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Public Comment to the WHO About Online Access to Imported Medicines and SDG 3.8

One of the Sustainable Development Goals, 3.8, created under UN auspices is: “Achieve universal health coverage, including financial risk protection, access to quality essential health-care services and access to safe, effective, quality and affordable essential medicines and vaccines for all.” Lower-income countries where majorities of citizens can’t afford basic healthcare are deserving of our urgent and generous help, but the pain and anguish faced by American families where people are dying because they can’t afford medicine must also be addressed.

Online access to safe and affordable imported medicine can improve and even saves lives of those who can’t afford medicine where they live. This is particularly the case in the United States, where over 30 million people have no health insurance at all, and approximately 87 million are not adequately insured [Commonwealth Fund, 2019].

Organized under the support of the World Health Organization (WHO), as part of the effort to achieve global healthcare goals, twelve multilateral global health and development organizations are seeking public comments to help them develop their “Global Action Plan for Healthy Lives and Well-being for All.” My comment is below.

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PharmacyChecker Submits Public Comments to HHS Focused on Internet Purchases of Medicines for Personal Import

From time to time, we participate in the public policy process by submitting public comments to government agencies requesting them. In May of this year, after introducing the Trump administration’s blue print plan for lowering drug prices, the Department of Health and Human Services (HHS) asked the public to comment on the Trump administration plan and/or make recommendations for lowering drug prices and out-of-pocket prescription costs.

I submitted comments that were laser-focused on PharmacyChecker’s area of greatest expertise, personal drug importation and online pharmacies. My comments clarify why and how properly-verified, international online pharmacies are a lifeline of safe and affordable medicines for Americans.

PharmacyChecker Public Comments to HHS July 13, 2018

The basic recommendations offered in the comments are below:

  • Under Section 804 (j) of the Food, Drug and Cosmetic Act, the Secretary of Health and Human Services should expressly permit medicine imports for personal use to empower patients seeking affordable medication.
  • Per the above, implement the Australian model of making personal drug importation legal with caveats to prohibit personal use imports of controlled drugs, especially prescription narcotics.
  • The FDA should end its blanket warning against ordering medicines online, imported for personal use from pharmacies in Canada and other countries, and instead provide guidance on best practices for those who choose to import.
  • The FDA should stop seizing personal imports of non-controlled medicines arriving from pharmacies that the FDA knows are licensed and require valid prescriptions.
  • The FDA should take no enforcement actions against international online pharmacies that it has reason to believe are the safest international options available to Americans and instead focus on those that represent the gravest threats, particularly ones that sell prescription narcotics.
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