|Pharmacy working conditions
|Ended on 11/22/2023
Walgreens comments 18VAC110-20-113 Pharmacy working conditions, Part I
Dear Executive Director Juran and respected Board members,
On behalf of all pharmacies owned and operated by Walgreen Co. in the state of Virginia, we thank you for the opportunity to comment on 18VAC110-20-113 Pharmacy working conditions. Walgreens appreciates the Board’s time and effort related to addressing working conditions and consideration of public comments on these rules.
We fully recognize that the pharmacy working environment can be challenging, and the Board is attempting to support pharmacists and pharmacy technicians. Walgreens is also aligned with the need to support our pharmacy team members. We believe there are additional actions in addition to the working conditions regulations that can be taken by the Board to improve workplace conditions.
In 2022, members of the NABP Work Group on Workplace Safety, Well-Being, and Working Conditions convened, and issued the following 5 recommendations to support a healthy work environment:
1. NABP collaborates with stakeholders to:
b. identify/set meaningful standards for staffing to include but not be limited to:
i. lunch breaks/shift lengths;
iii. clinical functions;
iv. use of automation technology; and
v. use of pharmacy technicians.
2. NABP reviews the Model Act to identify model act language that can create barriers to care and suggest edits to submit to the Committee on Law Enforcement/Legislation.
3. NABP encourages industry stakeholders to amplify current messaging to educate patients about pharmacy operations to manage expectations.
4. NABP encourages boards of pharmacy to consider pathways to innovation such as automation and central fill, reimagine new delivery models that support pharmacists’ ability to provide patient care services and address staffing shortages.
5. NABP encourages boards of pharmacy to review and revise regulations to utilize pharmacy technicians to augment the role of the pharmacist and to identify current pharmacist-only duties that could be safely and competently performed by non-pharmacist personnel.
While we acknowledge the Board has taken great strides to require pharmacy permit holders to address working conditions, we respectfully ask the Board to examine ways it can improve workplace conditions.
Based on feedback we have received from Virginia licensed pharmacists and pharmacy technicians working in our pharmacies, below are five ways the Board can implement changes to provide relief to pharmacies:
Walgreens recommends an amendment to 110-20-110 that would allow a pharmacist's professional judgment to determine the appropriate amount of pharmacy support.
Walgreens recommends that the Board eliminate or reduce the 2-year experience requirement to become a PIC in the state of Virginia.
Walgreens asks the Board to modify its current inspection approach to focus on measures that impact patient safety. This will help reduce any unnecessary and burdensome tasks being placed on pharmacy staff. Walgreens respectfully requests that if the Board does not want to amend and reduce the intensity of its inspections, an alternative approach could be to provide advance notice of the inspection to allow for the pharmacy an opportunity to provide an additional staff member available to assist the inspector and not remove a pharmacy team member from the workflow.
Walgreens recommends the Board introduce a support/ancillary personnel category that would enable utilization of such persons without significant training and certification barriers.
Walgreens recommends the following amendments to 18-110-20-276(B)(3) and 18-110-20-276(F) Central or remote processing to include:
B. A pharmacy may outsource certain prescription processing functions as described in subsection A to another pharmacy in Virginia or a registered non-resident pharmacy under the following conditions:
1. The pharmacies shall either have the same owner or have a written contract describing the scope of services to be provided and the responsibilities and accountabilities of each pharmacy in compliance with all federal and state laws and regulations related to the practice of pharmacy;
2. Any central or remote pharmacy shall comply with Virginia law and regulation with respect to requirements for supervision of pharmacy technicians and the duties which are restricted to pharmacists and pharmacy technicians. Pharmacy technicians at the remote pharmacy shall either be registered in Virginia or possess credentials substantially equivalent to those required for a technician registered in Virginia;
3. A pharmacist licensed in Virginia or duly licensed within the state that they reside and employed by a Virginia licensed facility, whether at the remote pharmacy or the dispensing pharmacy, shall perform a check for accuracy on all processing done by the remote processor; and
4. The pharmacies shall share a common electronic file or have technology, which allows sufficient information necessary to process a non-dispensing function.
F. Nothing in this section shall prohibit an individual employed by a Virginia licensed facility and licensed as a pharmacist in Virginia or duly licensed within the state that they reside from accessing the employer pharmacy's database from a remote location for the purpose of performing certain prescription processing functions as described in subsection A, provided the pharmacy establishes controls to protect the privacy and security of confidential records.
Walgreens appreciates the Board’s efforts to address workplace conditions and respectfully asks that the Board consider the recommendations to reduce regulatory barriers that have been provided above.
Director, Pharmacy Affairs
 NABP Report of the Work Group on Workplace Safety, Well-Being, and Working Conditions. 2022 Release.