Express Scripts Statement on Counterfeit Drugs

Express Scripts strongly supports all measures to eliminate counterfeit drugs from the pharmaceutical supply chain.

ESI does not purchase prescription pharmaceuticals from secondary drug suppliers, nor do we purchase any repackaged pharmaceutical products.  These are the two main identified sources of counterfeit drugs.

All of Express Scripts’ prescription pharmaceuticals are purchased directly from brand and generic pharmaceutical manufacturers or from one of the three major pharmaceutical wholesalers; Cardinal Health, McKesson and AmerisourceBergen.  All three provide ESI with detailed documentation regarding the authenticity of drug products purchased from them by ESI. 

All three wholesalers have an internal policy in place that requires all non-manufacturer distributors to sign an agreement stating that any product sold to the wholesalers shall be procured only from manufacturers licensed by the U.S. Food and Drug Administration, authorized distributors of such manufacturers, or licensed pharmaceutical wholesalers.  All three wholesalers maintain a database of Authorized Distributors. 

Each wholesaler has a compliance officer in place to perform audits of non-manufacturing distributors. This compliance officer is a member of the wholesaler’s compliance department, and is charged with assessing a non-manufacturing distributor's procedures and practices before issuing an authorized status for each supplier.

ESI’s wholesalers are licensed and regulated under the authority of the federal Prescription Drug Marketing Act (PDMA) and by each state in which they do business.  Wholesalers are also regulated by the Drug Enforcement Administration (DEA), which conducts regular inspections of their facilities.  In regulating distributors, the PDMA sets storage and handling requirements, specific procedures for inspecting and accepting product into inventory, and detailed record keeping relating to the receipt and disposition of prescription pharmaceuticals.  The wholesalers receive a detailed “pedigree,” when purchasing from an authorized distributor of the manufacturer which identifies the origin and transaction history for that particular product back to the manufacturer or their authorized distributor.  All three of ESI’s wholesalers operate under these safeguards. 

The ESI Corporate Procurement Department is responsible for qualification and selection of approved drug product suppliers, for both brand and generic drugs.  All approved pharmaceutical suppliers must be licensed to distribute prescription drug products by their respective state of residence as well as any other outlying state that requires drug distributor non-resident licensure. 

Each of ESI’s home delivery pharmacies has a purchasing and receiving department that is responsible for placing and receiving orders only from approved vendors.  ESI’s purchasing managers are not allowed to purchase drug products from non-approved suppliers or any secondary drug suppliers. 

Corporate Drug Procurement

Express Scripts complies with all state and federal laws and regulations applicable to its business, including maintaining any necessary licenses and permits. 

Mail Service Pharmacy Licensure

Our mail service pharmacy facilities are licensed in each of the states in which they are located.  Furthermore, each pharmacy maintains non-resident pharmacy registration in the 48 states that require such registrations.  We also are allowed to mail prescriptions to U.S. territories and Puerto Rico.

Pharmacy Licenses

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