…cont’d

Pharmacists
Pharmacists can have a similar influence by ensuring that prescriptions are filled accurately and appropriately in terms of the quantity and frequency of the drugs dispensed. If a pharmacist feels that a drug is being over-prescribed to a patient, they should verify the prescription with the physician and, if they are still unsatisfied, file a report with the regulatory college, ministry of health, or the drug benefit provider.

Like physicians, the Canadian pharmacy profession is also demonstrating a commitment to dealing with this issue. Both the Ontario Pharmacy Association (OPA) and Ontario College of Pharmacists have joined CPSO on the multidisciplinary Narcotics Advisory Board. This type of collaborative approach is key to producing successful results. The CAIF report indicates that the pharmacy profession can increase the positive impact they have on this issue if they:

• “increase the abuse-and diversion-related training in pharmacy education curricula and continuing professional education;
• exert closer point-of-sale scrutiny of certain prescriptions and patients;
• consider developing protocols in conjunction with PBMs and other prescription payers; and
• support strong licensing sanctions and other penalties against pharmacists guilty of drug diversion.

Manufacturers
Drug manufacturers have a responsibility to take whatever steps they can to limit any possible harm caused by their products. To this end, the CAIF suggests they should voluntarily:

• acknowledge and educate all concerned about their products’ potential for abuse;
• provide intelligence to authorities when their purchase data reveal potential diversion; and
• comply with the letter and spirit of the law requiring prudent restraint with their products’ off-label uses.

Government
At a higher level, government has an obligation to ensure that the necessary legislative controls are in place. Canada falls behind other countries in its legislative controls and, where controls exist, in the execution of those controls. For example, New York State requires that “all written prescriptions in the state be written on state-supplied forms specially designed with unique identifier numbers and other features to help prevent fraud and identify doctor shopping.”

In B.C., there is a prescription review program that has been quite successful in combating double-doctoring. This program permits the B.C. College of Physicians and Surgeons access to a subset of the PharmaNet database giving accurate, next-day information on all controlled substances prescribed in B.C. This allows the College to perform periodic reviews for specific drugs of potential risk for abuse, misuse, or diversion and to share the results with the College’s Prescription Review Committee who may then direct a review of particular prescribing patterns of concern.

The College also calls on lawmakers to “swiftly and decisively penalize the small fraction of prescribers and dispensers who facilitate drug diversion and abuse. These actions illegally enrich them, and can kill abusers.” Finally, lawmakers must ensure that the necessary social programs are adequately staffed and funded to increase assistance those that are victims of narcotics addiction and abuse.

The need for a collaborative approach is echoed by well-known American drug diversion expert Bill Mahon, former executive director of the CHCAA’s U.S. counterpart, the National Health Care Anti-Fraud Association. “No one party—the medical or pharmacy professions, law enforcement, licensing boards, legislators, prescription payers or the pharmaceutical industry—can address the epidemic alone,” says Mahon. “But each can play a vital role. Equally important, everyone should collaborate”.

CHCAA and its members are committed to tackling this problem on behalf of their clients and plan members. We believe there would be significant benefit in the creation of a joint task force with wider representation from all stakeholder organizations including (but not limited to) those listed above. We invite other stakeholders to join us in the creation of this drug diversion task force that can examine how we can leverage our collective resources to overcome the challenges of this complex problem.

Alistair Forsyth is a senior research analyst with the Canadian Health Care Anti-fraud Association in Toronto.

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