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  6:19 pm
Commenter: Otto Wachsmann, Community Pharmacist

Opposition to amendment

I am opposed to amending the labelling requirements for prescription labels to delete the identification of the pharmacies involved with filling patient prescriptions.

When patients come into a pharmacy, they should be given information which properly identifies the pharmacies involved with processing their prescription.  This critical information needs to be fully transparent.

Health care providers also need to have ready access to this information.  Many caregivers and emergency services personel are trained to bring patient's prescription bottles to the point of care.  Not having the complete information on the label can create a delay when that patient's healthcare provider calls the information on the label only to discover that pharmacy does not have the complete information.  In this instance that provider may have to hang up and dial another pharmacy.  Once that occurs with several encounters, that provider is less likely to call to verify what can be critical information in treating that patient.

We already have violations on these labelling requirements which seem to go unchecked particularity with certain mail order pharmacies.  Since Humana began sending Medicare Part D prescriptions into our state they have a pharmacy address and phone number on their label which is not the pharmacy number.  Instead they provide the contact number to their customer services line.  When we call for prescription transfers we have to first, call the number on the label and provide all of our information as well at the information to the customer services representative who then will transfer our phone call to the actual pharmacy.  Once the call finally gets to the pharmacy, we have to reverify the information once again only the be transferred to the pharmacist to verify a third time and finally provide the transfer.  This process can easily take 15 - 20 minutes.  Doing that several times a day is quite time consuming and frustrating for a pharmacist who has to multi-task to remain anywhere close to profitable.  Unfortunately this frustration can then lead to patient safety issues as the now stressed pharmacist becomes tainted by the frustration of getting the transfer and is less focused on the task at hand.

Pharmacy regulations are there for a reason.  That reason is patient safety.  Not having the complete information about the pharmacies associated with filling each prescription is not transparent to the patient and can delay patient care activities with the provider.  CVS is asking for a resolution to a problem that they have created.  They need to figure out how to comply with the existing patient safety related regulations.

I wish to thank the Board of Pharmacy for allowing us to comment on these important matters.

CommentID: 80187