The Virginia Community College System appreciates the Department of Health Professions’ commitment to regular review of policies and the invitation for comment. While several of our colleges have commented here, on behalf of the system, I write to encourage considering an adjustment in the number of instructional hours required. When the regulations increased the requirement, many colleges struggled to adjust to this significant change, which impacted instructor availability, space for classes, and ongoing programmatic costs.   Data across colleges that have offered the program reflect significant declines in enrollments since the change in regulations, with some colleges reporting no enrollments. Since Fall 2023, 11 out of 15 colleges stopped enrolling students in the pharmacy tech program. Also, with the externship requirement, many rural colleges are limited in their options to find opportunities for their students to fulfill all of the current requirements. Moreover, and most important, the current regulations have created a much longer distance between students who wish to enter the field and build careers and the businesses who need to hire certified technicians.

The VCCS would welcome a “right-sizing” of the instructional program length. Perhaps there is a happy medium between the previous standard and the current one. We would welcome joining the Department and the Board in conversations about options and next steps.