Agencies | Governor
Virginia Regulatory Town Hall
Agency
Department of Health Professions
Board
Board of Pharmacy
chapter
Regulations Governing the Practice of Pharmacy [18 VAC 110 ‑ 20]
Action Delivery of dispensed prescriptions; labeling
Stage Proposed
Comment Period Ends 6/16/2020
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6/1/20  12:12 pm
Commenter: Steven Hylton, Clark's Pharmacy

Labeling requires
 

First of all why we do need any changes in our labeling practices?  It seems very logical to have the name and address of the pharmacy providing the medications to be clearly labeled on the medication label for questions from the patients or ease of finding information by law enforcement or caregivers.  

The only reason I could see for not including this information would be to deceive the patient from the knowledge of who filled their prescription.  

Why would large corporations start filling prescriptions in other states to ship to their local stores?   They could be ashamed that they don't want their local pharmacist to fill the prescription.  More likely they are trying to usurp the Virginia Board of Pharmacy to in order to not fill these prescriptions according to the standards set by our BOP.  Another reason could be tax implications.   Hiring workers and building closed doors pharmacies in other states, would not only prevent the Commonwealth from collecting taxes on these facilities and employees, but be a windfall in profit of these corporations over smaller independent pharmacies who don't have the option of filling prescriptions in a different state.  

When independent pharmacies close (and they are closing) it hits the poorest areas of our state the worst.  Making policies that only help certain large corporations make more money, without any benefit for our patients seems like a waste of paper and ink for this Board.  

Would this regulation make our patients any safer?  (these medications would be filled under the guidance of other states, do they know Virginians better than our BOP?)

Would this regulation bring in more revenue for the state to help more patients? (Tax dollars would go to other localities and wouldn't be here to help Virginians)

Would this regulation give some corporations advantages over other corportations? Only large companies (probably owned by PBMs) would benifit, making it harder for small business to keep up

Would this regulations make medications more accessible for our patients?  There is no proof that this would make medications more accessible

 

Therefore please do not move forward with this regulation and spend more of your efforts on the current drug shortages and ways to make replacement medication easier to get paid for from these PBMs that won't less us substitute medications like generic albuterols when there is a shortage in the market

Steven C Hylton, PharmD

CommentID: 80176