Dear Sirs,

I respectfully request that the proposed amendment 18VAC 110-20-275 be emphatically denied for several good reasons.

This amendment does nothing to help protect public safety and in fact does the opposite and causes public harm.

It will cause more stress to front line retail pharmacists due to negatively impacting their workflow procedures by increasing the time it takes them to perform routine prescription transfers. This added stress which can be at high levels as it is, will add more distraction and thus create a greater potential for errors than if this process would be left alone as it stands.

The implication that more white space on the label is safer by eliminating the pharmacy phone number is untrue and a poor attempt at justification of a bad change in the regulations. I feel if you check with ISMP, they will not advocate nor appreciate the comments by CVS Caremark in that regard.

This amendment is a blatant attempt by CVS to manipulate the board of pharmacy and if passed, will demonstrate that Corporate Pharmacy Benefit Manager profits outweigh the need for public safety.

This amendment is all about increasing the practice of central filling to the detriment of local pharmacies both chain and independent.  CVS management is seeking to cut hours and staffing and further lower pharmacist and pharmacy staff wages with this kind of practice.  Is this for public safety?

I would note that that this amendment will lead to more Virginia prescriptions being filled out of state by a large mail order type operations which are not inspected by the board to insure the regulations of Virginia are being complied with as is the case with local pharmacies.

Mailed prescriptions are subject to temperature fluctuations that are outside of the labeling for the product and could thus be adulterated. This seems to be a risk to Virginia patient’s lives that the board is not very concerned about.  They have repeatedly denied regulations adding temperature-tracking devices to mailed prescriptions.

Let’s be open and honest about this amendment. It is a corporate manipulation of the board of pharmacy disguised, as something needed which it is not.  Historically, many employees of CVS have worked for or held positions on the board, and the companies interests seem to be represented with higher regard than the public good at times.

I would hereby request it be denied.

Thank you for your considerations in this matter,

John W. Frye R.Ph.

Cedar Bluff, VA