Dear Ms. Yeatts:

I am writing to you in my capacity as Sr Director of Regulatory Affairs for CVS Health and its family of pharmacies.  CVS Health, the largest pharmacy health care provider in the United States, is uniquely positioned to provide diverse access points of care to patients in the state of Virginia through our integrated offerings across the spectrum of pharmacy care.   CVS Health appreciates the opportunity to submit comments on the Virginia Board of Pharmacy proposed amendment to 18VAC110-20-275 Delivery of Dispensed Prescriptions.  We would also like to thank the Board for their vigilance to continuously improve the laws and regulations that guide pharmacists, pharmacy interns and pharmacy technicians serving Virginia patients. 

CVS Health appreciates the Board’s acceptance of our Petition for Rule-making and proposed language to amend 18VAC 110-20-275, which changes the policy and procedure requirements for delivery to another pharmacy,  allowing for a unique identifier to be used in identifying all pharmacies utilized in filling and dispensing the prescription.   Amendments also include the allowance for the unique identifier to not be placed on the label if the pharmacy solely holds the prescription for further pickup and delivery without being involved in the filling and dispensing.  As we have mentioned previously, the Institute for Safe Medication Practices  published industry guidelines for medication labels for community and mail order pharmacies in which they suggest maximizing the use of white space on a label to improve medication adherence and reduce inadvertent medication errors.¹  The proposed language would assist in achieving maximum white space, while still providing an audit trail for the tracking of the prescription, as required, and providing the patient with one contact pharmacy (the dispensing pharmacy) to answer any questions or provide additional counseling. 

CVS Health appreciates the opportunity to submit comments for this proposed rule amendment.  If you have any questions, please contact me directly.

Sincerely,

Lauren Paul, PharmD, MS

Sr Director, Pharmacy Regulatory Affairs

CVS Health

References:

1. Principles of Designing a Medication Label for Community Pharmacy and Mail Order Pharmacy Prescription Packages. Available from: https://www.ismp.org/recommendations/designing-medication-label-community-pharmacy (Accessed March 23, 2020).