Transparency Key to Curbing Prescription Drug Diversion, Abuse, NACDS Tells House Panel



Arlington, Va, April 7, 2014 — Urging transparency in how federal agencies conduct enforcement activities to help curb prescription drug diversion and abuse, NACDS submitted a written statement in lead-up to today’s hearing of the U.S. House Committee on Energy and Commerce Subcommittee on Health, titled “Improving Predictability and Transparency in DEA and FDA Regulation.” The Association also emphasized the need for government agencies to work together to address this growing challenge, while ensuring that legitimate patient access to prescription drugs will not be harmed.

“Pharmacists are front-line healthcare providers and are one of the most accessible members of a healthcare team,” NACDS wrote in its statement.

In its statement, NACDS emphasized chain pharmacy’s commitment to partnering with federal and state agencies, law enforcement, policymakers and other stakeholders to work on viable strategies to prevent prescription drug diversion and abuse. The statement also cited pharmacy’s continuous support of the mission and efforts of the Drug Enforcement Administration (DEA) and the Food and Drug Administration (FDA).

But NACDS also cited concerns with inconsistency and lack of transparency in DEA’s inspection processes.

“To help address the problems of DEA opaqueness and inconsistency, we support efforts to promote accountability and transparency with respect to DEA’s inspection and enforcement programs,” NACDS wrote in its statement.

NACDS urges specific actions to rectify transparency concerns, including development of an inspection manual and compliance guidelines, improving accountability and consistency among field offices and public disclosure of inspections.

“We believe these recommendations would greatly increase predictability and transparency in DEA regulation. The adoption of such recommendations would greatly enhance the compliance efforts of DEA registrants, thus leading to more effective DEA regulation and oversight,” NACDS wrote in its statement.

Pharmacists are required “to take on diverse and sometimes conflicting roles,” NACDS wrote in its statement. “On the one hand, pharmacists have a strong ethical duty to serve the medical needs of their patients in providing neighborhood care. On the other hand, community pharmacists are also required to be evaluators of the legitimate medical use of controlled substances.”

In its statement, NACDS also recognized existing programs that are useful and enhancements can further help in combatting prescription drug abuse, such as electronic prescribing, prescription monitoring programs, and law enforcement-authorized programs for return and disposal of unwanted prescription drugs.

Today’s hearing also examined the Ensuring Patient Access and Effective Drug Enforcement Act of 2013 (H.R.4069), which NACDS has previously supported, citing the bill’s importance in establishing a collaborative effort with government and private sector experts to help curb prescription drug abuse and safeguard patients.

“We believe that bringing together stakeholders to address the problems associated with prescription drug abuse in this manner would provide better solutions than have been developed to date. Improved collaboration and coordination among federal agencies and other stakeholders would benefit all, including the patient, whose legitimate access to medication must be preserved in order for any potential solution to be successful,”

NACDS wrote in its statement. NACDS expressed appreciation for the panel’s attention to the problems of prescription drug diversion and abuse and safeguarding legitimate patient access to much-needed medications.

“We look forward to working with policy makers and stakeholders on these important issues,” NACDS concluded in its statement.

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