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The Division is seeking input on the development of a new Compound Medications Plan-Based
Audit for physicians that prescribe compound drugs.
Many of you are probably familiar with the recent increase in the number of compound drugs being
prescribed by some physicians. By far, the most common type of compound drug being prescribed
is topical creams. These are usually pain creams or scar creams. These creams are often billed at
astronomical sums, sometimes over $10,000.00 for a one month supply. These creams often contain
common, inexpensive ingredients and have no proven efficacy over FDA approved drugs.
CBS News ran a national story last year on insurance companies receiving outrageous billing for
unwanted prescription creams. The story reported on a Dallas compounding pharmacy under federal
investigation for its practices.
The ODG Treatment Guidelines do not recommend compound drugs as a first line therapy. Rather,
commercially available, FDA-approved drugs should be given an adequate trial. The ODG also
notes,
Recently, some pharmacies have been making and marketing stock compound drugs
for the WC patient population. Among the FDA “Red Flags” for Enforcement Action
on Compounded Drugs is: "Compounding drugs in anticipation of receiving
prescriptions, except in very limited quantities in relation to amounts compounded
after receiving valid prescriptions."
One has to wonder whether the physicians prescribing these compound creams have some
motivation for doing so other than the patient’s best interests. These physicians should keep in mind
that if they have a compensation arrangement with or financial interest in the pharmacy, they are
required to disclose it in accordance with DWC Rule 180.24.