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Transcript of Fma presentation
Recent Trends in Pain Clinic and Community Pharmacy ActivityPresented by Dr. Jacinta Gau, Ph.D.
Research Assistance by Erika Brooke, M.S.
University of Central Florida 1
Background of the Study
• UCF researchers received federal funding to study HB 7095 (“pill mill law”) from multiple perspectives
• Cannot fully isolate from PDMP and the 2010 pain clinic law, as well as ramped-up law enforcement efforts
• These laws imposed new restrictions on persons who prescribe or dispense controlled substances for the treatment of chronic, non-malignant pain, and on pain clinics and pharmacies
• This presentation will focus on facilities
• The following data are from the Florida Department of Health
• Analyses and interpretations are those of the UCF researchers, not DOH
2
New PMC Applications Received (Annual Counts)
0
200
400
600
800
1000
1200
2010 2011 2012 2013
*2013 data as of May 10
5
Summary of PMC Application and New PMC Trend
• High in 2010, likely an artifact of FS 458.3265
• Continual reduction thereafter suggests genuine downward trend in new applications and new clinics
• Monthly mean new apps. down 74% in 2013 compared to 2011
• Consistent with hypothesis that HB 7095 had an impact
• Deterrence?
• Consistent with other data and reports
• Medical examiner reporting reduction in Rx pill related deaths
• News reports of a reduction in the number of clinics
• Law enforcement claims that Rx pills are becoming harder to get and more expensive
8
New CPharm Applications Received (Monthly Mean)
0
5
10
15
20
25
30
35
40
2008 2009 2010 2011 2012 20139
New CPharm Applications Received (Annual Counts)
0
50
100
150
200
250
300
350
400
450
2008 2009 2010 2011 2012 2013
*2008 data incomplete; 2013 as of May 1010
New CPharm Permits Issued (Annual Counts)
0
50
100
150
200
250
300
350
400
450
2008 2009 2010 2011 2012 2013
*2008 data incomplete; 2013 as of May 1012
Summary of CPharm New Applications and Permits• Apparent slight downward trend since 2010
• Suggests no systematic efforts to circumvent the dispensing ban through collusion
• No new market
• However, viewed in light of anecdotes about restrictive dispensing practices at large pharmacies and small supplies that run out, need to monitor legitimate pain patients’ access
13
PMC Administrative Closures (Annual Counts)
0
100
200
300
400
500
600
700
2010 2011 2012 2013
*2010 data incomplete; 2013 as of May 1015
Summary of Administrative Closures• Clear downward trend in self-closures since 2011
• Consistent with hypothesis that HB 7095 had an impact, even if indirect
• Reduction in new applications and permits
• Fewer in operation overall meant a more stable customer base
• Future question: were they closing for non-voluntary reasons instead? In particular, law enforcement investigations?
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PMC Complaints Received and Disciplinary Actions(Monthly Mean)
0
1
2
3
4
5
6
7
8
9
10
2010 2011 2012 2013
Compl.
Disc.
Em. Axn
18
PMC Complaints Received and Disciplinary Actions(Annual Counts)
0
10
20
30
40
50
60
70
80
90
100
2010 2011 2012 2013
Compl.
Disc.
Em. Axn
*2010 data incomplete; 2013 as of May 1019
CPharm Complaints Received and Disciplinary Actions(Monthly Mean)
0
5
10
15
20
25
2008 2009 2010 2011 2012 2013
Compl.
Disc.
Em. Axn
20
CPharm Complaints Received and Disciplinary Actions(Annual Counts)
0
50
100
150
200
250
300
2008 2009 2010 2011 2012 2013
Compl.
Disc.
Em. Axn
*2008 data incomplete; 2013 as of May 1021
Summary of Complaints and Discipline• Noticeable decline in complaints about PMCs– monthly mean
down 66% in 2013 relative to 2010
• Sharpest annual drop is from 2011 (7.42; n = 89) to 2012 (3.08; n = 37)– HB 7095 took effect July 1, 2011
• Required reception and waiting areas, restrooms
• Enhanced ability for clinics to be declared nuisances
• Deterrence
• Closures of problematic locations
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Summary of Complaints and Discipline• No similar trend in complaints about community pharmacies
• Suggests that this the PMC decline is not simply part of a general decline in complaints– the PMC decline was unique
• Suggestive of legislation taking effect and having an impact
• But there are a lot of complaints about pharmacies
• Perhaps worth a legislative investigation
• Hard to interpret DOH disciplinary action patterns
• Missing variable: referrals to law enforcement
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