CVS Case
CVS Case
*This case was prepared by Yixing Chen, Christine Shields, and Michelle Urban for and under the direction of O. C. Ferrell and Linda
Ferrell © 2014. It was prepared for classroom discussion rather than to illustrate either effective or ineffective handling of an adminis-
trative, ethical, or legal decision by management. All sources used for this case were obtained through publicly available material.
439
quarters, with dividend increases for 11 consecutive The allegations initiated investigations by the Office
years. Today, CVS is one of the largest pharmacy health of Civil Rights (OCR) and the FTC, marking the first
care providers and pharmacies in the United States, and such collaborative investigation into a company’s prac-
is comprised of four business functions: CVS/Caremark, tices. These investigations revealed other issues as well,
MinuteClinic, PBM Services, and Retail Pharmacy. including a failure of company policies and procedures
The following case will explain some of the legal to completely address the safe handling of sensitive
and ethical challenges CVS/Caremark has encoun- patient information, lack of proper employee training
tered, including a settlement with the Federal Trade on disposal of sensitive information, and negligence
Commission (FTC) and U.S. Department of Health in establishing repercussions for violations of proper
& Human Services (HHS) regarding violations of the disposal methods. This was in spite of the fact that
Health Insurance Portability and Accountability Act CVS materials reassure clients that their privacy is a top
(HIPAA) Privacy Rule, deceptive business practices, and priority for the pharmacy. This claim, in addition to the
unseemly conduct by a manager resulting in a death. investigative findings, prompted the FTC to allege that
Our examination will also include how CVS/Caremark CVS was making deceptive claims and had unfair securi-
responded to such allegations, and how they have ty practices, both of which are violations of the FTC Act.
worked to redefine the company as a healthcare pro- CVS settled the case with the U.S. Department
vider. We will analyze the company’s ethical structure, of Health & Human Services (HHS), which over-
including their recent decision to stop selling cigarettes, sees the enforcement of the HIPAA Privacy Rule, for
as well as an overview of some criticisms the company $2.25 million regarding improper disposal of patients’
has received during their transition. The conclusion health information. The settlement also mandated that
offers some insights into the future challenges CVS will the company implement a Corrective Action Plan with
likely experience. the following seven guidelines: (1) revise and distribute
policies regarding disposal of protected health infor-
mation; (2) discipline employees who violate them;
ETHICAL CHALLENGES (3) train workforce on new requirements; (4) conduct
internal monitoring; (5) involve a qualified, indepen-
Like most large companies, CVS must frequently dent third-party to assess company compliance with
address ethical risk areas and maintain socially respon- requirements and submit reports to HHS; (6) establish
sible relationships with stakeholders. Although CVS internal reporting procedures requiring employees to
has excelled in social responsibility, it has suffered from report all violations of these new privacy policies; and
ethical lapses in the past. The next section addresses (7) submit compliance reports to HHS for three years.
some of CVS’s most notable ethical challenges, some of The company also settled with the FTC by signing a
which resulted in legal repercussions. consent order, requiring the company to develop a com-
prehensive program that would ensure the security and
confidentiality of information collected from customers.
HIPAA Privacy Case of 2009 In so doing, the company agreed to a biennial audit
from an independent third party. This audit is meant to
As a company grows and achieves widespread influ-
ensure that CVS’s program meets the FTC’s standards
ence, it also inherits a responsibility to act ethically and
for its security program. CVS is forbidden by law from
within the law. In 2009, CVS/Caremark was accused of
misrepresenting its security practices.
improperly disposing of patients’ health information. It
was alleged that company employees threw prescription
bottle labels and old prescriptions into the trash with-
out destroying sensitive patient information, making it
Deceptive Business Practices
possible for the information to fall into public hands. In addition to privacy challenges, CVS/Caremark
This is a violation of the HIPAA Privacy Rule, which has been accused of deceptive business practices.
requires companies operating in the health industry to A 2008 civil lawsuit involving 28 states was filed
properly safeguard the information of their patients. against the personal benefits management division of
CVS/Caremark, which acts as the prescription drug The DEA suspension decreased the amount of such
claim intermediary between employers and employees. narcotics being distributed to the two CVS locations by
It also maintains relationships with drugstores and 80 percent in a period of three months, limiting their
manufacturers. The allegations of the lawsuit included ability to make a profit. When the matter came before
urging doctors to switch patients to name brand pre- a federal judge, he ruled that the company was at fault
scriptions under the notion that it would save them for lack of proper oversight in distributing the drug and
money. Furthermore, these switches were encouraged other narcotics. The ruling further implied company
without informing doctors of the financial burden it negligence as such a large amount of pills should have
would impose on patients, and employer healthcare been noticed as a blatant abnormality.
plans were not informed that this activity would benefit Later that year, the DEA completely revoked
CVS/Caremark. This could be seen as a conflict of inter- the licenses of the two locations to sell controlled
est at the expense of customers. Due to these allegations, substances—the first time this has occurred with a
the suit called for a revision in how the division gives national retail pharmacy chain. CVS claims that they
information to consumers. In the end, CVS/Caremark have improved their procedures regarding its distribu-
signed a consent decree without admitting fault and tion of controlled substances; however, the DEA’s claims
paid a settlement of $38.5 million to reimburse states explicitly included negligence on the part of pharmacists
for the legal costs and patients overcharged due to the in light of obvious “questionable circumstances.” These
switch in prescription. In a similar matter, a multiyear- circumstances included the fact that several customers
long FTC investigation concluded (in 2009) that the were coming to Florida from out of state to fill pre-
company had misled consumers regarding prices on scriptions. Many lacked insurance and paid in cash, a
certain prescriptions in one of its Medicare plans. red flag that can suggest illegal use of drugs. This was
The switch harmed elderly customers as they were in addition to the heavy pill problem in the area which
billed for up to ten times the amount they anticipated. had already prompted state legislation.
CVS/Caremark settled with the FTC for $5 million to Testimonies from employees indicated company
reimburse customers for the change in price. negligence as they had knowledge of the top prescrib-
ing doctors in the area and awareness that daily oxy-
codone quotas were being depleted—sometimes within
30 minutes of the pharmacy opening. Pharmacists also
Overdistribution of Oxycodone indicated that they set aside pills for those patients they
In 2012, CVS faced challenges with another federal considered to have a real need for them because they
agency—the Drug Enforcement Administration (DEA). had strong suspicions that most of the people purchas-
The DEA suspended the company’s license to sell con- ing the pills were abusers. They did not feel at liberty
trolled substances at two Florida locations, only a few to refuse prescriptions to customers, however, because
miles apart from one another. These locations were they are not trained to diagnose illnesses. In 2013, CVS
found to have ordered a total of 3 million oxycodone announced a review of its database of healthcare pro-
pills in 2011. The average order for a U.S. pharmacy viders to find abnormalities in narcotic prescriptions.
in the same year is 69,000 pills. Intensifying the mat- They found and notified at least 36 providers to whom
ter, abuse of narcotics (pain pills) is prevalent in the they would no longer fill orders due to high prescrip-
area. Florida state legislation had been implemented in tion rates.
response to the issue as local clinics became known as Another incident in 2014 involving the disap-
“pill mills” for their liberal distribution of prescriptions pearance of 37,000 pain pills in four California stores
for pain pills. brought the DEA and CVS together again. These stores
CVS responded to the DEA’s investigation by have a history of not being able to account for sev-
notifying some of the area doctors that they would eral pain prescription drugs. This incident carries up to
not fill prescriptions written for oxycodone (Schedule 2,973 violations of the Federal Controlled Substances
II narcotics). However, they also requested a tempo- Act and could cost the company up to $29 million
rary restraining order against the DEA, which would in penalties. In 2012, the DEA investigated missing
disable the temporary suspension of selling the drugs. pills in a store wherein an employee admitted taking
approximately 20,000 pills. This piqued the curiosity of Innovative programs such as Pharmacy Advisor and
investigators, who found three retail locations that each Maintenance Choice, developed in collaboration with
had thousands of pills missing. researchers from Harvard University and Brigham and
Women’s Hospital, help patients stay on their medica-
tions. Research shows that regular interaction between
Death of a Shoplifter patient and pharmacist increases the likelihood that
patients will adhere to their medication regimen. Many
In 2010, a man accused of shoplifting toothpaste was patients who take regular prescriptions often think that
chased out of a CVS store by a manager. Video surveil- they are well enough to cease taking their medication.
lance footage showed an altercation between the two. However, when the symptoms of their ailments reap-
Six bystanders came to the manager’s assistance, one of pear, the costs are great, both financially and medically.
whom was seen kicking and punching the perpetrator CVS’s programs allow the company to inform patients
while the manager held him around the neck. Within about the benefits and risks of these effects through edu-
seconds, the man was heard saying he could not breathe cation and awareness. The entire industry also benefits
and died shortly thereafter. Police investigated the from this knowledge by preventing more costly medical
incident and have not filed charges despite the medical procedures due to medication non-adherence, which
examiner’s classification of the death as a homicide. The occurs when patients skip or incorrectly take their dos-
manager claimed that the shoplifter punched him, so he age requirements. This is estimated to cost between $5
retaliated in self defense. The victim’s mother is filing a and $10 for every $1 spent on adherence programs.
civil lawsuit against the manager and claiming CVS is These services are key components of CVS’s com-
liable for her son’s death. Whether or not CVS is found petitive advantage, allowing them to provide the best
culpable, the tragedy cast a shadow over CVS and how possible patient care. They were also proactive in pre-
it handles shoplifters. paring patients for Health Care Reform. For instance,
CVS/Caremark partnered with the Centers for Medicare
and Medicaid Services to raise awareness about new
MOVING TOWARD A services available to Medicare patients under the ACA.
To help people keep up with these and other
HEALTHCARE COMPANY changes in healthcare, CVS has established its pres-
Despite the ethical challenges CVS has experienced, it ence on social media and mobile devices. The company
is trying to reposition itself as a socially responsible introduced a mobile application for customers to con-
organization that places priority on consumer health. veniently refill prescriptions, while their Facebook and
Being a quality healthcare company not only offers Twitter pages provide helpful health tips. Customers
reputational benefits, but financial advantages as well. benefit from using CVS’s digital tools for savings and
Changes in both the economic and healthcare landscape new user experience. CVS’s iPad application allows
are creating new opportunities for CVS to provide dif- individuals to have a 3D digital pharmacy experience
ferent programs and redefine itself. Trends including reminiscent of shopping in store. Those who are unable
the declining number of primary care physicians, the to physically visit the store, or prefer the convenience
16 million baby boomers who are becoming eligible of shopping from home, are able to partake in the CVS
for Medicare benefits, and the more than 30 million experience through the company’s technology. With
newly insured Americans under the Affordable Care over 10 million registered users, many are saving money
Act (ACA) offer CVS an attractive market in which to and time filling and refilling prescriptions as well as
expand. For example, CVS has refocused its efforts on having instant access to essential drug information.
supplying the growing need for chronic disease man- MinuteClinics are one of the major contributors
agement that consumes costly resources when patients to CVS’s rebranding efforts. These clinics are the first
do not adhere to physician recommended medications in healthcare retail history to be accredited by the
and monitoring methods to maintain health. PBM ser- Joint Commission, the national evaluation and certify-
vices are being successfully implemented, including mail ing agency for healthcare organizations and programs
order, specialty pharmacy, plan design and administra- in the United States. This accreditation signifies the
tion, formulary management, discounted drug purchase clinic’s commitment to and execution in providing safe,
arrangements, and disease management services. quality healthcare that meets nationally set standards.
In addition to healthcare services, MinuteClinics provide Walmart Stores, Inc., Walgreen Co., and Rite Aid Corp.,
smoking cessation and weight loss programs that con- highlighting the contradiction of selling deadly products
tribute positively to people’s health. These clinics are and healthcare services simultaneously. The letter also
also the first retail clinic provider to launch a partner- noted that drug store sales make it easier for younger
ship with the National Patient Safety Foundation for its age groups to begin smoking and more difficult for
health literacy program to help improve patient educa- those trying to quit smoking. Walmart and Walgreen
tion and community health. acknowledged the letter, but made no indication that
Under the ACA, healthcare organizations are eli- they would stop selling tobacco products. Rite Aid
gible to become members of the Accountable Care responded by saying they will continue to sell both
Organizations (ACO) program. This program ensures tobacco products as well as smoking cessation services,
that members are accountable in providing quality as the practice is legal. While this letter does not seem
healthcare to the sick as well as meeting certain stan- to have much of an influence on retailers, some specu-
dards to provide health-conscious programs such as late that it increases the pressure on the $100 billion
those related to smoking cessation and weight loss. tobacco industry, which is already facing decreasing
Accountability is measured by positive outcomes, result- sales, rising taxes, and smoking bans. For CVS, the
ing in cost savings, which in turn is divided up among decision will affect their short-term profits and reduce
members to continue these effective programs and each share by $0.06–$0.09 each. Investors do not seem
services. There are at least 123 ACOs in the United worried, however, as the long-term benefits will make
States, and more than 360 ACOs have been established up the difference.
as Medicare providers since the ACA went into effect—
covering over 5.3 million patients.
CRITICISM AGAINST CVS
REVEALING CVS’S NEW CVS’s new programs are encroaching on the medical
industry by providing services to patients. As custom-
DIRECTION: TOBACCO-FREE CVS ers increasingly choose to visit local pharmacy clinics
In order to be consistent with their transition from for aches, pains, or common illnesses, primary physi-
pharmacy to healthcare company, CVS has made some cians are feeling the losses, especially since this sector’s
landmark decisions aimed toward helping individuals healthcare professionals are dwindling. Choosing a
lead healthier lives. In 2014, CVS announced that it retail pharmacy clinic over a physician’s office benefits
would no longer sell tobacco products. The revenues the patient with lower costs and savings, which is a
generated from selling tobacco products are about threat to traditional doctors’ offices. Some groups are
$2 billion annually, so this bold decision sends a strong publicizing negative feedback on pharmacy care. For
message to stakeholders regarding the values of the instance, the American Academy of Pediatrics issued
company. A company that is consistent in their actions a statement warning patients not to visit such clinics
will gain a good reputation, which will attract more because they cannot offer the specialized care children
customers and generate revenue. This decision also need. Some groups argue that programs such as CVS’s
gives CVS an advantage in terms of the ACA. As the MinuteClinic do not offer the same caliber of service
ACA changes the healthcare landscape, companies are and care as a doctor. However, as stated above, CVS
racing to get a stronghold in the new system to be listed holds itself to a very high standard for care in trying to
as a preferred pharmacy. CVS/Caremark’s alignment in help patients be healthy. It continues to be accredited by
defining itself as a healthcare provider will likely result the Joint Commission.
in stronger relationships with doctors and hospitals, CVS MinuteClinics do recognize their limitations,
creating an advantage of preference. The goal is that however. Their website offers information to visitors
referrals for medication will be done through CVS and regarding when they should and should not visit the
serve to boost reputation within all CVS segments. clinics. For example, the website recommends that
This, in conjunction with its status as an ACO, puts patients with severe symptoms such as chest pain, short-
CVS in a competitive position to attract newly insured ness of breath and difficulty breathing, poisoning, tem-
Americans. peratures above 103 degrees Fahrenheit (for adults) and
This decision spurred 24 state attorneys general 104 (for children), and ailments requiring controlled
to send letters to other pharmacy retailers, including substances should seek care elsewhere. MinuteClinics
staff nurse practitioners and physician assistants who all stakeholder needs are addressed. The following sec-
are able to provide services for minor wounds, com- tions will describe how they meet the needs of other
mon illnesses, wellness tests and physicals, etc. Other stakeholders.
information regarding insurance and pricing are also
available on the website.
Employees
CVS implemented the Values in Action program for
STAKEHOLDER ORIENTATION employees, giving them a chance to recognize colleagues
CVS’s mission to be a pharmacy innovation company is through online reward systems. Peers can nominate
guided by five values: innovation, collaboration, caring, each other across the company for leadership traits and
integrity, and accountability. CVS uses these values to other commendable accomplishments. Each nomination
determine their actions and decisions, which offers a grants points, which can be redeemed for merchandise,
glimpse into their ethical culture. The company’s goal is travel, and more. Programs like these let employees
to use their assets to reinvent the pharmacy experience know they are valued and empower them in their com-
and offer innovative solutions that help people on a bet- mitment to CVS. The Values in Action Breakthrough
ter path to health. This goal relays to stakeholders that Awards is an annual company-wide broadcast that
the company cares about their health. CVS/Caremark’s honors specific individuals exemplifying the company’s
business is committed to fostering a culture that values in innovation, collaboration, caring, integrity,
encourages creativity and innovation, recognizing that and accountability.
contributions from all members are a high priority. This CVS focuses strongly on compliance and integrity
commitment highlights their value of collaboration with training for employees. The compliance and integrity
partners and stakeholders, which also serves to hold training for employees is led by a Compliance Officer.
them accountable for their operating activities—thus Regular compliance education and training programs,
strengthening their integrity. Another important factor a confidential 24/7 ethics hotline, and an efficient
in their ethical culture is to address enhanced access to audit, response, and prevention process are components
care while also lowering its cost. that make this program comprehensive. The company
CEO Larry J. Merlo emphasizes the long-term per- also supports the development of employees through
spective the company is committed to with each deci- professional development training sessions. The pur-
sion and how it will affect each stakeholder group. He pose of such training is not only to keep employees
states that CVS’s priorities remain in customer health, current on new technologies and processes but to help
the sustainability of healthcare systems, good steward- them advance in their careers within the company.
ship, positive contributions to their communities, and a
meaningful workplace for employees. Such a statement
from the top leader of the company sets the tone that
creates the ethical culture behind CVS. The company’s
Shareholders
Code of Conduct includes ethical behavior expecta- CVS seeks to protect shareholder interests while main-
tions, and they are proud to have good relationships taining broad stakeholder engagement. As a result,
with employee unions who represent approximately CVS carefully designed a comprehensive corporate
6 percent of their workforce. CVS employs a Chief governance system ranging from board independence
Compliance Officer, offers regular compliance educa- to executive compensation. Following a corporate gov-
tion and training, provides an ethics hotline for con- ernance framework, a variety of specialized committees
fidential reporting, and has developed a response and has been established with different functions for share-
prevention guideline for addressing violations of CVS’s holders. From an information governance standpoint,
policies or federal, state, or local laws. CVS’s corporate the oversight committee makes recommendations to
governance includes a privacy program, information enhance the ability of information security. On behalf of
security, and a corporate framework that focuses on the the board of directors, the audit committee is in charge
company’s values. of the risk oversight and is responsible for protecting
So far we have addressed how CVS meets the the reputation and core interests of the company.
needs of its customer stakeholders. However, CVS In order to balance the interests of different groups,
tries to maintain a stakeholder orientation in which senior management created a reformative executive
“CVS Pays $2.25 Million & Toughens Disposal Practices Timothy W. Martin, “CVS to Kick Cigarette Habit,”
to Settle HIPAA Privacy Case,” U.S. Department of The Wall Street Journal, February 6, 2014, pp. B1–B2.
Health and Human Services, http://www.hhs.gov/ James P. Miller, “CVS Caremark Settles Deceptive-
ocr/privacy/hipaa/enforcement/examples/cvsresolu- practices Complaint for $38.5 Million,” Chicago
tionagreement.html (accessed August 2, 2014). Tribune, February 15, 2008, http://articles.chicagotri-
Mike Estrel, “States Urge Retailers to Drop Tobacco,” bune.com/2008-02-15/business/0802140788_1_cvs-
The Wall Street Journal, March 18, 2014, p. B3. caremark-caremark-rx-pharmacy-benefits (accessed
“Everybody Loves a Quitter,” CVS MinuteClinic, http:// August 2, 2014).
www.cvs.com/minuteclinic/resources/smoking-cessation Chris Morran, “CVS Being Investigated After 37,000 Pain
(accessed August 4, 2014). Pills Go Missing,” The Consumerist, March 11, 2014,
Joseph H. Harmison, “CVS Caremark Abuses Warrant http://consumerist.com/2014/03/11/cvs-being-inves-
through FTC Investigation and Remedies,” The Hill, tigated-after-37000-pain-pills-go-missing/ (accessed
May 25, 2010, http://thehill.com/blogs/congress-blog/ August 4, 2014).
healthcare/99759-cvs-caremark-abuses-warrant-through- Mark Morelli, “Healthy First: CVS Will Stop Selling
ftc-investigation-and-remedies (accessed August 2, 2014). Cigarettes,” The Motley Fool, February 7, 2014, http://
“Investor Fact Sheet,” CVS Caremark, March 2014, www.fool.com/investing/general/2014/02/07/healthy-
http://investors.cvscaremark.com/˜/media/Files/C/CVS- first-cvs-will-stop-selling-cigarettes.aspx (accessed
IR/reports/cvs-factsheet.pdf (accessed August 5, 2014). August 6, 2014).
Chris Isidore, “Cigarette Sales: Walgreens, Rite-Aid, “Our Pharmacy Advisor Program,” CVS Caremark, http://
Wal-Mart, Kroger & Safeway Urged to Selling info.cvscaremark.com/cvs-insights/our-pharmacy-advi-
Tobacco,” CNN Money, March 17, 2014, http:// sor-program (accessed August 4, 2014).
www.wptv.com/web/wptv/news/health/cigarette-sales- Paul Edward Parker, “Rite Aid Responds to CVS Decision
walgreens-rite-aid-wal-mart-kroger-safeway-urged-to- to Stop Selling Tobacco,” Providence Journal, February 6,
selling-tobacco (accessed August 6, 2014). 2014, http://www.providencejournal.com/breaking-news/
Bruce Japsen, “How Obamacare Helps CVS Kick The content/20140206-rite-aid-responds-to-cvs-decision-to-
Habit,” Forbes, February 2, 2014, http://www.forbes stop-selling-tobacco.ece (accessed August 6, 2014).
.com/sites/brucejapsen/2014/02/15/how-obamacare- Amy Pavuk, “Rx for Danger: DEA Blasts CVS for
helps-cvs-kick-the-habit/ (accessed June 6, 2014). Ignoring ‘Red Flags’ at Sanford Stores,” Orlando
Elisabeth Leamy, “Drug Discount Cards Help You Save Sentinel, October 28, 2012, http://articles.orlandosen-
on Prescription Meds,” ABC News, August 20, 2012, tinel.com/2012-10-28/news/os-cvs-dea-oxycodone-
http://abcnews.go.com/Business/drug-discount-cards- ban-20121028_1_sanford-cvs-sanford-pharmacies-
save-money-prescription-meds/story?id=17029498 sanford-stores (accessed August 4, 2014).
(accessed August 5, 2014). Amy Pavuk, “Two Sanford Pharmacies Banned From
Donna Leinwand Leger, “DEA: Oxycodone Orders by Selling Oxycodone, Controlled Substances,” Orlando
Pharmacies 20 Times Average,” USA Today, Sentinel, September 12, 2012, http://articles.orlan-
February 7, 2012, http://usatoday30.usatoday.com/ dosentinel.com/2012-09-12/news/os-sanford-cvs-
money/industries/health/story/2012-02-06/dea-cvs-oxy- caremark-revoke-drugs-20120912_1_revokes-prescrip-
codone-raid/52994168/1 (accessed August 4, 2014). tion-drug-abuse-oxycodone-and-other-prescription
Natasha Leonard, “Homeless man Choked to Death (accessed August 4, 2014).
After Shoplifting Toothpaste,” Salon, January 18, “Press Release: More Partnerships between Doctors and
2013, http://www.salon.com/2013/01/18/homeless_ Hospitals Strengthen Coordinated Care for Medicare
man_choked_to_death_after_shoplifting_toothpaste/ Beneficiaries,” Centers for Medicare and Medicaid
(accessed August 4, 2014). Services Press Release, December 23, 2013, http://
“The Long-Term Incentive Plan,” CVS Carenark, March www.cms.gov/Newsroom/MediaReleaseDatabase/
24, 2009, http://www.wikinvest.com/stock/CVS_ Press-Releases/2013-Press-Releases-Items/2013-12-23.
Caremark_Corporation_(CVS)/Long-term_Incentive_ html (accessed August 4, 2014).
Plan (accessed August 6, 2014). “Quality,” CVS MinuteClinic, http://www.cvs.com/minute-
Kris Maher and Sara Germano, “CVS Takes Steps on clinic/visit/about-us/quality (accessed August 4, 2014).
Meth Abuse in West Virginia,” The Wall Street Journal, “Services,” CVS MinuteClinics, http://www.cvs.com/
July 8, 2014, p. A3. minuteclinic/services (accessed August 4, 2014).
Kyle Stock, “Pediatricians Seek Risk-to Kids and CVS Caremark, http://info.cvscaremark.com/about-us/
Themselves-in DrugStore Health Clinics,” Bloomberg our-purpose-building-bridge-better-health (accessed
Businessweek, February 24, 2014, http://www.busi- August 5, 2014).
nessweek.com/articles/2014-02-24/pediatricians-see- Jessica Wohl, “CVS Cuts Off Docs Who Prescribe Too
risk-to-kids-and-themselves-in-drug-store-health-clinics Many Narcotics,” NBC News, August 22, 2013, http://
(accessed June 6, 2014). www.nbcnews.com/health/health-news/cvs-cuts-docs-
“We’re a Pharmacy Innovation Company and Every Day who-prescribe-too-many-narcotics-f6C10975693
We’re Working to Make Health Care Better,” About (accessed August 4, 2014).