Agencies | Governor
Virginia Regulatory Town Hall
Department of Health Professions
Board of Pharmacy
Regulations Governing the Practice of Pharmacy [18 VAC 110 ‑ 20]
Action Delivery of dispensed prescriptions; labeling
Stage Proposed
Comment Period Ends 6/16/2020
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6/1/20  5:06 pm
Commenter: Jennifer Helmke, Bremo Pharmacy

Focus on the SIG not the phone number


I am writing in against this change.  By removing the identifying phone number of the pharmacy, it will hurt patient safety and reduce the ability to properly conduct a medication reconciliation. The amount of space a 10 digit pharmacy phone number takes up is extremely minor and would not lead to extra space for the most important part of the label, the directions.

At our pharmacy , our phone number is built into our logo and our label designs are completely customizable.  Font sizes can be increased or shrunk and we always have extra room.  Our directions will also fill the allowable space to maximize the dedicated directions space.   

As a pharmacist at an independent with 2 locations, we get calls for each other’s locations all the time.  It delays response from doctors and delays delivery to patients when the caller does not have the correct contact number.  If we remove the pharmacy identifier, all chains become the same. It would begin a guessing game of who to call or where to send the prescription to.  

If most patients are unaware of how to take their medications, how do we expect them to know the phone number of the pharmacy in which it was filled? With prescription transfers, the phone number IS the paper trail to transfer the prescription.  

With poly-pharmacy becoming such a problem, between mail order and prescription shopping, imagine the struggle to conduct a medication reconciliation for a patient entering or leaving the hospital.  If the tech had the bottle with the pharmacy phone number, they may reach out to get the last fill date or other clarification.  Without it, they will not have the time to call all of the pharmacies of that chain in the area to get the information, leading to gaps in the record causing potential medication related complications resulting higher medical expense. 

The focus of any change should be having a consistent sentence equation for the SIG, patient instructions.  This has been studied over and over and found that even though a patient can read the directions, it differs from how they interpret them and take the medication.  By changing the direction verbiage to a standard that has been studied and would be required to use for prescription directions, increasing consistency and clarity, this would reduce patient harm and errors.  

I require all of my directions to be in the following order: Verb, # ( number not in words), dosage form, route, frequency, with indication if known.  ( TAKE 1 TABLET BY MOUTH EVERY DAY FOR BLOOD PRESSURE).  

I have transferred prescriptions from other pharmacies in which the sig was so poorly written, that I had to call the prescriber to understand how the patient was to take the medication or call the pharmacy back to request the original hard copy for clarity.  (Ex: B12 injection - take 1ml every 90 days) This was an injection in which the prescription should have been inject 1 ml intramuscularly every 30 days.  Without requiring a route, the patient may have taken this orally and been off track by 60 days.   This to me would be more important. However, if there was not a phone number on the patients label for me to call to get the correct information, how would I be able to track down the chain pharmacy in which this prescription was poorly dispensed? 

I challenge you to take a look at your own prescription label and see if the phone number should be the focus of change. 

Jenni Helmke, PharmD

CommentID: 80179