NATIONAL CLEARINGHOUSE ON INTERNET PRESCRIBING

The National Clearinghouse on Internet Prescribing emerged from a meeting between state and federal regulatory authorities and pharmaceutical industry representatives hosted by the Federation in January 2000 to discuss the challenges associated with the regulation of prescribing and dispensing of medications via the Internet. There was consensus that the Federation was in a unique position to assist regulatory authorities in their investigation of websites and associated physicians. In September 2000, the Clearinghouse was established within the Federation to collect and disseminate information on "rogue" Internet pharmacy websites offering prescribing and dispensing of prescription medications to consumers. This initiative achieves three broad goals:

Cooperation and Collaboration

The Federation is uniquely qualified to serve this function because of its formal relationship with all state medical boards in the United States and its territories and its well-established lines of communication with state and federal regulatory authorities, including the Department of Justice, the Drug Enforcement Administration, the Food and Drug Administration, and the Federal Trade Commission; national associations such as the National Association of Boards of Pharmacy, the National Association of Drug Diversion Investigators, the National Association of Controlled Substances Authorities, and the National Association of Attorneys General; representatives of the pharmaceutical industry; and the media. As the national association for state medical boards, the Federation is well positioned to facilitate communication and cooperation between regulatory authorities and the private sector.

Information Clearinghouse

A major goal of the Clearinghouse is to facilitate communication among all entities that play a role in regulating Internet pharmacy operations and the physicians associated with them. Regulatory efforts of state medical boards and other authorities have been complicated by a number of factors including:

1. The inability to identify the physical location of the business/pharmacy.
2. Anonymous physicians approving prescriptions.
3. The lack of licensing information on such physicians and associated pharmacists and pharmacies.

Because online pharmacies operate in multiple states, regulatory authorities experience difficulty in tracking and monitoring enforcement actions. This lack of a formal vehicle for communication has resulted in the duplication of efforts and missed opportunities for cooperation among regulators. Since inception, the Clearinghouse has been successful in establishing lines of communication between state and federal regulatory authorities having jurisdiction over Internet prescribing and has assisted in the identification of numerous physicians, pharmacies, and website owners. Additionally, the Clearinghouse actively supports state medical board efforts to promulgate policy or guidelines for physician practice via the Internet. The Federation adopted the Model Guidelines for the Appropriate Use of the Internet in Medical Practice in April 2002, one of the first national standards for Internet medical practice.

Investigation

The Clearinghouse actively seeks to identify physicians and pharmacies associated with "rogue" pharmacy websites through the online purchase of medication. The information generated by a purchase is subsequently reported to all affected state and federal regulatory agencies and complaints are filed with state medical and pharmacy boards.

RELATED HEALTH RISKS

"Rogue" Internet pharmacy websites, those that allow consumers to obtain prescription medications without an evaluation by a physician, pose an immediate threat to the public's health and safety. Health risks include

1. Adverse drug reactions and/or interactions
2. Misdiagnosis or delay in diagnosis
3. Failure to identify complicating conditions
4. Misuse, abuse, and diversion of prescription medications, including controlled substances.

Medical complications resulting from the use of prescription medications obtained online rarely come to the attention of regulators because consumers are reluctant to report untoward results or have no knowledge of how to pursue complaints.

RESULTS OF CLEARINGHOUSE ACTIVITIES

Information generated by the Clearinghouse has assisted regulatory efforts of state medical and pharmacy boards and federal authorities to identify areas where regulatory efforts are likely to overlap, thus reducing duplication of efforts and unnecessary drains on limited staff and financial resources. Clearinghouse efforts have contributed to a safer Internet pharmacy environment where consumers can benefit from the convenience and accessibility of Internet commerce while enjoying the protection afforded by appropriate regulation. Additionally, eliminating "rogue" Internet pharmacy websites will permit legitimate operations to compete on a level playing field where market share is determined by such issues as price and quality of service.