At the HDA Distribution Management Conference in Palm Desert this week, state boards of pharmacy leaders shared insights into Drug Supply Chain Security Act (DSCSA) readiness at the dispenser level.
In comments similar to those made last year (The Simple Email Issue Holding Up DSCSA-Implementation Activity), panelists discussed challenges with finding and verifying the contact information at pharmacy trading partners for DSCSA activities.
"We really rely on NABP for even the small things like who do we call? Who do we talk to? Who do we email? … NABP helps us navigate that world,” said Kim Grinston, executive director, Missouri Board of Pharmacy.
People may incorrectly assume that the state boards have all the current contact information for trading partners, said moderator Josh Bolin, associate executive director for government affairs and innovation, National Association of Boards of Pharmacy. In some cases an email address may be updated because of a renewal. But many boards have the contact information from when a dispenser first became licensed. If a pharmacy was licensed 25 years ago, then the email contact may also be 25 years old. As Grinston noted, that person may have left, won the lottery, retired, etc.
Panelists emphasized the importance of accurate contact information in relation to public safety concerns, particularly for timely interventions in cases of suspect product. In these cases, product may need to be pulled or regulatory bodies notified, and it's not an ideal time for a wild goose chase. “That time is critical,” said Mark Hardy, executive director, North Dakota Board of Pharmacy. “From a public safety perspective, the quicker that that can happen, the better off we all are.”
In some cases, boards may receive responses from entities that are not authorized to speak on behalf of the licensee or are not aware of their DSCSA activities. This may only become apparent as the investigation gets underway.
Bolin explained that NABP has received positive feedback from the states throughout recent pilots with Pulse by NABP on being able to hone in on the DSCSA contact for a given organization. Pulse is a secure digital platform designed to simplify the process of achieving DSCSA compliance, providing a network of verified relationships, enabling consistent communication with trusted partners across the supply chain.
Additionally, the panelists agreed with the idea of publishing state board regulator contact information to facilitate easier access, with participants recognizing the value of transparency and accessibility in ensuring regulatory compliance and public safety. Mark Klawitter, board inspector, Montana Board of Pharmacy, noted, “In Montana, the inspectors are listed on our board webpage with our phone numbers and our email addresses… when there's a challenge that you're facing, we can get you in touch with the correct people.”
