The Virginia Health Care Association (VHCA), which represents over 270 long term care facilities in the Commonwealth of Virginia, supports this petition for rulemaking.  Allowing a “back-up” pharmacy to initially dispense a prescription without that constituting a prescription transfer would help ensure patients receive their medication in a timely manner.  This efficiency is especially important in circumstances when the patient is beginning a new, clinically critical medication.  Changing the regulations as proposed would also improve the continuity of care when patients are transferred from hospitals to nursing facilities and the on-site pharmacy may not have the new prescription on-hand.  

I work in a LTC, mail order pharmacy which handles many backup requests for our consumers. The vast majority of these requests are for antibiotics and other emergency meds which patients need quickly.  We have been handling these requests as transfers per the Board requirement, which means we have to transfer the medication to another (local to the patient) pharmacy and then transfer it back to us if it is not a one time order or a control. This process is very time consuming and frequently results in more of a delay for start of treatment. Additionally, some of the pharmacies our patients' caregivers would like to utilize as backup pharmacies consider the extra work to be too prohibitive and refuse to accept our transfers, which causes even more of a delay in start of treatment.

I support the change for backup requirement for long term care pharmacies.  I currently work at a long term care pharmacy, and we send many prescriptions to backup pharmacies every day.  Our patients typically need acute care meds or new prescriptions/dose changes to begin immediately.  It is very time-consuming for both us and the retail pharmacy to do a transfer of each of these prescriptions, negatively impacting patient care.  In fact, many of the retail pharmacies we call will refuse to serivce our patients any longer due to the time/effort of transferring the prescription back and forth when they may only be filling a three day supply.  My patients and their caregivers cannot always go the the backup pharmacy of their choice because the backup pharmacy will not fill these prescriptions.  I strongly feel if change the requirements, we can benefit our patients and their caregivers.