1. Recent Trends in Pain
Clinic and Community
Pharmacy Activity
Presented by Dr. Jacinta Gau, Ph.D.
Research Assistance by Erika Brooke, M.S.
University of Central Florida 1

2. Background of the Study
• UCF researchers received federal funding to study HB 7095
(“pill mill law”) from multiple perspectives
• Cannot fully isolate from PDMP and the 2010 pain clinic law, as
well as ramped-up law enforcement efforts
• These laws imposed new restrictions on persons who
prescribe or dispense controlled substances for the treatment
of chronic, non-malignant pain, and on pain clinics and
pharmacies
• This presentation will focus on facilities
• The following data are from the Florida Department of Health
• Analyses and interpretations are those of the UCF researchers,
not DOH 2

3. Part I: Registration and New
Establishments
3

4. NewPMCApplicationsReceived(MonthlyMean)
0
10
20
30
40
50
60
70
80
90
2010 2011 2012 2013
4

5. NewPMCApplicationsReceived(AnnualCounts)
0
200
400
600
800
1000
1200
2010 2011 2012 2013
*2013 data as of May 10
5

6. NewPMCs(Monthly Mean)
0
10
20
30
40
50
60
70
80
90
100
2010 2011 2012 2013
6

7. NewPMCs(Annual Counts)
0
200
400
600
800
1000
1200
2010 2011 2012 2013
*2013 data as of May 10
7

8. Summary of PMC Application and
New PMC Trend
• High in 2010, likely an artifact of FS 458.3265
• Continual reduction thereafter suggests genuine downward
trend in new applications and new clinics
• Monthly mean new apps. down 74% in 2013 compared to 2011
• Consistent with hypothesis that HB 7095 had an impact
• Deterrence?
• Consistent with other data and reports
• Medical examiner reporting reduction in Rx pill related deaths
• News reports of a reduction in the number of clinics
• Law enforcement claims that Rx pills are becoming harder to get
and more expensive
8

9. NewCPharmApplicationsReceived(MonthlyMean)
0
5
10
15
20
25
30
35
40
2008 2009 2010 2011 2012 2013
9

10. NewCPharmApplicationsReceived(AnnualCounts)
0
50
100
150
200
250
300
350
400
450
2008 2009 2010 2011 2012 2013
*2008 data incomplete; 2013 as of May 10
10

11. NewCPharmPermitsIssued(Monthly Mean)
0
5
10
15
20
25
30
35
40
2008 2009 2010 2011 2012 2013
11

12. NewCPharmPermitsIssued(Annual Counts)
0
50
100
150
200
250
300
350
400
450
2008 2009 2010 2011 2012 2013
*2008 data incomplete; 2013 as of May 10
12

13. Summary of CPharm New
Applications and Permits
• Apparent slight downward trend since 2010
• Suggests no systematic efforts to circumvent the dispensing ban
through collusion
• No new market
• However, viewed in light of anecdotes about restrictive
dispensing practices at large pharmacies and small supplies
that run out, need to monitor legitimate pain patients’ access
13

14. PMCAdministrative Closures
(MonthlyMean)
0
10
20
30
40
50
60
2010 2011 2012 2013
14

15. PMCAdministrativeClosures(AnnualCounts)
0
100
200
300
400
500
600
700
2010 2011 2012 2013
*2010 data incomplete; 2013 as of May 10
15

16. Summary of Administrative
Closures
• Clear downward trend in self-closures since 2011
• Consistent with hypothesis that HB 7095 had an impact, even if
indirect
• Reduction in new applications and permits
• Fewer in operation overall meant a more stable customer base
• Future question: were they closing for non-voluntary reasons
instead? In particular, law enforcement investigations?
16

17. Part II: Enforcement
17

18. PMCComplaintsReceivedandDisciplinaryActions
(MonthlyMean)
0
1
2
3
4
5
6
7
8
9
10
2010 2011 2012 2013
Compl.
Disc.
Em. Axn
18

19. PMCComplaintsReceivedandDisciplinaryActions
(AnnualCounts)
0
10
20
30
40
50
60
70
80
90
100
2010 2011 2012 2013
Compl.
Disc.
Em. Axn
*2010 data incomplete; 2013 as of May 10
19

20. CPharmComplaintsReceivedandDisciplinaryActions
(MonthlyMean)
0
5
10
15
20
25
2008 2009 2010 2011 2012 2013
Compl.
Disc.
Em. Axn
20

21. CPharmComplaintsReceivedandDisciplinaryActions
(AnnualCounts)
0
50
100
150
200
250
300
2008 2009 2010 2011 2012 2013
Compl.
Disc.
Em. Axn
*2008 data incomplete; 2013 as of May 10
21

22. Summary of Complaints and
Discipline
• Noticeable decline in complaints about PMCs– monthly mean
down 66% in 2013 relative to 2010
• Sharpest annual drop is from 2011 (7.42; n = 89) to 2012 (3.08; n
= 37)– HB 7095 took effect July 1, 2011
• Required reception and waiting areas, restrooms
• Enhanced ability for clinics to be declared nuisances
• Deterrence
• Closures of problematic locations
22

23. Summary of Complaints and
Discipline
• No similar trend in complaints about community pharmacies
• Suggests that this the PMC decline is not simply part of a general
decline in complaints– the PMC decline was unique
• Suggestive of legislation taking effect and having an impact
• But there are a lot of complaints about pharmacies
• Perhaps worth a legislative investigation
• Hard to interpret DOH disciplinary action patterns
• Missing variable: referrals to law enforcement
23