I am writing on behalf of Blue Ridge Community College to strongly advocate for amendments to 18 VAC 110-21-141. The current regulations place unnecessary constraints on workforce development and financial sustainability for both students and colleges. We request three specific actions:

1. Right-Size Instructional Hours (60–80 Hours) We request the Board reduce the required instructional hours from 400+ back to the previous standard of 60–80 hours. This restores alignment with national norms and prior Virginia requirements. The current inflated hour requirement increases costs and time-to-completion without delivering demonstrable gains in safety or competency, creating a barrier to entry for the workforce our region desperately needs.

2. Implement a Simulation-Based Model (Eliminate Externships) We urge the Board to authorize high-quality simulation to replace the mandatory externship component. The current externship requirement creates a critical bottleneck: it imposes a financial burden on students, places strain on understaffed employers who struggle to train externs, and strictly limits program enrollment. By shifting to a simulation-based learning model, we can ensure every student masters critical skills in a controlled, consistent environment while significantly improving program accessibility.

3. Close the "Certification Loophole" We urge the Board to close the disparity in 18 VAC 110-21-141(B)(1). Currently, retail pharmacies can bypass formal education requirements by hiring "technicians in training" who complete 500 on-the-job hours and a brief online course to qualify for the PTCB/NHA exam. Meanwhile, community college students face significantly higher academic hurdles for the same credential. The regulation should be amended to ensure consistency across all training pathways, leveling the playing field for students and ensuring that competency—not the training venue—is the standard.