| 9/16/2010 9:22 am Date / Time filed with the Register of Regulations | VA.R. Document Number: R____-______ |
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Virginia Register Publication Information
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Transmittal Sheet: Response to Petition for Rulemaking
Initial Agency Notice
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Agency Decision
| Promulgating Board: | Board of Pharmacy |
| Regulatory Coordinator: | Caroline Juran, RPh (804)367-4416 caroline.juran@dhp.virginia.gov |
| Agency Contact: | Elaine J. Yeatts Agency Regulatory Coordinator (804)367-4688 elaine.yeatts@dhp.virginia.gov |
| Contact Address: | Department of Health Professions 9960 Mayland Drive, Suite 300 Richmond, VA 23233 |
| Chapter Affected: | |
| 18 vac 110 - 20: | Virginia Board of Pharmacy Regulations |
| Statutory Authority: |
State: Chapters 33 and 34 of Title 54.1 Federal: |
| Date Petition Received | 05/17/2010 |
| Petitioner | Eric Haas |
Amend requirement for filing prescriptions to allow filing by date of initial dispensing
or date of initial entry into pharmacy electronic record keeping system if such a
system is employed by the pharmacy. The rationale for the request is that prescriptions
are often placed into electronic systems for later dispensing, and retrieval and reassignment
of the date is cumbersome and unnecessary and may promote errors in a patient's record.
Agency Plan
The Board will receive public comment on the petition for rule-making and will review
the petition and any comment at its meeting on September 8, 2010 to make decision
on whether to initiate rule-making.
| Publication Date | 06/21/2010 (comment period will also begin on this date) |
| Comment End Date | 07/21/2010 |
Take no action
| Agency Response Date | 09/08/2010 |
The Board denied the petition but agreed that it would like to query other states
to determine policies and/or rules for entry of different dates into an electronic
record keeping system. An informal opinion from the Drug Enforcement Administration
states that, while not directly prohibited, the policy of "holding" a prescription
in a computer for subsequent filling is not advisable and presents a diversion issue.
The Board will revisit the request after additional information is obtained.