October 1, 2020

NABP Position Statement on New Federal Importation Rules

For years, policymakers have sought to lower prescription drug costs for Americans. On September 24, 2020, as part of the “America First Healthcare Plan,” the Trump Administration announced plans that will allow the importation of prescription drugs from Canada. The plans include the implementation of the Final Rule on the Importation of Prescription Drugs and two distinct requests for industry proposals for reimportation of insulin and individual prescription drug importation. While the National Association of Boards of Pharmacy (NABP) appreciates these efforts to increase patient access to affordable medications, we must also ensure that those medications are safe.

NABP is the independent, international, and impartial association that assists its member boards and jurisdictions in developing, implementing, and enforcing uniform standards for the purpose of protecting the public health. NABP is the only not-for-profit professional association that represents the boards of pharmacy in all 50 United States, the District of Columbia, Guam, Puerto Rico, the Virgin Islands, the Bahamas, and all 10 Canadian provinces. Our member boards of pharmacy are responsible for ensuring the safety of the prescription drug supply chain and the products in it.

The sale of counterfeit drugs is lucrative, generating over $200 billion a year in profit for global criminal networks. Allowing Americans to import medications from Canada and other foreign countries opens an additional point of vulnerability in the US prescription drug supply chain. Specifically, each separate proposal effectively creates a new and distinct prescription drug supply chain that will require state regulatory oversight and monitoring, only with fewer protections. This patchwork approach is a step away from the tightly regulated supply chain and safeguards currently in place to ensure the efficacy and safety of prescription medications. The National Association of Pharmacy Regulatory Authorities, NABP’s counterpart in Canada, has expressed concern that exportation of medicines out of Canada will threaten the supply available to its citizens. This, in turn, will increase the opportunity for counterfeit medications to enter its supply chain, endangering both US and Canadian patients.

NABP is also concerned that encouraging prescription drug importation will lead to the proliferation of rogue online pharmacy websites that will undoubtedly purport to be authorized to import medications from foreign countries. Rogue pharmacy networks are opportunistic and will look for any opportunity to prey on vulnerable patients. In NABP’s May 2020 Rogue Rx Activity Report, we detail the trends we have seen during the coronavirus disease 2019 pandemic.

As the actual benefit and savings of the prescription drug importation plans are unknown, we would encourage state and federal regulators to study this issue more carefully prior to placing American patients and the prescription drug supply chain at risk.