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The Total Points (Denominator When Calculating Grades) Is 100. Each Question Is Worth 1.25 Points Including The Extra Credit
The Total Points (Denominator When Calculating Grades) Is 100. Each Question Is Worth 1.25 Points Including The Extra Credit
Exam Breakdown: 80 questions with 1 extra credit question; the breakdown below is an approximate
range for each lecture to get to 80 questions. The total points (denominator when calculating grades) is 100.
Each question is worth 1.25 points including the extra credit.
Lecture 1 ~ 12 - 16 questions
Lecture 2 ~ 15 - 17 questions
Lecture 3 ~ 15 - 17 questions
Lecture 4 ~ 15 - 17 questions
Lecture 5 ~ 15 - 17 questions
Lecture I
US
Constitution
CMS
1. Human Health Services: FDA and CMS (Medicaid and Medicare) 2.
Dep of Justice: DEA, FBI, ATF (alcohol, tobacco, and firearms)
3. FTC
4. SEC (corporations)
5. Homeland Security: Coast Guard and FEMA What are the
state federal agencies that we have talked about?
▫ i. More AZ State board of Pharmacy, AZ department of Health Services, AHCCCS
Specifically:
1. Arizona Dept of Health Services (ADHS)
2. DPS: Sheriff and Local Police
3. AZ Attorney General
4. ASBP (pharm board)
5. AHCCCS
hastobewithin
Who is involved in a criminal case? samestatetofollow
▫ State & accused
Who is involved in a civil case?
▫ Plaintiff & defendant
In a criminal case, what is the determinant?
▫ Guilty beyond reasonable
▫ Determined by doubt courts
Where does congress derive its authority for drug distribution from what piece?
▫ (of the US Interstate commerceConstitution)
▫ Can clause apply to foreign nationals, US States,
and Indian Tribes What does the supremacy clause of the constitution mean?
▫ Whichever is stricter is the one that takes precedence
Did the food drug and cosmetic act (FDCA) originate the definition for misbranding and adulteration or
expand it?
T/F: Medical Device Amendment was the first law to give extensive authority over medical devices?
▫ TRUE
▫ Before this law, FDA had little authority over devices
i. We can now have classification of devices by function AND risk, premarket approval and
testing, est of performance standards, conformance with GMP reg, adherence to record and reporting
requirements ii. Class I (low risk, needles, gloves)- Class III (high risk, like pacemakers, and valves)
Under the Prescription drug marketing Act (PDMA)/ Dingle Bill, can hospital resell drugs purchased
from manufacturers and wholesalers to community pharmacies?
▫ NO
▫ Because: protection of pub health, secondary wholesale distribution schemes, unfair comp, reimport of Rx drugs,
dist of Rx samples
Who has the exception to re -import drugs?
▫ Manufacturer
s
▫ Under PDMA
Are Pharmacists allowed to distribute drug samples?
▫ NO
▫ Under PDMA: no to sale, trade, or purchase of rx samples
i. And no pharmacy can distribute samples (exception: hosp entity pharmacy where a
practitioner auth sample and adequate records kept) ii. Before PDMA: too many
samples, less records, and improper sales
Are pharmacists allowed to traffic prescription drugs coupons?
▫ No
▫ Under PDMA
i. Can get 10 years in prison and/or 250K Fine!!
ii. Not even just across the border but also sold for profit with coupons, etc Are stated
required to license drug wholesalers?
▫ Yes
Can a community pharmacy keep drug samples in the pharmacy?
▫ No
Did the Dietary Supplement Health and Education Act (DSHEA) strip the FDA of pre-market
approval
for dietary supplements?
▫ Ye
i. Also, the act s defined the supplement to be a drug when there are drug claims in the promotion
ii. Supplements must state the disclaimer that the product has not been eval by FDA and not
intended to diagnose, txt, cure, or prevent disease
What agency is responsible for the enforcement of the poison prevention packaging act?
▫ Consumer Product safety commission (CPSC)
raithuman
protective package 1. Must dispense with new safety
closure
Is there an exception for oral contraceptives, estrogen/progesterone containing products to the poison
prevention packaging act?
▫ Yes, if they’re in the memory/mnemonic devices
i. Other exceptions include: drugs to institutionalized patients, sublingual Nitro tablets,
aerosol containers, Medrol tablets, K+ supplements Are OTC products an exception to the PPPA?
▫ Yes, it is the product, not the overarching brand
i. OTC must be in child resistant with exception being one package size of an OTC product
for the elderly or handicapped may be in non-child resistant
1. Must say for households without young children or not child resistant
Can prescribers make blanket requests for patients for non-child resistant packaging for their patients?
▫ NO, but
i. Prescribers may request that a single rx order be in non-safe packaging, but not a blanket request!
macy for an inspection during normal business
Does the FDA need a warrant to walk into the phar hours?
▫ NO
i. They do not need to state the reason for the inspection either
Who appoints the board members for the AZ state board of pharmacy (ASBP) or any of the other
Lecture III
Definition of a drug
▫ Articles intended for use in diagnosis, cure, mitigation, treatment, or prevention of disease in ;
man or otherand
animals
▫ ) intended to affect Articles (other thanthe structure or any function of the body of man or other animals; and
▫ Articles intended food for use as a component of any articles specified in clause (A), (B), or
(C)
▫ Recognized in USP, Homeopathic Pharmacopeia, NF, or supplements to them
Official compendia recognized by the FDCA; they exist as:
▫ United States Pharmacopeia (USP)
monopra
no
▫ Artificial sweeteners publicnopreapproval
▫ Caloric supplements (Ensure, etc) exclusivity process
nbahasa
rat contraceptive Yes fee boxalabening packagemea
t
Yes▫ If she asks, Medical Foods are
under medical supervision and include diet management (ie. Food without phenylalanine for phenylketonuria)
If trying to get a drug approved, what if the final step that has to be filed with FDA?
▫ NDA
i. Submit an IND before phase I and clinical studies
ii. NDA after Phase III is done
happeneT
When is an SNDA used? idk what
▫ Switch from rx to otc
▫ Or add another indication
▫ Or changes to update information for an already approved drug
What does parallel track mean?
▫ Individual patient access to investigational drugs for serious conditions
i. Approval to treat an indv pt ii. Approval is conditional upon completion of post-
marketing (P-IV) Clinical studies When are phase 4 clinical trials done?
▫ After it has been approved and is on the market
▫ Never ending
▫ Some mandated by the FDA
Do manufacturers that are trying to produce an authorized generic, do they need to file an NDA, ANDA,
or SNDA?
▫ NO, they don’t have to file anything!
i. There is another process where they can file an ANDA- generic drug application- not req
to prove safety and efficacy- must be a bioequivalent
ii. The authorized generic pathway- without these applications- brand sells rights to make
generic to someone with 180 days exclusivity
If an OTC were to be added to the market using the monograph process, is there a timeline?
▫ NO! -- it’s a public process, no pre-market approval needed (because using specific recipe), NO
MARKET EXCLUSIVITY, no user fees, final monograph open to everyone, active ingredient
specific and eval by otc drug category, no timeline, may req studies, no premarket review of
trade
i. NDA process, on the other hand:
1. Pre-market app, confidential filing, user fee, market exclusivity, mandated FDA
timelines, may require clinical studies, approved label is unique, approved NDA
is license to market, trade name is reviewed
k
What are the components of ‘LABELING’? blac box
▫ The label PLUS any ‘accompanying’ information such as package insert, the patient package
insert, med guide, or other materials like consumer info (box itself too) What are the 8 components
required on manufacturers label?
▫ Drug name
▫ Established name *generic or chemical
▫ Strength
▫ Recommended dosage
▫ Lot number
▫ Expiration date
▫ Quantity
▫ Legend statement: “Rx only” or “caution: federal law prohibits dispensing without prescription”
Regarding REMS (risk evaluation and mitigation strategies), the FDA may require a manufacturer to
implement special procedures to reduce these risks which include: (some have to do all 4 and most only
require one or two of them-any combo)
▫ Communication
▫ plan
Medication
▫ Elements to assure guide safe use (ETASU)
▫ Implementation system
What are the components of an NDC number?
▫ First five digits=
▫ Middle four digits= manufacturer/labeler/distributor drug product
▫ Last tw o digits= package size and type of
drug Which law -digit NDC?requires an 11
▫ HIPPA
i. -digit code FDA req a
Understand that the NDC 10 —like transaction information, drug supply portionis
required for lots of shit
of DSCSA, to track where things are going in the process
▫ NDC number used for a lot, like processing 3rd party claims, tracking dist of products, universal
product identifier, DOES NOT indicate that the drug has received FDA approval
Are manufacturers required to put NDC’s in linear barcode format on a label?
▫ YES! -- also part of track and
T/F: The drug facts trace label on OTC product is different from a prescription drug
product
▫ TRU
i. OTC E for patients to educate themselves on the product (will be on OSCE probably.. Or the
Prescription requirements when someone brings one to the pharmacy)
1. Active ingredient
2. Purpose
3. Uses
4. Warnings
5. Directions
6. Other info: storage
7. Inactive ingredients
8. Qs and Comments
9. Name and address of manu
10. Net quantity
ii. doctors Rx
1. A couple of questions up
Does the FDA have statutory authority to recall all drug products?
▫ NAY!
FDA has statutory authority to mandate recalls for:
▫ Devices
▫ Biologics
▫ Tobacco products
▫ Infant formula
▫ Human tissue intended for transplantation
▫ Interstate milk shipments
What is worse, Class 1 or Class 3 drug recall?
▫ Class 1—somebody could
i. Serious health die consequences
ii. Recall stocks in pharmacies and notify pts with this drug 1. Class II: product may cause
temp or reversible effects
a. Recall stocks
2. Class III: unlikely to cause adverse health conseq
a. Recall may be because of misspelling on label: Misbranded!
What would violate the true statement principles required for prescription advertising from
manufacturers?
▫ Its false or misleading
▫ The ad contains information that favors effectiveness information over side effects and
contraindications
▫ If it excludes material fact
Drug price competition and patent restoration act (PTRA) of 1984
▫ Created the ANDA for generic drug
approvals
▫ Allows FDA to grant innovator drugs patent-term extensions
▫ Exclusivity= exclusive marketing rights granted by the FDA upon approval of a
i. Granted with drug NDA approval
Patents and market exclusivity are different
▫ Exclusivity can extend life of a product before generic competition comes in
How long are patents valid for?
▫ 20 years, issued by patent office
T or F: One of the requirements of post-marketing surveillance is that manufacturers are required to report any
serious adverse drug reactions to FDA.
▫ True
i. For ANY event, if reported to them, they must report even if not about the drug they
made
ii. Manufacturers have AERS
iii. Pharmacies have MedWatch and ISMP-MERP Compounding Quality Act of DQSA,
title 1:
▫ Drug compounding (applies to human consumption only)- NOT ANIMALS!!
i. Ensured safety of compounded drugs
ii. For human use
iii. 503B for outsourcing facilities iv. Applies to licensed pharmacists, practitioners,
outsourcing
DQSA, Title 1 also created 503b outsourcing facilities that can-do large-scale compounding or for office
use?
▫ True
Drug Manufacturers are not allowed to promote their drug product through direct-to-consumer
mechanisms.
▫ FALSE
Lecture IV
▫
days
pickstatus
change
How long to notify on change in address? immediately
▫ 10
Do you need to days report IPPE and APPE hours to the board?
▫ No, the school does
Do you need a fingerprint clearance card?
▫ Ye
To be an intern s preceptor:
▫ Min 1 year experience as an actively practicing pharmacist
▫ Needs an unrestricted, current license
▫ If found guilty of violating law, etc, enters into agreement satisfactory to board
Teacher and
▫ mentor Responsible yintem
▫ Review policies and procedures
▫ Provide opportunity and skill development
▫ Provide timely and realistic feedback
▫ Resp for actions of intern
Pharmacy licensure:
▫ Reciprocity:
i. Use Original Board License and take the state MPJE ii. Does not need to prove
schooling/graduating from because already have license Residency iii. Do not
have to worry about submitting training hours because already have license
DO
II postmarketing
hours CE
i. Phase
1. Including 3 hours opioid, etc ae
▫ P
i. technician
20 hours CE
1. Including 3 hours opioid, etc
▫ Immunizations: animals
TitleIDQ
Need 2 hours CE
i.
mum : nitrite
Naloxone
Dispensing
▫
i. No Ce required
ii. But, need to complete 1 hour of training
1. AzPA does it for free
If I’m the PIC, how fast do I need to tell the board I’m not the PIC anymore: ▫ Immediately/24
hours
How fast should the employer tell the board of the PIC resigning or a new one starting: ▫
Immediately/24 hours
If I am the director of hospital pharmacy, what should I put in my permit application:
▫ Hospital’s Dep of Health Services License
▫ Number of Beds
▫ Manager/administrator’s Name
Do all pharmacies have to participate and complete Quality Assurance Programs(CQA) in AZ?
▫ HELL YEAH
▫ If she asks... Pharmacies that already meet these requirements because of other licensing: i.
Hospital
1. License from Dept of health services ii.
Certified by CMS (Medicaid and care)
iii. Accredited by Joint Commission iv. Accredited by
American Osteopathic Association Are CQA records subject to
subpoena or discovery?
▫ NO
CQA Responsibilities:
▫ Developed, implemented, and utilized
▫ Every 2 years policies and procedures
▫ reviewed
Policies and procedures readily available to employees and for inspection by the
▫ Medication error board data is
utilized and reviewed regularly ▫ All documents to CQA maintained for 2 years
Community Pharmacy Requirements (she specified ones bolded)
▫ Min area: 300 sq ft for 3 people
Plus 60 sq ft
person If
i. for additional
3people
▫
Hospital
pharmacy
500 sq feet
Compounding and Dispensing Counter
▫ Working area for compounding and dispensing
▫ Area for pt counseling
▫ Narcotic safety cabinet
▫ Security standards
▫ Drug storage and security
▫ Hot and Cold water
▫ Separate and review expired and non-expired drugs
▫ Restroom within 100 feet
▫ Fridge
▫ Register
▫ Graduates
▫ Mortar and pestle
▫ Spatulas
▫ Balance
▫ Ointment tile
▫ Red C stamp
▫ Copy of pharm practice act, admin rules, and CS act
▫ Prof reference library
▫ Label assortments
▫ Antidote and interaction info ▫
Poison control phone number
manager abedpitsnine
▫
i. Dependent on beds, and type of hospital, etc
ii. Board may require more
▫ Must be locked
▫ Sanitation, ventilation, temp and moisture control, security and separation of products
▫ Reference library
▫ Hot and cold water
▫ Fridge and Freezer
▫ Laminar air flow hood
All permits must be displayed in the pharmacy:
▫ Tru
All licenses must be e displayed in the pharmacy
▫ Fals
▫ Privacy issue e and issue related to stalking and restraining orders ( ) Limited Services
pharmacies and what they are:
▫ Correctional Facility
▫ Mail-Order Pharmacy
▫ LT Care
▫ Sterile Pharmaceutical Products Pharmacy
▫ Nuclear Pharmacy
Closing pharmacy Down, what time frame does the permit holder need to notify the DEA: ▫
14 days before close
If I am the pharmacy owner whose pharmacy is closing, am I responsible for returning the all the the
Lecture V
m
o Can interns do control substance transfers?
o Yes
− How long do you have to keep prescription orders in AZ? o 7 years from last date filled
▪ 10 for Medicaid is she asks
− For control substance image orders, an electronic image is NOT sufficient to meet storage —must have hard
requirement copy!
sAll prescriptions must be serial numbered, dated and filed in the order which compounded or
−
dispensed
− Electronic
image record keeping system, I must maintain the original hard copy of non-controlled prescriptions for 30 days-
FALSE norequirementodays
− Medicare stipulates that orders covered by Medicare must be kept for 10 years from date last filled
− Can an Arizona pharmacist can fill all prescription orders, both controlled and non-controlled, from a
prescriber in Russia?
o No, controlled substances cannot be filled from another country. Just non-controlled − Which
of the following is true regarding the transfer of a controlled prescription order?
o Controlled prescriptions may only be transferred one time (True)
o Technicians may accept a receive controlled substance prescription orders (False) o Interns may
accept and receive controlled substance prescription transfers (True) − A reference listed (RL)
drug, with an AB2 rating needs a generic substitution. What generic rating
MUST be substituted for the reference listed drug o
AB2
− What is the definition of pharmaceutically equivalent vs therapeutically
equivalent? o Pharmaceutical equivalent: drug products have the same
ingredient form, route, strength, and active
s
o Therapeutic equivalent: pharmaceutically equivalent + bioequivalent
areo (Bioequivalent= products display comparable bioavailability at site of action under similar
conditions)
hacking− If a drug has an AB rating, what kind of issue has been resolved?
o Bioequivalence issue
− In AZ, can a pharmacist use professional judgement and do prescription order adaptation for
noncontrolled and controlled substance prescription orders?
o No, professional judgment can only be used for non-controls
− What do we have to check when doing retrospective review by the DUR board?
o Duplicates
o Contraindications
Revieherkanoot
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