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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10/23/23  1:56 pm
Commenter: Anonymous

Does the Pharmacy Working Conditions emergency regulation apply to nonresident pharmacies?

Section 54.1-3434.1 of the Code of Virginia states that a nonresident pharmacy “shall also certify that it complies with all lawful directions and requests for information from the regulatory or licensing agency of the jurisdiction in which it is licensed as well as with all requests for information made by the Board pursuant to this section.”

Regarding 18VAC110-20 "Regulations Governing the Practice of Pharmacy (Emergency)," is there clarification on whether this applies to pharmacies licensed by the Virginia Board of Pharmacy as nonresident pharmacies? 

Thank you for taking action to support pharmacy personnel and create environments that promote patient safety. 

CommentID: 220443

10/25/23  8:43 am
Commenter: Anonymous

Regulatory Action

I totally support this! It’s about time pharmacists have a say in the workplace. Conditions have become overwhelming. It’s more work without more help or hands. 

CommentID: 220444

10/25/23  8:45 am
Commenter: Fozia Ibrahim


As a pharmacist I fully support this!

CommentID: 220445

10/25/23  9:23 am
Commenter: Zachary May

This is a good start, but needs to go further

The regulations, as proposed, are a good first step towards improving working conditions.  However, even though these have already been in place as emergency regulations, there has been zero response from any of the large corporations to actually implement changes to improve the working conditions thus far.   For example, one large chain still allows pharmacists a lunch break, but because the pharmacy remains open while the pharmacist is on lunch, the pharmacist is still required to address mandatory counseling blocks (such as generic "90 day refill" blocks).  If their 30 minute lunch break turns into a 5 minute lunch break, so be it.  Likewise, another large chain does close for lunch, but at a set time.  Regardless of if the pharmacist is helping patients or not after 1:30, the pharmacist is required to return promptly at 2:00.  If the pharmacist is administering immunizations, or is counseling a patient, and doesn't get to actually leave the pharmacy until 1:45, they still have to be back at 2:00.  The technicians, on the other hand, are guaranteed a protected 30 minutes, whether they leave at 1:30, 1:45, or later.  I have had a permit holder point blank state that "you have 30 minutes to eat somewhere in your 11 hour shift.  Figure it out".

Large corporations will, quite simply, look at the proposed regulations and will pull out the policy manual that says "we already meet these regs".  Because they do.  Any pharmacist that challenges the corporate budget or corporate direction will not be termed or demoted because they challenged the actual work conditions, they'll be punished for "poor customer service".   As an example, Walgreens very publicly announced that they "will no longer hold pharmacy teams accountable to performance metrics".  That's true.  They don't.  Prior to my leaving the company they changed their performance evaluations to only focus on "leadership qualities".  However, these "leadership qualities" are then tied more deeply to "did you're pharmacy meet goal script growth?  Immunizations? MTM?"  No?  Then you must have poor leadership.  It's easy for the board to put in regulation "Avoid the introduction of...quotas...", and it's just as easy for a corporation to hide those quotas behind the vague umbrella of "effective leadership skills".

My pharmacy did over 800 prescriptions in the span of 3 days with 1 pharmacist and 2 technicians.  I went to the bathroom two times in 10 hours on the first day, one time the second day, and was unable to the third day because while I had 2 technicians, they were both acting as cashiers for the majority of that time.  So 1 pharmacist entered scripts, reviewed them accuracy, filled a good chunk of those scripts, and verified for product correctness.  In addition, about 25%-30% of those required mandatory patient counseling after checkout (dictated by the corporate software).  This is after the emergency regulations were published.  We did several dozen immunizations, and received constant pressure from our management to also complete additional MTM claims because "we were over 100 active claims".  I could, very easily, have told my management "I'm sorry, but the volume we are attempting to fill with only 2 certified technicians is unsafe and we are unable to accommodate any additional services right now".  However, I still need my job.  I absolutely guarantee I would receive a very strong warning, if not lose my position.  I could lodge a formal complaint, but it wouldn't do any good, the company would replace me with another pharmacist less vocal and say "I have poor customer service skills and am not respective of my patients needs".

No, without concrete minimums in writing that are black and white corporations will continue to use and abuse pharmacists.  We're "highly compensated individuals" and as such, according to the corporations, deserve every bit of what they want to dish out.  The Board needs to step up to protect both the patients and the pharmacists.  Pharmacist walk-outs (of which I did not participate) only hurt the patients.  They get publicity, but that's it.  When CVS is posting over $320 billion in revenue for 2022, I seriously doubt 22 pharmacies closing for a few days because of a walkout will truly make an impact.  At the end of the day, corporate pharmacy boards are ruled by non-pharmacists that will do everything to keep shareholders happy and profits as high as possible.  I fully intend to exit pharmacy well before my retirement age, if possible.  I have many friends that have exited retail completely, and in some cases pharmacy completely.  What happens when retail pharmacies can't be staffed, not because of COVID, but because the pharmacists are not there to staff them?  Pharmacy deserts.  Mail order.  I think everyone can agree its inconvenient for a patient to drive 30 to 40 minutes to find a pharmacy in rural areas.  But Virginia is in large part rural.  Nobody likes mail order.  There's a reason mail order market share has never gotten above single digits since its conception.

Any regulatory movement should address working conditions in black and white.

  • Pharmacists are people too.  A six hour shift should mandate a 30 minute lunch break and one fifteen minute break for every 4 hours worked.  Both should be uninterrupted.  Pharmacists and techs are in a high-stress, high-risk environment.  Research shows that even small breaks from workflow and the job can reduce stress, fatigue, and ultimately errors.  The regulations should specifically state breaks must be uninterrupted and must allow the full defined break period.
  • Pharmacy staffing regulations should define absolute minimums required to safely operate a pharmacy, and these minimums should take into account the services provided by a pharmacy.  From a safety perspective, no pharmacist should ever be required to work alone except in an emergency; 1 certified technician should always be present with the pharmacist.
    • It is unreasonable to dispense 400 prescriptions and expect scheduled immunizations, walk-in immunizations, and MTM to be completed by 1 pharmacist in a shift.  This is in addition to everything else required to keep a pharmacy running that does not involve direct patient care.  To put that into perspective, on an average with zero other expectations, I am spending approximately 1 minute and 20 seconds on a prescription.  That includes entering the script, filling the script, and reviewing it for accuracy and safety.  Given that filling a script is ~30-45 seconds of that and entry is ~20 additional seconds, a single pharmacist in a 9.5 hour shift filling 400 prescriptions is only spending about 10-20 seconds per script actually reviewing it for accuracy and safety.  10-20 seconds to perform a DUR check against the patient profile and make sure the script was actually entered correctly.  And that assumes zero other responsibilities.  In reality, we're looking at probably 5 seconds or less.  How is this safe?  But that is the corporate expectation.  That or stay after business close to get it done.  Again, I know personally of pharmacists that have stayed 4-5 hours after the close of business just to fill prescriptions, worked a 14 hour day, and repeated it again and again because that is the corporate expectation.  Again, I believe defining a reasonable minimum of 1 pharmacist for every 200-250 prescriptions dispensed would improve that patient safety margin.  Additionally, defining technician minimums as at least 1 technician hour for every 10-11 prescriptions entered (not sold, entered) would help ensure that pharmacists are not the sole point of contact on a script from entry to dispensing and again, improve that patient safety margin.
  • A popular tool over the last few years has been the introduction of appointment-based vaccinations and clinical services.  That's fine, but its again an unreasonable expectation to have an appointment scheduled for an immunization and expect the pharmacist to drop everything they are doing for that appointment.  In the setting of appointment-based clinical services, a pharmacist dedicated to that service should be scheduled outside of the pharmacist dedicated to dispensing prescriptions.  I can recall a recent conversation with my district manager wherein I had turned away several vaccine appointments because I was the sole pharmacist on duty and, between the walk-in vaccines and the volume of the business at the time, I was unable to accommodate those additional services.  Because one of the patient's had complained, I was in no uncertain terms told that I was to take appointments first, ahead of anything else going on in the pharmacy, and that in no circumstances could I ever turn away a shot on the basis of how busy the pharmacy was.
  • Another popular tool has been the introduction of "net promoter scores (NPS)".  Or, how "happy" your customers/patients are based on a 5-point scale.  Technically, since a pharmacist cannot be terminated over failing to meet metrics, the NPS score is where its at now if you want to get rid of a pharmacy manager or pharmacist.  Regulations should encompass NPS scores as invalid for performance evaluations.  We've all had the experience of a survey at a business; healthcare is no place for these surveys.  The people that answer them are either very pleased with the business, or angry and want to make a point.  While there can be learning moments from these survey responses, corporate management also holds them over pharmacist's heads.  Anytime we have a neutral (3/5) response, we have to call and find out what we can do better.  99% of the time its "fill my prescription faster" or "hire more help so I don't have to wait in line as long".  On average our pharmacy will have the prescription done in 10 minutes or less, or, in the name of customer service, will fill it while they stand there in less than a minute.  We, as pharmacists, cannot objectively approach a patient when we are held to survey results.  Pharmacists naturally want to help people; that being said the answer we give is not always what the patient wants to hear.  That does not mean its the wrong answer, but it also should not lead to me having to deal with my district manager to explain why the patient was upset that I didn't comply with their demands.  There have been multiple attempts at evaluating the effects of patient satisfaction surveys on healthcare outcomes; the results are a mixed bag.  In some cases it appears patients satisfied with their care are more adherent and have improved outcomes, while in other studies it appears that tying satisfaction surveys to performance results in worse outcomes.  In either case, like production quotas and quality metrics, pharmacists and pharmacy teams should not be held to NPS scores as performance measures.

Ultimately, legislatively the issue with DIR fees and PBMs needs to be addressed, as in my own personal opinion PBMs are the root of the problem.  Pharmacy is the only business, to my knowledge, where we sell a product or service for less than its value, and have no guarantee to ever get paid for the full value of that product or service.

I believe the regulations as proposed are a good first step, but they don't go far enough.  Simply because, by their interpretation, corporations can truthfully say "we meet these regulations" and continue pushing pharmacy teams to the breaking point at the expense of patient safety.  The regulations to address working conditions should be clear, black-and-white standards much like the physical standards of pharmacies, that do not leave any room for interpretation.  In summary:

  • Break periods should be clearly defined, with clearly stated requirements for breaks with regards to shift lengths, break length, and number of breaks
  • Regulations should establish staffing minimums to safely operate a pharmacy that a clear and unambiguous and address the prescription volume that warrants multiple pharmacists, as well as clearly state staffing levels required for clinical services in addition to dispensing.  Regulations should also clearly state that no pharmacist should be required to work alone without at least 1 certified technician at all times.
  • Pharmacies that offer appointment-based clinical services in addition to traditional dispensing should staff an additional pharmacist during those hours that appointment-based services are available, whose sole responsibility is to provide care for those patients to allow the dispensing pharmacist to focus on safely dispensing medication.
  • Regulations should clearly state that production quotas and metrics in addition to patient satisfaction surveys shall not be introduced to the pharmacy for the purpose of pharmacist or technician performance evaluation.
CommentID: 220446

10/25/23  9:35 am
Commenter: Anonymous

Thirty minute break time ...

We will not get an uninterrupted break time to eat unless this is enforced by the Board by a designated lunch time that has to be posted and given.

CommentID: 220447

10/25/23  10:12 am
Commenter: Norther Virginia retail pharmacist.

Pharmacist working conditions

We need more help. A pharmacy that fills 400 prescription a day plus all the vaccination needs three full time pharmacist plus two full time technicians working together to provide a safe service to customers. In a place we work RPH gets no break. Every company must give their pharmacist half an hour break by closing the pharmacy for half a hour. A pharmacist should not work for 9 hours without lunch or bathroom break and provide excellent service day after day. For every 150 prescription we need to add another pharmacist. Pharmacist can not type , count , dispense and ring up customers all by herself or himself  and run out to give vaccines too  in a safe manner. Every  pharmacy must have enough techs and clerks so the pharmacist does not have to juggle between typing, counting ,counseling ,answering the phones and giving immunization. It is physically getting impossible and mentally putting the pharmacist under so much pressure. No patient is safe under this working condition and mistake might happen every day. Company should hire immunizer for busier pharmacies.
we can not be on top of the all  the metrics while juggling to serve the patients who are standing right in front of us for their prescriptions or vaccinations. Most of us have to stay over after closing to keep up with the metrics. Working conditions for most pharmacists are getting unbearable to the point that no one wants to work for retail. We need help and we need change for patients safety and our mental health. We need more help. We can not work under this much pressure day after day. 

CommentID: 220448

10/25/23  11:54 am
Commenter: Anonymous

Too much work load and stress for little payment

The work load is too much and it adds to the stress level. This will cause more mistakes for the pharmacists.

CommentID: 220449

10/25/23  12:17 pm
Commenter: Anonymous

Working conditions
  • While this regulation helps it does not go far enough. A PIC can try to set limits on volume and conditions alone, but ultimately that person could potentially be fired at the will of the organization. Also, the new requirements for technician certification impedes our ability to train  and retain new hires. The process is too lengthy. This is leading to less help available at the tech level.
CommentID: 220450

10/25/23  12:42 pm
Commenter: Eric Paradisi


I have been practicing pharmacy in VA for 28 years. I support this measure to improve patient safety and pharmacy working conditions. I am conserved that it will not be enforceable. 

CommentID: 220451

10/25/23  12:53 pm
Commenter: Anonymous


We need a better and more humane working conditions 

we have been working in terrible and exhausting environment 

none stop without break and lack of help 

CommentID: 220452

10/25/23  1:52 pm
Commenter: Anonymous


Support!!! I have seen many pharmacists have strong physical and emotional exhaustion at work. We need work-life balance. 

CommentID: 220453

10/25/23  2:02 pm
Commenter: Emily Gelzinis


I support better working rules for pharmacy staff. It all comes down to patient safety and better working conditions lead to better outcomes for both our patients and our pharmacy staff. 

CommentID: 220455

10/25/23  2:38 pm
Commenter: Kimberley Paradisi


 I have been practicing pharmacy in Virginia for over 2 decades. I support this measure to improve patient safety and improve working conditions in the pharmacies. 

CommentID: 220456

10/25/23  2:55 pm
Commenter: Northern Virginia Pharmacist

Very stressful work conditions with little help and pay!

Being a Pharmacist has become my worst nightmare. The stress has become overwhelming. Working in the pharmacy is not healthy for the Pharmacist or their staff. Everyday there are new expectations with less help! We need Help Changing the way pharmacies are operating and how the pharmacist are treated.

CommentID: 220457

10/25/23  6:10 pm
Commenter: Anonymous


Work way too hard and much just to have pay amounts that do not match the effort put in. The amount of stress dealt with compared to how much we are being payed is not adding up. 

CommentID: 220459

10/25/23  7:02 pm
Commenter: Anonymous


We need a safer and a better environment to work as pharmacists 

we have been working 12 hours with no breaks or sufficient help 

mistakes will keep happening, we are dealing with patients life here

we can provide a lot more with a better help 

CommentID: 220460

10/25/23  8:23 pm
Commenter: Anonymous


In order to properly pactice the oath of the pharmacist, there needs to be safer working conditions for pharmacists and their staff.  Safer working conditions including at the minimum a proper meal break without interruption and qualified support staff is critical to providing the best care to patients who are becoming more reliant on community pharmacists for care.

CommentID: 220461

10/25/23  10:16 pm
Commenter: Northern Virginia Pharmacist

Retail pharmacy is sadly going downhill !

I love practicing pharmacy in the retail setting. I have been working at the same pharmacy for more than 20 years. I know many of my customers by name, know their medications, their preferences. I have been helping whole families with their prescriptions, seeing the kids growing up, graduating from high school, from colleges. My customers and I, we are like a big family. For recent years, the significant meaning of helping my beloved customers to get the medications that they need at the price they can afford to help them getting better, that meaning is getting smaller and smaller. Instead, stress, work overload, pharmacy budget cut, and a myriad endless demand of chores required by the company are interfering with my time and energy dedicated to the profession of pharmacy.

Retail pharmacy is now a place where we are supposed to make money for the boss. Profit, sales, prescription count, labor cost saving, these are the goals. Nobody cares about pharmacists working 12-hour shift and spend significant time before opening and after closing time to get things done. Being a pharmacy manager is not money worth, it means spending more time out of the regular working schedule to get things done without getting paid. It is very damaging to our health when we work 12 hours in a row without a real break, taking 1-2 bathroom breaks ( 2 bathroom breaks is a blessing from above) and eating junk food full of sugar and rely on caffeine to give us energy to function. Since we do not have a Union, we do not have actual meal break. Since we are salaried employees, we do not get paid overtime if we stay to work after closing the pharmacy to get things done. The more dedicated we are to the profession of pharmacy, the more time we work without getting paid and the faster we are digging our graves. 

The pay rate for pharmacy technicians are laughable, dirt cheap. We rely on good pharmacy technicians to help us throughout the day. It is not easy to train a cashier to become a pharmacy technician. The new online training requiring 400 hours of learning makes it very difficult to hire people interested in working at the pharmacy. People can find a job paying $16, $17, $18 an hour at various places, why working as a tech-in-training earning less than $13 an hour for about 2 years and once passing the National Pharmacy Tech Exam only receiving a tiny pay increase and working as a pharmacy technician earning $15.20 ( my recent tech passing the exam in August after almost 2 years working on the online tech training program ) !!!!!!! The company does not want to increase the pay rate of our knowledgeable pharmacy technicians. Of course, we are losing good pharmacy technicians left and right, leaving retail pharmacy after a few years to work in hospital pharmacies with better salaries. 
Cannot even keep a technician after 8 hours of work to help with the crazy workload because of overtime, forbidden by the company. It is cruel pure human labor exploitation when pharmacists are working extremely long hours before opening and after closing for years without getting paid to try to finish the heavy workload. Well, cannot blame capitalism,   can we ? 

Vaccinations is profit making, money making for the company. Walk-in welcome, online appointments set at 15 minutes per slot. It takes time to give a shot, and it takes tremendous time to key in the computer a prescription for vaccine ( lot number, expiration date, name of the provider, what dose number of Covid shot provided )..Besides vaccinations, pharmacists are supposed to check prescriptions keyed in the computer by technicians, check drug interactions, filling prescriptions, receiving verbal orders from doctors, on hold with other pharmacies to transfer prescriptions, .. We are human beings, not machine. We have a speed limit, energy limit, mental and physical able to do up to a certain amount of duties in a limited amount of time. When it comes to the point that the crazy workload with limited help can result in harm to our customers, harm to the pharmacy personnel, regulations about pharmacy working conditions need to be created and reinforced.

Sadly, pharmacists are replaceable. Any burned out retail pharmacist can quit the job and the company will hire another pharmacist to work. 
As long as companies keep paying a low pay rate to pharmacy technicians and pharmacy clerks and keep a low pharmacy budget, high turnover in pharmacy personnel will cause a lot of mental, physical and emotional damage to the retail pharmacist. Money is the key part to improve pharmacy working conditions, and sadly, I personally think that the Board of Pharmacy has no power in making working conditions in retail pharmacy better and safer. 



CommentID: 220462

10/25/23  11:07 pm
Commenter: Northern Virginia Pharmacist

How is this even a job anymore?

It feels like we are slaves to the public tolerating verbal abuse daily, threats about metrics from corporate, and being told we can all be replaced for new hires at a lower pay rate.  All this without a meal break, inability to see the light of day for 12 hours, and God forbid you have to go to the bathroom.  It's no longer a's jail.

CommentID: 220463

10/25/23  11:12 pm
Commenter: Support



CommentID: 220464

10/25/23  11:45 pm
Commenter: Mei Wu


What is the purpose of emergency regulations if company like Giant Foods completely disregard it?   Please, speaking from an exhausted pharmacist, change Virginia Emergency Regulations into a law.  Your pharmacy teams and your patients need your SUPPORT! Thank you! 




CommentID: 220465

10/25/23  11:53 pm
Commenter: Anonymous

Great first step

I have been a pharmacist for 13 years, and every year the position seems to be a bit more difficult. I think that these new regulations are a great first step. I would only ask that they be enforced against chains. Right now, the day to day tasks are almost impossible to fulfill as we usually don't have adequate staff. The work environment has slowly become unsafe over the last decade. 

CommentID: 220466

10/26/23  12:47 am
Commenter: Northern Virginia Pharmacist

We are at the mercy of the VA BOP

I completely support and admire the VA BOP for finally implementing something for their pharmacists.  We are at the mercy of the VA BOP to permanently implement these regulations.  If not, then it will all be for nothing.  As a pharmacist, I am thankful for the new support and acknowledgment from the Board that we are humans and not robots designed to fulfill a greedy company's metrics.

CommentID: 220467

10/26/23  8:34 am
Commenter: Anonymous


As a pharmacist, I support this!

CommentID: 220468

10/26/23  10:19 am
Commenter: Jenny



CommentID: 220469

10/26/23  10:24 am
Commenter: Anonymous


patient care is in jeopardy due to the CURRENT DANGEROUS working environment pharmacist have to work in every day.

It is very very very very easy to make a mistake when YOU are the ONLY person working at a pharmacy for 12 hours shift with NO bathroom break and NO meal break. These are all tasks, a pharmacist have to do on a daily basis every day such as: you have to accept the incoming medication order (example 1- 15 totes full of medications), accept incoming mail with potential vaccines that need attention immediately (whether they need to be put in fridge or freezer according such as flu, covid), accept doctors or other providers (nurse, physician assistant) calling in prescription over the phone or making adjustments to prescription or other questions from providers all over the phone, taking care of the line for people trying to pick up prescription in-person, taking care of people trying to drop of prescriptions in person, giving vaccines, typing in-coming prescription in the electronic system, pre-verify prescriptions, counting prescriptions by hand these days (because counting machine(for example Kirby) is broken these days and corporate has no comment if they will replace it or not),verifying prescription, answering question from patients/customers or their family member in person, answer question from patient/customers on the phone, trying to refill a prescription from a patient who is calling in from the phone, trying to meet vaccine quotes from corporate (for example: we are not allow to have zero flu shot quote for the day right now), dealing with recalls (can be 1-5 recalls in 1 day), trying to listen to conference calls about new updates, trying to do random corporate miscellaneous task that are handed to us and tell us we are not allow to have a zero count for the day ( example: corporate telling us to advertise a coupon book and with the profit that corporate will donate to a random charity), and then finally customer service every day ( for example: trying to apologize to the customers that get frustrated with me because that prescriptions cannot be done in 1-5 minutes because I am only person at the pharmacy and there is 1-20 task at any given time from 1-20 different people in different locations all waiting to be done and I am only human and can only do 1 task at a time.

I thank board of pharmacy so much for attempting do something about the work place environment for pharmacy but this is an only start and more needs to be done! please please please make it a law- please! Patient care is very important but when a pharmacist health is imposed by the environment that they are given, how can a pharmacist under all this stress be expected to take care of a patient with optimal care? It only leads to mistake being done, and patient care being impacted as a result.  And what of the results from all this? When a mistake is done in the pharmacy, a pharmacist try to resolve it through calling the doctor and patient and following up with them, writing up that incident report (which can take 1-4 hours), follow up report about what can be done better (and the answer to just double check everything and be  more aware next time) but it is really better? when you are the only person at the pharmacy and this same mistake can happen again because you have a burn out pharmacist as a result?

What is the answer from corporate? just fire that pharmacist- they are replaceable. 

you get a burn-out pharmacist that is fired as a consequence and a result from the current working conditions that pharmacy have are in practice right now. 

pharmacist study 4 years in graduate school, and 1-4 years in undergraduate school to get the pre-requisite, get burn out from work due to the current work environment and can get fired in 1 day. pharmacist are humans. customer service is never easy. patient are very important. but you as a person have to healthy yourself to have the energy to take care of another person(patient) so PLEASE BOARD OF PHARMACY - please make laws to help optimize patient care and help pharmacist so they are in a safe work environment to do so because pharmacy CURRENT WORK PLACE IS NOT SAFE for patient and pharmacist at the moment.

Oh, and you ask: why do we not hire more people you ask? because it is impossible to find a person who will help this pharmacist with all the task listed above (see the text above) at MINIMUM wage due to current union laws and minimal wage, anyone can find a better job outside the pharmacy for 20 dollars easily. (for example: you can get paid $20 dollars per hour at McDonald's and that is the minimal pay at McDonalds). so why would anyone bother to work at pharmacy and help a pharmacist??? that is exactly the reason no one apply at the pharmacy. 

The new regulation that board of pharmacy put in place around July 2022 about pharmacy tech in training hinders the pharmacy currently- so even when we(pharmacy) get a person to train( tech in training), they (the tech in training) is spending all their time doing the modules and quizzes that are required by board of pharmacy about learning what a tech in training does and knowledge they are supposed to know and as a result: there is almost no minutes left for a pharmacy tech in training- to help pharmacy with any other tasks or help a patient out. The amount of time it takes to train a tech-in-training into a pharmacy tech increases due to the current regulations, laws so help is very hard to find these days at the pharmacy and when a tech-in-training is spending all their time with modules and a customer comes into the pharmacy, the tech-in-training is still learning and has to depend on the pharmacist to come out and help the patient themselves, which just adds another task to do on the already burn-out pharmacist.

board of pharmacy please- please help patient care be optimal by creating a safe environment for pharmacist to do so because corporate does not care. and pharmacist are humans too just like patients. the care of patient is very important to pharmacist. pharmacist try everyday to do so by giving it their best every day- getting burn out for the patients. we just get yelled at by patients and corporate everyday given the circumstance we are in.

nothing will change without the board of pharmacy. CHANGE Is needed. please board of pharmacy- the future rest on you.

signed a-very-burned-out pharmacist- in northern Virginia.




changes that I recommend to board of pharmacy

-please make it illegal for a pharmacist to be alone at a pharmacy.

-if there is a immunization clinic- the time it takes to process a vaccine through a patient insurance - pharmacist should also be allowed to get paid for that.

-consider creating remote jobs where someone can help a pharmacist type prescriptions on the electronic system.

-allow pharmacist to have a meal time/bathroom break without getting yelled at by a patient

-increase minimum hourly pay for pharmacy clerks, tech-in-training so pharmacy can find help

-outlaw vaccine quotes or miscellanous quotes- task that corporate require pharmacist to do- such as selling a coupon book (because that is taking time away from patient care)



CommentID: 220470

10/26/23  1:26 pm
Commenter: Northern Virginia Pharmacist

Company greed leads to deteriorating pharmacy working conditions

Money, money, money. Profit, profit, profit… Keep chanting these words because it is the daily mantra while working at the pharmacy.

Making more and more money is what a for-profit-company aims for. Pharmacists are now a dime a dozen and can be fired at at any time, replaced by a younger pharmacist that will work extra hours without paid, without complaining, so grateful to get a job that helps to pay off the huge student loan. 

We have a primary computer at the pharmacy that automatically shuts down after a few minutes without printing activity and we have to turn the power off or pull the plug to get it restarted numerous times in a 12-hour shift, also helping us to get some exercises lifting that heavy computer out and put it back in after restarting it. Thanks to the company who refuses to give us a new printer, we have to work with that piece of trash for more than 3 years. The support tech comes many times but cannot do anything to fix the printer to make our life easier.

Ordering supplies is another nightmare. Cannot order too many toners for the pharmacy printers, cannot ask for more cases of legal paper… With more vaccinations processed, more prescriptions processed, the printer runs out of ink faster. The manager and  assistant manager of the store were transferred to another store, the new manager and assistant manager are on duty but their information still lingers at their former home stores. Nobody in the store knows or has access to order supplies. Is it adding stress and pressure to a pharmacist ? Yes, definitely yes.

Just simple things like inadequate supplies can become a straw that contribute to negatively impact a pharmacist, mentally, physically, psychologically. Let alone the inadequate help at the pharmacy. Do not even mention the damage inflicted on the pharmacist’s kidneys due to lack of bathroom breaks. Cannot even eat anything out of a bland diet if having some time to ingest some nutritional thing to keep us alive and functional. 

Corporate greed will never leads to improved pharmacy working conditions. The lack of pharmacy inspectors from VA Board of Pharmacy means that any suggestions/ laws passed by the Board to make pharmacy working conditions safer and better will not be reinforced. Paying a fine to the Board is just a tiny sum of money for corporates in comparison to the money saved by imposing a low pharmacy budget with limited help and demanding higher and higher prescription count and prescription sale with just one pharmacist working daily at the pharmacy in most pharmacies. 

Too coward to put my real name for fear of retaliation/ retribution. 
Admire the CVS pharmacists and Walgreens pharmacists walk out to demand better pharmacy working conditions. 










CommentID: 220471

10/26/23  4:26 pm
Commenter: Anonymous

Expanded Scope of Practice without Expanded Resources

Growing up, I didn't see pharmacists doing half of what they do now. While pharmacy technicians are required to be trained and certified, that assistance does not make up for a pharmacist who is overwhelmed with all of the tasks s/he is required to perform.

The emergency regulation needs to be made a law.

CommentID: 220472

10/26/23  6:47 pm
Commenter: Stacey Wilcox

Safe work is healthier

Drug errors are dangerous.  Quotas are dangerous.  Distractions are dangerous.  Yet, distractions as part of regular workflow and quota systems are found in most pharmacies.  Why?  Because the financial bottom line, not patient safety, motivates most corporate decisions.  Nothing about this is new.  What is new is the volume.

The volume of medications available on the market, the volume of patients per pharmacy, the volume of DUR issues that must be reviewed and mitigated have all increased drastically in the past 10-20 years.  Add this increased volume to the idea that most staffing decisions are based on financial reviews done by non-health care trained individuals and we find ourselves in the current dangerous situation; those who have the training and desire to prevent drug errors are not afforded the proper time and focus to do so.  

It is far past time for our regulatory institutions to step in and create formal guidelines for safe staffing practices and working conditions that promote safe patient outcomes within our pharmacies.  I firmly support these newly drafted regulations. 

CommentID: 220473

10/26/23  9:22 pm
Commenter: Anonymous


Lunch break is a right for health care workers.

CommentID: 220474

10/27/23  4:02 am
Commenter: Anonymous


Lunch breaks should be a right for everyone. It’s very hard to take care of patients when you are by yourself at the pharmacy as it increases the risk for mistakes for an error to happen substantially. Please make it a rule that pharmacist are never by themselves. Corporate always starts cutting help hours in summer and then in the fall when we do flu vaccines- and the need increase for other vaccines like rsv, or Covid, pneumonia increases the amount of work . Then we do not have the help we need to do more in the pharmacy. Pharmacist come 1-2 hours before work and stay 1-3 hours after work to finish work every day to make up the difference but is that fair? Please find a way so pharmacy can find help . No one applies to be a pharmacy clerk or tech  these days because the pay is minimum and the amount of work to the job does not correlate accordingly.  My pharmacy been looking for help since July and no one has apply because of the minimum pay but corporate does not care. The vaccines quotes should be outlaw. Corporate only care about profit. Everyone at the pharmacy is getting burn out and it affects patient care. No one wants an error to happen ever. When everyone is burn out at pharmacy, error happen and patient care is impacted. 

CommentID: 220475

10/27/23  8:34 am
Commenter: Anonymous

VA Pharmacist


CommentID: 220476

10/27/23  9:33 am
Commenter: Anonymous


In the Fall, we are always behind in our work because everyone is sick (and needs medicine) or wants vaccinations and we do not have enough hours in the workday to fill every single medication that comes in and we fall behind or barely keep up. After flu season is over, corporate cuts hours so then we start to fall behind because we do not have enough people in the pharmacy to complete the work that needs to be done. The pharmacist at my site never takes a break during the day because it would just mean we would fall behind even more. There needs to be more than one pharmacist in the pharmacy at a time during peak hours and during lunch breaks so that a pharmacist feels comfortable taking a break. All of the staff are making more mistakes because we have a large volume of patients and not enough staff, and instead of corporate making it a priority to try to hire more people they just come down on current employees really hard with punishment for their mistakes. We should be punished for mistakes, but it needs to be recognized that the conditions we are working in are causing these mistakes to happen more frequently. Corporate should be required to give a store/pharmacy more hours overall based on the volume of work they have, not based on what season it is. Corporate should also be taking fault in the conditions they are subjecting community pharmacists and technicians to, which causes mistakes that affect patient care. 

CommentID: 220477

10/27/23  11:07 am
Commenter: Anonymous


Too much workload, less pay, less help, no lunch break. Pharmacists are being abused. 

CommentID: 220479

10/27/23  12:03 pm
Commenter: Anonymous


As a former tech that left the field due to not seeing a fair future, I support this action.

CommentID: 220480

10/27/23  12:30 pm
Commenter: Eric Haas

Vague and unenforceable

This is long and wordy while still being too vague on specific points.  This meets the requirement to create workplace legislation without actually changing anything.  Specifically, it’s attempted standards will remain unenforceable.

CommentID: 220482

10/27/23  8:25 pm
Commenter: Northern Virginia Pharmacist


Than you for beginning to pave the way to support your pharmacists.   It's been a long time coming.  However,  our profession wouldn't be in this situation if something was done proactively. 

CommentID: 220485

10/29/23  4:25 pm
Commenter: Anonymous

Understaffed and corporations not doing anything about it unless the law is changed!!

Pharmacies are understaffed and pharmacists are overworked and all corporations care about is business and productions but neglect hiring sufficient staff nor increasing pharmacy technician pay despite the rigorous training and work put into registering for the tech in training program. Then they quit after all the training is done and they are a licensed technician because the pay is not competitive enough. The law needs to change to provide better staffing and increase technician pay. 

CommentID: 220486

10/29/23  11:36 pm
Commenter: Pharmacist, Giant Food Pharmacy

Please help me serve my patients better.
18VAC110-20-110 section E Please take note that my employer has made it clear that legal action will be taken against any PIC who removes a pharmacy permit upon leaving. Please update this section to instead read, PIC will notify the Board of Pharmacy in writing immediately upon leaving post. 
Please update and approve the emergency working conditions regulations into law to help me provide better patient care for our community. As of now, my employer has made no changes to support your emergency regulations.
18VAC110-20-113 section A & B The PIC name is on the pharmacy permit. The PIC does not have the ability to provide the objectives of this section. Please update wording to read the employer of the PIC, unless independently owned. Otherwise, I foresee corporate twisting your intentions.
18VAC110-20-113 section D Please update this section to require a copy of the form also be sent to the Virginia Board of Pharmacy, documentation and action(s) taken to be reviewed upon subsequent standard inspection. Every company claims to have an anti-retaliation policy, but unfortunately I do not feel that a company has its employees in its best interests when it comes to profit. Please re-word this section to include such follow-up to strengthen this section and further protect the PIC and the pharmacist-on-duty reporters
Current working conditions have pharmacy teams overworked and stressed to unhealthy levels. While it is often mandated that pharmacy technicians receive breaks, it is currently near impossible at many stores for the pharmacists to eat or even use the bathroom during shifts. When your board put a 30 minute break into law for pharmacists years ago, my supervisor told me I could take a few minutes here, a few minutes there and that I did not need to eat my full meal in one sitting.
I know too well, that working without pause for up to and over 12 hours per day not only decreases my ability to give my best patient care, but also increases my risk of prescription errors. The current work loads this fall have been unbearable for many pharmacy teams who are short-staffed. To add to insult, our supervisors repeatedly demand that pharmacists break the pharmacy oath and put more profitable immunizations before patients in need of prescriptions. 
Since the pandemic, there has been tremendous turn over in pharmacy teams. Your community pharmacists are not only working on prescriptions, providing immunizations, doing strep/flu/covid testing and every day pharmacy tasks; but continually training new team members which is both exhausting and patience sapping. 
On a grand scale, current working conditions have affected the ability of pharmacy schools to draw qualified applicants resulting in lower graduating classes. As a preceptor, I had one student graduating in 6 months who could tell me very little about drugs and a third year student who could actually not tell me his own name in a coherent fashion. I worry about the future of the pharmacy profession if talented students keep choosing other professions. How will patient care change in the years to come if graduating pharmacists become those who would not have been chosen for enrollment otherwise? 
Please take permanent action to not only allow pharmacy teams to serve its patients in the best way possible, but also long term save the pharmacy profession. I call on you as pharmacist: Please uphold the oath you took at graduation to "embrace and advocate change in the profession of pharmacy that improves patient care".


CommentID: 220487

10/30/23  10:50 am
Commenter: Anonymous

Working condition are not good and it affects patient care

Working conditions are not great. Pharmacy are severely understaffed everywhere in every chain -. There is never a overlap between pharmacist ever. Growing up - I heard 3 pharmacist work on the same day at the same store, and new pharmacist can ask an more experienced pharmacist any question. These days- new pharmacist get a few day training and then you are on your own. That’s still going to affect patient care in a not good way. Sometimes, just having one technician with me- you think I as a pharmacist has enough help to help customers for the whole day? You’re completely wrong!!!

Not all technicians are good! Some technicians need you to do their job for them and my own job so then I’m doing two jobs while this one technicians just becomes reduce to a cashier clerk and nothing more. Who’s typing all the prescription, pre-verify all the prescription, counting all the mediations by hand, verifying all the prescription, bagging all the prescription, putting away medications, doing the order, pick up phone and answer question, do vaccination- it’s the one pharmacist by themselves. Why don’t I get better technician? Because it’s either I’m by myself or have this one technician. It’s hard to find help these days because no one apply to be a pharm technician at minimum wage and the union stops the pay from increasing. How am I supposed to provide great patient care when  I’m doing two people jobs? It’s put a huge strain on my own body as a result and I’ve lost several pounds in the last couple years due to this increase stress since the pandemic.

There needs to be a safe environment to provide patient care . But the current working conditions do not provide that. You get a burn out pharmacist 

CommentID: 220488

10/30/23  2:27 pm
Commenter: Anonymous

This is a start, but more needs to be done seriously. Support

There is not enough help in the pharmacy, every pharmacy needs more help. Safeway, Harris teeter, Giant food, CVS, outpatient, hospital, Costco, Walgreens, Wegmans- every single pharmacy I go to- I hear the same thing - not enough help at the pharmacy. The number of prescription we do a day and the amount of work we put in to fill those prescription - we have to kill ourself to pump out those prescription every single day.  This impacts patient care. Every day, guidelines change, we have to do more things . New vaccines like RSV for examples. Do strep test. Do curbside pickup. Do mail prescriptions. Advertise coupons books. Advertise reward programs for the corporate with no break or lunch break. Dealing with slow internet and technology issues 

even though I come 1-2 hours early and I stay 1-3 hours after my shift, work at the pharmacy is never done. Inventory. Transferring medications to other pharmacy to reduce expires. Pulling expired medication. Scanning consent form  for vaccines several hours earlier. Submitting information to government for Covid vaccines- whether it’s was left or right deltoid thing. Dealing with the drive though section of the pharmacy.

No one applies to pharmacy for work as tech or tech in training anymore these days with the current pay being minimum wage. How am I supposed to provide great patient care without being distracted every second with another task from corporate and not enough help? I’m human and a person . I try my best but how do I tackle 1-300 prescriptions a day without enough help? This impacts patient care.

this is a start but more needs to be done! 

CommentID: 220489

10/31/23  11:45 am
Commenter: Anonymous


Pharmacists need better work conditions for several reasons:

  1. Patient Safety: Pharmacists play a crucial role in ensuring the safe and effective use of medications. Fatigue and stress due to long working hours can compromise their ability to provide accurate medication counseling and prevent medication errors.

  2. Workload: Many pharmacists face heavy workloads, with high prescription volumes and administrative tasks. Improved work conditions, including manageable workloads, can enhance their ability to provide quality patient care.

  3. Mental Health: Stress and burnout are common in the pharmacy profession. Better work conditions, such as reasonable work hours and breaks, can help safeguard the mental well-being of pharmacists.

  4. Staffing Levels: Adequate staffing is essential to meet patient needs. Understaffing can lead to rushed work and potential errors. Better work conditions should include appropriate staffing levels to ensure patient safety.

  5. Career Development: Pharmacists may benefit from opportunities for professional development and continuing education. Improved work conditions can allow them the time and resources for career growth.

  6. Respect and Recognition: Pharmacists are highly trained professionals, but they may not always receive the recognition and respect they deserve. Better work conditions can help foster a more positive and supportive work environment.

  7. Job Satisfaction: When pharmacists have better work conditions, they are more likely to be satisfied with their careers, leading to improved job performance and patient outcomes.

In summary, better work conditions for pharmacists are essential to ensure patient safety, protect their mental health, and enhance their job satisfaction, which ultimately benefits both healthcare providers and patients.

CommentID: 220492

10/31/23  11:49 am
Commenter: Anonymous


Better work conditions in pharmacies are crucial to enhance patient care by reducing the likelihood of medication errors. These improved conditions can help prevent fatigue and stress, which can lead to mistakes. They enable pharmacists to pay closer attention to detail, reduce rushed work, and minimize distractions, resulting in more accurate medication dispensing and counseling. Additionally, better work conditions support a healthier work-life balance, which can lead to more alert and focused pharmacists. Furthermore, they provide time for continuous learning, helping pharmacists stay updated on best practices, ultimately improving patient safety and care.

CommentID: 220493

10/31/23  11:51 am
Commenter: Anonymous


Pharmacies are often short-staffed, and pharmacists frequently experience burnout due to these demanding work conditions. This has a detrimental impact on patient care as exhausted pharmacists are more prone to making errors, especially in a high-pressure, fast-paced environment. Moreover, corporate expectations often add to this burden by continuously increasing the tasks pharmacists are expected to handle daily. The combination of short staffing, burnout, and an ever-growing workload significantly increases the risk of mistakes, potentially compromising patient safety and the quality of care provided.

CommentID: 220494

10/31/23  11:58 am
Commenter: Anonymous


Dear board of pharmacy,

I am writing to express my concern about the current work conditions for pharmacists. The pharmacy field is facing a growing issue of understaffing and increasing workloads, leading to pharmacist burnout and a higher risk of medication errors. Corporate pressures often prioritize metrics over pharmacist well-being.

I urge the Board of Pharmacy to consider regulations that improve the work environment for pharmacists, addressing staffing levels, workload management, and policies that prioritize well-being. These changes will prevent errors, enhance patient care, and create a safer environment.

Please take action to protect both patients and the pharmacists who serve them.

CommentID: 220495

10/31/23  12:02 pm
Commenter: Anonymous


Dear Board of Pharmacy,

I am writing to highlight a concerning trend in the pharmacy profession. Pharmacists are consistently going above and beyond, often arriving 1-2 hours early and staying late 1-3 hours after their shifts without compensation to complete their work. These dedicated efforts are due to an ever-increasing workload, including responsibilities like administering RSV vaccines and performing strep tests, all with insufficient support in the pharmacy.

This excessive workload and stress are pushing pharmacists to their limits, resulting in burnout and significantly increasing the risk of medication errors, which is detrimental to patient care. I kindly request that the Board of Pharmacy take action to improve the work environment for pharmacists, address staffing concerns, and implement policies to ensure fair compensation for their additional efforts.

Protecting pharmacist well-being is essential for maintaining the high standard of care our patients deserve.

CommentID: 220496

10/31/23  12:07 pm
Commenter: Anonymous


I hope this letter finds you well. I am writing as a concerned citizen and a strong advocate for patient care and the well-being of pharmacists. I am seeking clarification on the purpose of emergency regulatory measures within the pharmacy profession and urging the State Board of Pharmacy to take action in making these measures permanent to enhance the working environment for pharmacists and ultimately improve patient care and reduce medication errors.

Emergency regulatory measures are designed to address immediate and critical issues, often stemming from unforeseen circumstances such as public health crises or emergencies. These measures are typically implemented to ensure that essential services, including the dispensing of medications, can continue in a safe and efficient manner during these challenging times.

However, it has come to my attention that some corporate entities may disregard or resist the implementation of these emergency regulations, which can hinder the potential benefits they offer, not only to pharmacists but also to the patients they serve. It is crucial that these measures are not only upheld but also considered for permanent integration into the pharmacy practice for several reasons:

  1. Improved Working Conditions: Permanent implementation of emergency regulatory measures can significantly improve the working conditions of pharmacists. By addressing staffing concerns, ensuring adequate breaks, and reducing workload, these measures can help prevent burnout and fatigue among pharmacists.

  2. Patient Care: A less stressed and overworked pharmacy workforce can provide better patient care. Reduced stress levels and increased focus can lead to fewer medication errors and better communication with patients.

  3. Enhanced Safety: Permanent regulatory changes can bolster the safety protocols in pharmacies, which is vital in ensuring the accuracy and integrity of the medication dispensing process.

  4. Legal Accountability: Corporations that disregard emergency regulatory measures should be held accountable for their actions to protect pharmacists' rights and maintain the integrity of the pharmacy profession.

I kindly request that the State Board of Pharmacy review the current emergency regulatory measures and consider making them permanent through appropriate legislative processes. By doing so, you can create an environment where pharmacists can thrive, improve patient care, and reduce the occurrence of medication errors.

I understand the complexities involved in regulatory changes, but the potential benefits for pharmacists and patients alike cannot be understated. I would be grateful for any information or guidance on how to further support this cause, and I am open to participating in any initiatives or discussions aimed at this goal.

Thank you for your attention to this important matter. I look forward to your response and hope for positive action in the near future.


burn out VA pharmacist 

CommentID: 220497

10/31/23  12:08 pm
Commenter: Anonymous


I'm writing to seek clarity on the purpose of emergency pharmacy regulations and to urge the State Board of Pharmacy to enact permanent measures that enhance pharmacists' working conditions, improve patient care, and reduce medication errors. Some corporations appear to disregard these regulations, compromising patient and pharmacist well-being. Making these measures permanent will ensure a better pharmacy environment and safer patient care.

CommentID: 220498

10/31/23  12:11 pm
Commenter: Anonymous


A cap on the number of prescriptions a pharmacist can handle daily, coupled with a long-term plan for increased staffing, is crucial to improving the work environment and reducing medication errors. Corporate decisions to cut pharmacy hours can negatively impact patient care. Ensuring pharmacists have adequate support in the pharmacy is essential for reducing medication errors and providing quality patient care.

CommentID: 220499

10/31/23  12:13 pm
Commenter: Anonymous


please make sure you turn this into law board of pharmacy please. corporate don't care unless its a law. 

pharmacist don't get a lunch or dinner break and have to work over time every day. and pharmacist get burn out because its not enough help in pharmacy and its so hard to find help in the pharmacy these days.

CommentID: 220500