Washington State Pharmacy Association


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Pharmacy Fulfillment for Consumer - Focused Telehealth Platforms

Published by Alliance for Pharmacy Compounding
and Washington State Pharmacy Association





Summary

Many compounding pharmacies have been tapped to provide “fulfillment” for certain digital, consumer-focused telehealth platforms that have emerged (e.g., GetRomans, Hims/Hers, etc.). Under those business models, the companies are currently looking to independent pharmacies to providing the prescription filling and dispensing, and are compensated on a cash basis, generally direct from the patients/consumers themselves. We further understand that many of these pharmacies, particularly for men’s health-related products, are compounding the products that are being dispensed to patients. While these models present great opportunity and simplicity, particularly given that they do not involve billing insurance, they are not without legal issues. 

These include:

1. The current Memorandum of Understanding (MOU) regarding inordinate distribution interstate and the impact on these models

2. The various Boards of Pharmacy’s positions on the MOU (i.e., will they engage in enforcement over inordinate distribution?)

3. The prohibition on compounding inordinate amounts of essential copies of FDA approved drugs

4. Various state telemedicine requirements

5. State fee splitting rules

6. “Do Not Compound” Lists and enforcement by FDA and/or the Boards of Pharmacy

Learning Objectives for Pharmacists: 

1. Understand the current landscape regarding digital, consumer-focused telehealth platforms that are utilizing compounding pharmacies for medication fulfillment, including the laws and regulations applicable to compounding pharmacies.
2. Understand the impact Federal laws, regulations and enforcement priorities will have on compounding pharmacies participating in such models, including the current Memorandum of Understanding (MOU) regarding inordinate distribution interstate and prohibitions on compounding inordinate amounts of essential copies of FDA approved drugs.
3. Determine the various Boards of Pharmacy’s positions on these arrangements, including the MOU, other FDA requirements, fee-splitting, and third-party delivery.
4. Explain various states' telemedicine requirements and the minimum requirements to allow for prescriptions to be written.

Accreditation Information:
This lesson is a knowledge-based CE activity and is targeted to pharmacists and technicians.


ACPE logoThe American Society of Health-System Pharmacists and UNC Eshelman School of Pharmacy are accredited by the Accreditation Council for Pharmacy Education as providers of continuing pharmacy education. This program is approved for 1.0 contact hours (0.1 CEUs) of continuing education credit for pharmacists and technicians. UAN #: 0046-9999-21-073-L04-P/T.

If you are interested in earning credit for this program, please note that you will be asked to enter your NABP e-Profile ID during the credit selection step of the registration process. If you have not yet registered your NABP e-Profile ID, please visit www.nabp.net.

CE credit and certificates of attendance will be provided only to those individuals who registered and logged into the webinar online. If you want CE credit and your certificate of attendance, you must have purchased the program and logged into the web portion under that registration so that we can verify attendance.


Presenters
Jesse C. Dresser, Esq.
Partner - Life Sciences Department - Frier Levitt

Jesse C. Dresser, Esq. is a Partner in Frier Levitt’s Life Sciences Department and heads the firm’s Pharmacy Practice Group.... Read More


How To Attend
Join the live program from your office, home, or hotel room using a computer with high speed internet. You may ask questions, participate in surveys, and post comments from your computer during the program. Please note that credit (if available) is only provided to registered attendees participating at their own computer and phone. Simple instructions with a link to the program will be sent when you register and again the day before the webinar.

Credit
If applicable, you may obtain credit in multiple jurisdictions simultaneously for this program (see pending/approved list below). Registrants in jurisdictions not listed below will receive a Certificate of Attendance/Completion that may or may not meet credit requirements in other jurisdictions. Where applicable, credit will be only awarded to a paid registrant attending the live program at their own computer and phone.

 Click on jurisdiction for specific details  


Refund Policy
SeminarWeb and Washington State Pharmacy Association programs are non-refundable.

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Washington State Pharmacy Association