Compounding Pharmacies and Fraud, Waste & Abuse

Compounding Pharmacies / FWA

- Compound Requirements

- Must be for medications for specific patients, for a specific condition, for a specific prescription

- Compounding in bulk for multiple patients before prescriptions are received is manufacturing!

- Limits

- Patients will probably not know

- Prescriber will not know unless they have a commercial arrangement with the pharmacy

- Health Plans will only know when doing analysis of medication utilization

- PBMs will only know when doing analysis of medication utilization

- What are compounds?

- Injectables with custom ingredients and dosing

- Oral tabs/caps with non-manufactured ingredients

- Oral liquids for custom dosing

- Topical medications in different bases for better absorption or non-allergic

- What are compounding pharmacies?

- Regulated by State laws

- Rationale:

- Children’s medications

- Allergic modifications

- Dosing modifications

- Mixing injectables

- Animal treatments

- Misc.

- Limits on compounding

- PBM restrictions on medications currently manufactured

- State oversight

- Lack of absorption or effectiveness

- FWA

- Small % of total dispensing

- Physician prescribing for custom medications with a commercial motive

- Pharmacists dispensing/manufacturing for multiple patients for custom medications with a commercial motive

- Sterility problems

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