Express Scripts Drug Trend Report: Specialty Products 1% of Products Dispensed, but 25% of the Spend.

If you have not seen it the newest edition of the Express Scripts Drug Trend Report was just published and features several highly anticipated enhancements, including a detailed forecast. In addition, the Commercial Spotlight offers in-depth insights into forecasting trend for the top therapy classes. You'll also find  proprietary annual update on the cost of pharmacy-related waste, which was $418 billion at the end of 2012. It's all online at DrugTrendReport.com.

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D2 has launched D2 STT/P Solutions™ which provides services focused on Track-Trace-Serialization-Pedigree

California SB 1307 Pedigree Law Goes into Effect in 20 Months

As you are aware, California Law SB 1307 has established dates and rules for mandatory e-pedigree requirements and serialization.  For manufacturers, the deadline for serialization of 50% of their products is January 1, 2015 - that is a little more than 20 months away.

D2 STT/P Solutions

D2 has launched D2 STT/P Solutions™ which provides services focused on Track-Trace-Serialization-Pedigree including:

Serialization-Track and Trace/Pedigree (STTP) Laws and Regulations

  • State
  • Federal
  • Key Wholesaler/Trading Partner Policies
  • 3PL capabilities
  • Service Providers
  • Serialization
  • Packaging Standards
  • Shipping Standards
  • Pending/Upcoming Enhancements
  • Regulation
  • Technology

We have formed the D2 STT/P Solutions™ to assist clients in managing pedigree including:

Providing industry expertise in conjunction with operational and manufacturing assessment in the evaluation and monitoring of compliance with the appropriate compliance standards in the supply chain; thus, ensuring your products flow through the supply channel with minimal potential disruptions.

  • Leading the review of standards utilized and implementation of distributing capabilities to assure STT/P compliance.
  • Providing ongoing distribution and management expertise in the development of certain internal and external policies and procedures.

To facilitate serialization and interoperability among trading partners, one of the first rules put forward by the Enforcement Subcommittee of the California Board of Pharmacy was the mandatory adoption of the FDA Standardized Numeric Identifier (SNI) as the “unique identifier” to be used on each drug package. At the same time, the Enforcement Subcommittee drafted a proposed rule covering the grandfathering of existing non-serialized, non-pedigreed stock that wholesalers and pharmacies must follow when SB 1307 goes into effect.

To summarize for your organization below are the highlights from the law:

A manufacturer of a dangerous drug distributed in California shall submit to the board, no later than December 31, 2014, a declaration signed under penalty of perjury by an owner, officer, or employee with authority to bind the manufacturer, containing the following:

A list and quantity of dangerous drugs by name and product package (SKU) type representing at least fifty (50) percent of the manufacturer’s total that are ready for initial implementation of the serialized electronic pedigree requirements as of January 1, 2015;

  • A statement identifying which one of the following methods was used to measure the percentage of drugs ready to be serialized: (i) unit volume, (ii) product package (SKU) type, or (iii) drug product family;
  • A statement describing the calculation(s) used to arrive at the percentage figure of dangerous drugs ready for serialized pedigree requirements;
  • A list and quantity of dangerous drugs by name and product package (SKU) type that are in the remaining percentage not yet ready to be serialized or subject to pedigree requirements; and,
  • A statement specifying the technology employed to meet the pedigree requirements, including but not limited to any platform(s), vendor(s), hardware, software, and communication technologies deployed.

A manufacturer of a dangerous drug distributed in California shall also submit to the board, no later than December 31, 2015, a declaration signed under penalty of perjury by an owner, officer, or employee with authority to bind the manufacturer, containing the following:

  • A list and quantity of its remaining dangerous drugs by name and product package (SKU) type that are ready for implementation of serialized electronic pedigree requirements as of January 1, 2016;
  • A statement identifying which one of the following methods was used to measure the final percentage of drugs to be serialized: (i) unit volume, (ii) product package (SKU) type, or (iii) drug product family;
  • A statement describing the calculation(s) used to arrive at the final percentage figure; and,
  • A statement specifying the technology employed to meet the pedigree requirements, including but not limited to any platform(s), vendor(s), hardware, software, and communication technologies deployed.

A manufacturer, wholesaler or re-packager seeking to designate dangerous drugs it possesses, owns, or controls that are not subject to the serialized electronic pedigree requirements, shall submit to the board, by no later than August 1, 2016, a declaration signed under penalty of perjury by an owner, officer, or employee with authority to bind the manufacturer, wholesaler or re-packager, containing the following summarized highlights from the law:

A manufacturer of a dangerous drug distributed in California shall submit to the board, no later than December 31, 2014, a declaration signed under penalty of perjury by an owner, officer, or employee with authority to bind the manufacturer, containing the following: A list and quantity of dangerous drugs by name, product package (SKU) type and National Drug Code (NDC) product identifier in the possession, ownership, or control of the manufacturer, wholesaler or re-packager that were acquired prior to July 1, 2016; and,

  • A statement that specifies the means and source of acquisition

While the term “grandfathered” is not used in the draft regulation, the staggering of the dates allows for manufacturer’s, wholesaler’s and re-packager’s inventory manufactured or obtained prior to the effective dates of SB 1307 to be traded so long as appropriate labeling is in place to assure compliance.

Is your company ready? To test your preparedness ask yourself these questions and determine whether you can answer them correctly.

1.     What is the difference between serialization, e-pedigree and track and trace?

2.     What are the common standards available for use to ensure interoperability among trading partners?

3.     At a practical level, what data carriers are available for manufacturers and downstream trading partners for encoding SNIs, and what are the respective benefits, costs and problems associated with each data carrier?

4.     As a manufacturer, are you intending to encode lot numbers and expiration dates into your SNI, or omit them? Why or why not?

5.     Are you prepared to find sufficient real estate on your labeling to support both a linear barcode to meet the hospital bar code rule as well as your chosen data carrier for your serialized product?

6.     If you have to change your label to accommodate both a linear bar code and a data carrier, how do you intend to inform FDA: a pre-approval supplement, or an annual report?

7.     Do you know what your third party logistics provider’s obligations are for receiving and reading serialized product under SB 1307?

8.     Aside from California, are you aware of the current status of other state legislation covering e-pedigrees? How about other countries?

9.     As a manufacturer, is your company registered in those states your products are currently being dispensed or administered in?

10.  For California law when must a manufacturer, wholesaler or pharmacy create a pedigree:

a.     When selling a drug?
b.     When acquiring a drug?
c.     When selling a drug at wholesale?

For more information contact Dan Steiber.

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New HHS Report Indicates Shocking Gaps between ASP and WAMP

The HHS Office of the Inspector General (OIG) released a report comparing average sales prices (ASP) to widely available market prices (WAMP) for selected drugs. The report compares ASPs to WAMPs for 14 drugs that have been identified in previous OIG reports for repeatedly exceeding the 5 percent ASP to average manufacturer price (AMP) threshold.

As part of the ASP price substitution policy, OIG is required to conduct studies that compare ASP to WAMP and AMP for Medicare Part B drugs to identify if the ASP of a drug exceeds either the WAMP or the AMP by a certain threshold.

The study revealed significant gaps in what is being reported between the manufacturers and the distributors in come cases gaps of over 300%!

D2 readers can find this document at http://oig.hhs.gov/oei/reports/oei-03-10-00280.pdf

Below is a summary statement taken from the above document.

Federal law requires OIG to conduct studies that compare ASPs to W AMPs and average manufacturer prices (AMP).  I f  OIG finds that the ASP of  a drug exceeds either the WAMP or AMP by a certain threshold (currently 5 percent), the Secretary of  Health and Human Services (the Secretary) may disregard the ASP for the drug when setting reimbursement amounts.  Since the implementation of the ASP reimbursement methodology, OIG has issued 27 reports comparing ASPs to W AMPs and AMPs

(2 comparing ASPs to WAMPs, 25 comparing ASPs to AMPs). The purpose of this review was to compare ASPs to W AMPs for 14 drugs that have been identified in previous OIG reports as repeatedly exceeding the 5-percent ASP-AMP threshold.  However, limitations and irregularities in the sales data provided by the distributors and manufacturers of the 14 drugs called into question the data's accuracy and reliability, and prevented us from measuring W AMPs against the threshold.

All of the manufacturers that reported direct sales to providers included data on their discounts and rebates for those sales.  However, two distributors (which sold over half of all the units reported to us) were not able to determine the discounts and rebates they provided, meaning that the W AMPs we calculated most likely did not reflect the actual prices paid in the marketplace.  In the past, OIG has had difficulty obtaining data on discounts and rebates from distributors, but in those instances, the missing data did not have the same impact on our results.

Furthermore, the total number of units sold reported to us by distributors and manufacturers differed substantially from the number reported to the Centers for Medicare & Medicaid Services (CMS) through quarterly ASP submissions, potentially resulting in our data reflecting an inaccurate number of sales.  Most likely because of these issues, the WAMPs we calculated varied widely from other pricing points; several drugs had WAMPs that were substantially higher than the associated ASPs and AMPs.  We plan to continue to fulfill our statutory mandate to conduct WAMP studies, and these issues will need to be addressed before any future efforts can be made to compare ASPs to WAMPs.  We will consider alternative methodologies that will allow us to conduct pricing comparisons, including directly surveying providers to obtain accurate and complete sales data.



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Charlie Bowlus of ECRM Passes

He was a true friend of mine and the industry and the founder of an extraordinary organization.  When I started consulting many years ago it was Charlie that offered me a hand and access to his event so I could network.  I'll be forever grateful for his wisdom and generosity.  Please say a prayer for his family and the extended family of his legacy, his ECRM employees.
Thank you.


Overwhelming Week at ASCO…but McKinsey’s Report on Exchanges Worth Review

D2 was in force at ASCO the last few days and buried in an avalanche of oncology news lots of news on favorable and unfavorable drug trials information from American Society of Clinical Oncology congress this week McKinsey & Co. released a report citing a shocking 30% of employers may cease offering health insurance  coverage to their staff once the exchanges are in place in 2014.  This means big changes in managed care teams and contracting for manufacturers and commercial payers.  D2’s own MCO field team is meeting now with payers across the nation as we launch programs for our clients and will keep you abreast of changes uncovered. Read more on the report here: How US health care reform will affect employee benefits.

Our D2 Managed Care Team provides national account coverage with payers on behalf of our clients http://www.d2rx.com/managecare.html , with our teams we focus on drug coverage on both the "medical/buy and bill" and the drug benefit.

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Pharma Execs Beware: Fair Market Value Assesments Are Your Best Defense

In sports and war and now business, sometimes your best offense is a great defense.

In a recently published article, Fox News describes the slippery slope many pharma execs are finding themselves in that in many ways can be better managed.  D2 has developed a scientific approach to assessing Fair Market Value of services based on a review of the market value of those services.  Should a legal audit ever take place the first defense can be a review of the rationalization of why your organization chose one vendors services over another.  Conducted by a third party such as D2, the value of such a review can be your best defense.  We use a team of associates that meticulously review all of the proposals and contacts.  We match like services on a grid with descriptions of those activities.  The grid harmonizes the activities so that there is a fair comparison of those activities and their subsequent pricing.  This service has utility in both establishing the efficiency of the service provider but also hold your organization accountable as well as the vendor for those services.

contact david.suchanek@d2rx.com , dean.erhardt@d2rx.com or dan.steiber@d2rx.com

WASHINGTON -- It's getting personal now. In a shift still evolving, federal enforcers are targeting individual executives in health care fraud cases that used to be aimed at impersonal corporations.

The new tactic is raising the anxiety level -- and risks -- for corporate honchos at drug companies, medical device manufacturers, nursing home chains and other major health care enterprises that deal with Medicare and Medicaid.

Previously, if a company got caught, its lawyers in many cases would be able to negotiate a financial settlement. The company would write the government a check for a number followed by lots of zeroes and promise not to break the rules again. Often the cost would just get passed on to customers.

Now, on top of fines paid by a company, senior executives can face criminal charges even if they weren't involved in the scheme but could have stopped it had they known. Furthermore, they can also be banned from doing business with government health programs, a career-ending consequence.

Many in industry see the more aggressive strategy as government overkill, meting out radical punishment to individuals whose guilt prosecutors would be hard pressed to prove to a jury.

The feds say they got frustrated with repeat violations and decided to start using enforcement tools that were already on the books but had been allowed to languish. By some estimates, health care fraud costs taxpayers $60 billion a year, galling when Medicare faces insolvency.

"When you look at the history of health care enforcement, we've seen a number of Fortune 500 companies that have been caught not once, not twice, but sometimes three times violating the trust of the American people, submitting false claims, paying kickbacks to doctors, marketing drugs which have not been tested for safety and efficacy," said Lewis Morris, chief counsel for the inspector general of the Health and Human Services Department.

"To our way of thinking, the men and women in the corporate suite aren't getting it," Morris continued. "If writing a check for $200 million isn't enough to have a company change its ways, then maybe we have got to have the individuals who are responsible for this held accountable. The behavior of a company starts at the top."

Lawyers who represent drug companies say the change has definitely caused a stir, but the end result is far from certain.

"People are alarmed," said Brien O'Connor, a partner in the Boston office of Ropes & Gray. "They want to know what facts and circumstances would cause the Justice Department to indict someone who hadn't even known about the misconduct. They are doing all they can to achieve compliance."

Others say high-powered corporate targets won't go meekly.

"If the government does continue to press its campaign against individuals, we will see the limits of the government's theories tested," said Paul Kalb, who heads the health care group at the law firm of Sidley Austin in Washington. "In my mind, there is a very important open question as to whether individuals can be held criminally culpable or lose their jobs simply by virtue of their status."

Although the Obama administration has increased scrutiny of corporate America generally, this shift in health care enforcement seems to have come up from the ranks, government and corporate attorneys say.

Investigators and lawyers at the HHS inspector general's office, the Justice Department and the Food and Drug Administration started moving more or less independently toward holding executives accountable. Morris outlined the inspector general's position in congressional testimony this spring, saying his office will use its power judiciously.

A test case is playing out with an 83-year-old drug company chief executive, Howard Solomon of New York City-based Forest Laboratories. Forest makes antidepressants, blood pressure drugs and other medications. Last month, the inspector general's office notified Forest that Solomon could potentially be banned from doing business with federal programs.

The power to ban or "exclude" an individual rests with the inspector general. It's routinely applied to low-level violators, but rarely to people of Solomon's rank. In the industry, they call it the "death penalty."

Last year, a Forest subsidiary pleaded guilty to criminal charges as part of a settlement with the Justice Department in which the company also agreed to pay $313 million to resolve long-running investigations. Prosecutors charged that Forest deliberately ignored an FDA warning to stop distributing an unapproved thyroid drug, promoted the use of an antidepressant in treating children although it was only approved for adults and misled FDA inspectors making a quality check at a manufacturing plant.

The company said it had considered the case closed. But then came the inspector general's letter.

"No one has ever alleged that Mr. Solomon has done anything wrong and excluding him would be completely unjustified," Herschel Weinstein, Forest's general counsel, said in a statement. "In prior cases where a senior executive has been excluded, that individual has been accused of wrongdoing and ultimately has either been convicted of or (pleaded) guilty to a crime."

Forest is fighting the move to ban Solomon. The inspector general's office refused to comment on the case, and no final decision has been made. In congressional testimony, Morris said that when there is evidence an executive knew or should have known about misconduct, the inspector general "will operate with a presumption in favor of exclusion of that executive."

Separate from the inspector general's power to ban, the FDA has resurrected something called the "Park Doctrine," which makes it easier for prosecutors to bring criminal charges against an executive.

The doctrine, stemming from a 1970s Supreme Court case, allows the government to charge corporate officers in the chain of command with a criminal misdemeanor. They could face up to a year in prison and fines if they had the authority and responsibility to prevent, detect or resolve misconduct affecting the public welfare but failed to do so.

It's making an entire industry nervous.


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Specialty Pharmacy Times Oncology Edition Just Published (link below)

The most prolific area of drug discovery is oncology and it is considered to be the “The Holy Grail” of specialty pharmacy. Cancer treatment or oncology medication therapy has evolved tremendously over the last decade and is more accessible to the benefits of specialty pharmacy practice. In this third edition of Specialty Pharmacy Times, we have again tapped the “best of best” to help provide our readers with insight into a number of the dynamics focused exclusively on oncology. We delve into the role of specialty pharmacy including the integral ethical decisions that specialty pharmacy providers are challenged to make as members of the patient’s health care team.
Dr. Correia, a member of our Editorial Board, discusses how when pharmacists focus on the whole person, patients are better able to follow their treatment plan—leading to better health and lower total health care costs. Dr. Brennan and The Zitter Group provide insights into a shift from “buy and bill” to a more cost-focused delivery system of leveraging specialty pharmacy, including infused products. Rena K. Goins explores the landscape of oncology care and the curious dynamics that come into play with the interrelationships of the various oncology organizations —from treatment pathways to distribution. Furthermore, we offer practice information on Accountable Care Organizations, MedGuides, e-Prescribing, Financial Assistance Programs, and some practical insights from the specialty pharmacy “bench.”

With this special edition focused on oncology, we continue our mission: Specialty Pharmacy Times is THE journal fully committed to setting the publication standard through peer-written and reviewed articles focused on the “real world” of specialty pharmacy practice.

Oncology treatment or “chemo” has most often been exclusively an oncologist office–administered therapy. However, the pharmaceutical industry has been working hard to provide more convenient dosage forms for patients, including many self-injectables and orals, which raises the challenge of where patients will receive their medication therapy in the future. Treatment access decisions are being made based on a number of factors, including reimbursement, cost, dosage form, patient care, and supply chain requirements—and are more recently, pharmacogenomics, to name a few. These decisions are frequently made by payers and the manufacturer and often driven by the services offered by specialty pharmacy. Which raises the question, is your pharmacy operation “in the game, or in the stands watching?” Many of the answers to this question and more lie ahead in this inaugural Specialty Pharmacy Times Oncology Edition. We invite you to enjoy this issue and pass it on!



Successful Strategy in Specialty Pharmacy Accreditation: Vital Care of Meridian

Vital Care Rx announced today that it is applying for Specialty Pharmacy Accreditation, Version 2.0 from URAC, a Washington, DC-based health care accrediting organization that establishes quality standards for the health care industry. URAC offers the only third-party, voluntary accreditation program of this scope for pharmacy benefit management and prescription services industry. All standards were developed by URAC’s Pharmacy Advisory Committee, which includes a wide range of stakeholders: employers, consumers, pharmacy consultants, health plans, retail pharmacy, pharmacy benefit management organizations, pharmacy professional organizations; labor, and large public purchasing groups. “Our team at Vital Care Rx has a long history of providing excellent service and high quality patient care. We are pleased to be pursuing the URAC Specialty Pharmacy Accreditation as demonstration of our commitment to the needs of our patients and clients,” said Logan Davis, Director of Clinical Services at Vital Care Rx. Vital Care Rx is an independently owned pharmacy based in Meridian, Mississippi. In business for over 25 years, Vital Care Rx is an innovator in high touch patient care and serves patients throughout the country. As a pharmacy providing specialty medications, the team at Vital Care Rx provides sophisticated compliance and adherence services to its patients and customized solutions to its industry partners. Its mission is, “We are a company dedicated to patient care. We believe achieving the best outcomes for our patients comes from a foundation of trust, communication and a commitment to delivering high-touch quality care. We measure our success by the outcomes of our patients, the satisfaction of our partners and the effectiveness of our relationships with providers.” “By choosing to seek URAC Specialty Pharmacy Accreditation, Version 2.0, Vital Care Rx has displayed leadership through a commitment to quality and accountability,” said Alan P. Spielman, URAC president and CEO. URAC’s Specialty Pharmacy Accreditation ensures that organizations meeting the rigors of accreditation uphold the highest standards in the industry. Accreditation reinforces best clinical and organizational practices for ensuring appropriate and safe medication use and optimal patient outcomes. Evidence for therapy counseling, disease education, care coordination, comprehensive patient education, and adherence management are critical for assuring successful medication patient management and safety — all standards evaluated under URAC’s Specialty Pharmacy Accreditation. It allows organizations to demonstrate their commitment to purchasers of services to the highest standards for quality management, patient safety and monitoring, and prescriber and consumer communications. Those organizations achieving accreditation distinguish themselves by demonstrating their commitment to quality, transparency, and efficiency—strengths viewed by many with a critical eye in today’s health care environment. Employers, health plans, prescribers, and PBMs ask for accreditation in RFPs as a means to validate an organization’s excellence in quality and patient management. Organizations meeting URAC’s Specialty Pharmacy Accreditation set themselves apart in a highly competitive marketplace as achieving best practices for managing complex medication therapies and patient management, thus assuring appropriate management of costly medication treatments. URAC, an independent, nonprofit organization, is a leader in promoting health care quality through accreditation and certification programs. URAC's standards keep pace with the rapid changes in the health care system, and provide a mark of distinction for health care organizations to demonstrate their commitment to quality and accountability. Through its broad-based governance structure and an inclusive standards development process, URAC ensures that all stakeholders are represented in setting meaningful standards for the health care industry. For more information, visit www.urac.org. For more information contact Logan Davis, Director of Clinical Services, at 877-229-1724 or visit www.vitalcarerx.com.

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Nashville Health Council: Deal Making Trends and Strategies for Health Care Companies

“The market is over health care reform, it’s in the rearview mirror,” said Rob DiGia, Global Head of Healthcare Banking, UBS Investment Bank
at a healthcare investor event held earlier this week.  DiGia was joined by other panelist from Morgan Stanley, Oak Investment Partners, Goldman Sachs, and a moderator from Brentwood Capital Advisors on May 10th for Nashville Health Care Council’s event “Financing the Deal:
Deal-making trends and strategies for health care companies.” DiGia continued his comments on the impact of health care reform stating it will
continue to be in the headlines for its political sensitivity, but that overall the managed care market has evolved to move past the noise and get down to the
business of delivering solutions to meet the new mandates.  “Americans are becoming active purchasers of health care, like in other countries,” he said.
He compared the new ACO model to the old failed practice management and MCO models, stating this time it should be successful as the stakeholders will
be accountable in new model.  He and other panelists placed strong emphasis on a movement to a provider centric model of care vs. a payer centric model.
Annie Lamont, Managing Partner, Oak Investment Partners reiterated the change in the market, “It was business to business, now it’s business to
consumer.”  Greater involvement by patients brings a new dynamic to the market.

The panel commented on the recent flurry of readily available
capital in the market for health care ventures with a particular focus on
companies that are service-based and leverage technology.  Andrew Bhak, Managing Director, Healthcare
Investment Banking, Morgan Stanley estimated $37billion in U.S. M&A
activity year-to-date with about half of that being in services based
companies.  Bhak sees a robust channel of
funding for health care firms continuing through the next year plus.  An interesting component of many deals is
that once announced, both entities are seeing a stock ‘bump’.  In the past it was usually a one-sided
gain.    Raz Zia, Managing Director, Merchant Banking
Division, Goldman Sachs identified another trend he’s seeing in partnerships
and deals – shared risk.  Zia says he
believes the health care winners will be the services companies and he sees
good success already with those companies that are in deals where each side
shares in a risk/reward model.  Provider
engagement in these models, Zia says, will create sustainable new businesses.

Moderated by Tom Wylly, Senior Partner, Brentwood Capital Advisors,
the panel is one in an ongoing series of events sponsored by the Nashville
Health Care Council.

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Accreditation Competitive Advantages

If you have recently filled out a request for proposal (RFP), you will see that one question that comes up over and over is “What accreditations does your organization have in place?” If your organization is not accredited with any of the major players, you could instantly lose out on future business growth opportunities.

There are challenges when determining the return on investment for an accreditation. It takes several hours of dedication to apply, document new SOP’s and implement improvements to your operations. However, there are several competitive advantages that are created by becoming accredited.

One advantage is your access to future RFP’s and business growth. This is also important when considering contract renewals for existing business. When it comes time to renew a contract, you may have to get an accreditation in order to keep the contract. This has just happened to several pharmacies who are involved with Blue Cross Blue Shield of North Carolina. They are mandating specialty pharmacies to become URAC accredited. The deadlines were tight but achievable. However, if you were not prepared and didn’t budget for these expenses, it could be a real challenge for your organization.

Another competitive advantage to accreditation is proper disaster recovery and planning. This is a something that most accreditations will review during the inspection. It will help you prepare your organization for natural disasters and other problems that could bring your business to a screeching halt. Some organization put off disaster management. They take the risk that something won’t happen. There are recent examples of organizations that were properly prepared for disaster recovery. They were able to continue their business operations during natural disasters and it instantly gave them a competitive advantage and win business during the natural disaster and future contracts.

Accreditation will hold an organization accountable on several levels. One way they do this is by forcing and organization to review and implement new policies and procedures. They guide an organization to continually improve their operations. This is another competitive advantage because this guidance can help your organization to become a leader in their specific services and products that are provided. This can get you recognized by key decision makers and improve the influx of RFP’s, thus growing your business.     

 Quintin Jessee, RPh., D.Ph.

Senior Consultant, D2 Pharma Consulting LLC

 Contact Information: Quintin.Jessee@d2rx.com

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