Laurel Ridge Community College respectfully requests two actions as part of the Virginia Board of Pharmacy’s 2026 periodic review of pharmacy regulations:

Right-size instructional hours: Reduce the required instructional hours for pharmacy technician education programs from 400+ hours to 60–80 hours, restoring alignment with prior Virginia requirements and national norms while maintaining safety and competency via national certification (PTCE/ExCPT). This supports affordability, access, and workforce supply without compromising quality. The Pharmacy Technician program should be a simulation-based learning model eliminating the externship component. The current externship requirement imposes a significant financial burden on students, places additional strain on employers who are already understaffed and struggling to train externs and limits the number of students we can enroll which directly reduces tuition revenue and makes the program financially unsustainable. With high-quality simulation, we can ensure students gain the necessary skills in a controlled, consistent environment while improving program accessibility and reducing stress on the healthcare workforce.

Close the certification loophole: Eliminate the “technician in training” pathway that allows candidates to bypass formal education programs—undercutting accredited training, depressing completion in public colleges, and producing inconsistent preparation. Instead, it requires completion of an approved, structured education program which the regulations already clearly articulate but have undermined with this technician in training loophole. 

Where the rules are misaligned

• Inflated minimum hours for college programs (400 hours) increase cost/time without demonstrable gains in pass rates or safety—while the Administrative Code otherwise focuses on program approval + national exam competency (not a fixed statewide hour count).
• A loophole allows employers to utilize “technicians in training,” accumulating 500 hours on?the?job hours and completing a self-pace, self-guided, low?cost online course before testing—bypassing formal education and eroding the public training pipeline. While 18VAC110?20?111 requires pharmacies to maintain site?specific training and limits trainee duties to those registered as trainees, the pathway’s net effect is substitution for structured education and is unregulated and inconsistent. We have witnessed pharmacies substituting these trainees as certified technicians to avoid red tape and deal with labor force shortages.

Action: Amend regulations and guidance to recognize 60–80 hours of structured education (didactic + lab/simulation + supervised experiential) as sufficient when paired with PTCE/ExCPT—and allow institutions to configure hours across modalities (e.g., 40–50 didactic/simulation + 20–30 experiential).

 Rationale:

• Competency is validated nationally: PTCE 2024 national pass rate = 70%, and PTCE/ExCPT remain robust measures of minimum competence. Virginia should emphasize outcomes (exam + competencies) over seat time.
• Quality assurance via accreditation: ASHP/ACPE or Board?recognized programs ensure curriculum and assessment rigor without mandating an arbitrary statewide hour total.
• Access & equity: Shorter, focused programs lower tuition and opportunity costs—critical for rural, working adult, military, and low?income learners VCCS serves. Since revising the program to the new codes, enrollments have decreased 60% and workforce demand has increased.  Over 180 openings along last year were posted in the Laurel Ridge Service Region.

Safeguards:

• Retain the national exam requirement and approved?program status.
• Require minimum skills check?offs (calculations, medication safety, order entry, federal requirements) documented in program completion records—aligned to PTCE/ExCPT domains.

Impact Analysis

If the 400?hour requirement remains in place

• Reduced access & completions: Longer programs depress enrollment, delay entry, and raise non?completion risk among working adults—contrary to EO?19 calls for cost?effective regulation.
• The Laurel Ridge Pass/Completion Rate is at a 10-year all-time low
• Laurel Ridge enrollment dived from serving 40 students per year to serving only 12 per year once the regulations changed.
• Widening employer gaps: Persistently high openings vs. fewer completers extends vacancy durations and overtime reliance across retail and health?system pharmacies. (Use HWDC 2024 and Virginia Works dashboards to quantify regional impacts.)
• 182 openings in the Laurel Ridge Service Region have been posted in the past 12 months.
• Equity concerns: Costs and schedules disproportionately deter rural, low?income, and caregiving students—populations VCCS is mandated to serve.

 If the certification/registration loophole is not addressed

• Program cannibalization: Employers will default to low?cost “train?up” pathways, weakening accredited pipelines and threatening program viability—especially in rural colleges where scale is tight.
• Inconsistent skill readiness: Site?specific training is variable; without a standardized education baseline, technicians may pass an exam yet lack exposure to essential lab/simulation competencies (e.g., aseptic technique simulations, error?prevention check?offs).
• Misaligned incentives: Short?term employer convenience undermines long?term workforce development and statewide quality assurance.

Conclusion

Laurel Ridge Community College asks the Board to (1) restore a pragmatic 60–80 hour education baseline tethered to national certification and (2) close the technician?in?training loophole so permanent registration requires completion of an approved education program. These adjustments will improve clarity, reduce unnecessary burden, and strengthen Virginia’s technician workforce pipeline—without sacrificing safety or competency—fully aligned with EO?19’s review objectives.