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DEA’s Rescheduling of Compounds Containing Hydrocodone and Oxycodone Means Tighter Restrictions by PBMs and State Regulatory Boards

On August 22, 2014, the United States Drug Enforcement Administration (DEA) published a notice in the Federal Register announcing the reclassification of Hydrocodone Combination Products (HCPs) as Schedule II narcotics under the Controlled Substances Act, 21 U.S.C. §§ 801, et. seq (the CSA). Under the new rule, any combination painkiller containing hydrocodone or oxycodone constitutes a Schedule II narcotic. The rule applies to widely used, name brand HCPs, such as...

The Office of the Medicare Inspector General Issues Advisory Opinion on a “Per-Fill” Arrangement Between a Specialty Pharmacy and a Local Pharmacy

On August 15, 2014, the Office of the Inspector General (OIG) published an advisory opinion (the “Advisory Opinion”) related to a Specialty Pharmacy paying local pharmacies on a “Per-Fill” basis for “Support Services” provided by the local pharmacy. The request for the Advisory Opinion was submitted by the Specialty Pharmacy. The Specialty Pharmacy proposed the following arrangement (the “Proposed Arrangement”): local pharmacy receives a prescription for specialty drugs that Local...