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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6/5/20  4:33 pm
Commenter: Kelly H Kale

Amendment of 18 VAC 110-20-275

Dear Board Members,

I am writing to you today in opposition to the proposed change to 18 VAC 110-20-275. This proposed change adds a layer of confusion to patients and ultimately could lead to delays in treatment and harm to patients. When a patient delivers and picks up a prescription medication from a pharmacy, they connect with that pharmacist. If that pharmacy is doing what it should be by law, that patient is seeing and talking to the providers of their care. When they get home and have a question, or are confused, or have a side effect from treatment and need to speak to their pharmacist they expect to talk to the person that was involved in their care at the pharmacy where they picked up their medication. The pharmacist that has been involved with and knows of all of their health issues. 

With this proposed change you will effectively be taking that pharmacist out of the equation. The patient will no longer have the contact information readily available to them to speak to the pharmacist that just counseled them at the drug counter. And what happens when the information given at the drug counter at time of pick-up is different than the information given at some call in line in another state. Most patients I know will stop therapy until they can reach their Doctor, and what if that is over a weekend or holiday?

The patient deserves our best care. That best care is to provide them all of the information necessary to take their medication properly and to be able to contact THEIR pharmacist when there is a problem. If a pharmacy opts to conduct their business model in such a way as to move filling operations off site then they also bear the responsibility of insuring that the patient has access to ALL pertinent information related to the filling of that prescription and how to contact THEIR pharmacist. Where it was filled (address and phone number) and who filled it, as well as the information as to where the patient actually did business (address and phone number), was consulted by their pharmacist and where they can contact someone when help is needed all need to be provided to the patient.

I hope you will consider this a critical public health concern and do the right thing for our patients.


Thank you,

Kelly Kale


CommentID: 80185