To: DPH-Testimony, Reg (DPH)

From: Muise, Gene

To: DPH-Testimony, Reg (DPH)

Cc: Abel, Brendan

Subject: 105cmr 720 - DFC regulations

Date: Thursday, January 19, 2017 3:33:34 PM

Thank you for the opportunity to comment on MA Chapter 258 of the Acts of 2014 (An act to increase the Opportunities for Long Term Substance Abuse Recovery)

This new law tasked the State Formulary Commission with preparing a drug formulary of substitutions for Schedule II or III opiates that the Commission has determined have a heightened level of public health risk due to the drugs’ potential for abuse and misuse. Pursuant to statute, where an opioid with a heightened level of public health risk (HPHR) has been prescribed without a notation of “dispense as written”, pharmacists must dispense an interchangeable abuse ‐deterrent product if one exists

Although I support the intent of the law I have concerns with some of the specific provisions. I do not feel the cost implications have been properly vetted. The Mt. Auburn Cambridge Independent Practice Association, Inc. (MACIPA) is responsible for the cost of prescriptions drugs for our commercial risk contracts. Based on my projections, the conversion of generic morphine sulfate extended release to branded Embeda, as proposed by the State Formulary Commission, could cost upwards of $31,000 annually. Although physicians can opt out by writing “dispense as written” this process in not common when prescribing generics, and therefore I do not feel is a viable process to maintain the utilization of a low cost generic. I would gladly recommend the conversion of generic morphine sulfate extended release to a morphine formulation with an abuse ‐deterrent, like Embeda, if there was data to support that the snorting or injecting of morphine was problematic in my patient population and the newer formulations would prevent such activity. To date I am unware of any evidence to support that hypothesis.

In summary, this law was developed with good intentions are I fully support its intention. However I feel that some of the cost implications may be excessive and with minimal benefit. I would advise removing any process that interchanges a generic opioid formulation to a more expensive branded product.

On behalf of the Mount Auburn Cambridge Independent Practice Association, Inc. (MACIPA). A physician membership organization, established in 1985 with over 500 physicians who have privileges at Mount Auburn Hospital. MACIPA physicians serve over 100,000 patients in the greater Cambridge, Watertown area.

Gene Muise R.Ph, MS.

Mount Auburn Cambridge Independent Practice Association (MACIPA) Director of Pharmacy

1380 Soldiers Field Rd Brighton, MA 02135

6172592129 Office Phone

6172592189 Office Fax

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