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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11/21/23  12:37 pm
Commenter: anonymous


please consider pharmacist to script/order volume or pharmacist to bed minimum staffing ratios. we have tech to pharmacist ratios but need to set minimum safe staffing for pharmacists otherwise no one will hire more as it is not profitable under current reimbursement strategies. i know staffing ratios is unpopular but its the right thing to do, set a MINIMUM that is safe

please consider more directive or details on who needs to respond to the proposed forms, who is the permit holder for a corporation or a big box? is the intent to put the response on someone who works outside of the pharmacy or is it enough that the supervisor of the PIC responds, or is that a conflict of interest?

please provide more information on what the action and expected response for the forms is. So they are audited on inspection, does the inspector review them and look for an appropriate response? is there a number that would trigger an investigation? what response is the forms supposed to trigger?

please consider looking at pharmacy reimbursement methods as the cuts to pharmacy and script profitability have no doubt contributed to this staffing crisis. take this up as your duty and charge. while you may say thats not your problem but it really is a significant root case and I would ask what you are doing with this working conditions policy: are you putting a band aid on the crisis or are you serious about fixing the underlying root cause which in effect improves the access, safety and welfare of the public?



CommentID: 220687