(213) 240-8101
March 1, 2001
Honorable Board of Supervisors
County of Los Angeles
383 Kenneth Hahn Hall of Administration
500 West Temple Street
Los Angeles, California 90012
Dear Supervisors:
PHARMACEUTICAL REVERSE DISTRIBUTION SERVICES AGREEMENT (All Districts)
(3 Votes)
IT IS RECOMMENDED THAT YOUR BOARD:
Approve and instruct the Director of Health Services, or his designee, to offer and sign an agreement, substantially similar to Exhibit I, with EXP Pharmaceutical Waste Management, Inc. to provide County pharmacies with reverse distribution services for inventorying, packaging, and return to the manufacturer of pharmaceutical/drug products that have exceeded their packaging expiration date, are damaged, or have been recalled, and have become non-dispensable, in exchange for full or partial credits, refunds, and/or drug replacements, in accordance with the manufacturers= policies; and the disposal of biohazardous (i.e., medical/pharmaceutical/drug products) waste products that are found to be non-dispensable and non-returnable to pharmaceutical/drug manufacturers, effective upon Board approval through June 30, 2006, at no net County cost.
PURPOSE OF RECOMMENDED ACTION:
In approving the recommended action, the Board is authorizing the Director of Health Services, or his designee, to sign an agreement with EXP Pharmaceutical Waste Management, Inc. (EXP), to provide pharmaceutical reverse distribution services to County pharmacies.
JUSTIFICATION:
Board approval of the recommended agreement will provide County pharmacies with a method of recovering full or partial credit compensation and replacement pharmaceutical/drug products from pharmaceutical manufacturers for expired, damaged, or recalled pharmaceutical/drug products which would otherwise be considered an unrecoverable expense.
Honorable Board of Supervisors
March 1, 2001
Page 2
FISCAL IMPACT:
The contractor will receive 9% to 10% (based upon type of pharmaceutical/drug handled [i.e., non-controlled or controlled substances]) of the total refund received from pharmaceutical/drug manufac-turers by participating County facility pharmacies, and a $1 per-pound disposal (non-hazardous
and hazardous waste) fee for pharmaceutical/drug products that do not qualify for credit compensation, and cannot be reverse distributed. Contractor is limited to receiving no more than 15% of the total refund received by a County pharamacy for all services performed by Contractor.
The total cost for pharmaceutical reverse distribution services for Fiscal Year (FY) 1999-00 was $162,879, based on total County facility pharmacy refunds of $1,614,930, or an actual total refund of $1,452,051 ($1,614,930 refund - $162,879 costs = $1,452,051).
FINANCING:
There are no net County costs under this agreement; costs for pharmaceutical reverse distribution services are paid entirely from the total refunds received. Since EXP bills on a percentage of the total dollar value recovered, it is in their best interest to ensure that the County obtains the maximum compensation for its reverse distributed pharmaceutical/drug products. (Funds from a participating County facility=s pharmacy budget may be used to pay the contractor since the reverse pharmaceutical refunds received by the County may include manufacturers= credits and/or drug replacements that may not be acceptable to contractor for use as payment. However, the use of such funds will not reduce the participating County facility=s pharmacy budget, since manufacturers= credits and/or drug replacements will be used to offset any pharmacy expenditures.) Note that, each Department (Department of Health Services, Department of Mental Health, Probation and Sheriff=s Departments) with County pharmacies participating in the program will be responsible for tracking their own manufacturer credits and/or drug replacements received and for paying their own pharmaceutical reversed distribution services bills, which were formally paid under a Purchase Order (PO) which has now since expired, and will be converted to the agreement format as described herein.
FACTS AND PROVISIONS/LEGAL REQUIREMENTS:
Normally, supply orders and use of supplies are adjusted by a County pharmacy from time-to-time to ensure that the majority of supplies held by the pharmacy are used before they reach their packaging expiration date. Since County pharmacies must order pharmaceutical/drug products in quantity, and maintain par levels of pharmaceuticals/drugs at all times (to properly serve the public and for contingency purposes) at each of its locations (including but not limited to, maintaining pharmaceuticals/drugs on hospital wards, clinics, and outpatient facilities), such pharmaceutical and drug stock cannot always be monitored and adjusted to optimize pharmaceutical par levels without exceeding packaging expiration dates, causing the pharmaceuticals/drugs to become non-dispensable.
Under the Controlled Substance Act of 1970, the Drug Enforcement Agency (DEA) assigned numbers to drugs based on the amount of narcotic, or narcotic-like substances, present in the drug and its level of habit forming or addicting propensities. The schedule numbers are "I" through "V", with "II" being
Honorable Board of Supervisors
March 1, 2001
Page 3
the strongest and "I" being illegal. The handling of scheduled drugs requires a DEA license, and the use of special control and inventory procedures prescribed by federal and state regulations. (Absence of such numbers on the drug label renders the drug non-scheduled [non-controlled] which can be handled and processed without DEA restrictions). EXP is a DEA registered reverse distributor, licensed to handle all scheduled (II through V) drugs, or controlled substances, and also possesses other related licenses and permits (i.e., Environmental Protection Agency [EPA] license, California Department of Health Services permit, and Weighmaster license) required to provide pharmaceutical reverse distribution services (including biohazardous waste disposal of non-returnable pharmaceutical/drug products) under the recommended agreement. In addition, EXP is the sole reverse distributor located in California and licensed by the California State Board of Pharmacy (i.e., California State Pharmacy Wholesaler=s license). An approved sole source letter is on file with DHS which discusses additional details.
Basic pharmaceutical reverse distribution services include, but are not limited to: 1) sorting pharmaceuticals/drugs by manufacturer, lot number, and expiration date; 2) generating of return inventory reports and all necessary DEA forms; 3) providing all packaging materials, and the boxing, packaging, and mailing/shipping of pharmaceuticals/drugs for return shipment to manufacturers; 4) preparing returned drug summary reports with anticipated return value/credits; and 5) disposing of all non-returnable pharmaceuticals/drugs, when requested.
All manufacturers credits, refunds, and/or drug replacements, are sent directly by the manufacturers to each County facility pharmacy participating in the reverse distribution program (See Attachment B, for list of participating facilities). This allows each facility to determine the dollar value of all manufacture credits, refunds, and/or drug replacements, and to confirm that EXP bills are within the appropriate percentage to be charged.
It should be noted that not all pharmaceuticals/drugs are returnable for credit or replacement. Non-returnable pharmaceuticals/drugs are considered pharmaceutical medical waste (divided into non-hazardous waste [usually non-scheduled pharmaceutical/drugs] and hazardous waste [usually scheduled/controlled pharmaceuticals/drugs]). The Department will have the option to use EXP to dispose of both non-hazardous and hazardous pharmaceutical waste under this agreement directly, since it offers a more secure method of disposal than using the Department=s current biohazardous waste contractors, especially when disposing of scheduled pharmaceuticals/drugs. EXP will only dispose of pharmaceutical waste which is a by-product of the reverse management process.
Under the agreement, either party may terminate for convenience upon 30 days advance written notice to the other party.
The agreement (Exhibit I) has been approved as to form by County Counsel.
Attachments A and B provide additional information.
Honorable Board of Supervisors
March 1, 2001
Page 4
CONTRACTING PROCESS:
It is not appropriate to advertise County sole source agreements on the Countywide Office of Small Business Web Site.
IMPACT ON CURRENT SERVICES (OR PROJECTS):
Provision of pharmaceutical reverse distribution services will assist County facilities in obtaining maximum manufacture credits and/or drug replacements for expired/damaged pharmaceuticals/drugs,
while achieving maximum inventory benefits.
When approved, this Department requires three signed copies of the Board's action.
Respectfully submitted,
Mark Finucane
Director of Health Services
MF:bb
Attachments
c: Chief Administrative Officer
County Counsel
Executive Officer, Board of Supervisors
BLECD371.GI
gti:02/13/01
ATTACHMENT A
SUMMARY OF AGREEMENT
1. TYPE OF SERVICE:
Provision of pharmaceutical reverse distribution services. (Basic pharmaceutical reverse distribution services include, but are not limited to: 1) sorting pharmaceuticals/drugs by manufacture, lot number, and expiration date; 2) generating of return inventory reports and all necessary DEA forms; 3) providing all packaging materials, and the boxing, packaging, and mailing/shipping of pharmaceuticals/drugs for return shipment to manufacturers; 4) preparing returned drug summary reports with anticipated return value/credits; and 5) disposing of all non-returnable pharmaceuticals/drugs, when requested.)
2. AGENCY ADDRESSES, CONTACT PERSONS, AND TELEPHONE NUMBERS:
Contractor:
EXP Pharmaceutical Waste Management, Inc.
1581 Orange Avenue, #C
Costa Mesa, California 92627
Attention: Mr. Timothy Fahy, South West Regional Manager
Telephone / Facsimile (FAX) Number: (800) 350-0396 / (949) 548-5849
3. TERM:
The term of the recommended agreement will become effective upon Board approval and continue through June 30, 2006.
4. FINANCIAL INFORMATION:
The contractor will receive 9% to 10% (based upon type of pharmaceutical/drug handled [i.e., non-controlled or controlled substances]) of the total refund received from pharmaceutical/drug manufacturers by participating County pharmacies, and a $1-per-pound disposal (non-hazardous and hazardous waste) fee for pharmaceutical/drug that do not qualify for credit compensation, and cannot be reverse distributed. In addition, the contractor is limited to receiving no more than 15% of the total refund received by a County pharmacy for all services performed by Contractor.
The total cost for pharmaceutical reverse distribution services for Fiscal Year (FY) 99-00 was $162,879, based on total County facility pharmacy refunds of $1,614,930, or an actual total refund of $1,452,051 ($1,614,930 refund - $162,879 costs = $1,452,051). There is no net County cost under this agreement, as costs for pharmaceutical reverse distribution services are paid entirely from the total refunds received.
5. ACCOUNTABLE FOR MONITORING AND EVALUATION:
LAC+USC Pharmacy Administration.
6. APPROVALS:
Clinical and Medical Affairs: Gail V. Anderson, Jr., M.D., Acting
Associate Director
Contracts and Grants Division: John H. Ricks, Chief
County Counsel (approval as to form): Sharon A. Reichman, Senior Deputy County Counsel
Attachment B
Page 1 of 2
County Pharmacies
1. Edward R. Roybal Comprehensive Health Center 245 South Fetterly Avenue
Pharmacy Director Telephone Number: (323) 780-2398
|
2. El Monte Comprehensive Health Center 10953 Ramona Boulevard
Pharmacy Director Telephone Number: (626) 579-8419
|
3. H. Claude Hudson Comprehensive Health Center 2829 South Grand Avenue
Pharmacy Director Telephone Number: (213) 744-3934
|
4. Harbor/UCLA Medical Center 1000 West Carson Street
Pharmacy Director Telephone Number: (310) 222-2357
|
5. High Desert Hospital 44900 North 60th Street, West
Pharmacy Director Telephone Number: (661) 945-8456
|
6. Hubert H. Humphrey Comprehensive Health Center 5850 South Main Street
Pharmacy Director Telephone Number: (323) 846-4421
|
7. Martin Luther King/Drew Medical Center 12021 South Wilmington Avenue
Pharmacy Director Telephone Number: (310) 668-3961
|
8. Los Angeles County Sheriff=s Department Sheriff=s Medical Services Pharmacy
Pharmacy Director Telephone Number: (213) 473-6553
|
9. Los Angeles County - Department of Mental Health 550 South Vermont Avenue
Pharmacy Director Telephone Number: (213) 738-4861
|
10. Los Angeles County - Probation Department Medical Division
Pharmacy Director Telephone Number: (323) 226-8850
|
11. Los Angeles County+University of Southern California ("LAC+USC") Medical Center
Pharmacy Director Telephone Number: (323) 226-6021
|
12. LAC+USC Medical Center (Outpatient Pharmacy) 1175 North Cummings Street
Pharmacy Director Telephone Number: (323) 226-5093
|
Attachment B
Page 2 of 2
County Pharmacies
13. LAC+USC Medical Center Pharmacy
Pharmacy Director Telephone Number: (323) 226-6021
|
14. LAC+USC Medical Center Women=s and Children=s Hospital
Pharmacy Director Telephone Number: (323) 226-3101
|
15. Long Beach Comprehensive Health Center 1333 Chestnut Avenue
Pharmacy Director Telephone Number: (562) 599-8723
|
16. Olive View/UCLA Medical Center 14445 Olive View Drive
Pharmacy Director Telephone Number: (818) 364-3059
|
17. Rancho Los Amigos Medical Center 7801 East Imperial Highway
Pharmacy Director Telephone Number: (562) 401-7235
|
18. Wilmington Health Center 1325 Board Avenue
Pharmacy Director Telephone Number: (310) 222-2455
|
Note that, Pharmacy Director is a generic title, and actual titles of Pharmacy Directors may vary from facility to facility.