Open Letter to Gov. DeSantis

March 27, 2020 The Honorable Ron DeSantis, Office of the Governor 400 S. Monroe St. Tallahassee, Florida 32399

Re: Concerns on the Unlabeled Use of Medications in the Management of COVID-19 Patients

Dear Gov. DeSantis:

This correspondence is provided on behalf of the Florida Pharmacy Association, Inc. (“FPA”), a not-for-profit corporation organized under the laws of this state which seeks to preserve and advance the practice of pharmacy and serves the professional needs of all pharmacists, pharmacy students, and pharmacy technicians in Florida. The FPA is the state’s largest and oldest professional society representing Florida pharmacists and pharmacies with over 3,500 members. The FPA is committed to improving public health and patient care, enhancing professional development, and advocating for the interests of the profession. The purpose of this letter is to bring to your attention certain prescribing practices that are endangering the health of Floridians and to request that you issue an emergency order, or direct the Board of Pharmacy in collaboration with the Board of Medicine to issue an emergency rule, limiting such practices.

Late last week, President Trump announced the promise of hydroxychloroquine as a potential treatment for COVID-19. This has resulted in a run on the medication. Several of our member pharmacies have reported that their supply of the medication is gone and they are unable to order more. We are gravely concerned that patients who rely on this medication for the treatment of lupus or rheumatoid arthritis will be unable to obtain the medication in the near future. Even more troubling, our members report that nearly all of the new prescriptions for hydroxychloroquine are being issued for the prescribing practitioners themselves or family members of the prescribing practitioners. We are very concerned with this practice of stockpiling of medications and believe that this type of practice behavior needs to be redirected.

Many of the medications for the treatment of lupus are immunosuppressive medications. These medications place individuals at a higher risk for infections, including the coronavirus. Hydroxychloroquine is one of the most widely-prescribed medications for the treatment of lupus because it is effective while having very little immunosuppressive effect. If lupus patients are unable to obtain hydroxychloroquine, they may be forced to make the difficult decision of taking a stronger immunosuppressive medication – placing them at higher risk of becoming infected with coronavirus – or not treating lupus at all.

I would like to bring to your attention a joint statement just released by the American Medical Association, American Pharmacists Association and the American Society of Health-System Pharmacists. In that statement there is an acknowledgement of the important role that physicians, pharmacists and health systems play in being stewards of health care resources. We hope that this joint message will assist you with an understanding of what we are bringing to your attention with this letter.

As of Monday, March 23, 2020, at least six states have taken action to prevent prescribing practitioners from unnecessarily prescribing the medication. We ask that Florida follow suit. Specifically, we request the issuance of an emergency order or rule stating the following.

No prescription for chloroquine or hydroxychloroquine may be dispensed unless all the following apply: 1. The prescription bears a written diagnosis from the prescriber consistent with the evidence for its use; 2. The prescription is limited to no more than thirty (30) tablets, unless the patient was previously established on the medication prior to the effective date of this order/rule; and 3. No refills may be permitted unless a new prescription is issued. This requirement does not apply to a patient previously established on the medication prior to the effective date of this order/rule.

We believe the above language implemented as a temporary rule ensures continued access to the medication while preventing unnecessary stockpiling.

Thank you for taking the time to consider this important matter and thank you for your continued leadership in navigating Florida through these challenging times. As always, please do not hesitate to contact me should have any questions or need any additional information.

With kindest regards,