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            The voice for pharmacy compounding │ 22 March 2024             

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From our Board Chair

Damned if we do, damned if we don't

Let’s say you’re APC. You get a call from a producer at a major news network saying that their celebrity medical doctor is doing a story on GLP-1 drugs and wants to include compounded GLP-1s in the piece. You spend over an hour on the phone briefing her, and you can tell she’s impressed with what she’s learning about compounding. She says the celebrity doc likes compounding, that it will be sympathetic coverage, not a hit job.

Then she asks what you knew all along she was going to ask: Can you recommend a pharmacy that compounds GLP-1s that would let us bring a camera crew to film that process, maybe interview the pharmacist? 


What do you do? Well, if you’re our APC staff you pause, because you know a few things.


You know that this could be a great opportunity to showcase compounding, to get sympathetic coverage that millions will see. 


And yet you know that sterile compounding pharmacy owners aren’t likely to want cameras in their compounding labs – FDA could be watching, right?


You also know those owners prefer to keep their heads down, not to draw the attention of drugmakers that would come with a nationally televised news story – and not just attention but a possible lawsuit – even though the pharmacy is 100 percent compliant with law and reg.


And yeah, you know that not just any sterile compounding pharmacy will do. Pharmacies with a recent FDA 483 or warning letter won’t do. Neither will a pharmacy that persists in advertising peptides that don’t meet the criteria for compounding. Because those things would certainly come out in the news story and would not be helpful.


But … You also know that if you don’t recommend the right compounding pharmacy, that producer will likely go out and find one on her own … and it may just be one of those pharmacies with FDA citations or reputations for skirting the rules.


So with all of that in mind, you pick up the phone, and you begin to beg and plead and cajole, only to be told no again and again and again.


I’d love to tell you this is all hypothetical, but it’s an accurate depiction of events of the past three weeks or so for our staff team.


And for me it’s the reminder that as a profession, we’re damned if we do, damned if we don’t. Damned with a lawsuit if we tell our story, damned with inaccurate reporting or the airing of dirty laundry if we don’t. The risks are high either way, of course, but we all tend to lean toward “don’t.”


Speaking just for myself, I’m beginning to rethink whether that’s the better answer. Maybe you, too. If so, let me hear from you. Because the media is still calling. And we need to seize opportunities when they present themselves.

 Joe


Joseph P. Navarra, RPh, FACA, FAPC is the owner of Town Total Compounding Center in Woodbury, New York. You can reach him at joseph.navarra@towntotalcompound.com.

ICYMI


This week's news

FDA wants to issue guidance docs without public comment


In a draft report and plan for guidance documents released by FDA earlier this year, the agency indicated that it intends to issue guidance documents without a public notice and comment period. The draft report is in response to a 2023 federal spending law that requires FDA to identify best practices for prioritization, development, issuance, and use of guidance documents.


“This is one of the more worrisome proposals we’ve seen from FDA,” said APC’s Tenille Davis. “The FDA staff is not all-knowing, and short of a national emergency, FDA needs to hear from stakeholders. That input can only serve to improve FDA guidance documents.”


According to FDA’s draft plan, the agency is considering issuing more Level 1 guidance documents for immediate implementation and categorizing more guidance documents as Level 2 — meaning more guidance documents would be implemented without a prior public comment period. 


The draft report received significant industry pushback, however — with some commenters indicating that this would open FDA up to legal challenges for failing to follow guidance regulation — so we’ll see if the agency moves forward with their plan. 


APC plans to raise the issue in its next listening session with the agency, set for May.

Wedgewood is APC's newest Silver-level supporter

Long-time APC supporter Wedgewood Pharmacy, a compounder focused exclusively on animal health, is our newest 2024 Silver-level Corporate Patron — a $25,000 commitment.


“I’m grateful to Wedgewood CEO Marcy Bliss and her team for this vote of confidence in APC,” said APC’s Scott Brunner. “It’s just the latest in the multitude of ways Wedgewood has supported our work over many years.”

10 days left to apply for APC Fellowship

Since the program’s inception in 1997, 162 professionals have been honored as APC Fellows. Tara Thompson, vice president of clinical and marketing at Revelation Pharma, is one of those professionals: 


“Becoming an APC Fellow has been a transformative experience. It's more than just an opportunity; it's a privilege to be part of a distinguished community dedicated to advancing the field of compounding pharmacy. This program has provided me with unparalleled mentorship, resources, and networking opportunities, empowering me to deepen my understanding and expertise in this specialized area of pharmacy practice.”


The deadline to apply for 2024 induction is March 31, so review the information on the APC Fellows webpage and start your application now. The induction will take place at APC’s Compounders on Capitol Hill event in September.

Yes, we're reviewing that 'demonstrably difficult' proposed rule

It’s been breathlessly anticipated for months, and this week it finally published: an FDA proposed rule regarding the Demonstrably Difficult to Compound list.  


First: It does not restrict compounded hormone therapy, as some feared it might. FDA CDER OCQC Director Gail Bormel had hinted in comments at last years’ Compounders on Capitol Hill event that the rule would not affect compounded hormones. (But that sure doesn’t mean the threat to restrict compounded hormone therapy has gone away.)


So: The proposed rule would classify as "demonstrably difficult to compound" three particular types of compounding: oral solid modified-release drug products that employ coated systems; liposome drug products; and drug products produced using hot melt extrusion. 


APC is still evaluating the proposed rule, in particular the six criteria the FDA indicates it will use to evaluate inclusion of additional substances on the Demonstrably Difficult to Compound List. Stay tuned.

Short takes

Korbutov joins ASKP3’s Expert Faculty. Jack Korbutov, president of APC PFM member The Art of Medicine in Philadelphia, has become the only pharmacist serving as Expert Faculty for the American Society of Ketamine Physicians, Psychotherapists, and Practitioners. Congrats, Jack. (He’s also on a panel at Owner Summit discussing our soon-to-be-released document on best practices for ketamine compounding.)  


FDA launches a new portal for reporting potential drug shortages. The portal expands access to CDER’s NextGen system and allows patients, providers, and professional organizations to report directly into the NextGen system without needing a NextGen account.

Tenille visits Wells. APC’s Tenille Davis visited APC PFM member Wells Pharmacy Network, in Ocala, Fla., this week for a tour. Thanks to the Wells team for hosting her.


Attending the APhA Convention this weekend? Drop by our booth (837) in the exhibit hall. And tell any students to drop by, too — we have a deal just for them on our 15-hour compounding course. 


Planning to attend AMMG in Miami? As an APC member, you can get 20% off the 3-day conference price with code ACR. We’ll be exhibiting there, too, so look for us.

Save these dates

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Quick links

APC Career Center

• Job seekers

• Employers


APC's Code of Ethics


Compounding Connections archive


Compounders on Capitol Hill


Continuing education

• Live webinars

• On-demand webinars


Current issues:

GFI #256 on animal compounding

Urgent-use compounding (HR 167)

Adverse events reporting framework 

Saving compounded hormones


EduCon


Owner Summit


Prescriber Briefing Resources


Invest in APC efforts

• CompPAC

• Campaign to save cBHT

• OneFund


Membership

• Renew

• Pharmacy/Facility Membership (PFM)

• APC Logo agreement for PFMs

• APC Logo agreement for individual members


Affinity service providers

Accounting & Tax Services: Rx Advisors

Audible Sunshine

Office Equipment: TUI Solutions

Online Payments Platform: HealNow

Patient-Reported Outcomes: OutcomeMD

Pharmacy Technician Certification Board

• Shipment Trackers, a shipping costs auditor 

• TUI Total Solutions

• TxtSquad


Alliance for Pharmacy Compounding | A4PC.org

APC is committed to addressing any concerns or complaints within one business day. Please send them — and, of course, any compliments — to info@a4pc.org.

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