This comment is being made in regards to the Notice of Intended Regulatory Action posted regarding changes to VAC 18VAC110-20-10 et seq. Specifically as outlined, the proposed update to 18VAC110-20-240 “Clarifying in subsection C that chart orders used in long term care facilities must include a quantity or duration of treatment.” Currently Virginia regulations do not specifically require a quantity on any prescription regardless of it being considered a “Chart Order”. The Board has already addressed this issue in Guidance Document 110-35 “While Virginia law does not specifically require that quantity be included on a prescription, written prescriptions must include some direction related to quantity to be dispensed, or authorized duration of the order by which the pharmacist can calculate the authorized quantity using directions for use and duration.  Federal regulations require that quantity be indicated on prescriptions for Schedule II-V controlled substances.” Therefore, Remedi SeniorCare does not feel the proposed changes referenced above are necessary.