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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11/17/23  3:23 pm
Commenter: Pharmacy Leader

Actionable topics for solutions in the workplace

I appreciate the opportunity for public comments to support the working conditions for Virginia Pharmacists, Technicians, and public safety. I would like to see the Virginia Board of Pharmacy take action to implement regulatory change that would directly impact better working conditions in the pharmacy. The impact would provide the support that is being expressed in many of the public comments posted and create an environment where our pharmacist can directly control the working environment by leveraging available support to safely serve the patients in our Virginia community. The actions requested below will provide a better working environment.  The 1st 3 items are commonly permitted in the majority of states. The practice of pharmacy in Virginia is not different in these other states and the Virginia regulatory requirements and restrictions create barriers towards being able to provide greater support or create unnecessary stress on pharmacy staffs. I am licensed pharmacist in 4 states, including Virginia. I am currently a practicing pharmacist in Virginia     


  • Remote processing. Remove the constraint of the pharmacist and technician to be a licensed pharmacist in Virginia and working within Virginia State lines. This will increase the access to pharmacist and technician across the nation to support pharmacy production remotely. Remote support includes data entry, data review, third party resolution/billing, inbound/outbound phone call support. This enables the pharmacist and technicians within the pharmacy can provide patient services such as immunizations and testing, point of care, and other services that directly support the health and wellbeing in our community.
  • Remove the technician to pharmacist ratio, which is currently 4:1 and allow the pharmacist on duty to determine the appropriate technician to pharmacist ratio for sufficient staffing. 24 states and DC currently do not have a technician ratio and a handful of others permit greater than 4:1. 
  • Remove 2-year experience as licensed pharmacist for Pharmacist in Charge. The most qualified candidate should be eligible to accept a PIC position regardless of pharmacist experience.  A PIC is a leadership position, and there are candidates that have previously served in a leadership capacity, but may not have pharmacist experience.  This limits career growth for pharmacists that exhibit the skills and performance to move into a management position such as pharmacy manager.  If a pharmacist is practice ready and licensed, they should be able to fulfill the pic role.
  • Stop unannounced annual inspections, move to announced scheduled visits. Board of Pharmacy Inspections are disruptive to the workday when unannounced. As a example, we had annual inspection on Monday, the inspector arrived at 9am and stayed until 6:30pm. One team member had to be removed from workflow to assist with the inspection leaving the team short staffed even though we adequately scheduled for the day. If these were announced the team could plan appropriate support for the inspection while maintaining workflow and patient care. The majority of non-sterile compounding inspections in most states take 2-3 hours at most.  An inspection that lasts all day is extremely stressful for all involved.  If the inspection were completed in an efficient manner, the inspections can remain unannounced. 
CommentID: 220649