The Virginia Society of Health-System Pharmacists (VSHP) appreciates the Board of Pharmacy's considerations for promulgating regulations on two areas of pharmacy practices that have become well incorporated into health-system pharmacy practice. We support the intent of the language proposed in this NOIRA. We would like to offer clarifying considerations and questions for the proposed language.

 

MEDICATION CAROUSELS

Section C, subsections 2b and 3b: VSHP requests that the Board revisit the language as written requiring the scanning of each unit dose / intact blister / unopened manufacturer. The current proposed language requires validation of the barcode based on type of product packaging, which is currently not a customizable option within medication carousel technology. The system cannot differentiate between when to require scanning a single unit dose vs. intact blister vs. unopened box. Instead, the system requires the scanning of a barcode of the product in order to proceed, regardless of it is a single unit or still attached to a whole box or blister. VSHP recommends adding language requiring the visual inspection by the pharmacy technician for all unit doses filled to a patient-specific dose or automated dispensing cabinet.

 

Another consideration is the requirement for scanning every single unit dose item to fill the order for a patient or automated dispense cabinet pocket. Although this is an option that can be implemented in the medication carousel technology, this counteracts the intent of this pharmacy automation technology to improve efficiency in addition to the added safety level of barcode validation.

 

RFID TECHNOLOGY

Section A, subsection 4: VSHP asks the Board to clarify expectations if errors are identified during the 5% pharmacist check, actions to be taken, and documentation. For example, does the pharmacist then expand to 10% check for validation?

 

Thank you for your attention and consideration.