Dear Colleagues;
The most important development of the past week for us pharmacists was the protocol negotiations between the SGK and TEB. Following this agreement, which concluded with a compromise and was sealed with signatures, comments will certainly be made and gains will be discussed. If we look at this agreement from a compounding (magistral) perspective; as will be remembered, on 13.03.2013, as the editorial board of Eczacının Sesi, we made a call through an article addressed to the Central Steering Committee of the Turkish Pharmacists’ Association, reminding in brief that ‘The current compounding tariff is inadequate in terms of content to include modern compounding ingredients; in this sense, an updated tariff enriched with current active and auxiliary substances needs to be reorganized; taking into account today’s economic conditions, it should be restructured to protect the Pharmacist’s Professional Fee and consider the current prices of raw ingredients; deductions made by the SGK during compounding prescription audits should not be left to the arbitrary interpretations of our colleagues working at that institution; and necessary steps should be taken as soon as possible to establish a scientific committee to evaluate disputes and appeals.’
Furthermore… in the article I wrote on 27.09.2015 under the title THE COMPOUNDING TARIFF MUST BE UPDATED AS SOON AS POSSIBLE..! , I gave examples from the Ottoman era to the present regarding the determination of the compounding tariff in our country and explained the journey of the Compounding Tariff. Today, in compounding formula calculations where different pricing methods are applied in Europe, I gave an example from Belgium; mentioning that the reform regarding compounding preparations in Belgium came into effect as of April 2014, I drew attention to the fact that this new regulation introduced new prices and new pharmacy fees solely for compounding preparations. Accordingly, I shared the following example, noting that pharmacists are compensated on an “all-inclusive” basis covering the type of preparation, time spent, ingredients, and materials, and that under the new regulation, all compounding preparations are divided into 3 distinct categories based on time spent, each corresponding to a different fee:
1- Simple preparations (capsules, solutions…) 20 minutes, €12.93
2- Dermatological preparations (creams, lotions…) 32.5 minutes, €21.03
3- Difficult-to-prepare preparations (suppositories, ovules…) 50 minutes, €32.35
I stated that they were priced as such.
In our country, however;
As a result of the efforts of our professional organization, with the Ministerial Approval dated March 23, 2011 from the Ministry of Finance, via the provision “Article 14: The fees specified in the tariff and attached schedules are republished at the beginning of each year by adding the revaluation rates published by the Ministry of Finance”, the challenge experienced regarding revaluation was resolved and the annual updating of the compounding tariff was guaranteed.
However;
Although it was stated by the latest Ministerial Approval dated March 23, 2011 that ”Regulations to be made after this date for the ‘Compounding Tariff’, which was prepared by our Association, is currently in force, and is used in pricing compounded medicines prepared in pharmacies, are deemed appropriate to be updated annually based on the revaluation rates determined by the General Communiqué on Tax Procedure Law published by the Ministry of Finance in accordance with the Tax Procedure Law No. 213, and to be published by the General Directorate of Pharmaceuticals and Pharmacy accordingly without requiring a new approval,” unfortunately the compounding tariff has not been updated in any way from that date to the present. It is a fact that pharmacists incur losses on the prescriptions they prepare, both because the compounding tariff fails to reflect modern content and adequately compensate for the pharmacist’s labor, and because the raw ingredient prices in the tariff remain far below the amounts invoiced to pharmacies by supplier companies. For this reason, an urgent reorganization of the compounding tariff is critically needed.
As pharmacists, who are the masters of the healing art, we remind that the compounding tariff was last updated on March 23, 2011; and we urgently demand from our professional organization that the compounding tariff be enriched in terms of raw ingredients to meet today’s modern compounding formulas, and that pricing be established so that the pharmacist receives fair compensation for their professional labor…
I had concluded my article with these wishes.
Today, finally, 5 (five) years after March 23, 2011, the date the compounding tariff was last updated, and after we repeatedly emphasized the importance of the issue, the renewal of the Compounding Tariff has been included among the protocol articles. Now our expectation is that, after waiting all these years, there will be a pricing study worthy of the Pharmacist’s Labor, both in terms of content and pricing.
Last week, I shared with you my article titled ‘Do Not Do It’ regarding the unjustified deductions made by SGK regarding Pantocaine. In response to SGK’s statement starting with “based on the opinion that it can be used at a concentration of 0.5–1% in topical prescriptions, and also at a concentration of 4% as a percutaneous local anesthetic in venous cannulation,”
I mentioned that in dentistry worldwide, and as specialized products on pharmacy shelves, tetracaine 2% and in local use tetracaine up to 7% are prescribed and used, and that this formula is approved by the FDA. In the emails received, our colleagues stated that there is no need to look abroad, that the medication named OTIMISIN DROPS, which is approved by the Ministry of Health in our country and reimbursed by SGK, contains pantocaine active substance at a rate of 2.2%, highlighting this contradiction and expressing that these deductions must be lifted. Rightfully, they asked the question: with this logic, will prescriptions containing Otimisin also be subject to deductions?
Indeed, it is impossible not to agree with our colleagues. It is not right to evaluate all prescriptions with this mindset based on an isolated case of misuse. Our colleagues working at this institution have the knowledge and competence to distinguish misused prescriptions from legitimate ones. This deduction is too technical a matter to be left solely to the discretion of the SGK Guidance and Inspection Department. We expect our colleagues serving in the institution to take initiative in correcting this mistake. You might say that SGK obtained an opinion from one of our universities when making these deductions. I had stated that I was curious about the question posed to our university on this matter. The way the question is formulated is of critical importance.
When we read this section I took from the book of our esteemed professor, Prof. Dr. Nurettin Mazhar ÖKTEL, Professor of Pharmacology at Ankara University Faculty of Pharmacy, what I mean will be clearly understood.
DOSES OF MEDICINES
The amount of medicine used for therapeutic purposes is called a dose. This is reviewed by dividing it into two:
1) Therapeutic dose (Dose thérapeutique, Dosis therapeutica)
2) Toxic dose (Dose toxique, Dosis toxica)
The therapeutic dose is also called the officinal dose (Dose officinale, Dosis officinalis).
This is also studied by dividing into three:
1 — Maximum dose (Dose maximale, Dosis maxima)
It is the highest amount of a medicine used for therapeutic purposes.
2 — Minimum dose (Dose minimale, Dosis minima)
It is the lowest amount of a medicine used for therapeutic purposes.
3 — Medium dose (Dose médiale, Dosis media)
It is the average amount of a medicine used for therapeutic purposes. Sodium sulfate
(Glauber’s) salt is a medicine that possesses pharmacological effects in several aspects.
It is used as a purgative (laxative) both in humans and animals.
For example: In horses, for this purpose (i.e. as a purgative), it is used in amounts of 250.0 – 750.0.
250.0 is the minimum dose. 750.0 is the maximum dose.
500.0, which lies between them, is the medium amount.
Apart from this, the therapeutic dose is divided into two: a large amount of medicine administered at once, and small amounts of medicine given at intervals.
The first of these is called Dosis plana, and the second is called Dosis refracta.
Toxic dose: This is also divided into two: The first is the toxic dose (Dose toxique, Dosis toxica), which is the non-fatal amount whose ingestion produces symptoms of poisoning. The second is the lethal dose (Dose létale, Dosis letalis), whose administration results in death following symptoms of poisoning.
The amount in which medicines are used also varies according to the routes by which they are administered. For example: the dose of a medicine administered per os (orally) is not the same as the amount of the same medicine administered intravenously. For this reason, in the dosage of medicines, it is necessary to take into account the routes through which they are administered and calculate their amounts accordingly.
This is what our professor states.
Compounded preparations are formulations prescribed by the physician specifically tailored to the individual and the severity of the disease. The physician can formulate the required dose for their patient up to the lethal dose. The pharmacist is obliged to prepare the prescription provided that it does not contain a lethal dose.
Our Demand;
I hope that our colleagues working within the institution fulfill their professional responsibilities by correcting the dosage error that caused the deduction, starting with the word ‘TROPICAL’ (presumably intended to mean topical) found in the letter sent from the SGK to pharmacies under the subject of pantocaine deductions.
Wishing you a good week…
Spec. Pharm. Ahmet Nezihi Pekcan
Pekcan Pharmacy – Konya
[email protected]
Tel: (332) 3520657
http://www.majistralformul.com/
