I would like to give my full support on the delivery of schedule VI drugs to be placed in automated dispensing devices.  As a recipient of this process through the pilot program, I see the benefit that it provides to facilities for several reasons.  As we are all experiencing unprecedented staffing shortages, having a standardized, reliable process for refilling of our ADDs that decreases the amount of time that is taken away from our facility staff is invaluable.  Also, the environment that the medications are being refilled in to be delivered to the facilities is focused on this process which provides for a more focused and uninterrupted workflow which decreases errors in refilling.  Lastly, the ability of the supplier (warehouse) to supply JIT and decrease the amount of medication that the facility needs to purchase and stock, and potential waste and expire, is fiscally responsible.  The thought and structure that has been put into this pilot should be allowed to be considered standard practice if not best practice.

Hello

This is a consistent and legal process and should be permitted per the regs.  It allows for accuracy and duties of the hospital site to be higher level for patients.  I strongly support the ability to deliver Schedule VI drugs to a facility to fill Pyxis.

Thank you Celene Crowley

I fully support the Delivery of Schedule VI drugs to automated dispensing devices amendments to section 460 and 490 of the current code.   The pharmacists checking the drugs prior to delivery are thorough and safe.  Benefits of this practice include but are not limited to:

• Pick process is segregated from the facility decreasing errors by improving workflow with dedicated staff and few interruptions
• The pharmacists checking the ADD orders have fewer distractions decreasing ADD filling errors
• The hospital pharmacists are able to direct their attention to direct patient care issues improving patient outcomes

This system of off-site pick and check has successfully helped and supported systems of all sizes.  As such, the pilot has proved the concepts’ worth and should be adopted by the state.

I would like to give my full support of the Delivery of Scheduled VI drugs to automated dispensing devices.   I see the benefit of the pilot program as we get our medications from this service.   It helps us with staffing so that we don't need to help pull these medications, if gives time back to our Pharmacists who are busy doing other things.

The program I feel has been successful in getting correct medications to our facilities for our staff to deliver.

I would like to give my support to the Delivery of Schedule VI drugs to be placed in automated dispensing devices. Our pharmacy has benefited from this pilot program in several ways. It gives us back time when the techs do not have to pull meds everyday for the fills.  As we are becoming more busy this is a huge time saver. It frees up our Pharmacists for patient care when they do not have to spend time checking medications that have been pulled.

This pilot program has worked well. Our shipments are on time and have always been correct. This program is a huge benefit for our pharmacy.

This is long overdue.  

This will help hospitals be more efficient and improve work flow.

I fully support the Delivery of Schedule VI drugs to be placed in automated dispensing devices.  Since being a part of the pilot program, I see the BIG benefits that it provides. 

• Time - this is invaluable. It frees up pharmacist and pharmacy techs at the facility to focus on patient care
• Decreased errors- At a facility, there is more room for human error due to continuous activity when trying to pick and check for refills. At the warehouse, it is focused and they have a process in place JUST for picking and checking drugs to provide minimal error. They have one focus. At a hospital when picking and checking, there are MANY distractions.

The program has been very successful and it shows great teamwork and innovation to keep our patients safe and have the best care possible!

HealthTrust and HCA's model to fill ADDs from a central location is a LEAN, just in time model.  This model limits the number of touchpoints involved, reducing introductions for error.

Similar models have been previously utilized in VA through Cardinal Health.  Cardinal's, CardinalAssist, a similar program where medications are received by the facility ready for a direct refill.

HealthTrust/ HCA's hub and spoke model is more efficient than the traditional workflows and allows Pharmacists on-site to work shoulder to shoulder with peers.  HCA has been forward-thinking with this initiative and others.  Moving Pharmacists one step closer to provider status.

I am writing to voice my strong and continued support of the CSC distribution and delivery for ADD machines. This process has multiple benefits including but not limited to: weathering of drug shortages due to size of scope, fiscal responsibility due to minimization of expired products or wasted products, time to facility technicians to focus on medication delivery and other patient centric activities, time for facility pharmacist to focus on clinical activities and patient centric activities, reduced errors with picking medications due to interruptions in the pharmacy. This program is highly supporting the facilities and should be expanded to other healthcare systems. Please vote in support of this pilot.

I fully support the Delivery of Schedule VI drugs to automated dispensing devices amendments to Section 460 and 490 of the current code.

• Helps each facility to decrease amount of time needed for safe patient care
• It definitely helps with purchasing more than needed items for each facility which can create more expired product and waste
• Helps out short staff hospital pharmacies to have our supplier (warehouse) fill our automated devices in advanced and checked by a pharmacist which gives quicker patient care service at each facility

I feel that the offsite pick and delivery has been very successful therefore should be recognized by the state

I would like to publicly voice my support of centralized distribution of Schedule VI medications for facility ADCs.  Consolidation of distributive pharmacy services into a hub and spoke model has benefited my current hospital significantly.  We have been able to take advantage of break bulk packaging, resulting in significant decreases in on-hand inventories.  Centralized fill of ADCs has freed additional pharmacist and technician time at the facility, thus allowing more time to focus on quality patient care.  The model has also allowed us to leverage technology, such as bar coding, to improve patient safety.  I encourage the Board to give a great deal of consideration to adding this process to the current regulations.

I would like to voice my support in the amendment to permit the delivery of Schedule VI medications pulled from a central location. This process has many benefits that includes but not limited to:

1. Provides an environment with minimal distractions for medications to be picked/checked for fill in an ADD. This helps with patient safety within hospitals.
2. Permits medication purchases to be streamlined to a location which can then distribute them as needed in a just in time manner which reduces overall pharmacy overhead and reduces waste/expired medications.
3. Getting through critical or long term shortages can be centrally managed by one group opposed to multiple (at each facility). This helps minimize hoarding at each facility which in turn helps contribute to improve all's ability to get through shortage situations and have necessary drugs for patient care.
4. Improves pharmacy workflow as it eliminates hours from Pharmacy Technician's day, that is historically spent picking medications, as well as from Pharmacist's day that is historically spent checking these medications for refill. This allows that time to be spent focused on more clinical, medication delivery and nursing support tasks. 

I would like to give my full support of the Delivery of Scheduled VI drugs to automated dispensing machines.  I see the benefit of the pilot program as we get our medications from this service.  It helps us with staffing so that we do not need help pulling majority of the medications for these machines.  It allows our Pharmacist time back so that they do not have to take time to check the fills that come from Delivery allowing them more time to work on getting other medications and IV's to the patients.

The program has been very successful in getting correct medications in a timely manner to our facilities for our staff to deliver to the devices.

This is to support the practice of pharmacist check of automated dispensing dispense fills at the centralized services center where the fill is done (as opposed to by pharmacist at the receiving hospital).  It's logical to do the check where the fill is done,  keeping oversight and responsibility directly connected to the work done.   The receiving hospitals are attesting to the success of the pilot and their great desire to make it permanent.  The Board setting the required safety standards while giving the impacted health system flexibility to best determine where the  work is done, also makes sense.

Gill B. Abernathy,  MS, RPh.

Reston Hospital Center has greatly benefitted from this practice.  Out pharmacists have been able to focus on clinical interventions and patient care rather than spending time checking medications to be loaded or refilled to the ADMs.  Whether done in house or from a central location, picks are checked by authorized team members.  For a hospital of our size, it also saves technician time to allow faster delivery of first doses as the technicians are not burdened by the routine refilling of the "fast mover" medications.  I strongly support this practice. 

I am in full support of the process of Pharmacist verification of non-narcotic (schedule VI) medications prior to dispensing from a central warehouse location, versus requiring a pharmacist to verify upon arrival on site, given that the verifying pharmacist is the terminal person to verify the medication(s) prior to application of tamper-proof seals and where final destination being placed in ADDs (i.e. Pyxis, AcuDose, Omnicel) via scanning/bar-code technology us being utilized by registered pharmacy technicians.

I strongly support this practice because it allows the on site Pharmacists to focus on patient care and clinical interventions instead of checking meds.  Whether the checking is done on site or from central location, the medications are being checked by licensed Pharmacists.

It is very time efficient to have the orders already checked and delivered instead of having to get the staff pharmacist to check everything 

I support the centralized distribution of Schedule VI medications for facility ADCs. As a practicing pharmacist in Virginia, I see many benefits to this delivery model.  It advances the practice of pharmacy and streamlines distribution.  I fully support this addition to VA Regs.

I fully support the petition for Delivery of Schedule VI drugs to be placed in automated dispensing devices. It saves Pharmacists and Pharmacy Technicians valuable time and resources that are needed to provide the best patient care we can.

I work in a setting that utilizes this process.  It is efficient from an economic standpoint as well as a work-flow standpoint.  It frees up valuable time for the pharmacists and technicians to concentrate their efforts on patient care, as well as decreasing distractions.   

I support the delivery of schedule VI drugs to be placed in the automated dispensing devices. This saves valuable time and resources for our facility.

I support the centralized distribution of Schedule VI medications for refill of facility ADCs.  This expansion streamlines distribution to allow facility pharmacist efforts to be redirected to providing lifesaving medications and other important patient care activities.  ADC's have barcode scanning and thus once checked by a pharmacist at distribution, I believe it is appropriate to be sent directly to the ACD, a second pharmacist is a redundancy.  We should take every opportunity to stream line medication delivery.  I support 18 VAC 110-20, Delivery of Schedule VI medications to be placed in ACD.

I give my full support of centralized distribution of Schedule VI medications to be placed in ACDs, 18 VAC 110-20.  This affords our pharmacists and technicians at the facilities time to provide the very best patient care.  This process overall makes for a safer process for medication filling, checking and drug shortage management as well.

As one of the pharmacists that will be performing this new task, I believe this will afford us the ability to decrease the time that a medication is out of stock.  This will allow a cost savings to the hospitals, whereas they will be able to receive items from the warehouse instead of from a third party.

We support the centralized distribution model that permits delivery of medications by pharmacy technicians at the receiving hospital. Checks and balances regarding medication safety are still maintained within the medication use system by leveraging the additional technology such as bar coding within the ADCs by pharmacy team members and nursing to ensure patient safety. 

I support the centralized distribution of schedule VI medications for refill of facility Automatic Dispensing devices. This process streamlines distribution to allow facility pharmacists to be available for checking and evaluating new orders with the precious time needed to ensure the orders are correct. The centralized orders are checked at a central location by a pharmacist and are transported to facilities clearly labeled for each individual machine. The only additional step is that the meds are then transported to the various hospitals for final delivery into the machines. This is really no different than having meds checked on site and then taken to machines. In a really big institution, the time it takes for these checked meds to get to the ADD may be just as long as the short car ride they take from a central warehouse. The barcode scanning ensures safety all the way through the process. Thank you for your consideration of this request

I support this petition to have centralized delivery of schedule VI medications to an automatic dispensing device at a facility.  This process saves valuable time at a facility by freeing up technicians and pharmacists to concentrate on maximizing patient care. 

I would like to voice my support of the centralized distribution of Schedule VI medications for facility automated dispensing machines. This process has benefited my current facility in many ways. The biggest benefit it has provided is to increase patient care at the facility. The process provides additional time for both the pharmacists and pharmacy technicians to provide direct patient care instead of spending that time to pull and verify medications. I personally feel like it decreases errors associated with pulling medications at the facility. The sole job of the people at the distribution warehouse is to pull the medications whereas we at the facility level can be distracted by phone calls and other distractions. This program is a huge benefit to our pharmacy, our hospital and our patients and I believe other healthcare organizations should have the opportunity to see the benefit it provides.

I support the petitioner's request to amend regulations concerning delivery of schedule VI drugs to be placed in hospital ADDs having been verified by a pharmacist at a central distribution company. A centralized pharmacist verifying orders can operate in a more streamlined environment with less distractions as compared to an on-site pharmacist. A centralized pharmacist also scans and links product barcodes to appropriate entries within hospital information systems. This results in less errors, improved patient safety, and allows more time for on-site staff to focus on clinical and interdisciplinary tasks. Centrally managed inventory assists sites with shortage and out of stock issues, as well as a reduction in wasted and expired meds, helping with cost savings and reducing potential delays in therapy for patients.

I fully support this effort, it will help to streamline the workload, reduce duplicated orders and so make the entire pharmacy run more efficiently.

I fully support petition 344 of a centralized pharmacy distribution center of schedule VI medications. A centralized system is more efficient, productive, safe and cost effective.

I write to offer comment in support of petition 344 regarding central distribution and pharmacist verification of schedule VI drugs being delivered directly to receiving hospital automated dispensing devices. Hospitals are continually forced to find more efficient, yet clinically sound, methods for providing care to patients.  It is an ongoing battle to optimize great patient care with reliable operations, both competing for time, manpower and other resources.  Distributing medications using a just-in-time model of distribution has allowed facilities to dramatically improve their economic performance by reducing inventory stored on the shelf at any given time, increase inventory turnover to keep fresh stock, and virtually eliminate waste through expiry.  Additionally, centralization has allowed for focused checking of the drug supply by dedicated distribution pharmacists, thereby allowing facility pharmacists to focus on the bedside patient care and support of the multidisciplinary care team.  This is the way of the future, supporting pharmacists to work a the top of their license and allowing the dedicated distributive staff to focus on their main objective to deliver cost efficient and accurate drug supply.

I fully support this petition concerning the delivery of schedule VI medications to an automated dispensing machine.  This would free up significant time to allow for additional focus on patient care within the facility while still maintaining patient safety as a top priority.   

This process is very effective in improving efficiency and allowing more pharmacist time dedicated towards direct patient care.

I support the petition of delivery of Schedule VI drugs to be placed in automated dispensing devices.  Significant safety advantages are in place today along with an initial pharmacist check at the central distribution site that make an additional check unnecessary.  The elimination of a redundant second check will allow the Pharmacist time to be re-focused on direct patient care activities that provide positive patient outcomes.

As someone who has worked both in the pharmacies receiving this service and in the facility providing it, I would like to offer my support of this pilot program.  The hospital pharmacy staff gains much needed time from this service that can be directed towards patient care. The facility providing this service has the advantage of minimal interruptions when pulling drugs for the ADD's.

I would like to take a moment to voice my support of the centralized distribution of Schedule VI medications for facility automated dispensing machines (ADC).  This program has benefited the facility by removing the task of pulling and verifying medications locally and sourcing it to individuals that can solely focus on this task.  What this means for the patients is locally more time and attention to pharmaceutical patient care.  In addition to having more time for patient care,  I believe the final delivery using this process to be more accurate as the individuals pulling and verifying can focus on a single task vs. the distractions that working in a facility presents. 

We support delivery of Schedule VI drugs to automated dispensing devices from Central Distribution areas.  In our practice, a medication from the Central Distribution department is barcode scanned six times before it reaches a patient.  These six scans include: medication barcode validation in EPIC, scan into drug storage carousel by technician, out of carousel by technician, medication accuracy scan by pharmacist, scan by hospital technician loading to automated cabinet and scan at bedside by nurse.  We are also researching the possibility of a future tech-check-tech model for this area due to significant amount of barcode scans.  Advances in technology and the extensive barcode scanning protocols in place help to significantly reduce errors and allow for increased efficiencies across our system.