Patients entering LTC Centers today have multiple chronic conditions relying on mulitple prescription medications to manage their complex healthcare conditions.  Our goal is to effectively and efficiently manage their pain, infections, shortness of breath and other significant changes in condition.

The use of electronic devices for Emergency and STAT boxes are becoming a standard of practice in acute LTC Facilities:

1. Electronic devices for 1st Dose are much safer as they guide nursing staff to the appropriate medication location,
2. Electronic devices for 1st Dose assist to minimize diversion potential by keeping electronic records of all removals, and
3. 1st dose dispensing is significantly different in the quantities utilized versus full on-site automated dispensing of all medications.

The LTC industry needs the Board to continue permitting electronic advancements in the provision of pharmacy services to provide quality of care to those we care for in these LTC facilities. I am requesting the BOP amend 18VAC110-20-540 and 18VAC110-20-550 to permit electronic devices in lieu of manual emergency drug kits and stat-drug boxes. It is my understanding that the Board currently defines all electronic devices as “Automated Dispensing Systems” requiring registration as such a device, regardless if the intended use of the device is for “1st Dose” or “Routine Dosing”. I  believe it is important to distinguish between the utilization of the devices and the requirements surrounding registration. This covers the Omnicell devices we at CCR use in our Centers.