Virginia Regulatory Town Hall
Department of Health Professions
Board of Pharmacy
Regulations Governing the Practice of Pharmacy [18 VAC 110 ‑ 20]
Action Pharmacy working conditions
Stage Emergency/NOIRA
Comment Period Ended on 11/22/2023
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10/29/23  11:36 pm
Commenter: Pharmacist, Giant Food Pharmacy

Please help me serve my patients better.
18VAC110-20-110 section E Please take note that my employer has made it clear that legal action will be taken against any PIC who removes a pharmacy permit upon leaving. Please update this section to instead read, PIC will notify the Board of Pharmacy in writing immediately upon leaving post. 
Please update and approve the emergency working conditions regulations into law to help me provide better patient care for our community. As of now, my employer has made no changes to support your emergency regulations.
18VAC110-20-113 section A & B The PIC name is on the pharmacy permit. The PIC does not have the ability to provide the objectives of this section. Please update wording to read the employer of the PIC, unless independently owned. Otherwise, I foresee corporate twisting your intentions.
18VAC110-20-113 section D Please update this section to require a copy of the form also be sent to the Virginia Board of Pharmacy, documentation and action(s) taken to be reviewed upon subsequent standard inspection. Every company claims to have an anti-retaliation policy, but unfortunately I do not feel that a company has its employees in its best interests when it comes to profit. Please re-word this section to include such follow-up to strengthen this section and further protect the PIC and the pharmacist-on-duty reporters
Current working conditions have pharmacy teams overworked and stressed to unhealthy levels. While it is often mandated that pharmacy technicians receive breaks, it is currently near impossible at many stores for the pharmacists to eat or even use the bathroom during shifts. When your board put a 30 minute break into law for pharmacists years ago, my supervisor told me I could take a few minutes here, a few minutes there and that I did not need to eat my full meal in one sitting.
I know too well, that working without pause for up to and over 12 hours per day not only decreases my ability to give my best patient care, but also increases my risk of prescription errors. The current work loads this fall have been unbearable for many pharmacy teams who are short-staffed. To add to insult, our supervisors repeatedly demand that pharmacists break the pharmacy oath and put more profitable immunizations before patients in need of prescriptions. 
Since the pandemic, there has been tremendous turn over in pharmacy teams. Your community pharmacists are not only working on prescriptions, providing immunizations, doing strep/flu/covid testing and every day pharmacy tasks; but continually training new team members which is both exhausting and patience sapping. 
On a grand scale, current working conditions have affected the ability of pharmacy schools to draw qualified applicants resulting in lower graduating classes. As a preceptor, I had one student graduating in 6 months who could tell me very little about drugs and a third year student who could actually not tell me his own name in a coherent fashion. I worry about the future of the pharmacy profession if talented students keep choosing other professions. How will patient care change in the years to come if graduating pharmacists become those who would not have been chosen for enrollment otherwise? 
Please take permanent action to not only allow pharmacy teams to serve its patients in the best way possible, but also long term save the pharmacy profession. I call on you as pharmacist: Please uphold the oath you took at graduation to "embrace and advocate change in the profession of pharmacy that improves patient care".


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