Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Pharmacy
 
chapter
Regulations Governing the Practice of Pharmacy [18 VAC 110 ‑ 20]
Action Exemption of automated dispensing devices stocked solely with emergency or stat-use medications from certain requirements of 18VAC110-20-555
Stage NOIRA
Comment Period Ended on 12/7/2022
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12/7/22  1:42 pm
Commenter: Brad McDaniel, Virginia Society of Health-system Pharmacists

Emergent Medication Access vis ADCs
 

VSHP supports the access to medications that are required in emergent circumstances and waiting for a pharmacist to review the order could adversely impact the patient’s condition. The Institute for Safe Medication Practice’s “Guidelines for the Safe Use of Automated Dispensing Cabinets” includes that such circumstances would include antidotes, rescue agents, and reversal agents, life-sustaining medications, and urgent comfort medications such as managing acute pain or intractable nausea and vomiting. 

Condition 1. VSHP requests that the Board consider the following exemptions to support timely access to medications outside of pharmacy service hours, when access to medications from a STAT box is needed:

-       Outside of pharmacy service hours

-       Nurse removes the medication under a patient profile (meaning that the ADC is configured as a “profiled” machine) – this is called an “override” function in the ADC

-       Medications provided for this indication are for emergent use (such as criteria outlined in ISMP’s guidelines)

-       Overrides are assessed periodically by the pharmacy provider for appropriate use of emergent medications

We believe these exemptions will support after-hours emergent access to medications and still allow for pharmacist review and verification of orders during pharmacy service hours.

Conditions 4(a) and 4(b) are appropriate exemptions to accomplish this objective.

Brad McDaniel, PharmD, MBA, BCCCP

Chair, Legislative Affairs Committee

Virginia Society of Health-systems Pharmacists

CommentID: 206529