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Helping Americans Get The Truth About Prescription Drug Savings
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Last week we wrote that we would present a new section of Gabe Levitt’s report on online pharmacies. This week, we are going to start off with the Executive Summary of the report. We’ve given a sample below, but you’ll have to visit to view the whole Executive Summary.

The U.S. government relies on the Government Accountability Office (GAO) for objective and independent research and analysis of government programs and policies that affect public health. GAO’s report entitled Internet Pharmacies: Federal Agencies and States Face Challenges Combatting Rogue Sites, Particularly Those Abroad (the “GAO report”) contains critical inaccuracies and omits important peer-reviewed research to the extent that lawmakers and their staffs will likely draw erroneous conclusions about international online pharmacies that could lead to overreaching and unnecessary enforcement actions that disadvantage consumers and threaten public health. The GAO report was written pursuant to Section 1127 of the Food and Drug Administration Safety and Innovation Act of 2012 (FDASIA), a law dedicated to protecting public health.

In contrast to the GAO report, the following holistic, consumer-focused, evidence-based analysis discusses online pharmacies within the important context of a health crisis caused by high drug prices in America, and can more appropriately guide lawmakers on how to protect the public from counterfeit or substandard medication. Legitimate public health concerns about rogue online pharmacies are being used to encourage legislative, regulatory, and private sector actions that curtail online access to safe and affordable medication. The consequence of overreach could be millions more Americans facing economic hardship or having to forgo prescribed medication, which studies show can lead to more sickness and death.

Fifty million Americans did not fill a prescription due to cost in 2012, according to the Commonwealth Fund. According to the Harvard School of Public Health, over half of Americans who do not take prescription medication due to cost report becoming sicker.1 That means potentially 25 million Americans become sicker each year because they can’t afford prescribed medication. According to the U.S. Centers for Disease Control and Prevention (CDC), about five million Americans buy prescription drugs from foreign sources each year for reasons of cost.  Additional estimates show that between four and five million Americans get their imported prescription drugs through international online pharmacies due to their lower prices.

As a government performance audit, the GAO report must abide by generally accepted government auditing standards (GAGAS). Those standards include a responsibility to meet stringent professional and ethical standards, including “…exercising reasonable care and professional skepticism.Reasonable care includes acting diligently in accordance with applicable professional standards and ethical principles. Professional skepticism is an attitude that includes a questioning mind and a critical assessment of evidence.”

The GAO report does not meet the appropriate performance audit standards because its conclusions are mostly based on consultations with stakeholders that have significant financial interests in the audit’s outcome or the organizations they fund: the GAO seems to rely on their data and positions without a “questioning mind and a critical assessment of evidence.” The GAO also misreports critical data it was provided by industry and government sources. GAO did not consult a wider range of available data, expert analyses, and stakeholders known to its authors that would have resulted in a more balanced analysis.[2] Central to the above, the GAO seems to neglect the public interest by completely omitting a discussion about Americans who rely on safe and effective prescription drug imports ordered from foreign Internet pharmacies, ones the GAO report mistakenly refers to as “rogue.”

To view the whole Executive Summary, please visit “Online Pharmacies, Personal Drug Importation and Public Health.”

1 Harvard School of Public Health/USA Today/Kaiser Family Foundation, Health Care Costs Survey (conducted April 25 –June 9, 2005). The survey finds that 20% of respondents, adult Americans, report not filling a prescription due to cost; 54% of those respondents said their condition got worse as a result. Extrapolated to the 2012 population of adults 18 and older, which is 234,564,071, the number is approximately 25 million people. See [Last accessed 7/5/2014].
2 Such as peer reviewed studies by Roger Bate and Aparna Mathur at the American Enterprise Institute; recommendations from studies funded by the California HealthCare Foundation; and earlier studies by GAO on Internet pharmacies, all of which are discussed in this report. Supporters of buying medications from international online pharmacies include Mature Voices Minnesota, Coalition of Wisconsin Aging Groups, the Congress of California Seniors, Third Power Age, and New York Statewide Senior Action Council; and non-governmental organizations such as and Demand Progress; and companies such as, founded in 2002 to evaluate online pharmacies, U.S. and foreign, and compare their drug prices
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