Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Pharmacy
 
chapter
Regulations Governing the Practice of Pharmacy [18 VAC 110 ‑ 20]
Action Addressing hours of continuous work by pharmacists
Stage NOIRA
Comment Period Ended on 10/10/2012
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10/9/12  10:47 pm
Commenter: H. Otto Wachsmann, Jr. Stony Creek Pharmacy

Pharmacy Work Conditions
 

As someone who has worked in community pharmacy for approximately 20 of my 26 years as a licensed pharmacist, I regret that I seem to be witnessing the de-professionalization of pharmacy.  There was once a time when the pharmacist in charge was afforded the priviledge of doing just that, being in charge of the pharmacy department.  I recall there were certain other regulations in place to prevent non-pharmacist management from making that determination.  Sadly to say we have become a profession of employee pharmacists.

That being said, I believe it inappropriate for the BOP to requlate mandatory breaks in a one size, fits all kind of way for all pharmacies.  In my pharmacy, we are only open for nine hours at a time.  We are not a high volume pharmacy filling 400 prescriptions a day.  We run at a fairly even pace most days and actually less busy than in years past as mandatory mail order or mailorder pharmacies that "steal" our patients and preferred Part D plans are eroding our business.  We try very hard to meet the needs of our existing patients in a timely fashion as it's our greatest strength as the next nearest pharmacy is over twenty miles away.  Quite honestly, if I am forced to step away from the counter for thirty minutes for a mandatory lunch break, I am more concerned I will be likely to allow an error to pass as I attempt to catch up on the prescriptions brought in by patients on their lunch breaks which have been dumped out by the doctor's office for their lunch break.  You can't predict pharmacy, patients don't make appointments.  When I think we're not going to be busy, we are and visa versa.

Otto Wachsmann

I believe what will have a bigger impact on reducing errors in my relatively low volume pharmacy is for the BOP to look into fixing the "noise" generated by false PBM DUR messages that are sent.  Optima Health for example, sends DUR messages for things like Max Day of 3 per day when you are billing for 30 tabs as a 30 day supply.  It is extremely frustrating to receive (and pay for the privilidge of receiving) e-scripts at my pharmacy meant for Stoney Creek Pharmacy in Nellysford by UVA residents who do not provide their NPI number and give the UVA outpatient pharmacy as their office telephone.  You look them up in the NPI directory and get the phone number for the School's admistrative person who registered their NPI number.  There is no way to contact the prescriber.  Manufacturer coupon cards and third party cards with incomplete and wrong information with unreadable 4 point font numbers on them create a lot of wasted effort and frustration.  If the BOP could create some requlations to eliminate or reduce these unnecesary distractions that kill workflow, we will have a lot more time to talk with our patients, check for errors and allow us all a better quality in the workplace.  Community pharmacy is far too focused on trivial things right now that don't do anything that adds to patient care as much as making sure they meet the things that an insurance audit is likely to charge them back for such as calculating 18 drops per ml in an ophthamic preparation instead of 21.5 drops per ml.  Please help us by allowing us to focus back on pharmacy by correcting the things generated by outside forces which are bad for pharmacy.  We have worked hard to be professionals.  Please allow us to determine the best way for us to practice in our particular environment.  If a licensee believes it is unsafe, allow them to make a complaint with the BOP and have it handled on a case by case basis.

CommentID: 24281