“if you torture the data for long enough, you can make them say anything.”..In my view, that is exactly what US CDC and DEA have been doing with their deliberate conflation and mis-characterization of research results on medical prescribing versus opioid-involved overdose mortality.
NORMAN J CLEMENT RPH., DDS, NORMAN L. CLEMENT PHARM-TECH, MALACHI F. MACKANDAL PHARMD, BELINDA BROWN-PARKER, IN THE SPIRIT OF JOSEPH SOLVO ESQ., INC.T. SPIRIT OF REV. IN THE SPIRIT OF WALTER R. CLEMENT BS., MS, MBA. HARVEY JENKINS MD, PH.D., IN THE SPIRIT OF C.T. VIVIAN, JELANI ZIMBABWE CLEMENT, BS., MBA., IN THE SPIRIT OF THE HON. PATRICE LUMUMBA, IN THE SPIRIT OF ERLIN CLEMENT SR., WALTER F. WRENN III., MD., JULIE KILLINGSWORTH, RENEE BLARE, RPH, DR. TERANCE SASAKI, MD LESLY POMPY MD., CHRISTOPHER RUSSO, MD., NANCY SEEFELDT, WILLIE GUINYARD BS., JOSEPH WEBSTER MD., MBA, BEVERLY C. PRINCE MD., FACS., NEIL ARNAND, MD., RICHARD KAUL, MD., LEROY BAYLOR, JAY K. JOSHI MD., MBA, ADRIENNE EDMUNDSON, ESTER HYATT PH.D., WALTER L. SMITH BS., IN THE SPIRIT OF BRAHM FISHER ESQ., MICHELE ALEXANDER MD., CUDJOE WILDING BS, MARTIN NJOKU, BS., RPH., IN THE SPIRIT OF DEBRA LYNN SHEPHERD, BERES E. MUSCHETT, STRATEGIC ADVISORS
By Walter R. Clement
THE TROUBLE WITH Tools of the Investigation
From the United States Attorneys’ Bulletin July 2018
“The Automation of Reports and Consolidated Orders System (ARCOS) is an online reporting system that includes reports from all DEA registrants who distribute specific controlled substances, including opioids. ARCOS can be a great source of data, particularly with regard to the volume of controlled substances being dispensed by certain professionals.
DEA plays an integral role in the regulation of physicians who prescribe opioids. In his article, Overview of the Drug Enforcement Administration Diversion Control Program, Louis J. Milione summarizes that regulation:
The DEA ARCOS is an automated, comprehensive drug reporting system that monitors the flow of DEA-controlled substances from their point of manufacture through commercial distribution channels to the point of sale or distribution at the dispensing/retail level – hospitals, retail pharmacies, practitioners, mid-level practitioners, and teaching institutions.
ARCOS accumulates these transactions, which are then summarized into reports, which give investigators in Federal and state government agencies information that can be used to identify the diversion of controlled substances into illicit distribution channels. “Information on drug distribution is used throughout the United States (U.S.). by U.S. Attorneys and DEA investigators to strengthen criminal cases in the courts.” Through their own word usage and practice, ” DEA uses statistical analyzation to review to determine and identify the diversion of controlled substances into illicit channels of distribution.”
Fascinating, Larry..In a more detailed and deeper way than I phrased the principle in one of my papers for the American Council on Science and Health, “if you torture the data for long enough, you can make them say anything.” In my view, that is exactly what US CDC and DEA have been doing with their deliberate conflation and mis-characterization of research results on medical prescribing versus opioid-involved overdose mortality.
….richard lawhern phd
FLAWED DATA ANALYTICS HAS RESULTED IN AN INCREASE IN PATIENT DEATH
THE TROUBLE DEA APPLYING PROBABILITY MATHEMATICS
However, what the DEA is doing is applying probability mathematics. Probability is a mathematical tool used to study randomness. It deals with the chance of an event occurring. Through this agency’s application of probability statistical mathematics, the DEA uses their ARCOS as an instigation tool to identify the diversion of controlled substances into illicit distribution channels.
This federal agency is monitoring “the point of sales from the point of manufacture through commercial distribution channels to the point of sale or distribution at the dispensing/retail level – hospitals, retail pharmacies, practitioners, mid-level practitioners, and teaching institutions.”
In essence, this agency monitors and prosecutes medical professionals for performing their license medical fiduciary responsibilities on patients.
“Dozens of retired black narcotics agents say their former agency, the U.S. Drug Enforcement Administration, has discriminated against its African-American employees for decades.”
The trouble with probability mathematics is if a doctor is good and performs exemplary service, medical professionals would be targeted despite his or her professional services.
For example, with the DEA ARCOS system, when a doctor or pharmacist orders a class 2 medication, the DEA knows the exact number of the medication ordered. With the DEA ARCOS system, the agency knows when the doctor’s prescription is and who by name receives the prescription. The agency knows when the pharmacist filled the prescription and by name as to who received the amount and type of class 2 medications.
It has been clearly seen that his agency applies geographic enforcement tactics to identify the diversion of controlled substances and illicit channels of distribution using probability and statistics.
When we examine the charges placed against medical professionals, we can clearly see the application of the ARCOS system when the agency write within their affidavit, “C.F.R. § 1306.04(a) (emphasis added). A pharmacist violates this provision only if the pharmacist “knowingly fill[s]” a “purported” prescription—i.e., a prescription that was not written, “in the usual course of professional treatment.”
To analyze and establish probability mathematics that a licensed professional and state “mis-practicing pharmacist “knowingly fill[s]” a “purported’” prescription—i.e., a prescription that was not written, “in the usual course of professional treatment.” This statement clearly establishes that the agents apply circumstantial analytical evidence to substantiate a violation.
Using the ARCOS system, each DEA understood well in advance how their system tracks and identifies each prescription, who received the medication, and how much medication was provided to the patient.
In essence, the DEA is applying inferential statistics, the null hypothesis that two possibilities are the same. If a pharmacist orders 6000 class oxycodone pills, the DEA approves the reception of the medication. In fact, the DEA approves the shipment and authorizes the reception of the medication at the pharmacy. However, with their knowledge of their approval for the pharmacist to receive the medication, the DEA often calls a pharmacy ‘pill mills.’.
“Distributors report sales of Schedule I, II, and some III opioid-based medications to the Drug Enforcement Administration (DEA) for its database, known as the Automation of Reports and Consolidated Orders System (ARCOS). From the point of manufacturing through commercial distribution to delivery to DEA- and state-registered pharmacies, hospitals, and other healthcare providers.”
It should be made clear that the DEA applies its ARCOS system data analytical reports, such as reports that must be provided within or attached to the investigative reports. No citizen should ever be subjected to inferential statistical investigatory tools and be subjected to governmental enforcement.
STOP DEA BIG LIE AND PROSECUTORIAL ABUSE!!!!!
THERE IS NO CORRELATION BETWEEN OPIOID PRESCRIPTION AND DRUG RELATED DEATH FDA STUDY SPECIFICALLY POINTS OUT!!!
CONGRESS MUST REORGANIZE THE DEA
The current enforcement practices of the DEA are biases based. The racial based culture is so powerful that members of the DEA lack the cognitive abilities to provide adequate and accurate law enforcement practices.”
FOR NOW, YOU ARE WITHIN