Posted February 17, 2019
There are several reasons for the wealth gap between White Americans and African Americans. I have been fortunate to have relevant, authentic conversations with several financial planning professionals that acknowledge the need for a deeper understanding of cultural differences that inform the way that various people groups manage their finances, professional relationships and personal priorities. Cultural competence is the starting point; it must become a standard cornerstone of the financial planning process. Cultural competence is the ability to demonstrate in a practical manner a genuine understanding of historical and cultural influences that inform the experiences and responses of diverse population groups. The National Education Association states cultural competence is “having an awareness of one’s own cultural identity and view about difference, and the ability to learn and build on the varying cultural and community norms of students and their families.” U.S. Census Bureau statistics indicate that by 2045 the United States will become “minority white” at 49.7 percent of the population. Financial advisors must hone the cultural competence skill and financial planning clients must demand it.
An advisor building a culturally competent practice will emphasize three areas for continuous growth and development for the benefit of the client base:
Cultural competence must include the richness and resilience of historically financially marginalized minorities. For example, Americans of African descent have a rich history of storytelling, empire building and academic prowess that extends further back in our history than the 1600s on the eastern shores of lands in the Americas. The history of African Americans cannot and does not begin with the Middle Passage and freedom from chattel slavery. Collectively, the citizens of this country must reclaim the history of the nation’s diverse people groups through knowledge, and experience the joy and appreciation of research, storytelling and sharing that gives life to the stories of ancestors and preserves the futures of descendants.
Know that African Americans and women that served in the military during WWII were entitled to a wide range of benefits, the very same benefits that all returning WWII Veterans were entitled to, in accordance with the Servicemen’s Readjustment Act of 1944 (The GI Bill). Know that many African American veterans were encouraged by the Veterans Administration to take vocational training, rather than attend university, many were told there was no economic need for black skilled workers, therefore no need for education. Know that many banks refused to loan African Americans the funds for homeownership and restrictive covenants were commonplace. Know the detrimental effects of red-lining.
Also know about Mansa Musa.
Also know about the Buffalo Soldiers.
Also know about Richard Robert Wright, Sr.
Also know about the Tuskegee Airmen.
In the end cultural competence must become the rule…second nature, rather than an exception or something to intentionally integrate into a practice. The financial planning profession must wrestle with the history of this country to serve the diverse population of this country. In the past I have noted that thorough financial and life planning at some point along the way forces individuals to grapple with family dynamics, money, death, and much more. “Much more” includes our country’s history, how financial professionals reach out to segments of our population that have been historically deprived of opportunities and financial tools to build wealth, and the potentially implied shame we impose upon marginalized people groups for not having enough assets to fully participate in our growth economy. Census numbers suggest the financial futures of our country’s various people groups depend on financial planning professionals with broader, well informed perspectives on diverse cultures.
Validating and prioritizing wants and needs, being honest about proactively effecting change to reach goals, and expecting the need for modifications when necessary are starting points for ALL OF US.
So, financial professionals and clients: grab a history book. Diversity in financial planning starts with understanding history.
Please Join Me!
The topic of this discussion will address the following questions:
Where: Online (Zoom)
When: Thursday, February 28th, 2019
Time: 12:00pm-12:30pm PST
What You Can Expect
This mission of the Mentoring Forum series is to empower, educate, and illuminate individuals who are interested in the Financial Planning industry. At each forum an expert will discuss a topic in the field of financial planning with the purpose of inspiring critical thought and discussion.
Come prepared with questions as you do not want to miss this unique opportunity to have a conversation with a professional in the field!
Posted December 13, 2018
Can the 529 ABLE account be expanded to include Opioid Use Disorder as a qualified disability? It is worth considering.
Prior to June 2018, the Whatcom County Sherriff’s office had a policy of denying individuals suffering from opioid use disorder (OUD) medications that treat opioid addiction. Inmates were required to go “cold turkey” during their time in custody. An exception was made for pregnant inmates. The Americans With Disabilities Act forbids discrimination against disabled individuals; a public entity cannot deny the benefits of the services programs, or activities of the public entity based upon a disability for which reasonable accommodations for access to the benefits can be made. Individuals suffering from OUD are considered disabled. The ACLU of Washington’s position in the class action civil rights lawsuit filed against Whatcom County and the Whatcom County Sherriff was that MAT or “medically assisted treatment” medications (which include buprenorphine and morphine) are “clinically appropriate medications” and are on par with other medications for people suffering from other medical ailments (e.g., heart or diabetes medicine). OUD is a “chronic” condition, effects brain chemistry and can require the use of MAT on a regular basis…even for the remaining years of the addict’s life. MAT helps addicts achieve better outcomes through their recovery journey, which may include reduction in unnecessary physical suffering, chance of relapse, and overdose. To deny incarcerated addicts suffering from OUD access to MAT is to single out a group of people deemed disabled by the ADA, which is discrimination and prohibited. The U. S. District Court in Seattle ruled that the Whatcom County Jail was, indeed, in violation of the ADA. OUD is a protected disability under ADA.
What is a qualified disabled person according to the Americans with Disabilities Act, Title II?
According to Title II, Section 201 of ADA, a “qualified individual with a disability” is a person with a disability who, “with or without reasonable modifications to rules, policies, or practices, the removal of architectural, communication, or transportation barriers, or the provision of auxiliary aids and services, meets the essential eligibility requirements for the receipt of services or the participation in programs or activities provided by a public entity.” Explicitly, ADA addresses public transportation, vehicles, construction and access to facilities. However, there is the idea that the services provided by the public entity (state or local government, department, agency, district, instrumentality, or commuter service) are to be available for all qualified individuals and the disability itself is to have no bearing on their qualifications to receive the service offered.
The plaintiffs in the ACLU of Washington case were entitled to receive the same medical services that other inmates received in Whatcom County Jail because OUD was a medical condition that required medication. Previous trouble with the law or the fact that they were not pregnant did not absolve the jail from treating the inmates fairly by offering medications to treat a chronic, debilitating and deadly condition.
What is a qualified disabled person according to the Social Security Administration?
The federal government has a very strict definition of disability. A recipient of benefits must not be able to work; the condition must be severe, significantly hindering ability to do basic work activities such as lifting, standing, walking and remembering. Blindness, in severe, non-correctable cases is a condition that warrants SSA benefits under the strict federal definition of disability. In addition, the condition must be expected to last more than one year or result in death. There is a five-step process when determining whether or not a person meets the criteria of qualified disabled person that addresses the following:
What is a qualified disabled person according to the requirements of a 529 ABLE account?
On December 19, 2014, President Obama signed The Stephen Beck, Jr. Achieving a Better Life Act of 2014 into legislation to facilitate a way for blind and disabled individuals to save money in tax advantaged accounts for the purpose of ensuring a better quality of life. Qualified disabled persons are individuals with a physical or mental disability (not necessarily limited to sight or hearing) that functionally limits their ability to be employed or substantially limits one or more life activities (walking, speaking, breathing, learning, or working.) In order to be qualified, the individual must meet the requirements set forth by title II or XVI of the Social Security Act.
According to the ABLE National Resource Center in Washington DC, qualified expenses are “any expenses related to the designated beneficiary’s blindness or disability that assist him/her in increasing and/or maintaining their health, independence and/or quality of life. These may include expenses related to education, housing, transportation, employment training and support, assistive technology, personal support services, health care expenses, financial management and administrative services and other disability related expenses that the beneficiary might incur as a result of having a disability.” Some of the noteworthy characteristics of ABLE accounts are:
As calamitous as the graph above appears, in December 2017 the National Institute on Drug Abuse published an overview of the results of the Monitoring the Future survey, a large-scale federal survey described as a continuing study of American youth. Two of the several highlights of the survey were: 1) while adult opioid use rates remain relatively high, the data shows that teen misuse is less frequent than ten years prior; and 2) teens reported that narcotics other than heroine were not as easy to acquire as they used to be in the past (In 2017, 35.8% of 12th graders felt they were easy to obtain, versus 54% in 2010).[i] View commentary by Dr. Nora Volkow, Director of the National Institute of Drug Abuse here.
However, the graph displays number of opioid deaths, not number of people “living in hell” per se. Those that are still struggling through the addiction contend with the economic and social barriers to recovery on a daily basis. Consider the Bureau of Labor Statistics Job Outlook for substance abuse, behavioral disorder and mental health counselors.
Employment of substance abuse, behavioral disorder, and mental health counselors is projected to grow 23 percent from 2016 to 2026, much faster than the average for all occupations. Employment growth is expected as people continue to seek addiction and mental health counseling services.
Demand for substance abuse, behavioral disorder, and mental health counselors is also expected to increase as states seek treatment and counseling services for drug offenders rather than jail time. In recent years, the criminal justice system has recognized that drug and other substance abuse addicts are less likely to offend again if they get treatment for their addiction. As a result, sentences often require drug offenders to attend treatment and counseling programs. In addition, some research suggests that these programs are more cost-effective than incarceration and states may use them as a method to reduce recidivism rates. In addition, there will be a continued need for counselors to work with military veterans to provide them the appropriate mental health or substance abuse counseling care. [ii]
A premise of “Thief” is that the opioid epidemic is systemic. “Thief – Overcoming Economic and Social Barriers to Recovery” dealt with some of the social, political, legal and financial planning issues that planners and clients must contend with during human capital recovery. On the road to recovery, opioid use disorder patients receive financial, social and emotional support in the form of pooled funds for groceries, transportation, educational and vocational experience expenses, dual diagnosis medication payments, rent payments, behavioral health therapy, and several iterations of treatment. The SSA List of Impairments identifies conditions that are severe enough to prevent gainful activity or to cause severe functional limitations that are permanent or will result in death—a tall hurdle that currently applies to 529 ABLE accounts. Recovery from OUD is very possible with support systems that provide long-term proactive management of the recovery with appropriate medication and supportive social and professional networks willing to create an environment for change. There are no easy, standardized solutions, but society, as a collective, can provide the tools to help families and communities help themselves by: 1) providing the ability to pool assets from several people in a tax advantaged manner ; and 2) accountability for expenditures. The 529 ABLE could be expanded to be such a tool in the midst of the opioid epidemic by not only increasing the age qualification limit, but also including OUD sufferers with documented dual diagnosis treatment as qualified disabled persons.
The plaintiffs in the ACLU of Washington case against Whatcom County and the Sherriff’s Department were teenagers when they became addicted to opiates and suffered from OUD for at least ten years prior to the incarceration that prompted the lawsuit. BLS statistics indicate that the need for behavioral health professionals will increase dramatically between now and 2026. Behavioral health professionals and the criminal justice system are adjusting their approach to counseling, diagnosis and incarceration.
The 529 ABLE account is not meant to transfer and preserve wealth. Families on the economic margins engage in a form of financial planning by pooling extremely limited resources for the benefit of a beneficiary. Why not expand the reach of an account type that is meant to (according to Section 101 of the ABLE Act of 2014):
1) Encourage and assist individuals and families in saving private funds for the purpose of supporting individuals with disabilities to maintain health, independence, and quality of life; and
2) Provide secure funding for disability-related expenses on behalf of designated beneficiaries with disabilities that will supplement, but not supplant, benefits provided through private insurance, the Medicaid program under title XIX of the Social Security Act, the supplemental security income program under title XVI of such Act, the beneficiary’s employment, and other sources.
…for the most vulnerable, for the sake of OUD beneficiaries and contributors?
It is worth considering.
[i] Kaiser Family Foundation, Opioid Overdose Deaths By Age Group, State Health Facts Tool, https://www.kff.org/other/state-indicator/opioid-overdose-deaths-by-age-group (visited December 12, 2018)
[ii] Bureau of Labor Statistics, U.S. Department of Labor, Occupational Outlook Handbook, Substance Abuse, Behavioral Disorder, and Mental Health Counselors,
on the Internet at https://www.bls.gov/ooh/community-and-social-service/substance-abuse-behavioral-disorder-and-mental-health-counselors.htm (visited November 22, 2018)
Posted November 29, 2018
“My life was a raging dumpster fire!” – Anonymous, after two weeks at a residential drug rehabilitation treatment center.
So, how does the practitioner or client engage in financial planning while the client is driven to desperately and surreptitiously feed their addiction or fearfully concede to a dependence on opiates? When abused, opiates morph into a swarm of locusts feeding on human capital. For an addict, or those individuals supporting the recovery efforts of an addict, human capital recovery starts by the client:
1) recognizing and acknowledging the reality of the client’s situation;
2) educating himself on options available for recovery;
3) determining a personalized course for recovery with the help of trusted personal and professional support systems;
4) Investing in himself by implementing a plan for recovery; and
5) pro-actively taking care of himself on an ongoing basis by attending therapy, living a healthy lifestyle, and rebuilding the parts of his life that may have been neglected during the darkest hours of dependence or addiction.
While developing a five-step plan may seem intuitive to some, there are challenges that must be acknowledged directly. Some of the challenges have to do with access to and affordability of treatment facilities, as well as the pharmaceutical industry’s and prescribing medical practitioners’ continued use of oxycodone. It is also important for patients to advocate for themselves—for their very own best interests from a position of power; knowledge is power.
Recent news, developments and perspectives…
The Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act, also known as the SUPPORT for Patients and Communities Act was signed into law on October 24, 2018. https://www.youtube.com/watch?v=2geQ0d3WsMY#action=share. This legislation is holistic in nature. It specifically addresses and provides guidance on opioid crisis issues such as Medicaid and Medicare provisions, detection and monitoring systems for synthetic opioids, behavioral health, opioid safety education, promotion of research to respond to the threat of the crisis itself, illicit drug importation, safe disposal of unused medication, treatment for veterans, support for grandparents caring for grandchildren, prescribing guidelines, support for mothers and care for infants suffering from neonatal abstinence syndrome and much, much more. See the text of the SUPPORT for Patients and Communities Act at the following link: https://www.congress.gov/bill/115th-congress/house-bill/6/text. The above list of areas covered by this Act is a mere fraction of the sweeping legislation.
The Drug Enforcement Agency (DEA) appears to be on the mission and engaged in the battle against illicit opioid distribution and prescribing practices. On November 15, 2018, Serio Juana Devoe was sentenced to 10 years in prison and eight years of supervision for attempting to distribute fentanyl and methamphetamines. The Anchorage Police Department and the Drug Enforcement Agency (DEA) cooperated on the case which was prosecuted as a result of the United States Department of Justice Project Safe Neighborhoods (PSN) program. PSN is a federally funded initiative that promotes nation-wide multi-agency efforts to reduce gun violence., On October 31, 2018, the acting administrator of the DEA Diversion Control Division, denied the DEA Certificate of Registration for Edward A. Ridgill, MD, effective immediately. In August 2016, Dr. Ridgill was one of two doctors in Lynwood, CA that was arrested on federal drug charges for issuing prescriptions without a medical purpose. He issued more that 21,000 prescriptions for hydrocodone (Vicodin or Norco), codeine (for example, promethazine with codeine cough syrup, street name purple drank), alprazolam (Xanax), and carisoprodol (muscle relaxer). According to the investigation affidavits, there was evidence that the two doctors were large-scale suppliers for gang members. In December 2017, Dr. Ridgill was convicted of 26 counts of unlawful distribution of controlled substances.
The US Department of Health and Human Services maintains the National Practitioners Data Bank (NPDB). The NPDB was established by Congress in 1986 and serves as a web-based repository of reports and data that contain information on medical malpractice payments and adverse actions pertaining to health care professionals (practitioners, providers and suppliers). An analysis of the most recent data reveals that between 1990 and 2017, there were a total of 3848 DEA Adverse Action Reports and 635,125 state licensure adverse reports. Below is a chart of the most relevant categories for the purposes of this report.
Adverse Action Reports
State Licensure Adverse Action Reports
|Advanced Practice Nurses||
The below is a graphic representation of the number of reports issued each year for the specific practitioners listed in the table above. Clearly, the number of reports issued by the DEA and state licensing organizations on an annual basis significantly increased after 2008.
Number of DEA Adverse Action Reports; 1990 – 2017
Number of state licensure Adverse Action Reports; 1990-2017
In May 1986 the medical journal Pain published a research report by Drs. Russell K. Portenoy and Kathleen M. Foley entitled “Chronic Use of Opioid Analgesics in Non-malignant Pain: Report of 38 cases.” The doctors re-examined up to 7 years of data collected on 38 pain patients that were undergoing some form of opioid analgesic pain management for non-malignant conditions. After retroactively examining factors such as dosage, pain relief, toxicity, time in pain management therapy, and personality factors of 38 patients, Portenoy and Foley concluded “that opioid maintenance therapy can be a safe, salutary and more humane alternative to the options of surgery or no treatment in those patients with intractable non-malignant pain and no history of drug abuse.” This study was used as the touchstone for the mass marketing of opioids as a go-to narcotic for pain relief…moderate to severe. As early as 1998, researches at the University of British Columbia in Vancouver published research that directly contradicted Purdue and FDA claims that OxyContin was safe to prescribe, in that there was a low probability that patients would become dependent on or addicted to the narcotic in a “time release” formulation. Purdue Pharma was aware of the research study published in the Journal of the Canadian Medical Association. The study revealed that on the streets of Vancouver, abusers learned to peel away the time release coating and crush the pills; they were called “peelers”, and one 30 milligram pill had a street value of $40. The very same pill sold for $1 at the pharmacy. It is against this backdrop that some pharmaceutical companies, distributors and medical professionals claim that they have no responsibility for the current opioid contagion. Consider:
Did I teach about pain management, specifically about opioid therapy, in a way that reflects misinformation? Well, against the standards of 2012, I guess I did…We didn’t know then what we know now.
My patients are on very high doses, and I have patients who are executives in companies, hedge fund managers, hospital executives…I think that some of the literature that has emerged is not balanced…
What we are now dealing with in the United States is a movement of the pendulum back toward a level of concern and fear that is driving some policy decisions, that in my opinion, are very likely to harm the public health by reducing access to these essential drugs., 
View the video-taped interview here: A Pain-Drug Champion Has Second Thoughts
The financial and human capital costs for treatment
The cost to treat substance abuse disorders is substantially less than the cost associated with battling the societal ills the abuse produces. Criminal justice, Neonatal Abstinence Syndrome, increased growth- rates and incidences of infectious diseases, injuries sustained while intoxicated and lost productivity are a few of the areas that increase the costs associated with the opioid epidemic. According to an article published in the Medical Care section of the American Public Health Association Journal, in 2013 only 3.6% of the $78 billion dollars spent on opioid use disorders in the United States was spent on treatment. United States Department of Defense estimates for substance abuse treatment are as follows:
To place these expenditures in context, average annual expenditures for diabetes mellitus is $3560, and $5624 for kidney disease patients. However, even more context is needed.
Residential substance abuse treatment programs that offer counseling, group therapy, psychological evaluations, medication, education about the addiction (remember, knowledge is power), psychosocial or behavioral interventions, family programs, relapse preventions programs, and sober housing referrals can be cost prohibitive for many of the would-be patients. The cost for these programs can be $15,000 to $30,000 per year…or higher. In accordance with the Affordable Care Act, mental health and substance abuse services are considered essential health benefits. It is important to review individual plans to determine the specifics of individual coverage, however pre-existing conditions are covered and there can be no annual or lifetime dollar limits on essential health benefits. Some insurance companies will require patients to attend and fail an out-patient program before approving a holistic residential program. Therefore, even after the addict triumphs over the barriers of facing the reality that they are suffering from an opioid use disorder and facing the fear of giving up the pills and potentially suffering from chronic pain that has been dulled by the opioid use, there can be confusion about costs and which treatment options will be successful and affordable. Because the addiction is chronic, treatment and self-care in the form of individual and group therapy, medications (especially in the case of dual diagnosis treatment), healthy living, and measured, deliberate re-entry into the work place are critical and require structured processes. All of this adds up to ongoing costs that do not even address the financial burdens amassed by the nuclear and extended family in the forms of child support, divorces, lost capital assets and destroyed careers. The primary concern is to get better physically, emotionally, and psychologically…which means that finding work is not a primary concern, even in the face of the mounting financial burdens. For a period of time, the recovering addict will need to acknowledge and deliberately, where practical, tackle the realities of the dumpster fire that consumed jobs, family relationships, friendships, health and assets. Everyone touched by the addiction is in recovery.
Creating Peace Of Mind Waypoints and course corrections…
Consider integrating the following life planning waypoints into your overall financial planning process to help mitigate the risks associated with opioid dependency or addiction.
As the recovery plan takes shape, consider integrating “recovery capital” in the following ways, which are listed in Dr. Bisaga’s book, which include, but are not limited to:
Participate in treatment and continuing care
Take advantage of therapy even if you have been doing well for a long time
Actively engage with a mutual self-help community
Encourage your partner and family to support your recovery
Support others in their recovery
Choose to live in an environment that is free of drugs
Finish education; find a stable and fulfilling job
Clear all past legal problems…and much more.
Preemptive and proactive life and financial planning are tools that can be used to help overcome social and economic barriers to recovery. There are no guarantees but being prepared is a plus. The process for recovery is unique for each person, however it includes having an awareness of current developments and perspectives, quantifying the cost of medical treatment, and planning for successful redemption of human capital with the help of planning professionals and trusted personal advocates. The SUPPORT for Patients and Communities Act is comprehensive, law enforcement and licensing agencies are engaged, communities are developing educational programs and partnerships to save lives, and estate planning tools are available to assist in the planning process. A systemic problem requires comprehensive, innovative solutions. Not all are listed here. Everyone touched by the contagion is in recovery–all hands on deck to encourage and support our loved ones as they douse the “dumpster fires.”
 Herraiz, Domingo S. “Project Safe Neighborhoods: America’s Network Against Gun Violence.” U.S. Department of Justice Office of Justice Programs Bureau of Justice Assistance, https://www.ncjrs.gov/pdffiles1/bja/205263.pdf, accessed on 11/24/2018.
 Underwood, Jodie. “Anchorage Man Sentenced for Fentanyl Trafficking” U.S Drug Enforcement Agency, https://www.dea.gov/press-releases/2018/11/15/anchorage-man-sentenced-fentanyl-trafficking , accessed on November 12, 2018
 US Department of Justice, Diversion Control Division, DEA Decision Order, https://www.deadiversion.usdoj.gov/fed_regs/actions/2018/fr1120_3.htm [Federal Register Volume 83, Number 224, Tuesday, November 20, 2018.
 Department of Justice, US Attorney’s Office Central District Of California, “Two Doctors Face Federal Charges of Illegally Writing Prescriptions for Addictive Narcotics Connected to Gang’s Drug Trafficking.” https://www.justice.gov/usao-cdca/pr/two-doctors-face-federal-charges-illegally-writing-prescriptions-addictive-narcotics. Augutst 29, 2016, accessed on 11/24/2018.
 Sajan MD, Amin, Trevor Corneil, MD and Stefan Grzybowski, MD, MClS. “The Street Value of Prescription Drugs,” from the Department of Family Practice, University of British Columbia, Vancouver, BC , CMAJ 1998, volume 159, pgs. 139-42 . www.cmaj.ca/content/cmaj/159/2/139.full.pdf, accessed on 11/24/2018.
 Catan, Thomas and Evan Perez. “A Pain-Drug Champion has Second Thoughts.” Wall Street Journal, Dec 15 2012, Eastern edition ed. ProQuest. 11/25/2018, accessed on 11/24/2018.
 Catan, Thomas and Evan Perez
 “FDA Approved new Opioid Drug Called Dsuvia.” https://abcnews.go.com/GMA/Wellness/video/fda-approved-opioid-drug-called-dsuvia-58940799, 11/3/2014, accessed on 11/13/2014.
 Florence CS, Zhou C, Luo F, Xu L. “The Economic Burden of Prescription Opioid Overdose, Abuse, and Dependence in the United States.” Med Care. 2016;54(10):901-906. doi:10.1097/MLR.0000000000000625. Accessed 11/13/2018.
 “Medications to Treat Opioid Use Disorder.” National Institute on Drug Abuse, https://www.drugabuse.gov/publications/research-reports/medications-to-treat-opioid-addiction/how-much-does-opioid-treatment-cost, accessed 11/24/2018.
 Adam Bisaga, MD, Overcoming Opioid Addiction, (New York: The Experiment, LLC, 2018) 177.
 “Mental Health and Substance Abuse Coverage.” Healthcare.gov, https://www.healthcare.gov/coverage/mental-health-substance-abuse-coverage/, accessed on 11/27/2018.
 “Surgeon General Urges More Americans to Carry Opioid Antidote.” Soundbite of Sleep Dealers “The Way Home,” NPR Morning Edition, hosted by Rachel Martin, 4/5/2018. https://www.npr.org/templates/transcript/transcript.php?storyId=599538089, accessed on 11/24/2018.
 “Disposal of Unused Medicines: What You Should Know.” U. S. Food and Drug Administration. https://www.fda.gov/Drugs/ResourcesForYou/Consumers/BuyingUsingMedicineSafely/EnsuringSafeUseofMedicine/SafeDisposalofMedicines/ucm186187.htm, accessed on 11/25/2018.
“Prescription Drug Take Back Day.” US Drug Enforcement Agency Diversion Division, https://www.deadiversion.usdoj.gov/drug_disposal/takeback/index.html, accessed on 11/27/2018.
 Bisaga 208.