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entitled 'Internet Pharmacies: Hydrocodone, an Addictive Narcotic Pain 
Medication, Is Available Without a Prescription Through the Internet' 
which was released on June 17, 2004.

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Before the Permanent Subcommittee on Investigations, Committee on 
Governmental Affairs, U.S. Senate:

For Release on Delivery Expected at 9:00 a.m. EDT Thursday, June 17, 

Internet Pharmacies:

Hydrocodone, an Addictive Narcotic Pain Medication, Is Available 
Without a Prescription Through the Internet:

Statement of Robert J. Cramer Managing Director, Office of Special 


Mr. Chairman and Members of the Subcommittee:

I am pleased to be here today to summarize the results of our 
investigation of some of the business practices of certain U.S. 
Internet pharmacies that sold narcotics without a prescription. Our 
testimony is part of a larger body of work GAO has performed that is 
the subject of a report and additional testimony we are releasing today 
that examines issues surrounding the availability and safety of 
prescription drugs sold over the Internet and the business practices of 
certain Internet pharmacies.[Footnote 1] We conducted our work from 
March 2004 through June 2004 in accordance with quality standards for 
investigations as set forth by the President's Council on Integrity and 

At your request, Mr. Chairman, we attempted to obtain information about 
the sources of hydrocodone[Footnote 2] that we purchased without a 
prescription from eight U.S. online pharmacies. Hydrocodone is an 
addictive narcotic pain medication, and illicit use of this drug has 
increased significantly in recent years. We contacted one of the 
pharmacies that had sold us hydrocodone in an attempt to determine the 
relationship between the Internet site and the pharmacy that dispensed 
the narcotic and to find out what role a physician may have played in 
facilitating our purchase. We also spoke to a physician who actually 
prescribed the narcotic for one of our purchases and appears to be 
operating an Internet drug business that caters almost exclusively to 
individuals purchasing hydrocodone. Although the Internet Web site and 
the physician have taken some measures to disguise their operation as a 
legitimate enterprise, their business practices suggest otherwise.

We determined the location of the pharmacy that we contacted based on 
the return address on the package in which the sample was delivered. 
Further, posing as a relative of the customer who had purchased 
hydrocodone from this Internet pharmacy, one of our investigators spoke 
to the pharmacist who dispensed the drug as well as the prescribing 
physician. Subsequently, we conducted surveillance of the office where 
the physician processes Internet drug orders.

In summary, we found that (1) one can purchase hydrocodone from certain 
Web sites on the Internet without providing a prescription or being 
examined by a physician; and (2) the Internet pharmacies from which we 
made our purchases of hydrocodone charge significantly higher prices 
for the drug than walk-in pharmacies. We concluded that those who 
participate in Internet drug operations that operate in this manner 
appear to be in the business of knowingly servicing, and profiting 
from, individuals who may purchase pain medication for illicit 

Purchases of Narcotic Pain Medication Without Prescriptions:

We obtained hydrocodone from eight domestic Web sites on which we 
placed orders without submitting a prescription or undergoing an 
examination by a physician. Six purchases, each from different Web 
sites, were dispensed by a single pharmacy located in a Southeastern 
state. The two remaining purchases were ordered from two separate Web 
sites and were dispensed by separate pharmacies located in states in 
the Southeast and Southwest.

We obtained the hydrocodone online by completing questionnaires on 
which a GAO staff member (the "customer") claimed that he had pain. In 
addition, he claimed that his doctor had prescribed hydrocodone for the 
pain, but that he had recently lost his health insurance and could not 
return to his doctor for a new prescription. Five Web sites sent the 
narcotic after receiving our order and credit card payment information. 
We received telephone calls from the three other suppliers before our 
order was completed. They asked questions about our purported need for 
the hydrocodone and prior use of the drug.

In our attempt to determine the relationship between the Internet site 
and the pharmacy that dispensed the narcotic, and to find out what role 
a physician may have played in facilitating our purchase, we contacted 
one of the pharmacies that had sent us hydrocodone. We also contacted 
the physician who "prescribed" a 30-day supply of the narcotic without 
seeing or speaking to the customer and without any confirmation from a 
physician that the customer had previously been under a doctor's care 
or had received a prescription for pain relief.

This specific purchase originated on February 26, 2004, when the 
customer, posing as a patient experiencing pain, used a pseudonym to 
place an order for hydrocodone. Customers are advised on the site that 
they are required to (1) fill out an online questionnaire, (2) receive 
a phone call from a medical professional to discuss the customer's 
medical condition to determine if he or she is approved for the drug, 
and (3) undergo a complete physical examination. If approved, the 
medication is billed to the customer's credit card.

Despite the claims on the Web site that customers must satisfy these 
requirements, we obtained the hydrocodone without undergoing a physical 
examination or producing any tangible evidence showing treatment by a 
doctor in the past. Indeed, the customer simply completed the online 
questionnaire and spoke by telephone to the physician's representative, 
who offered the customer two options for satisfying the physical 
examination requirement: (1) for $199, the customer could visit a 
physician at one of two clinics in the area where the customer lived; 
or (2) for $49, the representative would fax or e-mail paperwork that 
the customer could take to his own physician to fill out and return to 
the pharmacy's physician. In addition, the representative told the 
customer that if he chose and paid for one of these two options with a 
credit card during their telephone conversation, the physician would 
immediately issue a 30-day prescription so that he could get his 
medication right away.

The customer told the representative that he needed to think about both 
options. However, the representative reemphasized that if he chose 
either the $199 or the $49 option and paid for it immediately, he could 
get his 30-day supply of hydrocodone right away. The customer then 
chose the $49 option and gave the representative his credit card 
information. After the transaction was complete, the representative 
reviewed the information that the customer submitted online and said 
that he would receive e-mails from her and from the Web site containing 
paperwork and information on how to pay for the medication.

The customer then asked if he needed to set up an appointment for a 
consultation with the physician, and the representative replied that 
she had already completed the consultation. Later that day, the 
customer received the paperwork and an e-mail link for a payment site. 
He went to the site and used his credit card to pay a total of $190 for 
his initial 30-day supply of hydrocodone.

Subsequent Investigation:

Subsequent to receipt of the hydrocodone, a GAO investigator, posing as 
a relative of the customer, contacted the pharmacy listed on the return 
address of the package in which it was delivered. The pharmacist 
confirmed that he had sent the drug and explained that he has a 
business relationship with the Web site on which we ordered it, and 
with a physician who sent a prescription for it to the pharmacist.

The investigator then telephoned the physician who confirmed that he 
prescribed the hydrocodone. The physician claimed that he never writes 
prescriptions for new medications for patients and that he always 
confirms that the patient has been on the medication in the past. The 
investigator asked whether the doctor had actually spoken with his 
relative, and the physician responded that one of his associates had in 
fact spoken to him. He said that he has a staff of several people who 
make such telephone calls to confirm that the customer has been on the 
medication in the past. He repeatedly asserted that the staff calls and 
speaks with the customer's physician who previously prescribed the 
medication. However, he confirmed that the telephone number his staff 
had called with respect to our purchase was simply the telephone number 
of the customer himself, not that of a physician.

The physician indicated to our investigator that he was handling his 
Internet drug business from a clinic he operates. When asked the name 
of the clinic, he indicated that it is part of a health care network 
and gave a name that does not correspond to the name of any existing 
health care network we could find or to any actual medical practice 
with which the physician is in fact affiliated. He said to our 
investigator, "90 percent of our business is for hydrocodone." He 
acknowledged that he currently provides prescriptions for five 
different Internet drug sites and disclosed that he previously wrote 
prescriptions for two Web sites that have been shut down.

When asked about the possibility of children buying narcotics through 
him, the physician claimed that the need for a credit card is the 
"safeguard" to prevent that from happening and that "a kid shouldn't 
have a credit card." However, he admitted that "parents call [him] all 
the time saying that their children have gotten hold of their credit 
cards." While he stated that the system can be used by customers to 
purchase drugs for illicit purposes, he repeatedly stressed that his 
online pharmacy business offers "a service for patients who don't have 
insurance, who can't afford to go and see a doctor."

However, this assertion is patently false. To the contrary, the 
customer paid a total of $190.00, and an additional $49.00 
"consultation" fee, for 60 tablets of hydrocodone that can be purchased 
for an average price of about $26.00 at local retail pharmacies at 
which we inquired. Thus, we paid nearly ten times the ordinary retail 
price of the drug because we did not have a prescription. The Drug 
Enforcement Administration provided us with information that the 
"street price" or illegal sales price of the hydrocodone we bought 
online is about $5 to $6 per pill. Thus, we paid slightly less than the 
street price for the drug from this source. The prices we paid for 
hydrocodone at the other seven Web sites from which we ordered it were 
also significantly higher than the retail price at local pharmacies. 
Overall, we paid the eight online pharmacies prices that were 3 to 16 
times the price charged for hydrocodone at local pharmacies.

During our visit to the site where the physician purports to operate a 
clinic, we saw no evidence of a health clinic. The site is a one-room 
storefront set up with several computers and telephones. The only 
individuals we saw going to or leaving the storefront appeared to be 
employees, and there was no sign on the premises indicating that the 
business was health related. When one of the employees was asked what 
kind of business is operated at the location, she responded that they 
do "computer consultations."

Concluding Observations:

Our investigation revealed that customers can purchase hydrocodone, a 
potentially dangerous and addictive controlled substance, from certain 
domestic Internet sites that do not require prescriptions. These Web 
sites appear to purposely cater to hydrocodone customers who are 
willing to pay a substantial markup for the painkillers because they do 
not have prescriptions. As a result, these sites appear to be in the 
business of profiting from illicit drug use rather than providing a 
safe, inexpensive alternative source of drugs for customers.



[1] U.S. General Accounting Office, Internet Pharmacies: Some Pose 
Safety Risks for Consumers, GAO-04-820 (Washington, D.C.: June 17, 
2004); Internet Pharmacies: Some Pose Safety Risks for Consumers and 
Are Unreliable in Their Business Practices, GAO-04-888T (Washington, 
D.C.: June 17, 2004).

[2] Hydrocodone, a Schedule III controlled substance, is the generic 
version of Vicodin. 

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