Agencies | Governor
Virginia Regulatory Town Hall
Department of Health Professions
Board of Pharmacy
Regulations Governing the Practice of Pharmacy [18 VAC 110 ‑ 20]
Action Brown bagging and white bagging
Stage Final
Comment Period Ends 6/9/2021
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5/24/21  3:56 pm
Commenter: Douglas E. Lischke on behalf of UVA Health

Comment on Regulations Governing the Practice of Pharmacy [18 VAC 110 ? 20]

May 24, 2021


Caroline D. Juran, RPh

Executive Director

Virginia Board of Pharmacy

9960 Mayland Drive, Suite 300

Henrico, VA 23233


Re:   Public Comment on Regulations Governing the Practice of Pharmacy [18 VAC 110 ? 20]


Dear Ms. Juran:


On behalf of the University of Virginia Health System (UVA Health), I thank you for the opportunity to provide comment to the Board of Pharmacy concerning the above-referenced Final Regulation dealing with “white bagging” and “brown bagging” practices. UVA Health fully supports and endorses the public comments submitted on May 21, 2021 by the Virginia Hospital and Healthcare Association (VHHA) concerning new Subsections F and G contained in the Final Regulation.  Further, UVA Health urges the Board of Pharmacy to implement the recommendations proposed by VHHA with respect to the Final Regulation. 


Thank you for your consideration of our comments.




Douglas E. Lischke, CPA, MBA

Chief Financial Officer

UVA Health

CommentID: 98672