Commenter: The Medical Society of Virginia

Opposition to the Proposed Change to Delivery of Dispense Prescriptions Labeling

The Medical Society of Virginia (MSV) serves as the voice for more than 10,000 physicians, residents, medical students, physician assistants, and physician assistant students, representing all medical specialties in all regions of the Commonwealth. On behalf of these clinicians, I am writing you in opposition to the proposed amendments to section 275 of Chapter 20 pertaining to the procedure for identifying all pharmacies involved in the filling and dispensing of a prescription.

MSV recently became aware of the proposed changes which would no longer require a unique identifier for a pharmacy to be listed on the prescription label when a pharmacy was not involved in filing or dispensing functions. Such changes to the regulations would result in many patients with prescriptions no longer having quick access to the contact information of their local pharmacist. To ensure patient safety, it is essential that patients are provided with the contact information of their local pharmacist who can help address the concerns or questions they may have regarding their prescriptions. Many patients have become accustomed to having this resource posted on their prescription label and to remove this critical information for patients is simply improper patient care and not the standard for which should be accepted. 

In addition to the detrimental effects to a patient’s health, this change would further jeopardize independent pharmacies who have already been suffering, with many closing in our highest need communities. The proposal would essentially promote removing neighborhood and independent pharmacies from the pharmaceutical process by allowing national organizations to use their centralized pharmacies to fill prescriptions and their corporate network pharmacies to deliver prescription. Cutting out independent and community pharmacies that often reside in low-income and rural areas will do nothing to increase access or support affordability for patients. Rather, such proposal would put the profits of vertically integrated insurers, pharmacy benefit managers, and pharmacy corporations over patients.

Furthermore, MSV has concerns that such proposed changes could make it more difficult for physicians to identify a patient’s local pharmacist and thus coordinate care. During visits, patients often may bring in a prescription which would typically include the number and/or address of a local pharmacist. This information, while essential for patients, is also helpful for physicians so that they can easily identify the pharmacist with whom to communicate to in the need of determining what other medications a patient may be taking and/or to discuss special needs of that patient. It also raises concerns around patient safety, if the physician is unable to verify the safety of drug supply chain, particularly for those patients that require infusions of specialty medications.

In summary, MSV feels the proposed changes, while may seem harmless, could result in numerous negative effects to patients, independent pharmacies, and the health care system at large.

We thank you for the opportunity to provide feedback on the proposed regulation change. If you have any questions, please do not hesitate to reach out to Clark Barrineau at cbarrineau@msv.org or 704.609.4948.