Good afternoon, 

I am writing as a graduate student of public health and resident of the Commonwealth of Virginia in response to the call for public comment for the Virginia Board of Pharmacy’s proposed amendment to 18VAC110-20-275 Delivery of Dispensed Prescriptions.  Thank you for the opportunity to provide input regarding unique pharmacy identifiers that are required on prescription medication labels.  There is a delicate balance regarding information that consumers need when it comes to their prescription medications.  It is important to provide enough information so that consumers can safely understand how, when, and why to take their medications as well as who to contact and how to reach that contact when questions arise.  Providing too much irrelevant information can overwhelm some consumers, leaving room for medication errors to occur.  It is vital to find this delicate balance.    

I write in support of the proposed amendment to 18VAC110-20-275 Delivery of Dispensed Prescriptions.  Annually the FDA receives more than 100,000 reports concerning potential medication errors.  The proposed amendment provides an opportunity to reduce potential medication errors.  According to the US Food and Drug Administration’s (FDA) article, Working to Reduce Medication Errors, prescription drug labels play an important role in preventing medication errors.  The FDA recommends that drug labels be designed so that consumers do not overlook important information1.  Prescription drug labels will have more room for this important information by reducing the number of unique pharmacy identifiers that are required on prescription medication labels. The important information will be clearer and more easily identified by the consumer potentially leading to a reduction in medication errors.   

It goes without saying that it is vital to be able to track the pharmacies that are involved in filling and dispensing prescription medications.  By including the unique identifiers for all pharmacies that are involved in filling and dispensing a prescription medication, a paper trail would be maintained that would include the final pharmacy from which a consumer obtained the prescription in case that information is ever needed.  This proposed amendment does not interfere in that system of checks and balances because it continues to require that the filling and dispensing pharmacies’ unique identifiers remain on the prescription label. The consumer continues to have access to the contact information for the pharmacy in case any questions or needs arise. 

Lastly, by omitting the unique identifier for pharmacies that are only holding prescription medications for consumer pick up or delivery, efforts are made to minimize the points of possible data breaches.  Any time unique identifiers are required for maintaining records there is  potential for those identifiers to be utilized in a data breach.  By minimizing unique identifiers that are provided to the general public, the chances of those data breaches occurring from this avenue are reduced.  The omission of these unique identifiers is one step closer to protecting personal health information.  

As a graduate student in public health, I appreciate the opportunity to be involved in the process of amending prescription drug policies.  It is encouraging that the Virginia Board of Pharmacy continuously works towards the safest possible medication administration while protecting the health care information.  Thank you for the time and efforts regarding the proposed amendment to 18VAC110-20-275 Delivery of Dispensed Prescriptions.  The risk of medication administration errors for those individuals filling prescriptions in the Commonwealth of Virginia will be reduced by eliminating the unique identifiers for pharmacies that are only holding prescription medications for a consumer to pick up or to be delivered to the consumer.  This amendment moves toward the delicate balance of providing the correct amount of information.  

1. Working to Reduce Medication Errors. Available from https://www.fda.gov/drugs/drug-information-consumers/working-reduce-medication-errors. Accessed May 25, 2020.