Commission could serve as a forum to assist states with implementing standardized policies.”
- Promoting Access to Naloxone: “Pharmacists and pharmacies are primed to work in conjunction with other healthcare providers to increase access to naloxone for overdose prevention purposes…A number of states have employed various approaches to make it easier for pharmacists to provide naloxone to patients…Chain pharmacy supports state laws and policies…that eliminate administrative barriers to pharmacist-provided naloxone by authorizing pharmacists to provide naloxone without patient-specific prescriptions…Additionally, we support liability protections for all healthcare providers, including pharmacists, who prescribe and dispense naloxone in good faith.”
- Take-back and Disposal of Consumers’ Unused Medications: “NACDS supports the safe and effective disposal of unwanted consumer medications, including controlled substances, to stem the abuse of such drugs and to better protect the environment…We believe that policymakers who have decided to tackle the drug disposal issue should ensure that pharmacies are able to create programs that best serve the needs of their patients, as well as workable solutions for their store locations. Overall, patients should have a wide variety of options for how they can dispose of their unused medications. With more options, we can expect to have higher patient participation in prescription drug disposal programs…When policymakers consider proposals for drug disposal, we ask that they consider retail pharmacies’ support for broad drug disposal programs that allow pharmacies to facilitate at least one of a variety of DEA authorized options for drug disposal…Retail pharmacies support consumer education programs on drug disposal developed and funded by the government and/or pharmaceutical manufacturers…Ideally, such materials would focus on the dangers of misuse and the potential for addiction to prescription controlled substances, treatment resources available, and the proper way to dispose of unused prescription controlled substances…Finally, any legislative package adopting the policy proposals outlined above should also include a preemption provision. NACDS encourages the Commission to work with DEA to promote continued periodic take-back events hosted by DEA. We also encourage the Commission to pursue patient education programs as outlined above.”
- Collaborative Legislative Solutions: “NACDS and our members are focusing our energies on real, workable solutions that will address the problem of prescription drug abuse while also ensuring that legitimate patients are able to receive their prescription pain medications. In line with this goal, we supported the recently enacted “Ensuring Patient Access and Effective Drug Enforcement Act” (P.L. 114-145). This legislation requires HHS [Department of Health and Human Services] to submit a report to Congress that identifies obstacles to legitimate patient access to controlled substances and outlines how collaboration among federal and state agencies and industry can benefit patients and prevent diversion and abuse of controlled substances…The report must be submitted to Congress no later than one year after the date of enactment. HHS has not met the one-year deadline for submitting this report to Congress.”
- Target Illegitimate Internet Drug Sellers: “NACDS believes that an important strategy to stop drug diversion and abuse is addressing the problem of illegitimate internet drug sellers. These illicit online drug sellers have websites that target U.S. consumers with ads to sell drugs often without any prescription required. They operate in clear violation of U.S. state and federal laws and regulations that protect public health and safety. They sell drugs to consumers without the safety precautions of a legitimate prescriber-patient relationship, a valid prescription, or a licensed U.S. pharmacy. We support targeting illegal internet drug sellers by enabling entities, such as domain name registrars that issue websites, financial entities that handle payment transactions, internet service providers that show the illegitimate websites on the internet, and common carriers that provide the mailing services, to stop illicit transactions at their point of interaction with these bad actors. NACDS serves on the Board of Directors of the Alliance for Safe Online Pharmacies (ASOP) to support their work to shut down illegal internet drug sellers.”
- Shutting Down Rogue Pain Clinics: “As the number of domestic-based rogue internet pharmacies has declined, there has been an increase in the number of rogue pain clinics. According to DEA, the practitioners in these clinics are responsible for the dispensing of millions of dosage units of oxycodone, a schedule II narcotic. NACDS supports the efforts of states that have enacted legislation to shut down these rogue clinics, such as the restriction of physicians’ ability to dispense oxycodone from pain clinics.”
Anderson’s complete comments include enhanced details related to each existing strategy and to each recommendation to the Commission.