The hour requirements for Pharmacy Technician education programs should be reduced, restoring alignment with prior Virginia requirements and national norms.  In addition, implement 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 that can enroll which 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.  

The program at PVCC was initiated out of a need for better qualified pharmacy technicians to be employed at UVA. Prior to the program's inception, the Pharmacy Manger of the Inpatient Pharmacy had experience with hiring candidates for open positions that had completed the Workforce Program under the PVCC umbrella and determined that individuals that completed that program performed at the necessary level for sufficient pharmacy operations. 

A formal education program allows the foundation of pharmacy operations to be taught in a focused format. On-the-job training may not be consistent from company to company. A person could be overwhelmed with trying to learn how to be a pharmacy technician while being a pharmacy technician. 

The pharmacy industry is advancing, and although the elimination of formal training programs could allow people to get hired quicker, patient safety could be at risk. 

Going from 400 hours to 60 - 80 is a drastic decrease in instructional time. 60 - 80 hours is not enough time for didactic, simulation, and experiential time. Patients' lives depend on quality training of pharmacy technicians regardless of the pharmacy setting. 

In years past there must have been a reason that instructional hours increased from 60 - 80 hours to 400 hours. Perhaps reducing the hours to 250 and have a tailored/standard curriculum that outlines specific topics to be covered (for example specific pharmacology context like just knowledge of the top 200 medications and classification).

Currently, the only way to become registered as a pharmacy technician in the state is to pass either the PTCB or NHA certification exam. If the hours are reduced, would the state go back to a state exam? 

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.

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.

I support amending 18VAC110-21-141(B)(e) because the National Healthcareer Association does not accredit, approve or formally recognize pharmacy technician training programs.  NHA functions solely as a national certifying body for individuals and does not exercise authority over educational program approval. 

As currently written, subsection B9e) references a program recognition process that does not exist, resulting in ambiguity and potential inconsistency in regulatory interpretation and enforcement. 

Amending this subsection to accurately reflect certification eligibility, rather than program recognition would enhance regulatory clarity. 

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.