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Well, its an approved drug, so they are using 505(2)(b). We don't have any visibility on how far along they are into the clinic with perfecting the formulation and animal testing, etc., so it's impossible to say when they might be ready to file an IND application.
Once in clinical trials, I assume they will go for a Phase 1/2 combined study. I don't know anything about Vivitrol...are their multiple dosages? The scope of the Phase 1/2 will depend on how many dosages are being tested (e.g., ropinirole is taking longer because four separate dosages are being tested).
If the Phase 1/2 is successful, I assume it will be outlicensed at that point.
If not, need at least one Phase III efficacy and one Phase III safety study.
If they are fast, they could get it done in three years or less.
This caught my eye on page 21 of Alkermes' most recent 10-Q.
"Government Matters
On June 22, 2017, the Company received a subpoena from an Office of the U.S. Attorney for documents related to VIVITROL. The Company is cooperating with the government."
https://www.sec.gov/Archives/edgar/data/1520262/000152026217000045/alks-20170930x10q.htm
Agreed...that was so weird that he didn't mention probuphine at the opioid commission meeting. There is undoubtedly more to the story.
Hey Turks,
Serenity was just pointing out that Zacks may be paid by Titan to cover Titan; and so if they are getting paid by Titan, there may be a bias in Titan's favor. So the comment is limited to Zacks' earning report.
I'm not too optimistic about the near-term future. Doctors are putting the ball in the insurance company's court; and the insurance companies are taking a lot of time to approve procedures. By the time the approval comes around, patients may no longer be interested.
Plus, insurance companies are not footing the whole bill for probuphine in many cases, and a lot of patients cannot afford it.
Braeburn seems to be blaming the REMS as well...requiring patients to be stablized on buprenorphine for six months, and requiring the implant to be held in a DEA approved facility, so that many doctors that want to buy it cannot keep it in their offices, thus they have to deal with the speciality pharmacy that fed ex's the implants to them on the actual day of the procedure...talk about a hassle.
Unless Braeburn lowers the price, I don't think things will get much better for probuphine anytime soon. They are being insanely greedy, and basically taking the position they would rather make no money at a high price than some money at a lower price. They also don't want to make probuphine more attractive than their injectables, because I believe them pay a higher royalty for probuphine. So they will wait to see what they can sell the injectables at, and then price probuphine just above that level. You and I know Indivior will beat them at injectables, but Derkacz got hired telling Apple Tree that he could beat Indivior. So his focus is going to be primarily there.
I was hoping for some congressional action, but that ain't gonna happen this year. Congress is focused entirely on the tax bill, so there will not be time for opioids this year. Next year though, especially before the mid-term elections, we will see some significant funding come through that hopefully will be directed to MAT, and hopefully having the DOJ going after insurance companies for failing to approve coverage. That type of thing will play well going into an election.
Derkacz is not a joke, but he inherited a mess from Sheldon, and he fired about a third of the sales reps. It will take time for that all to get sorted out.
The rest of the programs seem to be going well, we just need to find a way to pay for them! I'm hoping Titan sells 100% of its European rights to probuphine for about a year of operating expenses. Remember, the rods only cost $600, and so an EU company could sell them for $2,400 a year an still make a 100% profit.
Also, I think it makes sense for them to outlicense any but T3 if they can get cash upfront. T3 is the white whale.
Wow, it pays the read the fine print.
New Zacks Report...reduced value to $5 from $6 per share
http://s1.q4cdn.com/460208960/files/News/2017/Nov-13-2017_TTNP_Vandermosten.pdf
One last thought...you don't have to be a weatherman to know which way the wind blows.
It won't be the payout I dreamed of, but I should at least be able to make my investment back and with a (small) profit.
Rubin: “We are evaluating alternatives and potential pathways available to us including ex-U.S. partnering opportunities for Probuphine, possible collaborations for one or more of our ProNeura programs and financing strategies. Importantly, I want to assure you that in addition to these alternatives that I just mentioned and in addition to our discussions with Braeburn and with treatment providers that are aimed at a fuller understanding of the impediments to the uptake of Probuphine, the Board is actively assessing all operative and strategic business options available that can increase shareholder value. We will keep you informed.”
Bhonsle: “Although we can’t go into all the details right now, I want to assure you that the Board and management are looking at all options for maximizing the value of Titan, both from the product portfolio and other strategic considerations. We look forward to reporting continued progress as we move forward.”
Legal Plumbing II
Braeburn is required under the License Agreement to use "Commercially Reasonable Efforts” to promote probuphine. In particular, "with respect to (a) Braeburn, that degree of skill, effort, expertise, and resources normally used (including the promptness in which such efforts and resources would be applied) consistent with standards generally accepted in the pharmaceutical industry, including with respect to the diligent development, manufacture and commercialization of pharmaceutical products of similar market and profit potential at a similar stage in development or product life as the Product; provided, however, that in determining the level of efforts and resources to be employed, Braeburn shall not be permitted to take into account any Second Product being developed or commercialized by Braeburn or any of its Affiliates”
Braeburn reduced their sales force by a third in July, and have performed sluggishly. It's clear they are waiting until injectables arrive to really start up their sales machine, which they are clearly not allowed to do under the license agreement.
Legal Plumbing
Just in case you’re interested in the Braeburn-Titan relationship….
Section 2.5(a) of the TTNP-Braeburn License agreements says “Titan will not Promote, or permit its Affiliates to Promote, market or sell any product that entails the continuous delivery of a therapeutic agent for the treatment of the Initial Indication in the Territory, or acquire, or permit its Affiliates to acquire, directly or indirectly any rights or interest in or to any such product that is being Promoted, marketed or sold in the Territory.”
So how do you explain the Titan/Opiant collobaration for a vivitrol like implant? Isn’t that a violation of the License Agreement?
First, “Initial Indication” is a defined term. It means: “the use of a Product for the treatment of opioid addiction.” Doesn’t sound too promising for Titan. But what is a Product?
Well, “Product” is defined as “a subdermal implant consisting of Compound and EVA which is expected to be marketed under Titan’s trademark Probuphine® or such other Product Trademarks as may be reflected in a Product NDA, for use in the treatment of the Initial Indication and/or Subsequent Indications in the Territory.”
OK, so the Product has to contain “Compound” to be subject to the noncompete. And “Compound” is defined as “the chemical compound known as buprenorphine.”
So…the prohibition is against selling subdermal implants with buprenorphine. No prohibition on selling implants with opioid antagonists.
Score one for Titan's lawyers. My guess is Braeburn’s management weren’t aware of the fine print.
Hey Rentier, couldn't help but check the board this afternoon and saw your post. No, I'm not under the impression TTNP has access to $50 million. But under the TTNP-Braeburn License Agreement...
"If Braeburn (i) sells in the Territory, or permits any of its Affiliates to sell in the Territory, a Second Product, or (ii) acquires, or permits its Affiliates to acquire, directly or indirectly, any rights or interest in or to a Second Product that is being sold in the Territory, Titan shall be entitled to receive aggregate royalties of up to fifty million dollars(US$50,000,000 dollars) at the rate of [*****]percent ([*****]%) of aggregate net sales of the Second Product in the Territory."
So Braeburn has to pay TTNP a single digit royalty (I've heard around 4%) on injectables sales up to $50 million. If Titan elects, Titan also has the right to get a higher royalty percentage (maybe 10%) for a reduced total amount (maybe $25 million).
Observations
I need to process this. Be back sometime next week. Thoughts:
1. I have been so wrong on this one. I never anticipated a lack of sales to this extent. I’m embarrassed, and it is humbling. But I cannot blame it on Titan. Braeburn takes part of the blame for a lousy launch, the FDA takes part of the blame for an unduly restrictive REMS and insurance companies take a huge part of the blame for making it nearly impossible to get approved for treatment, or for doctors to get paid for doing it. All this talk about the opioid crisis is just that: talk.
2. The Titan-Braeburn relationship is horrible. The fact that Titan didn’t know the sales numbers until a few days ago is pathetic; it’s not how you treat a “partner.” I appreciate that Titan is looking into what happened, but what can they do if they find out? Sale of probuphine is entirely in Braeburn’s control, and it’s pretty clear that they are basically sitting on probuphine until injectables are approved. Although they could, they are not going to price probuphine more competitively, because that could cut into their injectables sales.
3. One ray of hope comes in the form of Braeburn's complaint regarding the REMS. Back in 2013, the CRL was issued because, even though probuphine demonstrated non-inferiority to suboxone, the FDA felt Titan should supply new clinical data demonstrating probuphine's effectiveness at additional higher dose levels more close approximating the blood levels of patients taking sublingual buprenorphine. Instead, Braeburn and Titan agreed with the FDA to conduct limited further studies on patients that had been stabilized on 8mg or less of buprenorphine a day for a period of at least six months.
The CRL becomes very interesting in light of the FDA's upcoming approval decisions for depot injections of buprenorphine (Indivior Pharmaceuticals for RPB 6000 and Braeburn Pharmaceuticals for CAM 2038). Both of these drugs did supply buprenorphine at higher dose levels comparable to the blood levels of patients taking sublingual buprenorphine. And yet both drugs performed no better than probuphine in terms of patients remaining drug free. If approved, they will be allowed to be used as a "first line" of treatment for recovering addicts.
I think there is a good possibility Braeburn goes back to the FDA to get the REMS changed (perhaps eliminate the 6 months requirement) especially in light of the whole “one size does not fit all” movement that we’ve seen demonstrated at the Opioid Commission meetings (and more recently promoted by Alkermes).
4. Titan does seem to be progressing on other fronts. I think they’ve done well. There are only 14 employees after all.
The EU marketing application is finally filed. I presume there is no partner because no one is interested as this time. They’ve showed some fight in them with the implant for a vivitrol like drug (with Opiant) and implant for pain (mystery, but I think Cara Therapeutics). Braeburn is probably more mad about pain (which they are going after) than the vivitrol implant (which is a complete antagonist and not really comparable to an agonist like buprenorphine). Ropinirole is hard to get excited about, but there is a huge potential for T3. I think these technologies would add value to the sales price in a sale of the company. The army malaria study is unlikely to result in any money unless we go to war in Southeast Asia or Africa. So let’s hope Titan doesn’t make anything off of that one.
5. In a weird way, the stock split is forcing management into the decision to sell the company.
As bad as things are, if the split had not happened I don’t think TTNP would be trading at $0.28 per share (the pre-split price as of today’s close). Probably closer to $0.40 a share. Psychologically for many retail investors, it’s easier to sell Titan at $1.55 than $0.28 cents. It doesn’t make sense but it’s true.
The facts are what they are, and Titan's cash runway expires in August of next year, just nine months away. In order to raise even a year's worth of funding, Titan would need to issue well over 20% of its capital stock; a transaction requiring stockholder approval under NASDAQ rules. I don’t think they have the votes for that.
Even if they went ahead and did such a transaction without stockholder approval (and got de-listed from NASDAQ for doing it), it still messes up management’s retirement plans. One year’s operating expenses ($12 million) at $1.50 a share would require them to issue 8,000,000 shares, diluting all shareholders by 25%. A share in TTNP becomes worth 25% less after such a transaction, and it would probably have to be followed by yet another for 2019 with no certainty that probuphine sales will materialize or that current development programs would have made any progress.
Note that management has been very adverse to dilution. It’s one thing to dilute when you have 120 million shares, and its all just OTCBB monopoly money and they can issue themselves replacement options without NASDAQ rules to comply with. With only 24 million shares outstanding, any dilution dramatically affects what Rubin and Bhonsle will eventually receive. For that reason, I think they will take what they can for the company, or sell one or more of its development programs, over the next few months. Sunil stated they were exploring “strategic alternatives.” Do an online search for “strategic alternatives” and see the types of press releases that come up.
On linked in....
Braeburn account rep just posted:
"Hi
The company I? am currently working for (Braeburn Pharmaceuticals) is looking to expand its sales force. Please go to our website and take a look at our product line and let me know if you would be interested in joining forces. Thank you for your time and interest."
Getting the feeling Apple Tree has had it with Braeburn also.
Titan should offer to buy back probuphine for $50 million (the cap on the 4% royalty Titan gets on injectable sales). Basically, Braeburn doesn't have to pay Titan any injectables warranties, and Titan gets the drug back.
Allows Braeburn a little more pricing room on injectables (they don't have to pay TTNP 4% of sales price), and it's clear they are not serious about probuphine anyway.
From the conference call, Sunil said they were looking a out-licensing and other "strategic alternatives" which is code for a sale.
You could get your wish before long.
A big part of the problem is cost. To the insurer, and for patient co-pays.
The most recent price I've seen is $5,900 (almost a thousand dollar increase since the first launch in June 2016).
Per Braeburn's S-1, the cost to Braeburn to manufacture the implant is $600 for four rods (one treatment).
That's a lot of profit. They've agreed upon a lower price for the Federal Supply Schedule ($3,750), so why charge more to insurers? Years ago Higgins wrote a report assuming a $2,500 cost per treatment...imagine the sales potential at that price level.
It's not that hard: if you can only sell 20 at $5,900 but could sell a thousand at $3,000, you'd lower the price, right? Make it up on the volume as the saying goes.
The fact they are not doing so is telling. Either they bought probuphine to table it (prevent competition), or they want to price their injectables at a similarly high rate and don't want probuphine to have a price advantage.
I will believe it when I see it...Braeburn's Derkacz tweeted about this this morning...
Healthcare Payers Make Groundbreaking Commitment to Improve Quality and Access to Addiction Treatment
https://www.shatterproof.org/posts/healthcare-payers-make-groundbreaking-commitment-improve-quality-and-access-addiction
It's actually worse than that.
I've assumed they make around $600 per implant (for discussion purposes, $5,200 price, less 20% withholding from Braeburn = $4,160; 15% royalty=$624).
So $40,000 = roughly 66 implants.
But remember, in the first quarter they had $44,000 in royalty revenue, and a majority of those patients decided to have a second treatment in the 3Q (let's say 40 out of 70 or so, but possibly higher).
That means of the 66 implants, on 26 were first time users.
Compare that to last quarter ($77,000) with roughly 128 first time users.
Something is not right, and I feel this decline is intentional on Braeburn's part.
Given these results, I wonder if anyone would buy the company right now.
I'm generally pleased with the various drug development programs (although the EU application took too long and where is the partner?), but it's clear that Titan made a collosal mistake in partnering with Braeburn. The lack of sales is on them, not Titan.
They had years to plan for everything they mention...insurance coverage, REMS challenges etc. It's like there was no launch plan at all other than to hire a bunch of people and hope for the best. By the way, $40,000 translates to around 60 implants. And Braeburn has 60 sales/field employees. One sale a quarter? I want that job.
Well, that stinks.
Problem seems to be:
1. Braeburn's sales force.
2. Insurance companies won't reimburse without requiring a lot of hurdles.
3. 6 months stabilized on bupe requirement in REMS.
Volume doesn't say something leaked to me. Could be lender's warrant shares registered in the recent S-3, someone who doesn't want to hold into earnings or mm's trying to scare some people into selling.
Another convert...
500 doesn't seem possible to me, but I'd be thrilled to be wrong. I expect at least $150 and anything over $200 would be really good.
News on EU more likely to drive things than earnings.
Wow...I was wondering why on earth Alkermes was promoting all treatments being available as well, given their history. Harris' investigation is probably to get the California AG to investigate, or to put pressure on the Republicans to investigate in Congress. We will see.
The Indivior lawsuit keeps going on....court just denied Indivior's motion to dismiss.
https://casetext.com/case/wisconsin-v-indivior-inc-in-re-suboxone-buprenorphine-hydrochloride-naloxone-antitrust-litig
Braeburn controls the drug for the US, so only they could go back to the FDA. As Serenity said, they may not want to because it could interfere with their own injectable sales.
EU is a different story, as Titan controls everything...
If the FDA approves CAM 2038 and RBP 6000, then I really don't see why Braeburn wouldn't file an sNDA for probuphine to be used as a "first response." It wouldn't cost anything, and the testing is already done from 2013, and they would put the FDA in the position of having to reject an opioid abuse alternative proven to be as effective as injectables. I don't think they have the guts to do that anymore.
Not arguing with selling if they can get the right price (which I think goes up given ropinirole and T3 prospects), but I think Indivior will clean their clock on injectables (they can afford to underprice and outmarket Braeburn). A "front line" implant might be the best way to compete for Braeburn.
What I wrote...
Ms. ********,
I have been monitoring with much interest the New Drug Applications submitted by Indivior Pharmaceuticals for RPB 6000 and Braeburn Pharmaceuticals for CAM 2038. Both drugs involve depot injections of buprenorphine for the treatment of opioid addiction. As you may know, the Pyschopharmacological Advisory Committee held meetings recently for each drug, and in each case voted overwhelmingly for approval.
I am interested in the FDA's decision making process with respect to probuphine. I would appreciate being afforded a written response (or, if that's impossible access to speak with someone on the FDA staff) regarding the treatment of these NDA's vis-a-vis the treatment of the NDA of Titan Pharmaceuticals for its implantable form of buprenorphine, Probuphine. The FDA approved probuphine in 2016, requiring that patients be stablized on oral buprenrophine for six months before usage. This followed the FDA's CRL for probuphine in 2013, which was issued despite the fact an advisory committee voted in favor of approval, and probuphine demonstrated non-inferiority over sublingual buprenorphine (suboxone).
From my review of the FDA briefing materials for RPB 6000 and CAM 2038, I am not able to determine how either drug performed better than probuphine did in 2013 with "front line" addicts who had only recently begun treatment. Titan's probuphine appears to have matched the performance of RPB 6000 and CAM 2038 in Cumulative Distribution Function (CDF) of Percentage of Urine Samples Negative for Illicit Opioids and the LS Means of the % Negative Urines.
For reference, please see
https://d1io3yog0oux5.cloudfront.net/_ea839ea383715833d75df26299b4b7c6/titanpharm/db/341/1103/pdf/ISAM-Probuphine.pdf)
On its face, it appears Titan Pharmaceuticals has been subjected to a double standard. The FDA's CRL nearly bankrupted the company in 2013, and had adversely affected the treatment of potentially thousands of opioid addicts who could have used probuphine over the last three years (a period where, as the FDA is aware, 170 people are dying each day from opioid addiction). I believe the public is owed a response as to the FDA's treatment of probuphine.
Your assistance would be greatly appreciated.
**************
We think alike.
I just sent a letter to the FDA requesting to speak to someone. They won't respond, because they don't have to, but it made me feel better.
It's sickening.
Seriously...I can't see how what Braeburn and Indivior are reporting is better than what Titan reported.
It was one thing to move the goal posts in 2013 to screw Titan.
And now they are moving them back to help injectables?
Help!!! Can somebody explain to me how the results Braeburn and Indivior are reporting are better than what Titan reported in 2013.
https://d1io3yog0oux5.cloudfront.net/_ea839ea383715833d75df26299b4b7c6/titanpharm/db/341/1103/pdf/ISAM-Probuphine.pdf
If not, why does there have to be a six month "stabilization" period prior to use of probuphine? Why not apply for a new label, except the low liklihood of approval because the FDA won't admit they were wrong.
Patrick Kennedy: At least $100 billion needed to fight opioids
Commission member who is close to Christie....
http://thehill.com/policy/healthcare/358518-patrick-kennedy-at-least-100-billion-needed-to-fight-opioids
Christie: Expect Trump to ask for 'billions' to fight opioid epidemic
Hopefully he knows something...
http://thehill.com/policy/healthcare/357699-christie-expect-trump-to-ask-for-billions-to-fight-opioid-epidemic
This will be interesting...injectables may not be as effective as I originally thought.
Also, there have been a ton of "concerned" counselors who have come out against probuphine, but have been in favor of the injectables. That is presumably because of the strict dispensing requirements of probuphine's REMS. I think these counselor/doctors figured they could administer the injectables themselves and be compensated for it, rather than have to refer it out to a clinic.
However, the FDA will require a REMS for injectables that limits dispensing to settings that have a DATA-waived (Drug Addiction and Treatment Act 2000) prescriber or are DEA registrants, and will require healthcare settings to become certified to dispense the injectables.
In other words, same distribution problems as probuphine.
In 2013, probuphine shows equivalency with suboxone = CRL.
In 2017, injectable has 13% success compared to 63% success for implant, and 18-1 vote in favor of approval.
Testimony from Indivior's Ad Comm for their injectable....
"But for the results that really matter, the efficacy was not at all impressive. Unfortunately, only 12-13% of treated participants were considered 100% abstaining from using opioids compared to 1% taking placebo. Even using the lower standard of abstaining 80% of the time, only 28-29% of treated participants did so.
These results are not nearly as good as other products already on the market. For example, on the label for the approved modified-release buprenorphine drug, Probuphine, it reports 63% of participants achieving 100% abstinence, using similar measures for 100%."
https://www.center4research.org/nchr-testimony-fda-injectable-buprenorphine-rbp-6000-indivior-opioid-use-disorder/
I don't know; I think Patrick Kennedy had it right it the last commission meeting when he stated everyone wanted to be on camera listening to the problems, but no one wanted to do anything about the solution.
One thing is for sure: insurance companies have a lot more influence in Congress than opioid addicts.
From the report:
Enforcing the Mental Health Parity and Addiction Equity Act (MHPAEA)
Spearheaded by Commission member former Congressman Kennedy, MHPAEA aimed to build upon the patient protections enacted by the Mental Health Parity Act (MHPA) passed in 1996, which provided that large group health plans could not impose annual or lifetime dollar limits on mental health benefits that are less favorable than any such limits imposed on medical/surgical benefits. In other words, parity is a simple concept that requires health insurance plans to offer behavioral health coverage that is comparable, and equal to, the coverage for physical health. In reality, creating appropriate parity regulations, and enforcement of parity laws, is far from simple MHPAEA extended these parity requirements to SUDs, but legislation did not require large group health plans and health insurance carriers to cover mental health or SUD benefits. The Affordable Care Act changed this by requiring coverage of mental health and SUD services as an essential health benefit in individual and small group plans.
However, while parity is a legal requirement, the existing means of monitoring and enforcing the parity act are insufficient. The sole means of enforcement under the parity act is equitable relief against the buyer of the insurance plan; and for the employer-based plans that are self-funding, DOL is presently permitted to enforce MHPAEA against only the employer, rather than the insurance company administering the benefits. The Commission heard from numerous organizations, such as the Parity Implementation Coalition, the Partnership for Drug-Free Kids, the National Council for Behavioral Health, Shatterproof, ASAM, and the American Academy of Addiction Psychiatry, about the need to systematically monitor and enforce MHPAEA to ensure parity in the coverage of mental health and addiction services. MHPAEA has been the impetus for much progress towards parity for behavioral health coverage; plans and employers have, by and large, done away with policies that are clear violations; provisions such as dollar-limits, visit limits, and outright prohibitions on certain treatment modalities that exist only on behavioral health benefits. However, what remains are violations that
are murkier and harder for regulators to discern, for example, non-quantitative treatment limits (NQTLs). These hurdles include medical necessity reviews that are more stringent on the behavioral health side than the medical/surgical side, limited provider networks, and onerous prior authorization requirements. In reality, it is often difficult to discern when a behavioral health benefit is “on par” with a medical/surgical benefit as different care settings and diagnoses have different policies regarding benefits, providers, and authorizations.
One goal of MHPAEA and other parity laws was to address cost-shifting from the commercial sector to the public sector for the financing of substance use and mental health treatment. Expanding the private sector share of expenditures could increase access to treatment for opioid and other drug use disorders. As of 2014, private cost-sharing did not increase in proportion to the private sector share of the insurance market. It financed only 18% of SUD treatment in 2014. Legislative changes providing DOL with the ability to impose a civil monetary penalty, such as those provided for violations of the Genetic Information Nondiscrimination Act (GINA), would encourage private insurance companies, and employers, to satisfy their legal obligations under MHPAEA and in turn, ensure they are adequately doing their part to address the country's opioid epidemic
Well, they didn't call for any level of funding, and my first response was that would have been a useful benchmark to include to measure the government's response. But the more I see actual effect of the government's response to the opioid epidemic, the more I believe that block grants of money to the States are just wasted. It is not spent on treatment. Instead, they spend it on more state funded counselors, ad campaigns, education centers...on jobs and political favors to political appointees rather than getting medicine to addicts. Those appointees are sure to be campaign workers for the governor who got them the job, etc. That's the problem with giving states/governors money. They use it to solidify their own political position, not on medicine.
The report pushes "evidence based" treatment (Mediciation Assisted Treatment), which is good.
The thing I liked the most was the detailed section on enforcing the Mental Health Parity Laws. And the comments by the Secretary of Labor at the final public meeting. He is itching for the power to go after insurance companies. Right now, the Federal Government doesn't have the standing to go after the insurance companies...its up to each State's insurance commissioner. Most state insurance commissioners come from the insurance industry!!! It's all politics...they are they as a quid pro quo for insurance company campaign contributions to state politicians, and basically what they do is make sure that insurance companies don't have to follow the law.
Giving the federal government the power to go after state insurance plants to enforce the Mental Health Parity laws would be huge. No more "prior approvals" or other "administrative burdens" that are slowing down probuphine sales.
Final Public Meeting of Opioid Commission
https://www.whitehouse.gov/live/meeting-presidents-commission-combating-drug-addiction-and-opioid-crisis-1
Here are the final recommendations of the White House opioid commission
Final report issued this afternoon.
https://www.statnews.com/2017/11/01/opioid-commission-white-house-final-report/