How to Spot a Pill Mill Webinar

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This is a PowerPoint (Converted to PDF) Presentation which was used during a webinar whose subject matter had to do with tips, tricks and cues that are a dead give away that a Doctor's Office is actually a Pill Mill.....This stuff is true....believe me...back in the day we would go to the pill mills in TX...YEP Good Ol' Lortab was my best friend for years. Read to Learn A lot about Pill Mills



Prescription Drug Abuse
Florida’s Health Crisis

Office of the Attorney General
Dave Aronberg
Special Prosecutor, Prescription Drug Trafficking

• Prescription drug diversion is the #1 public
safety threat confronting Floridians today.
• Florida has become the epicenter for the
availability and abuse of controlled
prescription drugs.
• Prescription drugs are now responsible for
killing 7 Floridians per day, and has been on an
upward trend for the past six years.

Increasing Oxycodone Deaths

What are Pill Mills?
• A “pill mill” is a doctor’s office, clinic, or health
care facility that routinely conspires in the
prescribing and dispensing of controlled
substances outside the scope of the prevailing
standards of medical practice in the
community or violates the laws of the state of
Florida regarding the prescribing or dispensing
of controlled prescription drugs.

Pill Mill Tip-Offs

Non-traditional medical office locations
No insurance accepted
Security guard at front door
Out of state license plates in parking lot
Parking lot loitering
Long lines inside and outside
Lack of medical equipment
Treatment options limited to pills only
Affiliations with specific pharmacies
Recent business name changes
Angry dog behind counter

Extent of the Problem
• Between 2003 and 2009, the number of
deaths caused by at least one prescription
drug more than doubled.
• Among young people ages 12-17, prescription
drugs have become the second most abused
illegal drug, behind marijuana.

Ground Zero –
Broward County
• In 2007, there were 4 pain
clinics operating in Broward
• In 2010, Broward Sheriff’s
Office listed 144 pain clinics
operating in the county.
• Today, there are 105 registered
pain clinics in Broward County.
• There are more pain clinics in
Broward than McDonalds in

Nationwide Comparison of Oxycodone Purchases by Practitioners
January - June 2010





























Nationwide Comparison of Oxycodone Purchases by Practitioners
January - June 2010


Units Purchased








Remaining States

Attorney General’s
Statewide Strategy

1. Criminal
2. Civil
3. Administrative
4. Legislative
5. Prevention

Regulating Pain Management

• F.S. 458.3265(1)(a) defines a pain management clinic.
• F.S. 465.0276(1)(b) creates the 72-hour dispensing rule.
• Department of Health (DOH) regulates pain clinics that are
owned by a medical and osteopathic physician.
• Agency for Healthcare Administration (AHCA) regulates
pain clinics that are not fully owned by medical and
osteopathic physicians.
• Pill Mills are attempting to evade our new laws and
“Wellness Centers”
“Urgent Care Centers”
“Rejuvenation Clinics”

“Detox Centers”

New Rules for Osteopaths
Rules 64B15-14.0051 & 14.0052
Standards of Practice:
Evaluation of Patient: complete medical history and physical exam
required, including urinalysis.
Treatment Plan: individualized, with objectives for reaching a
rehabilitative end-state.
Patient records: includes maintenance of file with duplicate prescription
scripts written.
Still to be adopted: Limiting the number of pills a doctor can prescribe.

Local Moratoria
• Temporary moratoria have helped communities limit
the growth of pill mills that fuel continued
prescription drug abuse.
• As of December 2010, there are more than 30 cities
and counties that have passed local ordinances
prohibiting new pain clinics.
• These successes belong to those in the community –
local officials, concerned citizens, anti-drug
coalitions, law enforcement agencies and others who
are taking a pro-active approach.

Best Practice Recommendations
• Pain clinics have to be licensed by the city/county
and pay an annual fee.
– Hillsborough County
– Titusville

• Clinics can only be located in areas that have
hospital/medical zoning.
– Titusville
– Delray Beach

• Clinics are prohibited co-locating in the same office
or building with a pharmacy.
– Martin County
– Oakland Park (DRAFT)

Best Practice Recommendations
• Prohibit cash-only pain clinics
– Orange County
– Orlando
– Satellite Beach

• Limit the hours of operation

Martin County

• Create city/county-wide taskforces for local solutions
– Broward
– Orlando

Prescription Drug Monitoring Program
• FS 893.055 creates the PDMP and the accompanying
Public Records law, FS 893.0551, that limits access to
confidential and private information in the PDMP
• Requires dispensing practitioners to report
dispensed II – IV controlled drugs to the database no
later than 15 days from the date of dispensing.
• The PDMP allows practitioners to:
• request access to the patient’s prescription history
information during office visit to ensure better patient
standard of care
• avoid prescribing medications that may be dangerous
when taken in combination with other medications
• identify possible “doctor shoppers”

• The proliferation of pain clinics that dispense
and prescribe legal opiates such as
Oxycodone, has helped fuel the problem of
prescription drug diversion and has made
Florida the “pill mill” for the entire country.
• Prescription drug diversion costs lives,
increases crime, and accelerates costs
connected to treatment, medical expenses
and Medicaid fraud.

PAUL VIDELA/[email protected] Local residents gathered along Manatee Avenue
outside of the 1910 Medical Clinic, a pain management clinic, to protest.

Office of the Attorney General

Dave Aronberg
Special Prosecutor, Prescription Drug Trafficking
[email protected]
(561) 837-5000

Pain Management Clinic Ordinance
City of Oakland Park




• End of 2008 - Emerging street crime trend

• 20 “Pain clinics” operating within City boundaries.
• Increase in the rates of street level narcotic sales

• From August 2008 – November 2009 Proliferation of Clinics & Drug Cases
– Pain clinics opened every 3 days in South Florida
– Broward County went from 47 clinics to 115
– Late 2009 – 50% of 1600 active drug cases being heard were for prescription



Problem (cont’d.)

• BSO Oakland Park Special Investigations Unit Activities:
• 2009
– 714 arrests associated with narcotics and pain clinics
– 7,200 prescriptions pills seized
– $119,447 in cash seized
– 95 vehicles seized
• January 1 to July 31, 2010
– 301 Total Arrests made
– 229 Felony Arrests (Includes 43 Drug Trafficking Arrests)
– 72 Misdemeanor Arrest
– Over 14,407 Prescription Pills Seized
– $58,073.00 in Cash Seized
– 60 Vehicles Seized


Dose Units
6 month period in 2008

2,738,700 units of oxycodone

Why Oakland Park?
• Lack of modern zoning regulations to address specific
demands of a pain clinic compared to surrounding cities;
parking, change of use regulations.
• Proximity of clinics to interstate highways
• Vacant office/retail space and low commercial lease rates
• Clustering of existing clinics & pharmacies created
demand for even more clinics


Pain clinics advertise, cluster around each
other and create problems for


Impact within the City of Oakland Park
• Homicide and violent crime
• Increase in neighborhood burglaries and
• Increase in drug trafficking of prescription
drugs street level sales
• Identity theft
• Organized crime
• Parking issues
• Loitering, littering and other nuisances for
adjoining neighborhoods

Oakland Park’s Draft Ordinance Outline
Chapter 24, Land Development Code
• New Business Categories: Pain Management Clinic, Pharmacy
& Rehabilitation, Drug Addiction Treatment, Therapy and
• Prohibits new clinics in NB and B-1 zoning districts.
• Conditional use for new pain clinics in B-2 & B-3.
• New Parking Requirements: 1 per 10 gross sq. ft. of customer
waiting area including the lobby and seating area; plus 1 per
200 gross sq. ft. of the remainder of the building.
• Change of Use. All new clinics would need to bring a property
up to current parking and landscape codes if they occupy
more than 25% of a building on a site.


Proposed Master Business List & Parking Code Changes
Chapter 24, Article III, Section 24-41, Master Business List:
Business Listings














Pain Management Clinic (see Chapter 7, Section 7151 of the Code of Ordinances for definition and
additional regulations)
Pharmacy (see NB zoning district regulations for
additional restrictions)


Rehabilitation, Drug Addiction Treatment, Therapy
and Counseling


(* = Permitted by Right; *7 = Conditional Use; Blank = Not permitted)

Chapter 24, Article VI, Section 24-80(C):
Parking Requirement Spaces
1 per 10 gross sq. ft. of customer waiting area including the lobby and
Pain Management
seating area; plus 1 per 200 gross sq. ft. of the remainder of the



Oakland Park’s Draft Ordinance Outline (cont’d)
Chapter 7, Licenses & Business Regulations
• Provides for the definition of a pain management clinic.
• Exceptions: Medical facilities and Hospitals, Surgical doctors offices
orthopedics, medical schools, any other medical clinic, office or facility
that does not prescribe controlled substances i.e., Chiropractor, Nonprofit
Organizations, Walgreens, CVS and Publix pharmacies.
Pain Management Clinic Permit
• Applicants must include the business operator, Medical Director and the
property owner.
• No employees of the clinic can have a felony conviction involving a
controlled substance.
• Disclosure of Interest Affidavit will detail all natural persons who are
involved in the business.


Oakland Park’s Draft Ordinance Outline (cont’d)

Clinics must be registered and provide proof of registration with DOH.
All clinics new and existing must be owned by a physician or a group of
No outdoor seating areas, queues or customer waiting areas.
Prohibits on site prescription drug dispensing for controlled substances.

Separation Requirements
– ½ mile separation between each clinic regardless of municipal
– ½ mile separation FROM community or special pharmacies regardless of
municipal boundaries.
– Discourages doctor shopping and mitigates the negative impacts from the
clustering of clinics.



Oakland Park’s Draft Ordinance Outline (cont’d)
• Conditional Use. Approval for new clinics required, existing clinics will be
legal nonconforming to having a conditional use approval.
• Inspections. All clinics must allow representatives of the City of Oakland
to enter and inspect their places of business during business hours or at
any time the business is occupied to verify compliance with the City’s
Code of Ordinances.
• Revocation of permit. Violations of the City Code of Ordinances and/or
clinics that are determined to be harmful to the public health, safety or
welfare of the city may have their permits revoked.
• Penalties & Enforcement.
– Arrest and imprisonment for up to 90 days;
– Fines up to $500 per day for each offense;
– Special Master process and procedures.


Existing Pain Clinics
• All existing clinics must file for the Pain Management Clinic Permit within
60 days of the adoption of the ordinance.
• Immediate compliance with the following is required:
• No employees of the clinic can have a felony conviction involving a
controlled substance.
• No outdoor seating areas, queues or customer waiting areas.
• Prohibits on site prescription drug dispensing for controlled
• Removal of all signage, symbols or vehicles identifying the
premises as a pain clinic from a building, site or parcel of land
where pain clinics have vacated and are no longer in operation.
• All existing clinics must comply with the distance separations within 5


Working with Law Enforcement
Lisa McElhaney
Broward County Sheriff’s Office
[email protected]

Ways to Work with Law Enforcement
• Have a Defined Strategy
– Identify Resources
– Identify Stakeholders

• Develop a Networking System to Coordinate
– Organize Specific Rolls & Responsibilities
– Organize a Recordkeeping System to Track ALL
Related Incidents, Actions, and Results

Law Enforcement Needs
• Primarily Focus on Public Safety Issues
– Immediate Threats receive higher priority

• Enforcement of Laws
– Criminal, Civil, Regulatory & Administrative
– Specialized Area requires Clarification of Violations
– Identify Appropriate Agency of Enforcement

Department of Health
Local Law Enforcement
Code Enforcement

Strategic Tactics
• Require Preplanning
• Education for ALL Stakeholders on Laws,
Regulations & Viable Responses
– Establish a Network with Local Stakeholders

• Identify Levels of Recognition & Authorization
for New Businesses (Prevention)
– Establish a Vetting Process
– Establish a Swift Response Mechanism for

Today’s Webinar Presenters
Senator Dave Aronberg
Special Prosecutor, Prescription Drug Trafficking
Office of the Florida Attorney General
[email protected]
Justin T. Proffitt, AICP
Senior Planner, Engineering & Community Development Department
City of Oakland Park
[email protected]
Lisa McElhaney
Broward County Sheriff’s Office
[email protected]
Kenneth Pratt, Esq.
Legislative Advocate
Florida League of Cities, Inc.
[email protected]

Thank you for participating in today’s webinar. For further
information on the FLC’s monthly webinars go to

301 South Bronough Street • Suite 300
P.O. Box 1757 • Tallahassee, FL 32302-1757
(850) 222-9684 • Fax (850) 222-3806

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