Erin Barrett, Director of Legislative and Regulatory Affairs

버지니아 약사 위원회

9960 메릴랜드 드라이브, 사무실 300

Henrico, Virginia 23233

2025년 6월 16일

배럿 씨에게

We wish to make comments in response to the public comment forum on document 110-14, Dispensing Medications to Blind or Low Vision Patients. We offer these comments as President and Legislative Chair of the largest organization of blind and low vision individuals, the National Federation of the Blind of Virginia. Our members throughout the state enable us to understand the barriers blind and low vision individuals face in using prescription medication. It is important that the regulations and guidance documents the Board of Pharmacy develops go beyond what is simply stated in the law. We request that the Board provide some specificity and guidance to pharmacists as to how the new law should be implemented.

With their busy schedules and limited time, pharmacists will undoubtedly be unfamiliar with the various options for providing accessible prescription labeling. Pharmacists may not take the time to wade through the U.S. Access Board’s Best Practices report and recommendations. I am also concerned that the guidance offered by the Access Board is over 10 years old and badly out of date.

We have held several meetings with pharmacists and their representatives, and all agreed that some guidance from the Board’s regulations and guidance documents would be helpful. The Board of Pharmacy can augment implementation of the law by providing some specificity in the following areas on its website and through communication with pharmacists:

• What information must and should be provided in an Audio label?
  • The Access Board Best Practices Report states that “all required information contained on the print drug container label should be provided on the accessible label in the same sequence as the print label.” Please state this directly in the Board’s regulations or guidance.
• What information must and should be provided on a large print label?
  • All information as specified above should be provided on the large print label and should be stated directly in the regulations or guidance.
• What are commercially available options for providing audio labels since both pharmacies and patients will be unfamiliar with the options?
  • We suggest that the guidance document provides some options that pharmacists can use to produce accessible labels. We have provided information and links to labeling devices in the attachment.
• What are available options and requirements for providing large print labels including details on font size since both pharmacies and patients will be unfamiliar with the options?
  • The Access Board states that the label should be printed in 18-point bold font on non-glossy paper with black text on a white or pale-yellow background. Please state this in the text of the Board’s regulations or guidance.
• Your draft regulations state that the accessible label should be affixed to the bottle and should be provided in the same timeframe as prescriptions are provided to other patients. The regulations or guidance should answer other questions, such as:
  • What are reasonable expectations between pharmacists and patients reuse/return of the equipment?
  • Can the pharmacy require that the patient pay for any recording devices or time to record the information?
  • When can the pharmacist require use of mail order or refuse to serve a patient?

With regard to counseling the pharmacist may provide, the regulations or guidance documents should state that the counseling should be provided in a private place where Protected Health Information (PHI) cannot be overheard by others, as required in HIPAA Regulations.

We have already heard from several NFB members that their pharmacists were unfamiliar with the law and guidance. Some even refused to provide an accessible label, possibly because they were unaware of various low-cost options available to do so. Your thoughtfulness in going beyond what the law states to address questions that may arise as pharmacists strive to implement the law will greatly assist pharmacies in implementing the legislation and enable blind and low vision patients to safely take their medication.

진심으로,

Tracy Soforenko

사장

National Federation of the Blind of Virginia

202-285-4595

president@nfbv.org

Bonnie O’Day, Legislative Chair

bonnoday@gmail.com