Section C of article 425 references the use of carousel technology and puts into place the necessary safeguards for technicians to safely and accurately dispense unit dose medications using barcode technology inherent in carousels technology.  The article properly identifies the steps to be followed for dispensing of patient specific medications as well as replenishment stock for automated dispensing systems.  The article does not specify dispensing of products that will be utilized in a satellite pharmacy or another hospital in the case of a hub and spoke distribution model.  I encourage the addition of language that allows for dispensing to another pharmacy location following the same safeguards as outlined for patient specific medications and automated dispensing systems.

Note there are two sections labeled section 3 in the carousel portion of the article.  It appears that this is a typo and perhaps the second section 3 should be section 4.  "3. A pharmacist shall verify the accuracy of all drugs prior to dispensing or leaving the pharmacy that are manually removed from the medication carousel by a pharmacy technician without the use of the robotic pharmacy system to guide the selection of the drug product. "  Carousel technology relies on barcode technology and not robotic technology for safety.  I believe the intent of this section is to specify that any medication that is removed from a carousel without following the required steps for section 3 (electronically transmitted order and barcode scanning each item) requires a pharmacist verification prior to dispensing.

Changes to this regulation is long overdue and I am pleased that VA is recognizing the value of automation and technology in the inpatient hospital system.