BILL ANALYSIS                                                                                                                                                                                                    �







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        |Hearing Date:May 7, 2012           |Bill No:SB                         |
        |                                   |1329                               |
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                      SENATE COMMITTEE ON BUSINESS, PROFESSIONS 
                               AND ECONOMIC DEVELOPMENT
                          Senator Curren D. Price, Jr., Chair
                                           

                        Bill No:        SB 1329Author:Simitian
                     As Amended:March 29, 2012          Fiscal:No

        
        SUBJECT:  Prescription drugs:  collection and distribution program.

        SUMMARY:  Revises and recasts provisions authorizing a county to 
        establish a drug repository and distribution program, to authorize a 
        program to be established by an action of the county board of 
        supervisors, or by the county public health officer, as specified; 
        expands the types of pharmacies that are eligible to participate in a 
        program; expands the types of health or care facilities authorized to 
        donate medication to a program; makes conforming and clarifying 
        changes.

         NOTE :  Double-referral to Health Committee, first.  This bill was 
        heard in Senate Health Committee on April 11, 2012 and approved by a 9 
        to 0 vote.

        Existing law, the Health and Safety Code (HSC):
        
       1)Authorizes the establishment of a voluntary drug repository and 
          distribution program for the purpose of distributing surplus 
          medications to persons in need of financial assistance to ensure 
          access to necessary pharmaceutical therapies.  
       (Health and Safety Code (HSC) � 150200)

       2)Authorizes counties, by ordinance, to establish a prescription drug 
          repository and distribution program (Program), subject to specified 
          requirements, for medically indigent patients to receive donated 
          prescription drugs free of charge.  (HSC � 150204)

       3)Allows the following entities to donate medication to a program:  
          (HSC � 150202)





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           a)   A skilled nursing facility (SNF).

           b)   A SNF designated as an institution for mental disease (IMD).

           c)   A drug wholesaler or a drug manufacturer.  (HSC � 150203)

       4)Limits the types of pharmacies that can dispense medication through 
          the program to county-owned pharmacies and pharmacies that contract 
          with the county.  (HSC � 150204 (a))

       5)Requires a county that elects to establish a program to establish 
          procedures for program eligibility for medically indigent patients, 
          and to ensure proper safety and management of medications, among 
          other requirements.  (HSC � 1050204 (b))

       6)Exempts prescription drug manufacturers, wholesalers, participating 
          pharmacies, SNFs, pharmacists and health care professionals who 
          accept or dispense prescription drugs from criminal or civil 
          liability for injury caused when donating, accepting, or dispensing 
          prescription drugs in compliance with the program provisions, except 
          for noncompliance with the program statute, bad faith or gross 
          negligence.  (HSC �� 150205, 150206)

       7)Prohibits the program statute from affecting disciplinary actions 
          taken by licensing and regulatory agencies.  (HSC � 150207)

        Existing law, the Business and Professions Code (BPC):
        
       1)Establishes the practice of pharmacy and provides for the licensing 
          and regulation of pharmacies and pharmacists by the Board of 
          Pharmacy within the Department of Consumer Affairs. 

       2)Authorizes a pharmacist to dispense a prescription medication in a 
          container that meets the requirements of state and federal law and 
          is correctly labeled.  (BPC � 4022)

       3)Specifies certain requirements regarding the dispensing and 
          furnishing of dangerous drugs and devices, and prohibits a person 
          from furnishing any dangerous drug or device except upon the 
          prescription of a physician, dentist, podiatrist, optometrist, 
          veterinarian or naturopathic doctor, as specified.  (BPC � 4059) 

       4)Authorizes a primary care clinic to purchase drugs at wholesale for 
          the administration and dispensing under the direction of a physician 
          and surgeon to patients registered at the clinic. (BPC � 4180).





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        This bill:

       1)Defines the following terms for purposes of the surplus medication 
          collection and distribution program:

           a)   "Eligible entities" to mean all of the following:

             i.     A licensed pharmacy that is county owned or that contracts 
               with the county.

             ii.                        A licensed pharmacy that is owned and 
               operated by a licensed primary care clinic. 

             iii.                       A licensed primary care clinic that is 
               licensed to administer and dispense drugs.

           b)   "Medication" or "medications" to mean, a dangerous drug as 
             defined in BPC � 4022.  

           c)   "Participating entity" to mean an eligible entity that has 
             received written or electronic documentation from the county 
             health department and that operates a repository and distribution 
             program, as specified.  

       2)Expands the types of health or care facilities authorized to donate 
          medication to include the following:

           a)   A licensed general acute care hospital.

           b)   A licensed acute psychiatric hospital.

           c)   A licensed intermediate care facility (ICF).

           d)   A licensed ICF/developmentally disabled-habilitative facility.

           e)   A licensed ICF /developmentally disabled-nursing facility.

           f)   A licensed correctional treatment center.

           g)   A licensed psychiatric health facility.

           h)   A licensed chemical dependency recovery hospital.

           i)   A licensed residential care facility for the elderly (RCFE).






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           j)   A licensed RCFE for persons with chronic, life-threatening 
             illness.

           aa)       An approved mental health rehabilitation center.

       3)Revises and recasts the provisions authorizing a county to establish 
          by ordinance, a repository and distribution program, to instead 
          authorize the program to be established by an action of the county 
          board of supervisors, or by the county public health officer, as 
          delegated by the county board of supervisors.

       4)Provides that only an eligible entity may participate in the program. 
           

       5)Requires an eligible entity that seeks to participate in the program 
          to inform the county health department in writing of its intent to 
          participate.  Prohibits an eligible entity from participating in the 
          program until it has received written or electronic documentation 
          from the county health department confirming that it has received 
          its notice of intent.

       6)Requires a participating entity in the program to disclose to the 
          county health department the name and location of the source of all 
          donated medication it receives, and requires a participating primary 
          care clinic to disclose to the county health department the 
          physician accountable to the Board of Pharmacy for the clinic's 
          program operations.

       7)Requires the county board of supervisors or county public health 
          officer, upon request, to make available to the Board of Pharmacy 
          the information in Item # 6) above.

       8)Authorizes the county board of supervisors, the county public health 
          officer, and the Board of Pharmacy to prohibit an eligible or 
          participating entity from participating in the program if the entity 
          does not comply with the provisions of the program.

       9)Allows medication donated to the program to be transferred to another 
          participating entity in the program for dispensing to eligible 
          patients.

       10)Provides the health or care facilities authorized by the bill to 
          donate medication and the eligible entities authorized to dispense 
          medication to receive the exemption from civil and criminal 
          liability established under existing law when donating, accepting or 
          dispensing drugs in the program, except for noncompliance with the 





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          program statute, bad faith or gross negligence.


        FISCAL EFFECT:  Unknown.  This bill has been keyed "non-fiscal" by 
        Legislative Counsel. 

        
        COMMENTS:
        
       1.Purpose.  This bill is sponsored by  Supporting Initiatives for 
          Redistribution of Unused Medication  (Sponsor), a non-profit 
          organization that connects drug donors and pharmacies.  According to 
          the Author, this bill builds on previous legislation,  SB 798  
          (Simitian, Chapter 444, 2005) that authorized counties to set up 
          drug collection and redistribution programs.

       According to the Author, this bill increases the accessibility of 
          prescription drugs for medically indigent patients by allowing a 
          greater number of health and community care facilities to donate 
          surplus medications to be dispensed to those in need, while also 
          reducing needless pharmaceutical waste.  The bill also allows 
          clinics, which more often serve this community, to participate, and 
          streamlines the program initiation process for counties, according 
          to the Author.

       The Author states:  "One third of California's uninsured forgo 
          prescription drugs due to cost.  The rest face an average retail 
          price of $71 per prescription.  Out of seven million who are 
          uninsured in California, over half take more than one prescription 
          a-day.  It is estimated that the U.S. generates 250 million pounds 
          of pharmaceutical waste annually which equates to billions of wasted 
          dollars; and in California alone, hundreds of millions of dollars in 
          usable medicine ends up destroyed in incinerators or dumped into our 
          water supply."

       According to the Author, SB 1329 does the following: 

          "      Broadens the prescription drug donor pool to allow other 
               health and care facilities (e.g. hospitals, long term care 
               facilities, residential care facilities, psychiatric health 
               facilities, and correctional treatment centers) to donate drugs 
               to eligible entities.

          "      Allows nonprofit, primary care clinics, which are licensed to 
               dispense prescription drugs by the Board of Pharmacy, to 
               receive the donated drugs.





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          "      Allows donated drugs from one pharmacy to be transferred to 
               another pharmacy.

          "      Includes an option for the county board of supervisors, or 
               public health official for the county to take action in 
               initiating the program.

          "      Requires that pharmacies and counties be approved by the 
               county health department and requires them to also notify the 
               county health department of the source(s) of their donated 
               medication.

          "      Allows the county Board of Supervisors, or county public 
               health official, or the Board of Pharmacy to exclude pharmacies 
               or clinics from participating.

        1. Background.  An issue brief from the National Conference of State 
           Legislatures indicates that 38 states have enacted laws as of 2010, 
           regarding prescription recycling programs for unused medications.

        In California, SB 798 authorized counties to establish a "surplus 
           prescription drug collection and distribution program" (Program).  
           Under the Program, counties can adopt an ordinance to establish 
           such a Program, under which SNFs, SNFs that are IMDs, drug 
           wholesalers, and drug manufacturers can donate unused medications 
           to county-owned pharmacies, or pharmacies that contract with the 
           county for dispensing to medically indigent patients free of 
           charge.  Prior to the enactment of SB 798, SNFs were required to 
           either destroy the drugs in the presence of a pharmacist or nurse, 
           or return the drugs to the issuing pharmacy (if unopened and in a 
           sealed container) for disposition.  To date, two counties (Santa 
           Clara and San Mateo) have established such a Program, and Santa 
           Clara indicates that it has saved approximately $5,000 through the 
           program as of February 2012.

        According to the Author, in these two counties, Program efforts 
           coordinated by SIRUM (the Sponsor of this measure)  are estimated 
           to have resulted in significant impact and savings since 2009:

             "       230,000 pills have been redistributed 
             "       $600,000 of drugs have been donated 
             "       thousands of estimated uninsured patients have been 
                assisted 
             "       70 medicine donors are participating






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           Counties establishing a Program have to meet certain requirements, 
           including establishing eligibility for medically indigent patients, 
           developing a formulary of medications appropriate for the Program, 
           ensuring the privacy of patients donating medication to the 
           Program, and ensuring proper safety and medication management.  
           Controlled substances (controlled substances are prescription drugs 
           with the potential for abuse) and medication in the possession of a 
           patient are not eligible for donation.  Only medication that is 
           donated in unopened, tamper-evident packaging or modified unit dose 
           containers that meet specified standards is eligible for donation.  
           Donated medication cannot have been in the possession of a patient 
           or any individual member of the public, and medication donated by a 
           SNF must have been under the control of the staff of the SNF.

           Medication that is dispensed under the Program is required to be in 
           a new and properly labeled container that is specific to the 
           eligible patient.  In addition, medication donated to the Program 
           must be segregated from the pharmacy's other drug stock by physical 
           means, for inventory, accounting, and inspection purposes.  
           Pharmacies must also keep complete records of the acquisition and 
           disposition of medication donated to and dispensed under the 
           Program.  Finally, a participating county-owned or 
           county-contracted pharmacy must follow the same procedural drug 
           pedigree requirements for donated drugs as it would follow for 
           drugs purchased from a wholesaler or directly from a drug 
           manufacturer.

       1.Prior legislation.   SB 798  (Simitian, Chapter 444, Statutes of 2005) 
          authorized the establishment of a voluntary prescription drug 
          collection and distribution program for the purpose of distributing 
          surplus prescription drugs to medically indigent patients free of 
          charge.
       
        2. Arguments in Support.  In sponsoring the bill  Supporting 
           Initiatives for Redistribution of Unused Medication  (SIRUM) 
           believes the bill will increase access to necessary, and in many 
           cases life-sustaining, prescription drugs to medically indigent 
           Californians while at the same time reduce the environmental impact 
           of pharmaceutical waste.  

        Writing in support of the bill, the  Santa Clara County Board of 
           Supervisors  states that the county established a program in 2008, 
           and believes that by expanding the types of health facilities that 
           can be involved in the program, the bill would increase the 
           effectiveness of the county's program and assist in establishing 
           similar programs around the state.





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        The  California Assisted Living Association  (CALA) states that the bill 
           will allow licensed assisted living communities and other community 
           care and health care facilities to donate unused medication to 
           approved local organizations which are authorized to redistribute 
           the medication to low-income, uninsured Californians.

        The  California Association of Health Facilities  (CAHF) argues this 
           bill would make it easier for counties to approve programs to allow 
           for the redistribution of unused medication from health care 
           providers to the uninsured.  CAHF states SNFs are estimated to 
           destroy up to 15% of their prescriptions each month, but that an 
           increasing number of SNFs (approximately 79 facilities) are taking 
           advantage of the unique program established by SB 789 in 2005, that 
           allows these facilities to donate surplus medications for 
           redistribution to uninsured residents.  

         Sierra Club California  writes in support that this would protect 
           people and the environment, from pharmaceutical chemicals that have 
           been linked to phenomena such as "feminized" male fish.  Even 
           though little study has been done to assess health impacts on 
           humans, pharmaceutical chemicals have been proven to adversely 
           affect wildlife and the environment, according to the Sierra Club.

        The  National Federation of Independent Business  (NFIB) states that 
           health facilities currently spend time and money disposing of 
           perfectly good medications.  NFIB argues with proper safeguards, 
           surplus medications that have not been distributed to the public 
           and has been maintained by health professionals should be put to 
           good use.  

        The  American Cancer Society  believes the bill will help more cancer 
           patients and survivors have access to the prescription drugs they 
           might otherwise have been forced to go without, and states that 
           more than 300,000 people in this country die from cancer each year 
           because they do not have access to appropriate care and treatment.  
           In California, it is estimated that 144,800 people will be 
           diagnosed with cancer this year, and that 55,415 will die from the 
           disease.

        The  California State Association of Counties  (CSAC) suggests that the 
           bill will simplify the way counties may establish a local 
           prescription drug collection and distribution program by allowing a 
           program to be authorized by the board of supervisors or by the 
           county public health officer.  CSAC also states the bill would 
           widen the pool of entities that may participate in a local program 





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           thereby casting a wider net for eligible pharmaceuticals available 
           for the program.
         
        Californians Against Waste  contends that county repository programs 
           are a cost-effective and practical way to divert unwanted drugs 
           from the waste stream.  

       3.Policy Issue.  This bill authorizes the Board of Pharmacy, a county 
          board of supervisors or a county public health officer to prohibit 
          an eligible entity or a participating entity from taking part in a 
          county program.  However, the bill does not establish any criteria 
          for the Board to prohibit a licensee from participating in the 
          program.  Although the Board of Pharmacy has not taken a position on 
          this bill, the Board's Legislation Committee analysis of the bill 
          raises this issue pointing out that there is no Board involvement in 
          the establishment of such a program, nor are there provisions that 
          require Board approval to participate in such a program.

       The Author's office has stated that the provision was included in the 
          bill following discussions with Board of Pharmacy staff, and was 
          added to specifically give the Board more authority than it 
          currently has under the law enacted in 2005.  The Author's office 
          has expressed a willingness to work with the Board to equitably 
          resolve this concern.

       The Author may wish to consider the criteria upon which a county board 
          of supervisors, a county health officer, or the Board of Pharmacy 
          may prohibit an eligible entity or a participating entity from 
          taking part in a county program.  As this bill moves forward, the 
          Author may wish to clarify this provision or remove it from the 
          bill.


        SUPPORT AND OPPOSITION:
        
         Support  :  

        Supporting Initiatives for Redistribution of Unused Medication 
        (Sponsor) 
        Aegis of Corte Madera
        American Cancer Society
        Bethesda Home
        California Assisted Living Association
        California Assisted Living Association
        California Association of Health Facilities (CAHF)
        California Medical Association (CMA)





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        California State Association of Counties
        Californians Against Waste
        Children's Recovery Center of Northern California
        Community Care on Palm
        Golden Age Convalescent Hospital
        Golden Empire Convalescent Hospital
        Marin Community Clinics
        Marlinda Imperial Convalescent Hospital
        National Federation of Independent Business
        San Francisco Towers
        Santa Clara County Board of Supervisors
        Sierra Club California
        Stonebrook Healthcare Center
        Wind Chime of Marin


         Opposition  :  

        None received as of May 1, 2012



        Consultant:G. V. Ayers