RD662 - Report on Pharmacist Initiation of Therapeutic Interchange – October 2025


Executive Summary:

Pursuant to SB745 passed during the 2025 General Assembly Session, the Board of Pharmacy convened a workgroup which met on August 12, 2025. The workgroup considered the required topics designated in SB745, which were as follows:

1. Review and analyze the current authority of pharmacists to initiate therapeutic interchange under all health carriers and plans and health care reimbursement methods, including plans covered by the Employee Retirement Income Security Act of 1974;

2. Make recommendations to streamline the existing therapeutic interchange process in the Commonwealth; and

3. Make recommendations for the modernization of such therapeutic interchange authority, particularly in cases of prescription drug shortages.

During its review of current laws regarding therapeutic interchange in other states (Appendices 1 and 2), the workgroup appeared to reach consensus on several recommendations for possible legislation to authorize therapeutic interchange. Those recommendations are detailed below in Part IV.

Workgroup Members(*1)

Erin Barrett, JD
Director of Leg. & Reg. Affairs, Virginia Department of Health Professions

Jared Calfee
Associate State Director for Advocacy and Outreach, AARP Virginia

Scott Castro
Senior Director of Health Policy, Medical Society of Virginia

Craig Connors
Vice President Payor Relations & Strategy, Virginia Hospital and Healthcare Association

Joshua Crawford, PharmD
Legislative Committee Co-Chair, Virginia Society of Health-System Pharmacists

Jennifer Deschenes, JD, MS
Deputy Executive Director, Board of Medicine

Joanne Dial, PharmD
Pharmacy Operations Specialist III, Controls, Kaiser Permanente

Shannon Dowdy, PharmD
Vice-Chairman, Board of Pharmacy

JoeMichael Fusco, PharmD
Pharmacy Operations Manager, Department of Medical Assistance Services

Johnny Garcia, PharmD
Pharmaceutical Care Management Association (virtual participation)

Sharon Gatewood, PharmD
Past-President, Virginia Pharmacy Association

Bill Hutchens, MD
Member, Board of Medicine

Caroline Juran, RPh
Executive Director, Virginia Board of Pharmacy

Larry Kocot, JD, Chair
Board of Pharmacy

Randall Mangrum, DNP, RN
Deputy Executive Director for Advanced Practice, Board of Nursing

Laurie Mauthe, PharmD
Pharmacy Account Director, Elevance Health

Arne Owens
Director, Virginia Department of Health Professions

Jamie Smith, PharmD
Clinical Pharmacy Services Manager, Department of Corrections

Jason Spouse, PharmD
National Association of Chain Drug Stores

Stephanie Wheawill, PharmD
Director, Division of Pharmacy Services, Department of Health

Derek Webb, PharmD
Member, Board of Pharmacy

Ling Yuan, PharmD
Member, Board of Pharmacy
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(*1) A representative from the Virginia Chapter of the American Academy of Pediatrics was unable to participate.