In regards to the change in PIC documentation, the organization of the form is a bit difficult to read given the track changes.  From what I have extracted from it, the limitation to the number of times a facility can change a PIC seems to be based on a fee limitation rather than a number of times cap that may or may not appropriately fix the solution.  In addition, the submission of a number of fees for changing the PIC is fair, but at the low price seems to allow for an infinite number of PIC which will punish facilities who cannot find a permanent PIC.  I did not see any clear grounds on how to handle a facility requiring temporary PIC coverage, or grounds to bypass fee punishments or grounds for filing in an expedited manner given appropriate grounds, (PIC passes away suddenly, PIC moving etc.)

In regards to the hours, live CE may be available, but in changing to nearly a third of the time for Live CE may be too much of a change.  LIve CEs are often difficult to schedule during work hours, sometimes have technical difficulties, and in regards to attending meetings not every job alots a pharmacist to accomplish visiting live CEs, not to mention increased costs for either paying or visiting live CE.  As such, switching to mandatory hours may not be received well given such a demand.  If Live CE to be pushed, then suggest switching to 2 hours for the first few years to assess how compliance goes, and from there can adjust the time.  Should 5 hours be passed, the board should redobule the efforts to then provide a planned list of live CEs on a monthly or bimonthly basis to assist and help pharmacists begin developing resources to meet this demand.  This way the board and the ASHP ca begin to work out an understanding that will benefit all parties involved.