Increasing Availability of Nonprescription Drugs; Request for Information

Dear Deputy Commissioner Graham, The American Pharmacists Association (APhA) and the National Community Pharmacists Association (NCPA) appreciate the opportunity to provide additional comments to the FDA's "Increasing Access to Nonprescription Drugs; Public Meeting; Request for Comments." APhA represents pharmacists, student pharmacists, and pharmacy technicians in all practice settings, including but not limited to community pharmacies, hospitals, long-term care facilities, specialty pharmacies, community health centers, physician offices, ambulatory clinics, managed care organizations, hospice settings, and government facilities. Our members strive to improve medication use, advance patient care, and enhance public health. NCPA represents America's community pharmacists, including 18,900 independent community pharmacies. Almost half of all community pharmacies provide long-term care services and play a critical role in ensuring patients have immediate access to medications in both community and long-term care (LTC) settings. Together, our members employ 205,000 individuals, and provide an expanding set of healthcare services to millions of patients every day. Our members are small business owners who are among America's most accessible healthcare providers. APhA and NCPA propose the following roadmap to FDA to ensure the ACNU framework successfully increases patient access while balancing safety concerns. Full comments are attached.

Dear Acting Deputy Commissioner Zeta, The American Pharmacists Association (APhA) appreciates the opportunity to provide comments on FDA's "Increasing Access to Nonprescription Drugs; Request for Information." APhA writes to emphasize that pharmacists provide direct patient care with nonprescription drugs, note that nonprescription status alone will not increase access to these medications, and restate our concerns regarding the Additional Condition for Nonprescription Use (ACNU) final rule. APhA represents pharmacists, student pharmacists, and pharmacy technicians in all practice settings, including but not limited to community pharmacies, hospitals, long-term care facilities, specialty pharmacies, community health centers, physician offices, ambulatory clinics, managed care organizations, hospice settings, and government facilities. Our members strive to improve medication use, advance patient care, and enhance public health. Full comments are attached.