NCPA identifies track-and-trace best practices
ALEXANDRIA, Va. — The National Community Pharmacists Association on Wednesday expressed its concerns over track-and-trace systems in its comments submitted to the U.S. Senate Health, Education, Labor and Pensions Committee hearing, “Securing the Pharmaceutical Supply Chain.”
"NCPA continues to feel that track-and-trace technologies remain largely unproven and such a system may prove to be prohibitively expensive for independent community pharmacies," stated Douglas Hoey, NCPA EVP and CEO. "We have identified a number of essential elements that should be considered as any proposed track and trace system is developed."
The NCPA had the following recommendations for the federal government:
- Any track-and-trace system should have a risk-based approach to determine the scope of which products will be targeted at the outset of the program, such as controlled substances and frequently counterfeited products;
- Federal grants designed to incentivize adapting of any track-and-trace program should include smaller participants in the supply chain, such as independent community pharmacies, that otherwise would be unduly financially burdened;
- There should be interoperability between the various systems for any track-and-trace program to pave the way for easier communications between various manufacturers and distributors;
- An authentication consensus should emerge about the definition and timing of when products will be verified, along with what will happen should the verification standard not be meet at any step in the process; and
- Independent community pharmacists should be allowed to use inference — a process that would allow them to scan or verify prescription drugs in larger batches instead of bottle by bottle.
“NCPA believes that the U.S. pharmaceutical supply chain is safe and secure,” Hoey said. “There are a number of different tactics or approaches that could provide further assurances of integrity — including efforts to combat pharmaceutical cargo theft and the implementation of national, uniform federal license standards for drug wholesalers.”