Report: Expired HIV Drugs Dispensed in Puerto Rico

Summary of Findings
 
Contrary to Federal and Commonwealth requirements, the Health Department did not ensure that:
?      ADAP drugs were dispensed by a licensed pharmacist or by a pharmacy technician under the direct supervision of a licensed pharmacist;
?      the Pharmacy Distribution Center and three treatment clinics maintained an adequate ADAP drug inventory system; and
?      expired ADAP drugs were properly disposed.

In addition, contrary to its policies, the Health Department did not always take advantage of the opportunity to return expired drugs to their manufacturer for credit.

These issues occurred because the Health Department did not have adequate controls to dispense, account for, and safeguard its ADAP drugs. As a result, HIV / AIDS patients may have been exposed to health risks associated with the dispensing of drugs by unlicensed personnel. In addition, the Health Department could not ensure that it did not claim Federal reimbursement for ADAP drugs that were lost, stolen, or expired. There is also a potential risk that ADAP-eligible patients may have been dispensed expired drugs.

Recommendations

We recommend that the Health Department:
?      ensure that ADAP drugs are dispensed by a licensed pharmacist or by a pharmacy technician under the direct supervision of a licensed pharmacist,
?      implement procedures to adequately account for ADAP drug inventories, and
?      implement procedures to properly dispose of expired ADAP drugs, and, if possible, request credit or exchange from manufacturers for eligible expired drugs.