Virginia Regulatory Town Hall
Department of Health Professions
Board of Pharmacy
Regulations Governing the Licensure of Pharmacists and Registration of Pharmacy Technicians [18 VAC 110 ‑ 21]
Action Periodic review result of Chapters 20 and 50; Promulgation of Chapters 15 and 21
Comment Period Ended on 8/10/2016
Next Comment     Back to List of Comments
8/9/16  4:12 pm
Commenter: Dale StClair, PharmD (Remedi SeniorCare)

NOIRA 18VAC110-20-240

This comment is being made in regards to the Notice of Intended Regulatory Action posted regarding changes to VAC 18VAC110-20-10 et seq. Specifically as outlined, the proposed update to 18VAC110-20-240 “Clarifying in subsection C that chart orders used in long term care facilities must include a quantity or duration of treatment.” Currently Virginia regulations do not specifically require a quantity on any prescription regardless of it being considered a “Chart Order”. The Board has already addressed this issue in Guidance Document 110-35 “While Virginia law does not specifically require that quantity be included on a prescription, written prescriptions must include some direction related to quantity to be dispensed, or authorized duration of the order by which the pharmacist can calculate the authorized quantity using directions for use and duration.  Federal regulations require that quantity be indicated on prescriptions for Schedule II-V controlled substances.” Therefore, Remedi SeniorCare does not feel the proposed changes referenced above are necessary. 

CommentID: 50761