The voice for pharmacy compounding | March 19 , 2021


From APC’s President
Shipping happiness
Dear A4PC,

Michael Blaire, RPh, FIACP
APC President
After debuting as the highest-ranking newcomer in Fortune magazine's annual "Best Companies to Work For" list in 2009, Zappos was acquired by Amazon in a deal valued at over $1.2 billion.
In his book Delivering Happiness, Zappos CEO Tony Hsieh shares the different lessons he learned in business and life, from starting a worm farm as a child, to building and selling LinkExchange and ultimately taking on a struggling shoe store and turning it into an online sensation. The story (when Mr. Hsieh is not congratulating himself and his company) is entertaining, insightful, and continually demonstrates how, by concentrating on the happiness of those around you, you can increase your own happiness — and profits — as well.
But one can only wonder how different this story would be if the federal government told Mr. Hsieh that he could only ship five percent of his products out of state. For that matter, would the online behemoth known as Amazon exist if the government had capped the amount of its products that could be shipped interstate? My pharmacy was exclusively veterinary, yet almost 80 percent of our prescriptions were shipped out of state.
The happiness lesson
My pharmacy’s shipping department had a shelf that contained boxes of treats for dogs, cats, horses, and even for the occasional bird, reptile, or pocket pet. Every prescription that left our pharmacy contained the appropriate treat. In our waiting room there were several bulletin boards filled with hundreds of “Thank you” notes and pictures of our patients — and more than 90 percent of those cards mentioned the treat. That’s delivering happiness!
My point is that compounding pharmacists have always known what it took Tony Hsieh two decades to learn: We take care of our patients and we improve their quality of life, whether they’re standing in our waiting rooms or live on the other side of the country. Which is why I need to bring up the FDA’s MOU again.
If you ship prescriptions out of state, your practice — and your patients’ quality of life — is at risk. Since I issued my call to action last month (remember the Uncle Sam poster?) we have received information that several of the most populous states in the union are saying that they will not sign the MOU. If you practice in California, Texas, New York, or Florida, your practice is being threatened.

In its assessment to OMB, FDA said it expected five states would not sign. Unfortunately, not all states are equivalent. Idaho, for example, said it won’t sign because there are only four compounding pharmacies in the state and none of them ship interstate. Compare that to Texas, a state that’s home to hundreds of compounding pharmacies, many of whom do ship out of state.
We still need you to contact your state boards of pharmacy, especially if you live in the states mentioned above. Let them know your situation, the populations you serve, and the number of people you employ. Respectfully request that they notify NABP of your concerns and explain why they are unable to sign. NABP needs to hear from every board of pharmacy, and FDA needs to hear from NABP. This shoe does not fit!
Michael Blaire is APC’s president, but his day job is vice president for government and regulatory affairs at Wedgewood Pharmacy in Scottsdale, Arizona. You can reach him at mblaire@wedgewoodpharmacy.com.
This Week
Halfway home (and a long way to go)
First: We’re only about two weeks away from the release of the Pharmacy Compounding Foundation’s third-party, independent analysis of the NASEM cBHT report. The PCF analysis is expected to serve as a much-needed counterweight to the FDA-manipulated NASEM report and should provide a more objective view of compounded hormone therapy. At the proper time, we’ll be asking for your help in using it to educate policymakers about compounded hormones, so stay tuned.
Next: APC’s much-awaited cBHT media campaign — through which we aim to show the human face of compounded hormone therapy — is also set to launch in early April. Finishing touches are being put on the landing page, digital ads, and materials we’ll be providing to compounders like you to inform patients and prescribers about the effort. It’s going to be great (if we do say so ourselves), and we can’t wait to show it to you.
But then: There’s the matter of funding it all. As the headline above says, we’re halfway home: We’ve raised just north of $800,000 of the needed $1.5 million to fund the media campaign, and most of that has come thanks to about 140 individual compounders like you. But there’s a long way to go to get to the goal, and if we don’t accomplish it in the next 75 days or so, we’ll be unable to afford the digital ad placements that are the crux of the campaign.

Yes, we are beginning outreach to vendors and institutions to ask for their financial support. But we also ask that you consider a monthly investment in the campaign of $250 or $500 or even $1,000 to help us achieve the goal. Think about the impact on your compounding business that the loss of cBHT would wreak — and then give to this campaign in proportion to that threat. Consider committing just ONE PERCENT of the revenue you’ll receive from cBHT this year. You can do that at A4PC.org/cbhtcampaign.
One more thing: Here’s a cBHT campaign fundraising piece you can share with vendors and prescribers you work with to urge them to invest in the effort.
Like we said, we’re halfway home, and that’s great. We’re counting on you to help us go the rest of the way.
New member resource: Know the kickback laws
As the country moves towards a "value-based" healthcare model, there's a greater chance of providers bumping into issues with either the Stark anti-self-referral law or federal anti-kickback statutes.
Knowing how interpretation of those laws has changed is crucial for pharmacists. A good starting point is a new document from APC: a white paper from the attorneys at Brown and Fortunado, "Changes to Stark and the Anti-Kickback Statute." You can read or download it on APC's website at A4PC.org/stateside, along with other public and members-only resources.
EduCon: It ain't over till it's over
But time is running out to take advantage of all the EduCon session content.
Don't forget, you can still "attend" EduCon 2021 Virtual and get all that sweet, sweet CE credit — but only until April 4. So if you didn't catch it live, no worries! Head over to A4PC.org/educon, register, and check out those great sessions while you still can!

HOLY MOLY! Owner Summit sold out!
APC's first (annual?) Owner Summit has sold out — we've reached the max capacity for our space with well more than 100 attendees. We hoped to create a program that would give compounder owners the information they need and the information they want, and it looks like we nailed it.
(If you miss the conference, you can still keep tabs: Follow us on social media (@a4pcrx), where we'll be live-posting about the sessions — the Twitter hashtag will be #apcownersummit.)
We're already thinking of how we can top this for 2022....
Coming Up
SOLD OUT March 26–27, 2021 — APC’s 2021 Compounding Pharmacy Owner Summit
April 6, 7, 8 — USP webinars on chapters <797>, <800>, and <795>, respectively
April 13; 2:00-3:00pm EDT — CE webinar: "Pharmacy Fulfillment for Consumer-Focused Telehealth Platforms"
June 10–11, 2021 — PCCA Act Conference (virtual)
June 16–17, 2021 — Compounding Pharmacy Compliance Virtual (APC members: Use code APC10 for 10% off registration!)
September 14–15, 2021 — Compounders on Capitol Hill (mark your calendars!)
September 22–24, 2021 — Compounding Pharmacy Compliance East
Short Takes
Medicare reimbursement: Good news for indy pharmacies, which had been getting the short end of the stick when it came to Covid vaccine reimbursement will see a big change: The Biden administration has raised Medicare reimbursement from $23 to $40 per shot.
Scam calls: The Arizona State Board of Pharmacy is warning pharmacists about fake calls from people claiming to be with the state board of pharmacy staff or law enforcement. Of note, these calls “spoofed” the board’s phone numbers so CallerID doesn't help. So, pro tip, in Arizona and elsewhere: Be wary about these calls, especially if they threaten your license or ask for money. (You can read the notice from the Arizona BoP here.
Three easy pieces:
If you were staring into the fridge thinking, “What three things can an independent pharmacy do to compete with Amazon?” you’re in luck: Forbes has an answer.
Vaccine secrecy: Fearing accusations of line-cutting, or having to reveal a diagnosis, “People Are Keeping Their Vaccines Secret.”
Pharmacy law scholarship: If you're a pharmacist attending law school, the American Society for Pharmacy Law has a scholarship you might be interested in. The $5,000 Fink Family Scholarship is for a pharmacist attending law school. Learn the details and see if you're eligible.
FDA’s smoking gun: The FOIA request from a coaltion of compounders revealed the startling depth of the FDA’s (inappropriate!) involvement in the NASEM report on cBHT. Read what those documents showed, and how the coalition’s attorney responded at A4PC.org/smokinggun.
Don't forget to download, print, and display the new APC Compounder’s Code of Ethics at A4PC.org/downloadthecode.
And don't forget to share with your team Jon Pritchett’s powerful video, "The APC Code of Ethics: Ensuring Your Reputation and Legal Standing" on APC’s updated Code of Ethics page.
