|Pharmacy working conditions
|Ended on 11/22/2023
Walgreens comments 18VAC110-20-113 Pharmacy working conditions, Part 2
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 a shared partnership between the pharmacy permit holder and pharmacy staff is necessary to ensure safe working conditions. Safety is a top priority and pharmacies must be able to continue to provide critical patient care services.
Walgreens would like to highlight the following four concerns with 18VAC110-20-113:
To illustrate this point, below are two real-world examples where shifting responsibility unilaterally to the permit holder may lead to a disconnect between the permit holder and PIC. The successful hiring and training of technicians work optimally when both the PIC and permit holder work together.
Example #1: If the hiring manager is also the PIC of the pharmacy, does the PIC have any portion of the responsibility for appropriate hiring, scheduling, and staffing?
Example #2: The PIC is ultimately responsible for training the pharmacy staff consistent with the requirements set forth in VA Statute 54.1-3321. Does the PIC hold any responsibility as well to ensure technicians are “sufficiently trained” within these rules?
To be clear, these examples are not to shift all of the responsibility to the PIC, but to demonstrate there should be a shared responsibility for both hiring and training of technicians.
Walgreens recommends the following amendment to 18VAC110-20-113(A) and 18VAC110-20-113(B)(1) & (4):
B. To provide a safe working environment in a pharmacy, a permit holder shall, at a minimum:
1. Along with the PIC, ensure sufficient personnel are scheduled to work at all times in order to prevent fatigue, distraction, or other conditions that interfere with a pharmacist's ability to practice with reasonable competence and safety. Staffing levels shall not be solely based on prescription volume, but shall consider any other requirements of pharmacy staff during working hours;
4. Along with the PIC, ensure staff are sufficiently trained to safely and adequately perform their assigned duties, ensure staff demonstrate competency, and ensure that pharmacy technician trainees work closely with pharmacists and pharmacy technicians with sufficient experience as determined by the PIC.
Walgreens therefore recommends that the Board issue guidance surrounding the proper use of metrics and improper utilization of quotas, as utilization of metrics can be open to individual interpretation.
Walgreens also respectfully requests the Board define pharmacy quotas and metrics within their rule, using the following suggested definitions:
Quotas: A measure that is tied to negative consequences for the individual failing to achieve
Metrics: A measure that is utilized to improve patient care or outcomes
Here are just a few examples that highlight the unintended consequences of shutting down patient care services:
Walgreens urges the Board that there should be no unilateral decision-making and that pharmacists and pharmacy permit holders should be working together to determine how best to address reducing any services due to safety reasons.
Walgreens recommends the following amendment to 18VAC110-20-113(C)
C. A pharmacy permit holder shall not override the control of the pharmacist on duty regarding all aspects of the practice of pharmacy, including a pharmacist's decision not to administer vaccines when one pharmacist is on duty and, in the pharmacist's professional judgment, vaccines cannot be administered safely. Prior to the discontinuation of any patient care services by a pharmacist, the pharmacist must first communicate their concerns to their immediate supervisor or permit holder in order to seek a solution. A pharmacist must not impede a patient’s access to care and must provide the patient an alternative pathway to seek services if the pharmacist’s decision is not to provide any patient care service.
Walgreens recommends the following amendments to 18VAC110-20-113(D)(1) &(2) and 18VAC110-20-113(E)(3):
E. Permit holders shall review completed staffing reports and shall:
Walgreens appreciates the Board’s efforts to address workplace conditions and respectfully asks that the Board consider the recommendations and amendments that have been provided above.
Director, Pharmacy Affairs