Challenges of thalidomide distribution in a hospital setting

The various physician, patient, and pharmacy requirements for participation in the System for Thalidomide Education and Prescribing Safety (S.T.E.P.S.) program and procedures that institutions may implement in order to comply with these requirements are described. In 1998, FDA approved the marketing of thalidomide (Thalomid, Celgene). Because of the drug's known teratogenic effects, FDA tightly controls the distribution of thalidomide in the United States. To comply with FDA requirements, Celgene developed the S.T.E.P.S. oversight program, which includes registration of thalidomide prescribers and pharmacies that dispense thalidomide, extensive patient education about the risks associated with thalidomide, and a registry of all patients receiving thalidomide. The S.T.E.P.S. program is considered part of the product label. The pharmacy requirements of the program were developed with a focus on a retail pharmacy practice model, which does not adequately reflect current hospital practice. The pharmacy department of the National Institutes of Health Clinical Center developed a model that adapts the S.T.E.P.S. program requirements to inpatient and outpatient institutional pharmacy practice. Procedures for registering patients and prescribers and dispensing thalidomide in the hospital setting were developed; the procedures were designed to meet the needs of both the inpatient and outpatient pharmacies and to comply with the requirements of the S.T.E.P.S. program.