Dear Executive Director Juran:

CVS Health appreciates the opportunity to submit comments regarding the proposed amendment to 18VAC110-20 as requested by Mr. Derek Phillips. This proposal if promulgated, will allow a pharmacist upon patient request, to dispense a quantity of Schedule VI medication in excess of the amount noted on the face of the prescription, not to exceed the total amount authorized by the prescriber provided the pharmacist deems the request appropriate for the patient.

As a leader in the pharmacy industry and an advocate for increased patient access to prescription medication, CVS Health supports the proposal as published in the Virginia Regulatory Town Hall Public Comment Forum.

Granting the pharmacist authority to dispense a quantity of a Schedule VI substance greater than the amount initially noted on the prescription include, but are not limited to, the following benefits to the patient and prescriber community.

• The patient will be afforded increased access to medication as well as the ability to receive them in a more convenient manner.
• Pharmacists will have increased opportunities to engage in patient care activities with the elimination of unnecessary communication with prescribers and office staff regarding this type of request.
• Enabling this activity will allow patients greater flexibility to obtain quantities of medication from their pharmacy of choice based on individual need.
• Allowing this type of request will align the patient to manage their healthcare from a more balanced position which should lead to improved medication adherence and positive outcome.

In closing, CVS Health appreciates the opportunity to provide these comments to the Board of Pharmacy for their review and consideration regarding this proposal and look forward to a favorable outcome for the patients of the Commonwealth of Virginia. 

Sincerely,

Bill Irvin, R.Ph.

Director, Pharmacy Regulatory Affairs

CVS Health