Please accept these comments to the NOIRA stage for the periodic review of pharmacy regulations on behalf of the Virginia Health Care Association-Virginia Center for Assisted Living (VHCA-VCAL), our members’ 30,000 employees, and the 29,000 residents served in our over 280 nursing centers and assisted living facilities. VHCA-VCAL is proud of our role as the Commonwealth’s largest association representing long term care. Our strength, effectiveness, and integrity are significantly enhanced by the diversity of our membership, which includes proprietary, non-profit, and government-operated facilities dedicated to providing the highest quality of care.

As this is only a NOIRA, it is difficult to interpret precisely what the Board intends to change.  However, VHCA-VCAL wants to express our general concern that any changes made to 18VAC110-20-240 do not diminish the fact that chart orders remain a valid prescribing method and that regulatory changes do not obstruct the availability/timeliness of medications nor staff resources for direct clinical care of nursing facility residents and patients.  As you are aware, regulations already require periodic order review for nursing facility residents which reconfirm any continued need for medication(s).

Thank you for the opportunity to comment.  Please direct any questions to Steve Ford, SVP, Policy and Reimbursement, at steve.ford@vhca.org  or (804) 212-1695.