Virginia Regulatory Town Hall
Department of Health Professions
Board of Pharmacy
Regulations Governing the Practice of Pharmacy [18 VAC 110 ‑ 20]
Action Brown bagging and white bagging
Comment Period Ended on 9/5/2018
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9/5/18  3:28 pm
Commenter: Tracie Chambers, Community Health Systems


My company owns 3 sites in Virginia.  We are committed to helping each of sites provide the best care to all patients' while meeting all rules and regulations.  Recently, during a Board visit, one site who had received a refrigerated med from a specialty pharmacy for a patient scheduled in the next day was asked if they had a written contract with this pharmacy to do business.  Of course the answer was No, as this is viewed as a patient's own med and having it sent directly from the other pharmacy to the hospital pharmacy helps assure the integrity of the product prior to use versus having the med sent to the patient at home where proper storage requirements cannot be verified.  The time of notification that the patient was coming in for a refrigerated, injectable med and time of receipt was approximately one week which would not allow the hospital enough time to set up a contract or written agreement with the specialty pharmacy.  I would hate to have to turn this patient population away but given the quick turnaround times, there is no way to be compliant with the current guideline for contracting.  I want each of our sites to be able to care for Virginia residents so would appreciate your consideration to grant exceptions for these patients' that require a refrigerated medication that insurance dictates must be purchased through a specialty pharmay and allow them to be viewed as patients' own meds just temporarily stored in the hospital pharmacy until day of administration similar to inpatients' that must use their own med if it is not available on the hospital formulary.

CommentID: 67115