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.