In comments submitted to a House subcommittee, the National Association of Chain Drug Stores called for more transparency in the way federal agencies conduct enforcement activities to help curb prescription drug abuse and diversion.


National Association of Chain Drug Stores, NACDS, prescription drug abuse, prescription drug diversion, House Committee on Energy and Commerce Subcommittee on Health, Improving Predictability and Transparency in DEA and FDA Regulation, Drug Enforcement Administration, Food and Drug Administration, pharmacists, pharmacy industry, nsuring Patient Access and Effective Drug Enforcement Act of 2013, H.R. 4069


































































































































































































































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NACDS: More transparency needed in efforts to curb Rx abuse, diversion

April 8th, 2014

ARLINGTON, Va. – In comments submitted to a House subcommittee, the National Association of Chain Drug Stores called for more transparency in the way federal agencies conduct enforcement activities to help curb prescription drug abuse and diversion.

NACDS said Monday that in its written statement to House Committee on Energy and Commerce Subcommittee on Health, titled "Improving Predictability and Transparency in DEA and FDA Regulation,"  also stressed the need for government agencies to work together to address this issue, while ensuring that legitimate patients won't have their access to prescription drugs impeded.

"Pharmacists are frontline health care providers and are one of the most accessible members of a health care team," NACDS wrote in its statement.

The association also emphasized chain pharmacy's commitment to partnering with federal and state agencies, law enforcement, policymakers and other stakeholders to work on  strategies to prevent prescription drug diversion and abuse. The statement also pointed to the pharmacy industry's steady support of the mission and efforts of the Drug Enforcement Administration and the Food and Drug Administration.

Still, NACDS 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,” the association said in its statement to the subcommittee.

NACDS urged 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," the association stated.

Pharmacists are required "to take on diverse and sometimes conflicting roles," NACDS noted. "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 comments, NACDS also recognized programs that are useful and enhancements that can further help thwart prescription drug abuse, such as electronic prescribing, prescription monitoring programs, and law enforcement-authorized programs for return and disposal of unwanted prescription drugs.

The hearing, too, examined the Ensuring Patient Access and Effective Drug Enforcement Act of 2013 (H.R. 4069), which NACDS has previously supported, citing the legislation'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," NACDS wrote. "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."

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