Learning Objectives 1. Describe addiction with current trends of use - - PDF document

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Learning Objectives 1. Describe addiction with current trends of use - - PDF document

Harm Reduction Strategies: The Humane Approach to Addictive Disorders Donna M. White RN, PhD, CS, CADAC Addiction Specialist, Lemuel Shattuck Hospital; Clinical faculty, MGH Institute of Health Professions and University of


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Harm Reduction Strategies: The Humane Approach to Addictive Disorders

Donna M. White RN, PhD, CS, CADAC

Addiction Specialist, Lemuel Shattuck Hospital; Clinical faculty, MGH Institute of Health Professions and University of Massachusetts/Boston Fellow-American Academy of Experts in Traumatic Stress Fellow – International Nurses Society on Addictions

Learning Objectives

  • 1. Describe addiction with current trends of use and

related terminology that are applicable to all professionals in healthcare.

  • 2. Describe harm reduction techniques to utilize when

working with clients, families, and community services.

  • 3. Demonstrate use of naloxone administration during
  • verdose of opioid.
  • 4. Discuss strategies for treatment and referral when

dealing with substance abuse problems.

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SLIDE 2

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Resources

  • Hazelden Foundation-Publishing
  • ASPMN -Position Statement in Patients with Addictive

Disease 1-888-342-7766 (www.aspmn.org)

  • Morgan, Betty (2005) “Knowing How to Play the Game”
  • American Society of Addiction Medicine (www.asam.org)
  • www.PainEDU.org
  • www.masspaininitiative.org
  • Harm Reduction Coalition (http://harmreduction.org)
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SLIDE 3
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SLIDE 4

1 2016 DEA Update: Audits, Inspections, and Staying Compliant

Mark Rubbins, Diversion Group Supervisor Drug Enforcement Administration New England Field Division

Learning Objectives

 Recognize current trends of

prescription drug diversion.

 Examine recent civil cases involving

registrants.

 Discuss nationwide prescription drug

take back initiative and disposal options.

 Summarize recent changes to laws and

regulations for controlled substances.

2 3

Diversion of Controlled Substances – You Don’t Need The Stats…

  • We are flooded with pain meds, benzo’s, etc. – which are

contributing to increased demand for heroin

  • Addiction to pain meds is a growing problem and affects

everyone everywhere

  • Cheap, available heroin – for some, the next step after

addiction to pills

  • Opioids are the new targets of regulations, enforcement,

treatment

  • Many of us may know a friend, co‐worker, relative who

was treated for pain – and turned into a user

4 5

2000 -2014: Unintentional drug overdose deaths in the US increased 137%, which was a 200% increase in overdose deaths involving opioids. 500,000 deaths due to prescription overdose 2015: Over 47,000 drug-related overdose deaths 28,647 deaths involved opioids, including heroin 19,000 deaths involved prescription opioid 1 death every 11.16 minutes 46 deaths by end of today’s session (8 hours) 129 deaths every 24 hours

Public Health Epidemic

CDC National Center for Health Statistics/Morbidity and Morality Weekly Report (MMWR); January 1, 2016 U.S. Drug Enforcement Administration Office of Diversion Control

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SLIDE 5

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National Overdose Deaths

Number of Deaths from Benzodiazepines

1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000 9,000 Total Female Male

Source: National Center for Health Statistics, CDC Wonder

National Overdose Deaths

Number of Deaths from Heroin

2,000 4,000 6,000 8,000 10,000 12,000 Total Female Male

U.S. Drug Enforcement Administration Office of Diversion Control

Prescription Opioid Analgesics Poisoning Deaths Prescription Opioid Analgesics Poisoning Deaths

Abuse Facts

 In 2014, 27 million Americans aged 12 or older

were current (past month) users of illicit drugs 1 in 10 Americans

 6.5 million used prescription-type

psychotherapeutic drugs (any pain relievers, tranquilizers, stimulants or sedatives) for non- medical purposes in a one-month period (2011 data – 6.1 million)

 4.3 non-medical users of pain killers  Non medical use of prescription type drugs is

second only to marijuana

12 SOURCE: 2014 National Survey on Drug Use and Health (NSDUH) published September 2014 by the Dept of HHS/ Substance Abuse and Mental Health Services Administration (SAMHSA)

2013 Partnership Attitude Tracking Study

 Troubling data on misuse/abuse of prescription

narcotics and stimulants

 Every day 2,700 teens try a controlled

medication to get high for the first time

 Perception of teens toward this misuse/abuse

very concerning

 Misconception of the dangers of these

substances

 Parental attitudes are contributing to the

problem – major disconnect!!

13

1SOURCE: 2013 PATS, Partnership for a Drug-Free America and MetLife Foundation, published September 2014

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SLIDE 6

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 Many teens mistakenly believe that

pharmaceuticals are safer than “street drugs” for a variety of reasons:

 They’re “medicine”  Obtained from doctors, pharmacies, friends or

family members – non threatening

 It is not necessary to buy them from traditional

“drug dealers” – after all, they came from a doctor, right?

14

1SOURCE: 2012 Parents and Teens Attitude Tracking Study Report, Partnership for a Drug-Free America and MetLife

Foundation, published July 22, 2014

2013 Partnership Attitude Tracking Study

 Problematic, cavalier attitude regarding

misuse/abuse of Rx drugs

 One in eight teens (about 2.7 million) reports

having abused or misused the stimulants Ritalin

  • r Adderall

 31% of teens believe that prescription

stimulants can be used as an effective study aid

15

1SOURCE: 2013 Parents and Teens Attitude Tracking Study Report, Partnership for a Drug-Free America and MetLife

Foundation, published July 22, 2014

2013 Partnership Attitude Tracking Study

 73% of teens say its easy to access Rx drugs

from their parents’ medicine cabinet

 38% of teens who have misused Rx drugs

  • btained them from parents’ medicine cabinet

 23% said parents would not care as much if

they were caught abusing Rx meds as compared to illicit drugs

16

1SOURCE: 2013 Parents and Teens Attitude Tracking Study Report, Partnership for a Drug-Free America and MetLife

Foundation, published July 22, 2014

2013 Partnership Attitude Tracking Study

The ‘OXY’ SUBCULTURE

Pain Clinic “Clients”

19

“No Florida Id Required” WHY? At least they also offer Detox too!

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SLIDE 7

4 Pharmacist’s Corresponding Responsibility

  • CFR §1306.04.(a) “ … a corresponding

responsibility rests with the pharmacist who fills the prescription. An order purporting to be a prescription issued not in the usual course pf professional treatment….is not a prescription within the meaning and intent of section 309 of the Act, and the person knowingly filling such a purported prescription, as well as the person issuing it, shall be subject to the penalties provided for violations of the provisions of law relating to controlled substances.”

Corresponding Responsibility by Pharmacist

The responsibility for the proper prescribing and dispensing of controlled substances is upon the prescribing practitioner, but a corresponding responsibility rests with the pharmacist who fills the prescription.

21 CFR § 1306.04(a)

U.S. Drug Enforcement Administration Office of Diversion Control

Corresponding Responsibility by Pharmacist

  • A pharmacist, by law, has a

corresponding responsibility to ensure that prescriptions are legitimate.

  • When a prescription is presented by

a patient or demanded to be filled for a patient by a doctor’s office, a pharmacist is not obligated to fill the prescription!!!

U.S. Drug Enforcement Administration Office of Diversion Control

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DEA’s Diversion Control Division

Our Mission:

  • Prevent, detect, and investigate the diversion of

controlled substances (pharmaceuticals, listed chemicals) from legitimate channels.

  • Ensure an adequate and uninterrupted supply of

controlled substances required for legitimate medical, commercial, and scientific needs.

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Diversion Control’s Legal Authority

Title 21 Food And Drugs CHAPTER 13 DRUG ABUSE PREVENTION AND CONTROL

  • 21 United States Code (U.S.C.) identifies the scheduling
  • f controlled substances
  • Authorizes DEA to register individuals and companies to

handle controlled substances

  • Specifies criminal, civil, and administrative sanctions

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Diversion Legal Authority (cont’d.)

CONTROLLED SUBSTANCE ACT REGULATIONS Title 21 Code of Federal Regulations

  • Track the flow of controlled substances

– Registration – Recordkeeping – Inventories – Security

Violations of requirements subject DEA registrants to civil monetary penalties and

  • ther sanctions
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DEA Diversion and Diversion Investigators

  • Diversion Investigators ‐ Regulatory and Criminal

Investigations – Scheduled Regulatory Investigations (work plan) – Pre‐Registration Investigations/Registration Modifications – Thefts and Losses – Intelligence Gathering – Drug Complaints (e.g., prescription forgery; illegal prescribing; hospital diversion) – usually with Tactical Diversion Squad, local PD, other agencies

30

Complete and Accurate Records

  • Biennial inventories
  • Receipt, transfer, or distribution requires:

– DEA Form 222 for Schedule I‐II drugs – Invoice for Schedule III‐V drugs

  • Report any theft or significant loss to local DEA

within 1 business day of discovery

  • Registrant shall also submit a DEA Form 106, Report
  • f Theft or Loss of Controlled Substances

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What is a significant loss?

  • 21 CFR § 1301.74(c)

“…When determining whether a loss is significant, a registrant should consider, among

  • thers, the following factors:

1) The actual quantity of controlled substances lost in relation to the type of business; 2) The specific controlled substances lost; 3) Whether the loss of the controlled substances can be associated with access to those controlled substances by specific individuals, or whether the loss can be attributed to unique activities that may take place involving the controlled substances; 4) A pattern of losses over a specific time period, whether the losses appear to be random, and the results of efforts taken to resolve the losses; and, if known, 5) Whether the specific controlled substances are likely candidates for diversion; 6) Local trends and other indicators of the diversion potential of the missing controlled substance.”

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How Important Are Good Records?

  • Civil penalties PER RECORDKEEPING VIOLATION…DOJ raised

from $10,000 to $14,502 effective August 1, 2016 (some go higher = $25,000)

  • Fines can be imposed even if the recordkeeping violation did not

result in diversion of controlled substances

  • A registrant’s good‐faith intent is not enough to prevent

potential penalties if recordkeeping violations exist

  • The rules apply to each DEA registrant (in some cases, even

individuals)

  • Don’t know who did it? Still need to report it
  • Can always file amended DEA 106 if initial numbers change
  • Can notify local DEA office if “missing” drugs are accounted for

32 33

Security Responsibilities

  • §1301.90 Employee screening procedures
  • It is the position of DEA that the obtaining of certain information …is vital to fairly

assess the likelihood of an employee committing a drug security breach. The need to know this information is a matter of business necessity, essential to overall controlled substances security. In this regard, it is believed that conviction of crimes and unauthorized use of controlled substances are activities that are proper subjects for inquiry. It is, therefore, assumed that the following questions will become a part of an employer's comprehensive employee screening program:

  • Question. Within the past five years, have you been convicted of a felony, or within

the past two years, of any misdemeanor or are you presently formally charged with committing a criminal offense? (Do not include any traffic violations, juvenile

  • ffenses or military convictions, except by general court‐martial.) If the answer is

yes, furnish details of conviction, offense, location, date and sentence.

  • Question. In the past three years, have you ever knowingly used any narcotics,

amphetamines or barbiturates, other than those prescribed to you by a physician? If the answer is yes, furnish details.

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Reporting and Discipline Responsibilities

  • 21 CFR § 1301.91 Employee responsibility to report drug

diversion

  • It is the position of DEA that an employee who has knowledge
  • f drug diversion from his employer by a fellow employee has

an obligation to report such information to a responsible security official of the employer…The employer shall inform all employees concerning this policy

  • 21 CFR § 1301.92 Illicit activities by employees
  • It is the position of DEA that employees who possess, sell, use
  • r divert controlled substances will subject themselves not
  • nly to State or Federal prosecution for any illicit activity, but

shall also immediately become the subject of independent action regarding their continued employment…

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We Take It Seriously

  • Tufts Medical Center (2016)

– Recordkeeping violations & ineffective controls : $100,000

  • Mass. General Hospital (2015)

– Recordkeeping violations & ineffective controls : $2.3 million

  • Dignity Health Hospital Group, CA (2014)

– Recordkeeping violations: $1.55 million

  • Jeanes Hospital , PA (2010)

– Recordkeeping violations: $130,000

  • Kino Hospital, AZ (2009)

– Recordkeeping violations: $1 million

  • St. Vincent Hospital of Indianapolis, IN (2007)

– Recordkeeping violations: $2 million

  • St. Joseph Regional Hospital, TX (2006)

– Recordkeeping violations & prescriptions not for legit med purpose : $750,000

35

We Take It Seriously

  • CVS Pharmacy (2016)

3.5 Million for violations involving the failure to perform their corresponding responsibility to ensure the legitimacy of prescriptions they filled

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Prescription Monitoring Programs

  • Utilize your PMP – invaluable tool in helping to

recognize drug seeking individuals

  • Every one of you has been scammed and will

get scammed – but when looking the other way becomes normal business, problems start

  • As with a physician who indiscriminately writes

for CDS, word spreads quickly and you will soon be the most popular pharmacy in town

DRUG ENFORCEMENT ADMINISTRATION | DIVERSION CONTROL PROGRAM

38

How Controlled Substances are Diverted

 Practitioners/Pharmacists

 Illegal distribution  Self abuse  Trading drugs for sex

 Employee pilferage

 Hospitals  Practitioners’ offices  Nursing homes  Retail pharmacies  Manufacturing / distribution

facilities

 Pharmacy/Other Theft

 Armed robbery  Burglary (Night Break-ins)  In Transit Loss (Hijacking)

 Patients

 Individual and organized

drug ring

 Doctor-shopping  Feigning illness  Forged / fraudulent /

altered prescriptions

Registration

  • On-line application much faster than paper

application – one week to get registration certificate vs. four-to-six weeks for paper

  • On-line application is approved same day it

comes to Registration Unit in Boston if all certifications are included and valid

  • Applicant must have a valid MA Medical

License and a valid MA Controlled Substance license before applying for a DEA Registration

Local Registration help MA contact Linda Marnell 617-557-2468 VT, CT, RI, NH ME contact Barbara Menhart 617-557-2200

40 DRUG ENFORCEMENT ADMINISTRATION | DIVERSION CONTROL PROGRAM

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Registration

  • Renewals: Registrant is sent a renewal

reminder letter 60 days prior to expiration. Letter goes to mail to address – if changed address and did not update or notify DEA, you will not receive letter.

  • Registrant is no longer authorized to order,

administer, dispense or store controlled substances.

  • On the expiration date, the registration is
  • fficially retired, and cannot be

reactivated.

Electronic Prescriptions for Controlled Substances (EPCS)

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EPCS

 Venders must have their systems

certified by a third-party entity that it complies with the regulations.

 Practitioners and pharmacies should

request a copy of the certificate.

 DEA Investigators will ask to see the

certificate.

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EPCS

 Fax vs. Electronic Prescription

 True electronic Rxs are transmitted as

electronic data files to the pharmacy, whose application securely import the data file into its database – utilizing 2 factor authentication

 A system that allows the prescriber to

“sign” his/her name does not conform to EPCS regulations (hand held device, tablet)

 A facsimile with a written signature is not

an electronic Rxs.

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EPCS

 More info on the DEA Website

www.DEAdiversion.gov

46

Disposal of Controlled Substances

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Secure and Responsible Drug Disposal Act of 2010

 Public Law 111-273  Enacted on October 12, 2010  This Act amended the Controlled Substances

Act to provide for disposal of controlled substances by certain persons.

 Ultimate Users  Long Term Care Facilities  Survivor of decedent

49

Disposal of Controlled Substances

 Final Rule Published September 9, 2014 in

the Federal Register

 Patients now have expanded options to

safely and responsibly dispose of unused/unwanted medications – through collection receptacles and mail-back packages

 Establishes “Authorized collectors”

Disposal of Controlled Substances

 DEA –registered retail pharmacies,

hospitals/clinics with an on-site pharmacy, narcotic treatment programs, manufacturers, distributors, and reverse distributors may become “authorized collectors”

 May apply to modify their registrations to

reflect this status

 May also conduct mail-back programs

Disposal of Controlled Substances

 Must be registered to handle schedule ll

CDS – all collected substances treated as schedule ll

 Standard of destruction – “non-

retrievable”

  • “cannot be transformed to a physical or

chemical condition or state as a controlled substance or CS analogue.”

Disposal of Controlled Substances

 Authorized retail pharmacies and

hospital/clinics with an on-site pharmacy may also place receptacles at LTCF’s

Disposal of Controlled Substances

 Authorizes Police Departments to

continue and expand current disposal programs

 Gives other entities access to becoming

“collectors” (Manufactureres, Distributors, Reverse Distributors, Pharmacies)

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SLIDE 12

9 Design of Collection Receptacle

  • Securely fastened to a permanent

structure.

  • Securely locked, substantially

constructed container with permanent outer container and removable inner liner.

  • Outer container must have small
  • pening that allows for contents to

be added but does not allow for removal of contents.

  • 21 CFR § 1317.75(e)

Collection Receptacle Location

  • Must be securely placed and maintained:
  • Inside collector’s registered location
  • Inside law enforcement’s physical

location, or

  • Inside an authorized LTCF

Collection Receptacle Location

  • Registered location – immediate proximity of

designated area where controlled substances are stored and at which an employee is present.

  • LTCF – located in secure area regularly monitored by

LTCF employees.

  • Hospital/clinic – located in an area regularly

monitored by employees, not in proximity of where emergency or urgent care is provided.

  • NTP – located in a room that does not contain any
  • ther controlled substances and is securely locked

with controlled access.

  • 21 CFR § 1317.75(d)

Collection Receptacle Inner Liner

  • Waterproof, tamper-evident, and tear-

resistant.

  • Removable and sealable upon removal without

emptying or touching contents.

  • Contents shall not be viewable from the outside

when sealed (i.e., can’t be transparent).

  • Size shall be clearly marked on the outside of

the liner (e.g., 5-gallon, 10-gallon).

  • Outside of liner shall have permanent, unique

ID number.

  • 21 CFR § 1317.60(a)

Access & Handling Sealed Inner Liners

  • Only employees of the collector may access

the inner liners.

  • The inner liner shall be sealed by two

employees immediately upon removal from the permanent outer container.

  • Sealed inner liner shall not be opened, x-

rayed, analyzed, or otherwise penetrated.

  • Practitioners cannot transport collected

controlled substances.

  • 21 CFR §§ 1317.60(b) and (c), 1317.05(c)

Mail-Back Program

  • Requirements of mail-back program
  • Only lawfully possessed schedules II-V

controlled substances may be collected

  • Controlled and non-controlled substances

may be collected together

  • 21 CFR § 1317.70 (b)
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Destruction of Controlled Substances

  • All controlled substances destroyed

by a registrant or caused to be destroyed by a registrant shall be destroyed in compliance with applicable Federal, State, tribal, and local laws and regulations and shall be rendered non-retrievable.

  • 21 CFR § 1317.90

Registrant Disposal Destruction of Sealed Inner Liners

  • Practitioners and Non-Practitioners shall dispose of

sealed inner liners by:

  • Prompt delivery to reverse distributor by common
  • r contract carrier or reverse distributor pick-up
  • Deliver sealed inner liners to a distributor’s

registered location by common or contract carrier

  • r distributor pick-up
  • Freight forwarding facilities may NOT be used
  • 21 CFR § 1317.05(c)(2)(iv) and (v)

12th National Take Back Day

October 22, 2016 (at least every 6 months)

DRUG ENFORCEMENT ADMINISTRATION DIVERSION CONTROL PROGRAM

Take Back Events

  • Take-back events are intended to be

limited-duration events that may take place at an unregistered location that is easily accessible to the public, such as a community center or town center.

  • Law Enforcement may continue to conduct

take-back events.

  • Any person may partner with Law

Enforcement.

  • Law Enforcement shall maintain control

and custody of collected substances until secure transfer, storage, or destruction has occurred.

  • Authorized collection receptacles and

inner liners “should” be used.

  • 21 CFR §§ 1317.35 and 1317.65

12th National Take Back Day: October 22, 2016

24,396 MA 2,534 RI 6,194 CT 24260 ME 3935 VT 8034 NH

Drug Enforcement Administration Diversion Control Program

Questions???? Thank You

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SLIDE 14
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SLIDE 15

1

E xamining Ne w Options in the Manage me nt of Insulin Re sistant T ype 2 Diabe te s: A F

  • c us on Basal Insulin T

he r apy

Jennifer Goldman, PharmD, CDE, BC-ADM, FCCP

Professor of Pharmacy Practice, School of Pharmacy, MCPHS University Clinical Pharmacist, Well Life Medical, Peabody, MA

Learning Objectives

1.

Identify challenges of currently available basal insulin therapy.

2.

Differentiate pharmacokinetic and pharmacodynamics actions of available and emerging basal insulins.

3.

Implement strategies for safely converting between U100 and concentrated insulin formulations in patients with type 2 diabetes.

4.

Discuss strategies for overcoming common barriers to optimal glucose control with basal insulin therapy.

Objective 1

Identify challenges of currently available basal insulin therapy

T2DM

 Characterized by chronic hyperglycemia  Associated with microvascular and

macrovascular complications

 Generally arises from a combination of

insulin resistance and beta cell dysfunction

 Associated with obesity, older age,

decreased physical activity

 Incidence increasing in children/adolescents

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SLIDE 16

2

Pathophysiologic Defects in T2DM The Ominous Octet

Defronzo RA, Diabetes. 2009; 58(4): 773-795

Clinical Inertia

T he ave rage time in months be fore a c hange was made in patie nts with A1C > 8% - Re trospe c tive re vie w > 7000 patie nts

Diabe te s Care 2015;38:140-149; Diabe to lo gia 2015;58:429-442

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SLIDE 17

3

Case example- insulin resistance

Will follow this case for 3 years- demonstrates varied insulins used (U100 glargine, U100 lispro, U500 regular, U100 detemir, U300 glargine, U200 degludec)

Case- U500 11/2013

 Mr. B is a 59 year old male (who retired on 9/9/10) here

today for first Pharmacy visit. He is accompanied by his wife who is instrumental in his care. He was diagnosed with DM in 2001.

 Followed by Cardiology- Cardiomyopathy, CHF, Heart

Mate II LVAD implantation in 2012 , Implantable defibrillator 2010

 Other PMH- HTN, hyperlipidemia, Afib, CRF (eGFR

50ml/min), depression, asthma, obesity, neuropathy

 He was last seen by Endocrinology for T2DM a few months

before where his Lantus (U100 glargine) and Humalog (U100 Lispro) were increased due to high A1C 9.3%.

 His c ur

r e nt r e gime n is U100 glar gine 80 units qam and 80 units qpm and U100 lispr

  • 20- 50 units with me als thr

e e time s a day and at snac ks. T

  • tal daily dose of insulin: ~

300 units

Objective 2

Differentiate pharmacokinetic and pharmacodynamics actions of available and emerging basal insulins. Mimicking Physiology: Basal-Bolus Insulin

Breakfast Lunch Dinner 4:00 8:00 12:00 16:00 20:00 24:00 4:00 8:00 Plasma Insulin Time

Basal

1/day

Prandial SA 3/day

PLUS

Po stgrad Me d. 2003;113(6):30-36

Huma n insulin a nd a nalog s

Onse t Pe ak

Duration Ra pid a c ting

aspart (Novolog™) glulisine (Apidra™) lispro (Humalog™ U100 and U200) inhaled (Afrezza™) 10-20min 25min 15-30min 15-30m 40-50min 45-48min 30m-2.5hr 53m 3-5hr 4-5.3hr 3-6.5hr 160min

Short a c ting - Re g ula r insulin

(Humulin-R™) (Novolin-R™) ~ 30m 1-3hr 1.5-3.5hr ~8h

Inte rme diate ac ting NPH “N”

(Humulin-N™) (Novolin-N™) 1-2hr 90min 2.8-13hr 4-12h 16-24hrs up to 24

L

  • ng a c ting

Glargine (Lantus™ U100) Detemir (Levemir™) Glargine (Toujeo U300) Degludec (Tresiba U200) 1.1hr 1.1-2hr 6h 30-90m None 10.8- < 24h 7.6- < 24h ≤ 36hrs ≤ 42h

Pre mixe d 70/30 N/R and 50/50 N/R NPL/lispro 75/25 (Humalog mix™), 50/50 aspart protamine/aspart 70/30 (Novolog mix™), 70/30 degludec/aspart (Ryzodeg™)*

0.5-1hr 10-15m 10-20m 2-10hrs 1-3hrs 1-4hrs 10-18hrs 10-16hrs 10-16hrs

Pharmacists Letter and PIs

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SLIDE 18

4

(U100/ U200 de glude c )

Concentrated insulins

 Re gular  U500 Regular  Rapid Ac ting  U200 Lispro (Humalog™)- same kinetics as

U100- more concentrated

 Basal  U300 Glargine (Toujeo™)- steady state 4-5

days, t ½ 19hrs

 U200 Degludec (Tresiba™) – “clinical” steady

state 3-4 days t ½ 25hrs

* Not pr

  • moting or

suppor ting any one insulin- r e fe r r ing moving for war d without using br and name s

U200 Lispro Kwikpen

Non-government insurance- copay card available; $25 per month copay

Lispro U200 Kwikpen

 Bioequivalent to U100 lispro (Q1)  Contains 600 units per pen instead of 300

units (still 3ml per pen)

 Fewer pens per month; half the volume  Risk for errors?

 Pens different color  A unit is a unit- so even if use the wrong pen,

the same units are injected

Humulin R U500 KwikPen

 Each pen holds 1500

units (3ml)

 Same size as other

KwikPens- dials in five unit increments

 Eliminates need for dose

conversion vs the vial

 Announced in 2016 Have read there will be a copay card- but unconfirmed

What is U 500 insulin?

 500 units/mL  20mL vial

"Information for the Physician: Humulin R Regular U-500 (Concentrated) Insulin Human Injection, USP (rDNA Origin)." E li L illy and Co mpany. (2013): 1-7. Web. 5 Feb. 2014. <http://pi.lilly.com/us/humulin-r-u500-pi.pdf>. http://www.humulin.com/index.aspx

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SLIDE 19

5

Humulin R U500 insulin

 When patients require over 200 U/day (Q2) or greater than 100

U per injection- physically too large for a single SC injection, requires more injections, adherence issues, worsening glycemic control

 The high concentration enables administration of large doses

  • f insulin in a small volume

 500 units/mL (vs other insulin U100); 5 x as potent * dangerous

error potential- new pen coming out 2016

 “REGULAR” insulin

 Its pharmacokinetics, however, resemble basal rate delivery similar to NPH

insulin

 The high concentration of U-500 results in delayed absorption and is

responsible for a slow rate of delivery

 Single doses of U-500 are generally active for 8 hours, although activity can

last up to 24 hours

 The range is due to variability in blood flow at the injection site and

sensitivity of insulin receptors

 Initial effects of U-500 are similar to regular insulin, with an onset of 30

minutes and peak effects seen within 1 to 3 hours

 Because of these pharmacokinetic properties- U-500 is dosed similar to

NPH, with 2 to 3 injections per day

Why Use Humulin R U-500?

 When TDD > 200 units  Requires smaller volume  Can reduce number of daily injections

http://www.humulin.com/pages/about-ru500.aspx

"Information for the Physician: Humulin R Regular U-500 (Concentrated) Insulin Human Injection, USP (rDNA Origin)." E li L illy and Co mpany. (2013): 1-7. Web. 5 Feb. 2014. <http://pi.lilly.com/us/humulin-r-u500-pi.pdf>.

Errors in administration

Humulin R U100 Humulin R U500

http://humulin.com/humulin-r-u-100.aspx http://www.humulin.com/index.aspx http://pi.lilly.com/us/humulin-r-u500-pi.pdf

Case- U500 11/2013

 Mr. B is a 59 year old male (who retired on 9/9/10) here

today for first Pharmacy visit. He is accompanied by his wife who is instrumental in his care. He was diagnosed with DM in 2001.

 Followed by Cardiology- Cardiomyopathy, CHF, Heart

Mate II LVAD implantation in 2012 , Implantable defibrillator 2010

 Other PMH- HTN, hyperlipidemia, Afib, CRF (eGFR

50ml/min), depression, asthma, obesity, neuropathy

 He was last seen by Endocrinology for T2DM a few

months before where his Lantus (U100 glargine) and Humalog (U100 Lispro) were increased due to high A1C 9.3%.

 His c ur

r e nt r e gime n is U100 glar gine 80 units qam and 80 units qpm and U100 lispr

  • 20-50 units with me als

thr e e time s a day and at snac ks. T

  • tal daily dose of

insulin: ~ 300 units

Case U500 11/2013

 Discontinue glargine and lispro (~300 units per

day)

 Initiate r

e gular U500 100 units (0.2ml) bid with br e akfast and dinne r

 Why start with TDD of 200 units?  Proper identification and management of

hypoglycemia reviewed

 Glucagon kit given  Joined gym; eating better  Happy with less injections

slide-20
SLIDE 20

6

Case U500 1/2014

 Follow up phone calls made between

appointments

 CGM placed between appointments  Enjoyed the data  Sent forms to get his own CGM  January A1C 7.8%  Exercising regularly now  Continue the mor

ning dose of Humulin R U500 0.34ml (170 units) and de c r e ase the e ve ning dose fr

  • m 0.32ml (160 units) to 0.31ml (155

units)

Case U500 3/14

 Admitted febrile illness  Endocrinology consulted  U500 dose at the time 0.34 ml (170U) and 0.25ml

(125U)

 Gives him:  NPH 60 / Humalog 20 at breakfast  Humalog 20 at supper  NPH 30 at bedtime  Humalog sliding scale  TDD prior at admission 295 units inpatient 130

and sliding scale

What do you think happened in the hospital?

Case U500 3/2014

 During hospitalization A1C 8.4%  Se lf inje c ting U500 0.34ml (170U) br

e akfast and 0.18-0.20ml (90-100U) dinne r

 Since ill- no exercise; but some hypo when he

does

 On e xe r

c ise days de c r e ase to 0.25ml (125U) and c ontinue 0.18-0.20ml (90-100U)

 Otherwise same as above  Patient to F/U with CGM rep

Case U500 4/2014

 Occasionally missing evening insulin dose  Continue d U500 -0.30ml (150U) br

e akfast on non-e xe r c ise days and 0.15ml-0.25ml (75- 125U) dinne r

 Needs better diet  Contact CGM rep

Case U500 6/2014

 Sometimes skips meals, poor choices, no

purposeful exercise

 Continue insulin U500 0.30 mL

(150 units) with br e akfast, reassess in one week to

see if an increase to 0.31 mL is appropriate

 Inc r

e ase U500 fr

  • m 0.20 to 0.21 (105 units)

in the evening

Case U500 9/2014

 Skipping meals on occasion and has

hypos

 Hasn’t missed insulin and plans to go back

to the gym

 A1C today 8.9% (up from 8.4%)  Inc r

e ase insulin Humulin R U-500 0.31 mL (155 units) in the mor ning

 If e xe r

c ising take insulin Humulin R U-500 0.25 mL (125 units) in the mor ning  Inc r

e ase insulin Humulin R U-500 0.22mL (110 units) in the e ve ning

slide-21
SLIDE 21

7

Case U500 1/2015

 Purchased exercise bike but not

motivated to exercise, eating when he wants, whatever he wants

 A1C is 9.4%  Continue 0.32ml (160U) if e xe r

c ising 0.25ml (125U) with br e akfast and 0.23ml (115U) be for e dinne r

 Initiate metformin ER 500mg daily  eGFR stable at 50ml/min

Eurich DT, McAlister FA, Blackburn DF, et al. Benefits and harms of antidiabetic agents in patients with diabetes and heart failure: systematic review. BMJ 2007; 335:497.

T

  • be c ontinue d…..

Basal insulin

Newer and concentrated formulations

What is the perfect basal insulin? History – the WHY?

 The first slow-release insulin marketed in 1950 was

NPH insulin

 intermediate duration of action, high inter- and

interpatient bioavailability and high rate of hypoglycemia

 Newer basal analog insulins modified to delay

their release into the blood, resulting in a flatter, peakless profile and a longer duration

 The first long-acting basal insulins were introduced

in 2000 (glargine U100) and in 2005 (detemir U100), followed by the longer-acting basal insulins glargine U300 and degludec U100 and U200 in 2015

(Abrahamson et al., 2010; Tibaldi, 2012, Tibaldi, 2014)

Duration of action

 The duration of action describes the duration of

fasting blood glucose control and is of importance for deciding the dosing interval (i.e.

  • nce- or twice daily dosing). (BASAL

)

 A duration of action of at least 24 hours is

required for true once-daily basal insulin dosing.

 The onset of action is not of high importance

when considering prescribing newer long-acting basal insulins because the duration of action of newer basal insulins covers or exceeds 24 hours, and these insulins are dosed at ste ady state.

Steady state

 Steady state pharmacokinetics are important for

chronically administered drug products, like LA basal insulin analogs (U300 glar

gine , U100/ U200 de glude c only)

 These long-acting insulin formulations attempt to

mimic the physiological profile of endogenous basal insulin secretion by providing a constant – steady state - plasma insulin profile (Basal)

 To achieve a steady state condition, repeated

  • nce-daily injections are required to reach a state

where the rate of absorption equals the rate of elimination

 When steady state is achieved, insulin levels are not

expected to further increase unless the dose or dosing interval is changed

Evans, 2011, Heise and Meneghini, 2014)

slide-22
SLIDE 22

8

Steady State

 The time to reach steady state depends on the

elimination half-life of a drug.

 Typically, steady state will be achieved after 4-5

half-lives.

 Compared with shorter acting basal insulin

formulations, the basal insulin analogs with longer half-lives will take longer to reach steady state.

 When dose adjustments of longer-acting basal

insulin analogs are needed, it should be noted that daily dose c hange s ar

e not r e c omme nde d

because the effect will only become apparent after a couple of days.

(Heise and Meneghini, 2014)

Insulin Stacking

 Describes the increasing accumulation of

insulin that can occur when additional

dose s of r apid-ac ting (pr andial-ie lispr

  • ,

r e gular , aspar t) insulin (Q3) are

administered before the previous bolus dose has been completely absorbed

 The resulting overlapping insulin effect is

associated with an increased risk of hypoglycemia

Heise et al., 2002; Bott et al., 2006; Aye et al., 2014; Heise & Meneghini, 2014; Danne et al., 2015

Insulin Stacking

 There is concern among clinicians that once-

daily administration of basal insulins with a half- life >24 hours could contribute to stacking and therefore hypoglycemia

 The PK of dosing for prandial and basal insulins is very

different.

 Prandial insulins have been designed to provide a

rapid rise and fall in insulin concentrations from a single dose, mimicking the effect of physiological pulses of insulin at mealtimes

 LA basal insulins are dosed at steady state, with the

aim of providing a flat, peakless insulin action profile

  • ver 24-hours

Heise et al., 2002; Bott et al., 2006; Aye et al., 2014; Heise & Meneghini, 2014; Danne et al., 2015

Insulin Stacking

 Onc e ste ady state is ac hie ve d for

a give n dose , insulin ac c umulation will not oc c ur be c ause the r ate of insulin absor ption e quals the r ate of uptake and e limination

 Clinical studies have shown that

undesirable stacking (and the associated increased risk of hypoglycemia) does not

  • ccur when long-acting basal insulins are

dosed appropriately and adjusted at appropriate time intervals.

Heise et al., 2002; Bott et al., 2006; Aye et al., 2014; Heise & Meneghini, 2014; Danne et al., 2015 Heise and Meneghini, 2014

U300 glargine

Non-government insurance- copay card available; $15 per month copay New pen in development- to deliver bigger dose – unknown timeline- majority of patients inject < 80units a day

slide-23
SLIDE 23

9

PK/PD Glargine U100/U300

 U300 Glargine provides the same number of units of

insulin as Gla-100 in a third of the injectable volume.

 PK/PD studies have shown that, following injection,

U300 glargine releases more gradually from the subcutaneous tissue precipitate than U100 glargine, giving a more constant PK profile with a prolonged duration of action beyond 24 hours.

 The increased half-life of U300 glargine was ~19hrs

compared with 12-13 hrs for U100 and glucose control was maintained up to 36 hours

 Low intra-patient variability, more predictable

(U300)

Klein et al., 2007, Heise et al., 2012, Toujeo PI, 2015, Becker et al., 2015a, Becker et al., 2015b; Shiramoto et al., 2015

U300 glargine forms a precipitate from which small amounts of insulin glargine are slowly released- smaller volume

U100 Glargine U300 Glargine

Clinical implications

 In six, phase 3, multinational, open-label studies in T1D and T2D patients,

Gla-300 consistently showed comparable glycemic control to Gla-100, with the findings of a meta-analysis of patient-level data showing a mean change in A1C level of –1.02% in both groups.

 A similar meta-analysis of patient-level data from phase 3 clinical trials in

T2D patients also showed that Gla-300 provided comparable glycemic control to Gla-100. The potential for reduced hypoglycemia with Gla-300 has been confirmed in the meta-analyses of phase 3 data.

 Gla-300 was associated with comparable or reduced nocturnal

hypoglycemia compared with Gla-100, with a relative risk of 0.75 (95% CI: 0.68 to 0.83).

 Gla-100 has an established long-term safety profile, and a long-term

clinical study (the ORIGIN study) has reported that Gla-100 has a neutral effect on cardiovascular outcomes and cancer.

 As Gla-300 and Gla-100 are based on the same insulin glargine molecule,

the safety of Gla-300 would be expected to be similar.

 Across the clinical trial program, Gla-300 was generally well tolerated, with

similar common adverse events and serious treatment emergent adverse events reported for both Gla-100 and Gla-300.

Goldman J, White J. New insulin glargine 300U/ml for the treatment of type 1 and Type 2 diabetes mellitus. Annals of Pharmacotherapy 2015, Vol. 49(10) 1153–1161. Ritzel et al., 2015

U100 and U200 degludec

Non-government insurance- copay card available; $15 per month copay

PK/PD Degludec U100/U200

 The elimination t1/2 of insulin degludec is 25 hours, which

provides low peak-to-trough variation in blood glucose levels throughout the 24-hour dose interval.

 At steady state, insulin degludec has a flat, evenly distributed

glucose-lowering profile with a duration of action that exceeds 26 hours (in people with type 2 diabetes), and linear dose- dependent increases in action making it suitable for once-daily dosing.

 Low intra-patient variability in glucose lowering effect,

providing a predictable day-to-day glucose lowering effect.

 As with insulin glargine, injections of different doses of insulin

degludec result in dose-dependent increases in circulating insulin levels.

(Q4)

 Howe ve r

, unlike Gla-100 and Gla-300, the two for mulations of insulin de glude c are bioe quivale nt and be have similarly.

Heise et al., 2012, Korsatko et al., 2013, Bode et al., 2014, Goldman-Levine JD, Patel D, Schnee

  • D. I

nsulin de glude c : A no ve l insulin analo gue . Ann Pharmacother. 2013;47(2):269-277

slide-24
SLIDE 24

10

Mechanism of action (1) Mechanism of action (2)

Clinical implications- degludec

 Insulin degludec 100 units/mL has an ultra-long, flat glucose-lowering PD profile,

with minimal peak-trough variations in effect, and is associated with a reduced risk

  • f nocturnal hypoglycemia compared with Gla-100.

 Insulin degludec 100 units/mL has a more predictable antiglycemic effect than Gla-

100 in patients with T1D, with a four-fold lower intra-patient variability in glucose lowering action.

 The lower intra-patient variability of response to insulin degludec 100 units/mL

compared with Gla-100 was also consistent over the 24-hour dose interval.

 Insulin degludec 200 units/mL was compared with Gla-100 in insulin-naïve T2D

patients; a similar reduction in A1C was achieved with both insulins, but insulin degludec 200 units/mL was associated with a greater reduction in fasting plasma glucose (FPG) levels at significantly lower insulin doses.

 No significant differences in the rates of overall and nocturnal confirmed

hypoglycemia were observed. There have been no comparison between insulin degludec (100 units/ml or 200 units/ml) with Gla-300.

 Clinical experience and long-term safety data for insulin degludec 100 and 200

units/mL are still limited, although no safety concerns regarding unexpected adverse events or accumulation of insulin have been identified to date.

 New data- Switch 1 and 2 (unpublished- press release) Heller et al., 2012, Mathieu et al., 2013, Zinman et al., 2012; Garber et al., 2012, Heise et al., 2012, Gough et al., 2013, Rosenstock et al., 2008, Goldman-Levine JD, Patel D, Schnee D. I nsulin de glude c : A no ve l insulin analo gue . Ann Pharmacother. 2013;47(2):269-277

Switch 1 Type 1 DM (Novo- Press Release)

 Randomized, double-blind, cross-over, treat-to-target trials, comparing

the safety and efficacy of insulin degludec and insulin glargine U100

 The overall purpose of the trial was to compare the hypoglycemia

  • ccurrence in people with type 1 diabetes

 Primary end-point of the trial was the number of treatment emergent

severe or blood glucose confirmed symptomatic hypoglycemia episodes during the maintenance period (ie after 16 weeks of treatment) in each treatment period.

 The trial showed non-inferiority in A1c reduction  Non-inferiority was demonstrated in the rate of severe or blood

glucose confirmed symptomatic hypoglycemia of insulin degludec compared to insulin glargine- statistic ally signific ant r

e duc tion of 11%

 Non-inferiority was demonstrated for the rate of severe or blood

glucose confirmed symptomatic nocturnal hypoglycemia -statistic ally

signific ant 36% reduction with insulin degludec compared to insulin

glargine.

 Superiority was demonstrated for the confirmatory secondary

endpoint of proportions of subjects experiencing severe hypoglycemia during the maintenance period- statistic ally signific ant 35% r

e duc tion.

Switch 2 Type 2 DM (Novo- Press Release)

 Randomized, double-blind, cross-over, treat-to-target trials, comparing the

safety and efficacy of insulin degludec and insulin glargine

 The overall purpose of the trial was to compare the hypoglycemia

  • ccurrence

 The primary end-point - was the number of treatment emergent severe or

blood glucose confirmed symptomatic hypoglycemia episodes during the maintenance period (ie after 16 weeks of treatment) in each treatment period.

 Non-inferiority in A1c reduction was shown between the insulins  Rate of severe or BG confirmed symptomatic hypoglycemia during the

maintenance period- statistic ally signific ant r

e duc tion of 30% with insulin

degludec compared to insulin glargine

 Severe or blood glucose symptomatic nocturnal confirmed hypoglycemia

in the maintenance period – statistic al signific ant r

e duc tion of 42%

 The secondary endpoint of proportions of subjects experiencing severe

hypoglycemia during the maintenance period did not reach statistical significance.

 The supportive end-point, rate of severe hypoglycemia, showe d a 46%

r e duc tion with insulin degludec in the maintenance period and a statistic al signific ant r e duc tion of 51% in the full treatment period.

Objective 3

Implement strategies for safely converting between U100 and concentrated insulin formulations in patients with T2DM

slide-25
SLIDE 25

11

Dosing scenarios

 Not all inclusive  See the following reference for additional

information and dosing guidelines including converting from LA to intermediate

Phar mac ists L e tte r : PL De tail-Doc ume nt, How to Switc h Insulin Pr

  • duc ts. Phar

mac ist’s L e tte r / Pr e sc r ibe r ’s L e tte r . June 2014.

Dose initiation- insulin naïve

U300 glargine U200 degludec T2DM 0.2 units/kg

  • nce a day

T2DM 10units once a day

T1DM- insulin naïve ~ 1/3-1/2 TTD basal and the remainder as SA with meals. General rule- 0.2-0.4 units/kg to calculate dose

Dosing – switching from once a day LA insulin

Insulin

U100 Gla rg ine U100 De te mir U300 Gla rg ine * U200 De glude c

Dial

30units 30units 30 units 30 units

Volume

0.3ml 0.3ml 0.1ml 0.2ml Pr

  • duc t PIs, PL

De tail-Doc ume nt, How to Switc h Insulin Pr

  • duc ts. Phar

mac ist’s L e tte r / Pr e sc r ibe r ’s L e tte r . June 2014.

  • A higher dose may be required

BID Long acting to QD

 Detemir bid- to U300 glargine or U200

degludec- reduce TTD by 20% and give

  • nce a day

 U100 glar

gine bid- to U300 glar gine c onve r t unit for unit (1:1) (Q5) or reduce

dose by 10% - to U200 degludec reduce TTD by 20% and give once a day

Pr

  • duc t PIs, PL

De tail-Doc ume nt, How to Switc h Insulin Pr

  • duc ts. Phar

mac ist’s L e tte r / Pr e sc r ibe r ’s L e tte r . June 2014.

NPH to Long Acting

NPH to de te mir

 Convert unit-per-unit  Some patients on

basal-bolus insulin may require more insulin detemir than NPH

 Give insulin detemir

  • nce daily, or divided

twice daily if necessary for control.

NPH to insulin glar gine U100 or U300 or de glude c U200  NPH once daily:

convert unit-per-unit and give once daily

 NPH twice daily:

reduce total daily dose by 20% and give once daily

 Do not increase dose

more often than every 3 to 4 days

Pr

  • duc t PIs, PL

De tail-Doc ume nt, How to Switc h Insulin Pr

  • duc ts. Phar

mac ist’s L e tte r / Pr e sc r ibe r ’s L e tte r . June 2014.

Dosing initiation and titration

U200 de glude c

 Inject once a day;

any time of day

 Dose increases every

3-4 days

 If miss dose, make

sure at least 8 hours between doses (up to 40 hours) U300 glar gine

 Inject once a day;

same time each day

 Dose increases every

3-4 days

 If miss dose, 3 hours

studied without a loss

  • f efficacy

*Menegini et al; Begin Flex. Diabetes Care. 2013;36(4):858-864.

slide-26
SLIDE 26

12

Timing of newer basal insulin dose

 Insulin glargine U100 and insulin detemir – same time of day in

24hrs

 Insulin detemir may require twice-daily dosing

 Insulin glargine U300 and insulin degludec U100/U200;

extended, flat PD action profiles of these insulins allow flexibility in dosing time (ie if they forgot their dose)

 Studies in T1D and T2D patients, showed that the injection time

  • f insulin degludec could be safely varied without

compromising either glycemic control or safety compared with same-time administration

 In the study in T2D patients, extreme dosing intervals of 8–40 hours

did not compromise glycemic control or safety.

 A subset of T2D patients treated with Gla-300 in EDITION-1 and

EDITION-2 were also advised to vary the time of daily injection

  • f Gla-300 by up to 3 hour

s; this did not impact efficacy or

safety compared with those that injected Gla-300 at the same time every 24 hours.

(Meneghini et al., 2013, Mathieu et al., 2013, Jeandidier et al., 2014

Flexible dosing

 What type of patient may be helped with

an insulin that is “forgiving” of missing doses

Insulin stability at room temperature that are “in use”

 Humalog, Novolog, Apidra – 28 days  Lantus- vial and pen 28 days  Levemir- vial and pen 42 days  Toujeo- pen 42 days (new- may not be in the PI)  Tresiba- pen 56 days  Humulin R vials – 40 days, Novolin R vials -42 days  Humulin N vials – 31 days, Novolin N vials – 42 days  Novolog Mix 70/30 - vial 28 days, pen 14 days  Humalog Mix 75/25 and 50/50- vial 28 days, pen 10

days

 Humulin 70/30- vial 31 days, pen 10 days  Novolin 70/30- vial 42 days  Ryzodeg 70-/30- pen 28days

Case U500 1/2015

 Purchased exercise bike but not

motivated to exercise, eating when he wants, whatever he wants

 A1C is 9.4%  Continue 0.32ml (160U) if e xe r

c ising 0.25ml (125U) with br e akfast and 0.23ml (115U) be for e dinne r

 Initiate metformin ER 500mg daily  eGFR stable at 50ml/min

Eurich DT, McAlister FA, Blackburn DF, et al. Benefits and harms of antidiabetic agents in patients with diabetes and heart failure: systematic review. BMJ 2007; 335:497.

T

  • be c ontinue d…..

Case U500 2/2015

 Using bike 3-4 times a week for 10 minutes  Poor diet  Only missed one injection of insulin this past week  Couldn’t tolerate metformin – GI symptoms  Initiate de te mir 80 units in the morning  Disc ontinue the c ur

r e nt dose s of U500 insulin and initiate 0.16 ml (80 units) 30 minute s be for e br e akfast. Initiate 0.16 ml (80 units) 30 minute s be for e dinne r .

 Increase morning U500 insulin by 0.02 ml (10 unit

increase) in the dose every 3 days if pre-dinner blood glucose is elevated (>200 mg/dl)

 If experiencing low blood glucose at night, decrease

U-500 at dinner to 50 units (0.10 ml). If continued low blood sugars, continue to decrease by 10 units.

Case U500 4/2015

 Inconsistent eating, skips meals, no

purposeful exercise

 A1C 9.1%  Discussed CGM and insulin pump  Continue U500 insulin at 0.24ml (120 units) in

the mor ning and 0.24ml (120 units) in the e ve ning.

 Continue de te mir 60 units in the mor

ning and 50 units at be dtime

 *Consider U300 glar

gine - pen dials to

80units

slide-27
SLIDE 27

13

Case U500 2/2016

 Before this visit- switched him to insulin glargine

U300 80 units once a day (was on 60 units bid of detemir)

 Caused significant peripheral edema, can worsen

heart failure- DCed and went back to detemir

 Continue Humulin U-500 insulin at 0.3ml (150 units)

in the mor ning and 0.3ml (150 units) in the e ve ning – c onside r switc hing to Humalog U200, injected

three times prior to meals, at next visit

 Initiate (U200 de glude c ) T

r e siba 120 units onc e daily in the evening starting tonight – monitor for

signs of edema – sent PA to insurance, gave samples and copay card- monitor FBS and make weekly increases as needed

 Disc ontinue de te mir 60 units bid

Case U500 2/2016

 Discontinue Humulin R U-500 insulin at 0.25ml

(125 units) in the morning and 0.1ml (50 units) in the evening

 Initiate Humalog U200 60 units be for

e e ac h me al

 If blood sugar

s ar e always 300 or gr e ate r , inc r e ase Humalog U200 by 10 units (le ave ne e dle in dial again)  Inc r

e ase T r e siba 120 units to 130 units onc e daily in the e ve ning star ting tonight

 Look at fasting blood sugars, if not 130-150 in 1

week, increase to Tresiba 140 units once daily in the evening

Case U500 3/2016

 Inc r

e ase Humalog U200 to 70 units be for e br e akfast and dinne r

 If pr

e -me al BG ar e >300, inje c t 80 units Humalog U200

 Inc r

e ase T r e siba fr

  • m 140 units to 150 units

daily

 Pharmacy to follow up in 1 week and will

consider increasing Tresiba to 160 units daily if FBG still elevated

Biosimilar insulin

 In the face of the growing costs associated with managing

the diabetes epidemic in the United States, as in much of the rest of the world, there is understandable interest in the potential for new ‘copies’ of existing insulins – termed biosimilar insulins – to reduce these costs and to improve access, as has been achieved with standard generic drugs.

 However, biosimilars are NOT

GE NE RICS; there are critical

differences between biological products and conventional chemical drugs which present specific challenges to manufacturers, regulators and clinicians.

 It is important that clinicians are aware of what biosimilarity

means for a biosimilar drug in terms of its comparison with its reference product to help them make an informed choice for their patients.

 In particular, consideration needs to be given to the

interchangeability of biosimilar drugs and the issues which surround switching patients from one to the other.

Biosimilar Insulin

 The recent and upcoming expiration of patent

protection for a number of insulin preparations will

  • pen up the insulin market worldwide to

manufacturers of insulin ‘copies’ or ‘biosimilars’.

 The potential attraction of these new insulins is clear

to a healthcare system facing the costs associated with managing the increasing number of patients with diabetes in the US, with hopes that they will deliver savings similar to those achieved with generic drugs.

 However, biosimilars are not generic drugs, and this

has important implications for their regulation and use.

 Cur

r e ntly the r e ar e no biosimilar s appr

  • ve d in the US,
  • nly one “follow- on” insulin, Basaglar

Biosimilar insulin

 Biosimilars are novel versions of biopharmaceutical

drugs intended to have the same PK/PD properties, efficacy and safety as the original biopharmaceutical drug.

 Insulin is a large molecule and biosimilars are

manufactured in a multiple complex stages. Creating the same amino acid structure will not necessarily lead to insulins with identical properties.

 Biosimilar insulins therefore have to undergo rigorous

clinical testing to demonstrate efficacy and safety prior to approval.

Blevins et al., 2015, Linnebjerg et al., 2015, Rosenstock et al., 2015. Eli Lilly & Boehringer Ingelheim, 2015; DeVries et al., 2015)

slide-28
SLIDE 28

14

Glargine (Basaglar) “Follow-on”

 FDA approved 1/2016 (Lilly/BI)  Not classified as biosimilar- it is “follow on”  Due on the market 12/16  Mylan/Biocon, Merck/Samsung Bioepis working on

biosimilar insulin glargine products

 Sanofi developing biosimilar of Lilly’s lispro (Humalog)  For regulatory reasons FDA not calling it a biosimilar-

rather a “new insulin”

 Europe- biosimilar; approved there  USA- clinical trials as a new insulin

 NOT a “generic”- not interchangeable

 What does this mean for patients?  Reduces cost? 15-20%  Unknown how will impact insurance

Being studied/developed

 Longer acting insulin (dosed less

frequently- 3, 4 days, 1-2 times a week)

 “smart insulin” that works based on

circulating blood sugars

 Oral, inhaled, transdermal, patch pumps

for T1 and T2

 Artificial pancreas

Objective 4

Discuss strategies for overcoming common barriers to optimal glucose control with basal insulin therapy

Place in therapy- newer basal insulins

 ANYONE

R E QUIR ING BASAL INSUL IN (Q6)

 Patients with hypoglycemia to NPH  Patients other regimens not lasting 24hours (U300

glargine/U200 degludec)

 Those requiring flexible dosing (U200 degludec-

8/40 hours, U300 glargine 3 hours)

 Those who require > 80units of insulin once a day

(degludec U200 pen dials to 160units)

 Those requiring multiple injections for a single dose  Physically too large for a single SC administration  Unpredictable absorption/not lasting 24 hours  Those who are insulin resistant/obesity

Place in therapy- Concentrated rapid acting and regular insulin

 Physically too large for a single SC administration  Those who are insulin resistant/obesity  Those requiring > 200 units of insulin TDD per day

(U500 regular)

 May be used without basal insulin  Some may need basal insulin added  Not highly studied  Those requiring large doses of mealtime insulin

(U200 lispro)

 Can be used in anyone needing mealtime

regardless of how large the dose

Contact info

 Email: jennifer.goldman@mcphs.edu  Twitter: JGoldman  LinkedIn: Jennifer Goldman  Faculty Bio:

http://www.mcphs.edu/about%20mcphs/direct

  • ry%20listing/Bio?id=0034245

 Practice Bio:

http://www.welllifemedical.org/OurProviders/Pr

  • viderDetail.aspx

Info on becoming a CDE: http://www.ncbde.org/certification_info/ Info on Board certification in advanced diabetes management (BC-ADM): http://www.diabeteseducator.org/ProfessionalResources/Certification/BC-ADM/

slide-29
SLIDE 29

15

1. Which of the following statements regarding insulin lispro (Humalog) is true?

  • 1. U100 lispro and U200 lispro are bioequivalent
  • 2. U200 lispro has a faster onset of action than U100

lispro

  • 3. U200 lispro has a longer duration of action than

U100 lispro

  • 4. Not sure

2. Humulin R U500 is most appropriate in patients requiring…

  • 1. A total daily dose of 100-150 units of insulin
  • 2. A total daily dose of 200 units of insulin or more
  • 3. A total daily dose of 500 units of insulin or more
  • 4. Not sure

3. Which of the following statements regarding insulin stacking is true?

  • 1. There is an increased risk of stacking with U300

glargine

  • 2. There is an increased risk of stacking with U200

degludec

  • 3. Both U300 glargine and U200 degludec can

cause stacking

  • 4. U100 and U200 lispro and U500 Humulin R can

cause stacking

  • 5. Not sure

4. Which of the following statements regarding insulin degludec (Tresiba) is true?

  • 1. U100 degludec and U200 degludec are

bioequivalent

  • 2. U200 degludec has a faster onset of action than

U100 degludec

  • 3. U200 degludec has a longer duration of action than

U100 degludec

  • 4. Not sure

5. In a patient receiving 30 units twice a day

  • f Lantus (U100 glargine) what would be

their dose if you changed to Toujeo (U300 glargine) insulin?

  • 1. U300 glargine 30 units twice a day
  • 2. U300 glargine 60 units once a day (1:1 conversion)
  • 3. U300 glargine 48 units once a day (20% less)
  • 4. U300 glargine 78 units once a day (20% more)
  • 5. Not sure

6. Which of the following statements regarding the new basal insulins are true?

  • 1. U200 degludec and U300 glargine should be

reserved for patients who are insulin resistant

  • 2. U200 degludec and U300 glargine are titrated daily

until maximum dose is reached

  • 3. U200 degludec and U300 glargine are appropriate

for anyone requiring basal insulin

  • 4. Not sure
slide-30
SLIDE 30
slide-31
SLIDE 31

1

2016 Pharmacy Law and Regulatory Update for Pharmacists

Michael Brosnan, PharmD, RPh, Pharmacy Investigator Michelle Chan, BS Pharm, RPh, Quality Assurance Pharmacist Vishal Thaker, PharmD, RPh, Quality Assurance Fellow

Commonwealth of Massachusetts Executive Office of Health and Human Services Department of Public Health Bureau of Health Professions Licensure Board of Registration in Pharmacy

Eric Sheehan, JD, Bureau Director; Massachusetts Department of Public Health, Bureau of Healthcare Safety and Quality

Learning Objectives

1. Identify changes to regulations governing the practice of pharmacy. 2. Describe the common deficiencies found by investigators during pharmacy compliance inspections. 3. Identify Board members and Board staff: Who’s on Causeway Street? 4. Identify the new Board of Pharmacy license categories (247 CMR 6). 5. Describe “above action level results” for compounding and reporting requirements.

Massachusetts Board of Registration in Pharmacy

Mission Statement

To promote, preserve, and protect the public health, safety, and welfare by fostering the provision of quality pharmaceutical care to the citizens of Massachusetts through the regulation of the practice of pharmacy, the

  • peration of pharmacies, and the distribution
  • f prescription drugs in the public interest.

Massachusetts Board of Registration in Pharmacy

Board of Registration in Pharmacy: Members & Staff

Massachusetts Board of Registration in Pharmacy

Pharmacy 2 Chain Pharmacists 1 LTCF Pharmacist 1 Pharmacy Technician 1 Sterile Compounder 1 Academic Pharmacist 2 Independent Pharmacists 1 Hospital pharmacist Healthcare Professionals 1 Nurse 1 Physician 2 Members of the Public

Pharmacy Board Make-Up

Massachusetts Board of Registration in Pharmacy

Pharmacy Board Members

Massachusetts Board of Registration in Pharmacy

Ed Taglieri Jr., RPh LTC Timothy Fensky, RPh Sterile Compounding Michael Godek, RPh Chain Pharmacy Garrett Cavanaugh, RPh Chain Pharmacy Patrick Gannon, RPh Hospital Catherine Basile, PharmD, RPh Academic Richard Tinsley, MBA, M.Ed. Public seat Susan Cornacchio, RN, JD Public seat William Cox, CPhT Technician Andrew Stein, Pharm D, RPh Independent Pharmacy Phillippe Bouvier, RPh Independent Pharmacy Ali Raja, MD, MBA, MPH Physician Karen Conley, DNP, RN, AOCN, NEA-BC Nurse

slide-32
SLIDE 32

2

Board of Registration in Pharmacy Staff Members

Massachusetts Board of Registration in Pharmacy

David Sencabaugh, RPh Executive Director Monica Vasquez, CPhT Associate Executive Director William E. Frisch, Jr., RPh Director of Pharmacy Compliance Heather Engman, JD, MPH Pharmacy Board Counsel Michelle Chan, RPh Quality Assurance Pharmacist Vishal Thaker, PharmD, RPh Pharmacy Consultant Richard Harris Program Analyst Joanne Trifone, RPh Director of Pharmacy Investigations Carolyn Reid Administrative Assistant Lau Kwan Administrative Assistant

Legislation vs. Regulations

Legislation (a.k.a. statute, laws) – Refers to a law enacted by a legislative body of a government – Provide the framework – Cannot explicitly cover all the potential interests by statute, so it delegates some of its authority to state agencies Regulation – Authorized by statutes, regulations (sometimes called rules or administrative laws) have the effect of law – State executive agencies carry out state laws through the development and enforcement of regulations – Enable the statute by providing the details of “how to” carry out the law

Massachusetts Board of Registration in Pharmacy

Promulgation of Regulations

The Process…

  • Develop Draft regulations
  • Establish and Schedule Public Comment Period
  • Hold Public Hearing
  • Review Public Comment and make Revisions based
  • n comments considered (if applicable)
  • Final draft approved by Board
  • New Regulation published and implemented

Massachusetts Board of Registration in Pharmacy

Massachusetts Board of Registration in Pharmacy

www.mass.gov/dph/boards/pharmacy OR Google MA Board of Pharmacy

Massachusetts Board of Registration in Pharmacy

  • Email Inquiry to the Board
  • News/updates and Board meetings
  • Board Advisory
  • Draft Regulations
  • Public Hearing

Massachusetts Board of Registration in Pharmacy

The Board Website Changes to Pharmacy Regulations

Massachusetts Board of Registration in Pharmacy

slide-33
SLIDE 33

3

Public Hearing

The public hearing on September 19, 2016 was held for proposed amendments to:

  • 247 CMR 3.00 - Pharmacist Licensure Requirements
  • 247 CMR 8.00 – Pharmacy Interns and Technicians
  • 247 CMR 10.00 – Investigations, Complaints and Board Actions
  • 247 CMR 16.00 – Collaborative Drug Therapy Management

Massachusetts Board of Registration in Pharmacy

247 CMR 3.00 Personal Registration Requirements

  • 247 CMR 3.00 sets requirements and procedures for

licensure as a pharmacist.

  • There will be a new proposed section added to 247 CMR

3.00 – “247 CMR 3.04”

  • This new section will set forth regulations for a retirement

category.

  • A licensee who meets eligibility requirements, may submit a

petition to place his/her license on retired status, which is non-disciplinary.

  • Intended for those who plan to permanently retire from

active practice in the Commonwealth and other jurisdictions

Massachusetts Board of Registration in Pharmacy

247 CMR 4.00 Personal Registration Renewal; Continuing Education Requirements

  • 247 CMR 4 set requirements for renew of licensing,

and continuing education.

  • Effective for the renewal period beginning January 1,

2015, a registrant seeking renewal of a personal registration must complete a minimum of twenty (20) contact hours of continuing education each calendar year of the two-year renewal cycle.

– (a) All registrants must complete at least 2 contact hours per calendar year in the area of pharmacy law – (b) No more than fifteen (15) contact hours per calendar year acquired through home study and other mediated instruction may be applied toward the minimum of 20 contact hours per calendar year

Massachusetts Board of Registration in Pharmacy

247 CMR 4.00 CE Requirements

  • Pharmacies and Pharmacists who engage in sterile
  • r complex non sterile compounding have additional

requirements:

– (c) A registrant who oversees or is directly engaged in the practice of sterile compounding or who practices in a pharmacy must complete at least five (5) contact hours per calendar year of continuing education in the area of sterile compounding. – (d) A registrant who oversees or is directly engaged in the practice of complex nonsterile compounding or who practices in a pharmacy must complete at least three (3) contact hours per calendar year of continuing education in the area of complex non-sterile compounding.

Massachusetts Board of Registration in Pharmacy

247 CMR 4.00 CE Requirements

  • Effective January 1, 2015, i.e. for the next renewal cycle

(2015 / 2016)

Massachusetts Board of Registration in Pharmacy

New Requirements

(beginning 1/1/15)

Previous Requirements

Total CE hours per year 20 15 Live 5 5 Law 2 2 Sterile Compounding

(if engaged or oversee)

5 N/A Non-Sterile Complex Compounding

(if engaged or oversee)

3 N/A

247 CMR 4.00 Recordkeeping

  • Section 4.06:

– Record-keeping by Registered Pharmacists 1) A pharmacist shall maintain documentation or a statement of credit demonstrating successful completion of the required contact hours of continuing education for a period of at least two years from the date of completion. 2) A pharmacist shall provide documentation or statements of credit demonstrating successful completion of required contact hours of continuing education to the Board upon request and in response to random audits.

  • The Board does not require CE documentation in order

to renew a license

Massachusetts Board of Registration in Pharmacy

slide-34
SLIDE 34

4

247 CMR 4.00 CE Reminders!

  • REMEMBER!

7) A registrant may not earn more than eight contact hours of continuing education in a calendar day. 8) A registrant shall not be required to complete continuing education in the calendar year in which the registrant has graduated from an approved college/school of pharmacy.

Massachusetts Board of Registration in Pharmacy

247 CMR 9.00

  • 9.02: Prescriptions by Mail: (1) A pharmacy and pharmacist may

dispense prescription drugs by mail or common carrier in a manner consistent with federal and state laws and regulations.

  • 9.04: Requirements for dispensing and refilling:

– (6) A pharmacy that provides bed-side delivery service of discharge prescriptions to patients in an inpatient healthcare facility must obtain patient consent to provide such services and may not restrict a patient’s freedom of choice of pharmacy services. A pharmacy that provides bedside delivery service shall deliver any medications directly to the patient or patient’s agent – (10) Only a pharmacist, pharmacy intern, or certified pharmacy technician who has the approval of the pharmacist on duty may receive new prescriptions over the telephone from a prescriber or authorized agent – (12) In order to determine whether a prescription is within date, the date the prescription was written or the “do not fill before” date shall not be

  • counted. The last day of the period shall be counted.

Massachusetts Board of Registration in Pharmacy

247 CMR 9.00

  • Numerous Additional Changes:

– 9.05 Daily Dosage Planners – 9.06 Specialty Packaging – 9.07 Emergency Med Kits – 9.08 Automated Pharmacy Systems – 9.09 Pharmacy Processing Automation – 9.10 Automated Dispensing Devices – 9.11 Return to Stock – 9.12 Transfer of Prescriptions – 9.13 Verifying a Practitioner’s Prescriptive Authority – 9.14 Maintenance of Prescription Files – 9.15 Prospective DUR – 9.16 Patient Counseling – 9.17 Pharmacy Operation – 9.18 Non-resident Pharmacies – 9.19 Security of Controlled Substances – 9.20 Storage of Refrigerated and Frozen Medications – 9.21 Pharmacy MOR – 9.22 Inspections and Investigations of Pharmacies – 9.23 Plans of Correction

Massachusetts Board of Registration in Pharmacy

247 CMR 8.00 Pharmacy Interns and Technicians

Massachusetts Board of Registration in Pharmacy

  • 247 CMR 8.00 sets requirements and procedures for

licensure as a pharmacy intern and pharmacy technician.

  • Some of the changes include:
  • Section 8.01 (8) - which requires PharmD graduates who accept

a residency in MA to obtain a pharmacy intern license until a MA pharmacist license is obtained.

  • Section 8.03 (1) - a pharmacy technician trainee will now be

required to hold a valid license from the Board to practice.

  • the maximum hour limitation for pharmacy technician trainees

is now 1250 hours or 1 year, whichever period is shorter.

  • Section 8.06 (3) – supervisory ratios would allow one

pharmacist to four support personnel provided two of them are pharmacy interns

247 CMR 8.00 Pharmacy Interns and Technicians

Massachusetts Board of Registration in Pharmacy

8.01 (2): The pharmacy internship shall be performed under the direct supervision of a registered pharmacist preceptor 8.01 (13): A registered pharmacist preceptor shall not directly supervise more than two (2) pharmacy interns at

  • ne time.
  • Skype is NOT direct supervision

247 CMR 10.00 Disciplinary Proceedings

Massachusetts Board of Registration in Pharmacy

  • 247 CMR 10.00 sets forth provisions relating to the

investigation of complaints, grounds for discipline, and disciplinary actions.

  • The new amendments to 247 CMR 10.00 addresses

in detail:

  • Investigations
  • Formal, docketed complaints
  • A licensee’s responsibility to respond
  • Actions available to be taken by the Board on formal, docketed

complaints

  • Summary actions
slide-35
SLIDE 35

5

247 CMR 16.00 Collaborative Drug Therapy Management

Massachusetts Board of Registration in Pharmacy

  • 247 CMR 16.00 sets forth standards and requirements for

pharmacists that enter into collaborative drug therapy management (CDTM) agreements.

  • Many of the changes made to 247 CMR 16.00 were for

clarification purposes. For example:

  • Section 16.2
  • To qualify to enter into CDTM practice: a pharmacist must have
  • completed five years of experience
  • have earned a doctor of pharmacy degree and entered into a

CDTM agreement prior to 1/1/16, or

  • have completed another education or residency criteria that

the Board determines is equivalent to five years of experience

247 CMR 17.00 Sterile Compounding

Massachusetts Board of Registration in Pharmacy

The purpose of 247 CMR 17.00 is to establish minimum professional standards for sterile compounding in order to safeguard the public health and welfare. 17.06: High Risk Level CSPs

  • A pharmacy may not engage in high risk level sterile compounding

until and unless: a) it submits an attestation of intent to engage in high risk level sterile compounding that is signed by the manager of record, pharmacist in charge of sterile compounding, and licensee, as applicable; and b) it receives notification from the Board that the pharmacy achieved a satisfactory Board inspection specifically pertaining to high risk level sterile compounding. All costs associated with inspections of non resident sterile compounding pharmacies shall be paid by the non-resident pharmacy or applicant

247 CMR17.18 Sterile Compounding Facility

1) Buffer Room a) A buffer room shall be at least 144 square feet. b) A buffer room may not contain a sink, drain, or any

  • ther source of water.

c) Buffer room doors shall be hands-free. d) A buffer room shall be supplied with HEPA filtered air. e) A buffer room shall be ISO Class 7 unless the pharmacy is utilizing (f) A buffer room shall be physically separated from the ante room by walls, doors, or pass-throughs.

Massachusetts Board of Registration in Pharmacy

247 CMR17.18 Sterile Compounding Facility

2) Ante Room a) An ante room shall be supplied with HEPA filtered air. b) An ante room shall be at least ISO Class 8. d) An ante room shall be at least 100 square feet. e) An ante room shall have a line of demarcation that separates the less clean area from the more clean area. f) An ante room shall have a stainless steel sink that: 1. is equipped with hands-free controls for water and soap dispensing; 2. has proper depth and capacity for hand washing up to the elbows; 3. is designed or installed to prevent standing water; 4. is located on the clean side of the line of demarcation away from the buffer room door; and 5. minimizes splashing and dripping of water on adjacent walls and floor.

Massachusetts Board of Registration in Pharmacy

247 CMR17.18 Sterile Compounding Facility

  • Ante Room Continued:

g) An ante room sink may not have an aerator mechanism on the nozzle. h) An ante room shall have lint-free, disposable towels located in proximity to sink to minimize water dripping and splashing. i) An ante room may not contain automatic hand dryers. j) An ante room’s plumbing systems shall be maintained in a good state of repair and be free of defects that could create conditions favorable for microbial growth. m) A cart used in the ante room shall be dedicated to one side of the line of demarcation. Only carts dedicated to the cleaner side of the line of demarcation may enter the buffer room after proper cleaning and disinfecting.

Massachusetts Board of Registration in Pharmacy

247 CMR17.22 Sterile Compounding Facility

  • Certification of Classified Areas

1) Primary and secondary engineering controls shall be certified at least:

a) once every 6 months b) whenever a PEC is relocated, added, or removed c) whenever the room is altered d) immediately following any major repair or major servicing of the compounding facility or engineering controls.

Massachusetts Board of Registration in Pharmacy

slide-36
SLIDE 36

6

Proposed New Licensure Categories

Massachusetts Board of Registration in Pharmacy

247 CMR 6.0

Registration, Management & Operation of a Pharmacy

  • Non-resident (retail and compounding, as applicable)

– Required for shipping any medication into MA – Manager of Record must be licensed in MA

  • Sterile Compounding
  • Non-Sterile Complex Compounding
  • Institutional Sterile Compounding
  • Provisional
  • Technician in Training

Massachusetts Board of Registration in Pharmacy

New Individual License

Non-Resident Licensure

  • All retail pharmacies shipping medications into

Massachusetts will require a MA license

  • The Manager of Record of the pharmacy is also required

to have a MA license

  • Additional specialty licensure is required if sterile

compounded and non-sterile complex compounded medications are being shipped into MA

  • Annual report to BORP

– MOR and managers license information – Certify compliance with all regulations – Current home state licensure, certified by home-state Board – List of drugs dispensed to MA

Massachusetts Board of Registration in Pharmacy

  • Required for Sterile Compounding, Non-Sterile Complex

Compounding, & Institutional Sterile Compounding

  • Issued in addition to DS license
  • Inspected yearly, prior to renewal. Non-transferable
  • Information required for annual report to BORP:

– # of prescriptions dispensed – Both in-state and out-of-state – Names of all states shipped to – List of all principal managers and MOR – Names and titles of all employees – Certified compliance with all regulations – CE compliance of MOR and RPhs on staff – Confirmation that all employees are trained

Massachusetts Board of Registration in Pharmacy

Specialty Licenses Institutional Sterile Compounding

Institutional pharmacies (hospital), which have not been previously regulated by the Board of Pharmacy, will now be required to obtain a separate “Specialty” license if they engage in sterile compounding.

Massachusetts Board of Registration in Pharmacy

Provisional Licensure

  • For pharmacies that fail to meet standards, but show

substantial compliance, and demonstrate the potential to achieve full compliance within the provisional period

  • Bridge license for those who attest to substantial

compliance prior to physical inspection

  • One-time issued license that is valid for up to 1 year
  • License may not be renewed or extended

Massachusetts Board of Registration in Pharmacy

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SLIDE 37

7

Common Deficiencies Found During Pharmacy Inspections

Massachusetts Board of Registration in Pharmacy

Common Deficiencies

Some of the most common deficiencies seen during pharmacy compliance inspections by investigators involve:

  • Perpetual inventories
  • Biennial inventories
  • Refrigerator issues
  • Pharmacy operations
  • Pharmacy staffing
  • Improper labeling
  • Compounding records

Massachusetts Board of Registration in Pharmacy

Perpetual Inventory

  • According to 247 CMR 9.10 (14), a pharmacy must

maintain a perpetual inventory of all Schedule II controlled substances that is in its possession, including those received, dispensed, or disposed of.

  • Perpetual inventories must be performed at least once

every 10 (ten) days.

  • This inventory must be kept for ALL Schedule II’s in

possession, even those that are expired or

  • rdered/received in error.

Massachusetts Board of Registration in Pharmacy Massachusetts Board of Registration in Pharmacy

Expired Schedule II’s not included in the perpetual inventory ALWAYS make sure they are included in your inventory!!!!

Biennial Inventory

  • A pharmacy must perform a biennial inventory of

controlled substances (Schedules II –V) in accordance to 21 Code of Federal Regulations § 1304.11.

  • This must be performed every 2 years and be readily

retrievable.

  • Schedule II: these substances must have an EXACT

count or measure of its contents

  • Schedules III - V: these substances may have an

estimated count performed UNLESS the container holds more than 1,000 tablets or capsules, in which an EXACT count is required.

Massachusetts Board of Registration in Pharmacy

Reports of Thefts/Losses

  • According to 247 CMR 6.02 (10), a pharmacy shall report

any loss of controlled substances deemed to be a significant amount.

  • The DEA must be notified in writing immediately (within 1

(one) business day)

  • A copy of DEA Form 106 (Report of Theft or Loss of

Controlled Substances) must be submitted to the Board.

  • An online “e-version” of the DEA 106 Form can be found

at: www.Deadiversion.usdoj.gov

Massachusetts Board of Registration in Pharmacy

slide-38
SLIDE 38

8

Massachusetts Board of Registration in Pharmacy

Example of the DEA 106 Form, “Report of Theft

  • r Loss of

Controlled Substances”

Pharmacy Operations

  • Policy NO. 2011-01:”Proper Storage of Refrigerated and

Frozen Medications in a Pharmacy”, was adopted by the Board on March 8, 2011.

  • The following standards of practice were implemented:
  • The use of single door refrigerators with an internal

freezer compartment were eliminated

  • Manual logs or digital thermometers with alarms were

used to ensure proper temperature maintenance

  • Policies were developed to handle out of range

temperatures

  • Pharmacy personnel were educated on proper use and

maintenance of equipment (i.e. no food products stored with medication)

Massachusetts Board of Registration in Pharmacy

Acceptable Forms of Refrigeration

Massachusetts Board of Registration in Pharmacy

Combination Refrigerator / Freezer Stand-alone freezer Stand-alone Refrigerator

Unacceptable Practices

Massachusetts Board of Registration in Pharmacy

Pharmacy Operations cont.

  • Another common deficiency seen during inspections is

the improper dispensing/storage of expired medication.

  • Per 247 CMR 9.01(10), a pharmacy shall not dispense
  • r distribute expired/outdated drugs.
  • Expired/outdated medication must be quarantined and

separated from the regular inventory.

Massachusetts Board of Registration in Pharmacy

Prescription Processing/Work flow

  • According to 247 CMR 6.01(5)(b), a pharmacy must

facilitate proper preparation and compounding of prescribed medications; and provide for an arrangement and storage of drugs that is calculated to prevent accidental misuse.

Massachusetts Board of Registration in Pharmacy

vs.

slide-39
SLIDE 39

9

Pharmacy Staffing

  • Per 247 CMR 8.06, a pharmacy may utilize support

personnel (pharmacy interns, certified pharmacy technicians, pharmacy technicians, and pharmacy technician trainees) in accordance to regulatory ratio requirements.

  • The MOR is responsible for the maintenance of adequate

staff in the pharmacy.

  • A registered pharmacist may not work more than 12

hours per day according to 247 CMR 6.02 (8)(C).

Massachusetts Board of Registration in Pharmacy

Pharmacy Staffing

  • A common deficiency seen is in regards to staffing ratios.
  • Per the 247 CMR 8.06 (3) draft regulations, a pharmacist

utilizing support personnel must do so with the following ratio requirements:

  • 1. One pharmacist for a maximum of four support personnel

provided:

  • a. At least one of the four support personnel is a certified

pharmacy technician and one is a pharmacy intern; or

  • b. At least two of the support personnel are certified pharmacy

technicians; or

  • c. Two of the support personnel are pharmacy interns.
  • 2. One pharmacist for a maximum of three support

personnel, provided at least one of the three support personnel is a pharmacy intern or a certified pharmacy technician.

Massachusetts Board of Registration in Pharmacy

Improperly Labeled Inventory

  • According to 247 CMR 9.01 (3)(10), a pharmacy shall provide

adequate procedures for insuring that all medication are accurately labeled and that for any medications dispensed, the medications include an accurate beyond use date and lot number.

  • A pharmacy must also comply with patient packaging standards in

accordance to Board Policy 98-011 (i.e. med paks)

  • A patient’s name should NOT be left on any return-to-stock (RTS)

medication bottles.

Massachusetts Board of Registration in Pharmacy

Examples of Improper Labeling

Massachusetts Board of Registration in Pharmacy

Compounding

  • Per 247 CMR 9.01 (3), community pharmacies must observe current

USP non-sterile compounding standards (USP 795).

  • Some examples of non-compliance include:
  • Failing to provide enough space for a designated compounding

area

  • Failing to maintain the necessary equipment to conduct

compounding (i.e. balance, sink, etc.)

  • Incorrectly assigning beyond-use-dates (BUDs) for specific

compounds

  • Failing to utilize compounding logs to record all preparations

Massachusetts Board of Registration in Pharmacy

Examples of Compounding Deficiencies

Massachusetts Board of Registration in Pharmacy

slide-40
SLIDE 40

10

“Above Action Level Results” For Compounding

Massachusetts Board of Registration in Pharmacy

“Above Action Level Results”

  • According to Draft Regulation 247 CMR 17.27 (1), “a pharmacy shall

take immediate remedial actions in the event that environmental monitoring results exceed action levels.”

  • The categorization of “Action Levels” by ISO Class and environmental

monitoring (EM) testing methods are as follows:

  • Massachusetts Board of Registration in Pharmacy

“Above Action Level Results”

  • Massachusetts Board of Registration in Pharmacy

“Above Action Level Results”

  • Per the Draft Regulation 247 CMR 17.28, some examples of what must be

done in order to remediate above action level environmental monitoring results are:

  • A pharmacist MOR or designee must notify the Board via email within 24

hours of receiving notification of above action level results.

  • A “Disclosure of Above Action Level Results” and microbiology reports must

be submitted to the Board within 7 days.

  • A pharmacy must immediately assess these above action level results and

may not prepare any CSPs until a remediation plan has been developed and implemented in accordance with “Board Policy 2015-xx: Response to Above Action Level Environmental Monitoring Results.”

  • A pharmacy must engage and work with qualified personnel to develop a

viable remediation plan.

  • A pharmacy shall submit a completed remediation plan, along with reports

from repeat environmental monitoring to the Board within 20 days of the initial notification of results.

  • A pharmacy shall demonstrate successful remediation by performing

repeat environmental monitoring of non-viable air, viable air, and surface (bacterial and fungal) as part of the remediation process.

  • Massachusetts Board of Registration in Pharmacy

“Above Action Level Results”

  • According to Draft Regulation 247 CMR 17.27 (1), “a pharmacy

shall take immediate remedial actions in the event that environmental monitoring results exceed action levels.”

  • Some of these actions are:
  • A pharmacist MOR or designee must notify the Board via email

within 24 hours of receiving notification of above action level results.

  • A “Disclosure of Above Action Level Results” and microbiology

reports must be submitted to the Board within 7 days.

  • A pharmacy shall submit a completed remediation plan, along with

reports from repeat environmental monitoring to the Board within 21 days of the initial notification of results.

  • A pharmacy shall demonstrate successful remediation by

performing repeat environmental monitoring of non-viable air, viable air, and surface (bacterial and fungal) as part of the remediation process

Massachusetts Board of Registration in Pharmacy

LEAN Concepts

Massachusetts Board of Registration in Pharmacy

slide-41
SLIDE 41

11

What Are Lean Concepts?

Massachusetts Board of Registration in Pharmacy

  • Lean is a systematic approach of eliminating and preventing waste in

every step of a process, in order to create value.

  • Lean is best implemented via a structured training program designed

through careful inspection of current workflow and operational systems to identify where improvements can be made.

  • Some examples of possible waste in the pharmacy practice setting are:
  • Correction: adverse drug events, medication errors
  • Overproduction: drugs returned to the pharmacy
  • Motion: poor pharmacy layout
  • Waiting: imbalanced workload, low productivity
  • Lack of standardization: performing tasks differently every time
  • These are all “wastes” that can potentially be eliminated in pharmacy

practice by utilizing Lean concepts.

LEAN Policy

Massachusetts Board of Registration in Pharmacy

  • During the most recent Board Meeting on August 30, 2016, Policy No.

2016-03: “An Introduction and Guide to the Practice and Implementation of Lean Concepts in a Pharmacy Setting”, was approved by the Board.

  • The purpose of this policy is to set forth guidance for pharmacies in

implementing Lean concepts training as stated by Chapter 159 of the Acts of 2014.

  • Per Chapter 159, sterile compounding, complex non-sterile

compounding, and institutional sterile compounding pharmacies shall ensure that their employees are trained in lean concepts before renewing their pharmacy license.

  • Upon renewal of a pharmacy license, the Pharmacy MOR shall attest

that their employees have been trained in these concepts.

Advisories

Massachusetts Board of Registration in Pharmacy

Staff Ratio Advisory

There is currently an Advisory on Staff Ratios available on the MA Board of Registration in Pharmacy website. For more information, please visit: http://www.mass.gov/eohhs/gov/dep artments/dph/programs/hcq/dhpl/pha rmacy/alerts/pharmacy-board- advisories.html

Massachusetts Board of Registration in Pharmacy

Manager of Record

  • A Manager of Record (MOR) for a pharmacy has many

responsibilities including:

  • The security and storage of controlled substances
  • Monitoring and enforcing policies and procedures
  • Having oversight of all staff and making sure they have active

licenses and are in good standing

  • Renewing the license for the pharmacy
  • Training pharmacy technicians and record keeping
  • Scheduling of support personnel and ensuring proper staffing
  • f the pharmacy
  • And many more..

Massachusetts Board of Registration in Pharmacy

New Managers of Record Advisory

Massachusetts Board of Registration in Pharmacy

Just like the Advisory on Staff Ratios, there is currently an Advisory for New Managers of Record available on the MA Board of Registration in Pharmacy website. This advisory discusses and serves as a reminder of some of the additional responsibilities required of new MORs. For more information, please visit: http://www.mass.gov/eohhs/gov/dep artments/dph/programs/hcq/dhpl/pha rmacy/alerts/pharmacy-board- advisories.html

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Pre-Filled Insulin Advisory

Massachusetts Board of Registration in Pharmacy

  • Reminds licensees of

regulations surrounding sterile compounding.

  • Cannot pre-fill insulin syringes

unless doing so in a Board approved clean room.

For more information, please visit: http://www.mass.gov/eohhs/gov/dep artments/dph/programs/hcq/dhpl/pha rmacy/alerts/pharmacy-board- advisories.html

Mandated Reporting Forms

Massachusetts Board of Registration in Pharmacy

  • Mandatory Disclosure Form
  • Serious Reportable Events
  • Loss of Controlled Substance

BORP Reporting Form

  • Disclosure of Abnormal Results

Form

  • Sterile Compounding Reporting

Form

  • Excel Spreadsheet for CSP

Prescriptions

  • Above Action Level EM Initial

Reporting Form

  • Above Action Level EM Final

Reporting Form

For more information, please visit:

http://www.mass.gov/eohhs/gov/departme nts/dph/programs/hcq/dhpl/pharmacy/man dated-reporting-forms-.html

Contact Info

Massachusetts Board of Registration in Pharmacy 239 Causeway Street- 5th Floor Boston, MA 02114 (800) 414-0168 Website: www.mass.gov/dph/boards/pharmacy Email: pharmacy.admin@Massmail.state.ma.us

Massachusetts Board of Registration in Pharmacy

Prescription Monitoring Program:

The Massachusetts Prescription Monitoring Tool (MassPAT)

Massachusetts Department of Public Health

November 8, 2016

  • Describe the impact of MassPAT on the prescribing

and dispensing communities and how pharmacists are crucial players.

  • Identify and utilize the interstate data sharing

functionality, taking advantage of operational efficiency.

  • Explain the impacts to the Prescription Monitoring

Program pursuant to Chapter 52 of the Acts of 2016, An Act relative to Substance Use, Treatment, Education and Prevention.

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Key Points

Health Care Providers

  • Prof. Boards

State Linkages in Opioid Epidemic

Drug Treatment

PMP is a component in the larger opioid effort

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Introduction to the Prescription Monitoring Program (PMP)

  • The MA PMP collects dispensing information on

Massachusetts Schedule II through V controlled substances dispensed pursuant to a prescription.

  • The Department analyzes PMP data to:
  • Determine prescribing and dispensing trends;
  • Provide patient prescription history information to prescribers and

dispensers;

  • Provide educational information to health care providers and the

public; and to

  • Provide case information to regulatory and law enforcement

agencies concerning drug distribution and diversion.

  • To fulfill this mission, the Department operates two tools:
  • PMP Clearinghouse – dispensed prescription data
  • MassPAT – patient prescription history

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What is Prescription Monitoring Program (PMP)?

  • The PMP Clearinghouse is a tool pharmacies use to submit dispensed

prescription data.

  • Pharmacies are required to report data within 24-hours or no later than

the next business day.

  • The PMP Clearinghouse went live on May 31, 2016.
  • Data submission requirements are detailed in the Data Submission

Guide

  • Outpatient pharmacies
  • Retail pharmacies
  • Clinic pharmacies
  • Veterans Affairs outpatient pharmacies
  • Out-of-state mail order pharmacies
  • Hospital medical orders filled for inpatients are not reported to the

PMP

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What is PMP Clearinghouse? Where does the data come from?

  • MassPAT is an online tool utilized by authorized providers that

supports safe prescribing and dispensing of Schedules II – V controlled substances.

  • By viewing a patient’s prescription history in the system, a provider

can avoid duplication of drug therapy and coordinate care by communicating with other providers to improve clinical outcomes and

  • verall patient health.
  • Utilization of MassPAT can also enable early identification of potential

prescription drug misuse, abuse or diversion and trigger early intervention.

  • Register online today for MassPAT! www.mass.gov/dph/masspat
  • All Schedules II-V controlled substances dispensed in the last 12

months to patients in Massachusetts.

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What is the Massachusetts Prescription Awareness Tool (MassPAT)? What data are available in MassPAT?

  • Doctors (MD, DO)
  • Pharmacists
  • Dentists (DMD, DDS)
  • Physician Assistants
  • Nurse Midwives, Nurse Antsiest, Nurse Practitioners
  • Medical Residents with Prescriptive Authority
  • Authorized Delegates (licensed (i.e. RN) and unlicensed)
  • Boards of Registrations
  • Law Enforcement agencies
  • As of October 15, Prescribers must check MassPAT each time the

prescriber issues a Schedule II or III narcotic to a patient. Prescribers must continue to check MassPAT the first time they prescribe to a patient a benzodiazepine.

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Who can access MassPAT? What is the required use of MassPAT? MassPAT since go-live

85 46,597 Accounts in MassPAT as of 10/21/16

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87

Massachusetts Prescription Awareness Tool (MassPAT)

Website: www.mass.gov/dph/dcp/pmp

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Available 24/7

MassPAT System Preview: Registration Page

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Click create an account to begin your MassPAT registration process

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BORIP, Pharmacy DEA(s) Professional license, Pharmacy DEA Pharmacy DEA

MassPAT Roles

Professional license, Pharmacy DEA

MassPAT System Preview: Pharmacist Enrollment

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Can enter multiple DEAs, if applicable Enter FN & LN as it appears on professional license Enter BORIP number. Optional NPI & NCPDP

MassPAT System Preview: Patient Search

Can select other states to search Partial spelling

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DOB always required Can conduct searches within past year

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Connecting with available PMPi & RxCheck states

PMPi connectivity with MassPAT

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VA PA NC MI WV KY LA AR MN OK NV CA ID AL AZ CO FL GA IA IL IN KS MO MS MT ND NE NM NY OH OR SC SD TN TX UT WA WI WY AK HI DC NJ MD RI VT ME DE NH MA CT PMPi state RxCheck state Implementing PMPi Source: Brandeis Center of Excellence & IJIS Jan 28, 2016 and NABP June 23, 2016 Legal barrier/no data sharing option

MassPAT System Preview: Patient Report

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4 expandable sections

MassPAT System Preview: Patient Report

Columns are sortable Can export report Drop down view of all patient name variations

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Patient summary information Displays search criteria

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MassPAT System Preview: Search History MassPAT since go-live

98 MassPAT Registration Communications

**MassPAT Searches excludes: Saturdays, Sundays, Labor Day & Columbus Day 9/12* 9/14 9/19 9/21 10/11 10/14

MassPAT Enrollment & Searches since Go-Live as of 10/21/2016

MassPAT since go-live

99 141,410 Patient Searches Conducted in MassPAT from 10/14/2016 to 10/21/2016

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101

Data Submission - PMP Clearinghouse

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Data Submission Requirements

Dispensers in MA and dispensers who deliver Schedule II ─ V prescriptions to MA are required to report controlled substance dispensation data by the end of the next business day to Appriss’ PMP Clearinghouse, as an agent of the Department.

  • A zero report must be reported on days when no

controlled substances were dispensed.

  • A waiver may be issued to a dispenser when a report

is not required due to a lack of dispensing on given days.

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Pharmacies are critical partners in ensuring data accuracy

Most common errors: 1. Prescriber Information:

  • a. Drug Enforcement Administration (DEA) number (PRE 02)
  • b. Name (PRE 05 & 06)

2. Patient Address

  • 3. Pick-up/Drop-off Relationship to Patient
  • 4. Payment Type

Please work with your pharmacists to ensure they are entering the right information.

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Prescribers can self audit: My Rx functionality

Select the DEA number(s) you’d like to search Select the date range (within past year) Option to search by drug name

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Prescribers may call you if they see errors in the data

Can sort by date, patient, birth year, drug name, days supply & pharmacy Lists all prescriptions written in past 12 months Can export PDF

  • r CSV file

Questions, comments?

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