Dear Executive Director Juran and Members of the Virginia Board of Pharmacy,

I am writing to you in my role as Executive Director of Pharmacy Regulatory Affairs for CVS Health and its family of pharmacies, which includes Omnicare. We appreciate the opportunity to submit comments on proposed rule amendments noticed for 18VAC1110-20-555 Use of automated dispensing devices. Omnicare 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.

Omnicare, a CVS Health Company, appreciates the opportunity to comment on proposed amendments to 18VAC110-20-555. We are supportive of the proposed amendments to align how stat drugs are treated with drugs that are accessed from an emergency drug kit that duals as an ADD, thus allowing access prior to electronic authorization from a pharmacist to not delay care of life-saving drugs for patients. However, we do request the Board clarify that the intent of the amendment is to allow for removal after pharmacist confirmation/permission upon review of a valid prescription or lawful order from a prescriber, but potentially before an electronic authorization is received. We do not believe the intent of the amendment was to relieve all parties from compliance with DEA regulations requiring a valid prescription or emergency prescription before the medication is removed for administration, so we request confirmation from the Board as to our understanding of the amendments.

CVS Health appreciates the Board’s consideration of request for clarification on the proposed rule amendments. Should the Board have any questions, please do not hesitate to contact me.

Sincerely,

Lauren Paul, PharmD, RPh, MS

Lauren Paul, PharmD, RPh, MS
Executive Director, Omnicare, a CVS Health company