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Virginia Regulatory Town Hall
Department of Health Professions
Board of Pharmacy
Regulations Governing the Practice of Pharmacy [18 VAC 110 ‑ 20]
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3/21/21  6:38 pm
Commenter: George Roberts Jr / Remington Drug Company

Dispensing of Schedule II Medications

This petition request is not necessary. As a Standard of Practice, most if not all pharmacists would question a patient when filling a Schedule II medication if the date written is more than a few days before the date of the request to fill the prescription. The majority of Schedule II prescriptions are transmitted electronically so a pharmacist would have time to contact the provider or even call the patient to discuss the delay in filling a medication in this class. The major exceptions are medications for ADHD and pain management. In at least these two cases multiple prescriptions are issued on the same day with "Do Not Fill Dates" on the second and third prescriptions. In these situations the intent is communicated by the "Do Not Fill" dates. Currently, following a  conversation with either the provider and/or the patient, a stale dated prescription could be filled based upon professional evaluation and clinical judgement by the pharmacist. This petition is an attempt, probably not the intention, to remove professional/clinical decision making on the part of a licensed pharmacist. Currently a pharmacist could refuse to fill the prescription, make clinical notes on the prescription/sign the prescription, and either keep the prescription (if requested by provider) or return the prescription to the patient. This petition would make the prescription invalid when presented for filling. What if the provider intended the prescription to be used "in case the previously treated condition presented suddenly"? This petition would not allow such an option. The petition is unnecessary and adds an excessive burden to the decision making ability of a pharmacist. I respectfully ask this petition not be considered for adoption.


CommentID: 97406