I am very opposed to the Board's requiring any portion of the CE requirement for pharmacists to be live.  I feel that in order for the board to impose this new requirement, it should have to provide some evidence showing that live or interactive CE is a better educational experience than self study coursework.  The Board has not provided this evidence in the documents I have reviewed thus far, but is merely expressing its opinion.  In my own experience, I have found that having to review home-study coursework and pass a substantial post-test requires much more attention to and retention of course material than sitting through a live lecture where all you have to do is wait for a CE code at the end and complete an evaluation, with nothing to prevent participants from spending the entire time on their phone or some other distraction.  Typically, live CE is a lot more expensive and inconvenient than home-study courses.  There is a plethora of home-study coursework available to pharmacists at minimal to no cost, and pharmacists can choose coursework that is relevant to their area of practice and interest, or where they may be weak and need additional education.  There is not even close to the same availability of live or interactive courses, forcing pharmacists to attend meetings or "interactive" courses that may not be offered at a time convenient to them, possibly even forcing them to take time off work or away from home/family.  Again, without a solid argument that live CE is more effective in maintaining pharmacist competency, I do not believe that the Board should be allowed to require this.  This new requirement will add substantial costs to renewing a pharmacist license, both in course costs as well as pharmacist time to attend a live or interactive program, without any stated basis or evidence shown for increased protection of the public health, safety and welfare.  

I have recently retired following almost 40 years.....yikes....from a regulatory pharmacy inspector/investigator position with VA Department of Health Professions.  I maintain an active pharmacist license and hope to continue my annual renewal.  I think pharmacists attempt to locate CE courses that are applicable to their practice setting. The majority of courses are related to clinical practice. If practicing in a hospital setting, pharmacists have many opportunities to obtain education via onsite pharmacology seminars, association meetings,  journals and online courses. Retail and specialty pharmacists can obtain education through online courses, association meetings and corporate training. I have struggled each year to find courses that provide additional education for my practice including drug security, excessive opioid dispensing and risks for dispensing errors.  However, I feel that when access to CE courses is easily accessible and affordable, a pharmacist with an active license will search for education that will keep them current with the requirements of their practice.  At least completion of an online course requires the successful passing of  a follow-up test.  I am not sure that  connecting a laptop to participate in a live  webinar or attending a speech  assures that education has been obtained.  Pharmacists who no longer practice, but enjoy the pride in maintaining an active license,  may choose to go inactive if expensive education costs are involved.

I do not think it is wise in the least to require live CE. Live CE is very difficult for people with busy lives to get, and as such it is usually attended at work where we are surrounded by distractions, or at home surrounded by distractions, or at other such places and times unconducive to learning. Quite often pharmacists will simply pick a live CE based on what best fits their schedule, rather than which topic they feel will benefit them. I have personally attended several targeted at inpatient pharmacists, even though I never have and likely never will work inpatient, simply because that was the most convenient time. None of this is helpful. Non-live CEs have a much broader array of selections, so pharmacists can pick the topics they feel they need to hone in on. And they can complete them when they have the time and focus to truly absorb and learn the material.

I am against the Live CE proposal. I agree with other commenters that we are all busy and will only pick live CEs that fit in our schedule and price range and will not necessarily have anything to do with our area of practice (ie waste of time). I would rather select CEs that are a topic that pertains to my every day job, which is much easier to do when not live. I don’t know of any evidence that shows Live is any more beneficial than not. I think it’s unnecessary and don’t see the point. I believe it would only serve to make my CE experiences less meaningful. 

Good evening,

The expectation of 5 live CEs is not much to ask for and should be supported.

Thank you,

Marcella R Brown, PharmD

With all due respect to the changes in the laws in regards to the continuing education .I feel that this will put more impact and stress on us as a pharmacist in charge , for example the change in hours is been changed when we converted from Rite Aid to walgreens from 78 hours per 2 week to 84 hours every two weeks with no pay Increases . I feel like any more regulations will make our  job harder . Big part  of our job description working for big corporate is also engaging into MTM’s  and Mirixa which takes most of our time .Also  we are part of the business plan to meet is increasing immunization. There should be a regulations to help us do our job better and more save . Like but not limited to the amount we spend ring people up on the register due to cutting labor hours , instead on focusing on filling rxs and catch possible drug interactions . 

I did my training in another state that required live CE so I was surprised that VA BOP did not require this. I feel that this would increase regional and state meetings from our pharmacy organizations and provide better networking opportunties for our pharmacist to share our ideas and struggles.  I worlk as in-patient pharmacist and at the very least this should increase the number of staff pharmacist that attend the monthly Interprofessional education events which I feel would be a benefit to our entire organization.  

I would like to see studies that prove that Live CEs provide pharmacists with significant learning outcomes versus self study CE courses. I do feel it is difficult to find and schedule live CE courses that accomadate our busy professional schedules along with family duties. Also, the expenses do add up. I am a pharmacist carrying a few state pharmacist licenses. I do not practice in Virginia but would like to keep my license active and if this increases my costs I would have to reconsider maintaining my license there.

With the new stated regulations, I believe the focus of care provided to patients in long term care facilities have been acknowledged and met with allowing a back up pharmacy to issue a 7 day supply to patients when primary pharmacy does not have medication readily available. It keep patients on track with the care they need. 

When it comes to the safety of the pharmacist and and the care of patients, the ability of allowing the pharmacist to recover a forged perscription or returning it to patient at his discreation under the circumstances will not only keep the pharmacist safe but the patients and other pharmacy staff out of harms way and trust with the pharmacist. 

As a full time undergraduate student, and managing to work 30 hours a week at the same time is stressful and leaves me with little time for my studies. To require 15 hours of in class continued education further takes away from my studies. Furthermore, the stress of having the hour requirements would hinder my grades in the classroom which I place a higher priority on. Due to the previously stated reasons, I do not agree with this amendment because it is unfair to undergraduates like myself that are trying to succee in pharmacology. 

The revisions made seem fine. As this is my first time having to review any sort of official revisions, I am somewhat confused at what the crossings out mean. As I am a pharmacy technician, I especially looked at the parts related and found most of those parts crossed out. The non-crossed out sections seem fine.

What's the logic?   Live c.e. Is a step back in the education process.  As everyone else has stated, it does not allow the pharmacist to rationally choose what type of c.e. Is needed in their practice.  I am already visualizing the all day seminars offering six hours of c.e. That can be attended, no matter what the subject matter entails.

I am against the live CE requirment for pharmacists. It is a step back in learning availibility where the pharmacist can focus their CEs on matters that pertain to their pharmacy rather than what live courses are available in their area.

I am not in favor of live CE as a requirement to renew Pharmacist license in the Commonwealth of Virginia. It is difficult to find free live CE's from websites and the times may not be good for many fulltime working pharmacists. Live CE's may not present topics that are interesting or relavent to the many areas a pharmacist may work at. I recommend against Live CE requirements for pharmacists.

There is nothing to be gained with a live CE.  Pharmacists have no time with their already over loaded work schedules rendering it difficult to find; the time, conveniently located site, an a topic relevent to practice area. There are many no cost CE’s with many topics that benefit many practice areas.

I attended one live CE once and honestly I didn’t absorb the information as well as I would like. I regretted afterwards, since it was unrelated to my field of practice yet I had to put quite an amount of efforts scheduling the time for it. I found that it didn’t help expand my scope of knowledge on the topic as I would attained in a self-study coursework. Normally, I studied/updated certain materials based on my own available timing thus enabled me that flexibility to do more research on it. 

From my own experience, I can conclude that Live CEs are costly, not conducive to my learning objectives, as well as being a time constraint to my already busy schedule.

Please don't do live CE's. Being a pharmacy technician is my job. I have  job to make money. My job costs me money. Yes you have to spend money to make money, but listen to this, the Pharmacy Technician Certification exam costs me $129 then the state licensure costs me $25 a year. Finding free or cheap CE's is hard enough. I work full time at 40 hours a week and I go to Nursing school full time. Being a technician is not an easy job. Down with live CE's Down with more regulation!

I believe Pharmacists & Pharmacy Technician’s  should complete as many hours of continuing education courses as possible to stay current with today’s issues. I agree on separating chapters for Pharmacists & Pharmacy Technician’s.

I am not in favor of changing the annual continuing education requirement to include five hours of live interactive continuing education.

I have read, in its entirety, the proposed changes to Board of Pharmacy Rules and Regs and the Statutes of the Commonwealth...and AGREE with ALL proposed changes...Once again, the Virginia Board has shown to be "pro-active" in making important changes to existing out-dated procedures...Keep up the Good Work...... Boards in the other 7 states that I am Registered IN...are still operating under out-dated and often Inadequate Laws and Rules.

Live CEs are a waste of time and should not be implemented. I am a full time graduate student and do not have the money or time to do live CE's. The board should provide some evidence that live CE's provide better training than other CE's if they really want to implement this. Also, I am confused as to how acting as a preceptor would count as a live CE. I don't have the opportunity to do this and so it places me at an unfair advantage and would require me to spend a lot of money on live CE's. 

Most of us are working full time and raising families.  We don't have time off to attend presentations.  It costs money and time away from our families - if we can get the time off at work.  I understand why live CE sounds good - sharing time with colleagues etc.  This is negated as most of us prefer to get the work done so we can go home to our familes.Thank you for understanding that work and pharmacy are not the primary reason we live. 

Live CE should not be a requirement for Pharmacist licensure.  Pharmacists should have the choice of how to receive their continuing educations requirements. 

Live or Interactive continuing education should NOT be a requirement. Live CEs are expensive, time wasting, and an ineffective way of transmitting information to Pharmacists. Traditional CEs are much better and more than sufficient in furthering the education of Pharmacy members. If it ain't broke, don't fix it.

i have attended some very good live ce classes relating to my practice of pharmacy.some were lacking in regards to our actual duties and responsibilities.i also noticed some attendees only came for the free meals!!!!

Reviewed and understood.

For community Pharmacist, I believe this requirement would be an unreasonable burden.  I know for myself and my fellow community pharmacist friends we would struggle to find these opportunities and would have to potentially pay far more to get these hours.  

I do not agree with the change to require 5 live CE hours. It is not practical for pharmacists, many of whom work more than 40 hours per week, to attend 2 or more courses throughout the year to remain licensed. In the past, the Board has required CE in a specific subject area in some years. I believe that would be the more prudent measure to ensure that pharmacists maintain current knowledge.

Dear Madam/Sirs:

I would like to respectively request that the addition of the requirement for live continuing be reconsidered.  Pharmacists do not always work hours that are flexibile enought to allow for live attendance at a particular time and/or place to receive their continuing education.  The internet has allowed me, and I'm sure other pharmacists, the ability to obtain good qualilty continuing pharmacy education at times that are convenient to my schedule and also allows me to choose topics that are both of interest to me and of particular utility to my practice.  A requirement to obtain a third of my annual requirement as live or interactive content would likely force me to take "something" that I could squeeze into my schedule, rather than a topic that was relavant. 

Thank you for taking the time to consider my feedback.

Annette L. Paul, RPh

Director, Clinical Services, Magellan Health Services

Glen Allen, VA

I am opposed to the proposed changes to the CE requirements. I do not feel there is any added benefit to requiring 5 of the hours to be live.   It puts an undue scheduling burden on the pharmacists and increases the expense of maintaining a license. Would Webinars or video teleconferences count as live CE?

I am in full support for a requirement of live CE. Pharmacists in other states have this requirement and it increases the professional network and knowledge through live CE. I was able to personally witness this through a pharmacist looking for live CE for her NC requirement. She joined the local organization and has become a more involved pharmacist in the profession. She has become an expert in her field and a role model for other pharmacists.  I look forward to this and think it will improve our quality of Virginia Pharmacist and the profession. 

I am against it because no one has 5hours to waste. The CE live can be made to 1 hour or 2 hours max. 

February 1, 2019

I have read the Agency Statement.  I'm still unclear as to what the goal is for requiring  mandatory five continuing education credits (out of the total fifteen).  This will be a huge burden to most pharmacists.  What is the goal? Please keep it simple if you reply.

Respectfully yours,

Brenda Birney, R. Ph.

C. Of the 15 contact hours required for annual renewal, at least five hours shall be obtained in courses or programs that are live or real-time interactive. Included in the five hours, the following may be credited:

1. A maximum of one hour for attendance at a board meeting or formal hearing; or

2. A maximum of one hour for serving as a preceptor for a pharmacy student or resident in an accredited school or program or for a foreign-trained student obtaining hours of practical experience.

I disagree with requiring Pharmacists to have 5 LIVE CE hours annually, when none are required at the moment. If webinars are included in the LIVE CE hours, then I can understand 1-2 LIVE CE hours annually to get us use to doing them. Then you can increase 1 hour per year at a time if necessary. However there also needs to be more readily available CHOICES of LIVE CE hour courses offered during NON-WORK hours. Please remember when LIVE CE hours are required, the costs will increase due to having a live presentation.

Thank you.

I do not agree with the required 5 hours of live continuing education.  This may be a nice option for some but should not be requied.  If more people are going to need to attend the same conference, there are issues with getting off from work.  Most of these conferences are quite costly.

I reviewed the new policies outlined by the board. I do not agree to requiring pharmacist to do 5 live CE hours. I believe the CE can do done on an array of subjects online. I do not agree that doing live CE hours is better than online courses. I urge the board to reconsider this requirement. Thank you for your time.

While, in my experience, live CE has been no more effective as a learning tool than reading an article and completing a quiz, I'm not opposed to this potential requirement however, pharmacists are likely going to have to take time away from work to attend live CE.  Due to limited availability of events and many pharmacist schedules including late evening and weekend hours, it may be difficult to make arrangements to attend during non-work hours.  If this becomes a requirement in order to maintain a pharmacist license, will employers be required to allow separate paid time off for pharmacists to attend live CE events, sufficient to account for travel time, etc?  I am currently living and working outside of Virginia and will continue to do so at least until my daughter graduates from high school.  I am also fortunate enough to have an employer who does allow paid time off for live CE.  If I were to return to VA with live CE as a requirement, this would be a significant concern.

I disagree with requiring pharmacists with active licenses to have to include 5 hours of live/interactive continuing education annually.  I understand the need for continuing education, in general, but how the pharmacist gets the requirement fulfilled, and how much of their personal time is required, should be at the discretion of the pharmacist.  I think this suggestion for change is too invasive, as it imposes significant inconvenience on the pharmacists, who, in most cases, already work long hours and give up a lot of opportunity for personal time activities with normal job requirements.

I do not feel this should be a mandatory requirement for pharmacists as many of us smaller independents are tied to our stores and it would make it extremely worrisome for us to try to find another pharmacist to cover our store in order to get away for a live CE and 5hrs of live CE at that. Many live CEs have an expense involved and if by chance they are free, there will be an expense on the business itself for what I just described in having to get another pharmacist to cover the store as well as the travel expense associated with getting to a live CE which is hopefully not an overnight stay. I have not heard the purpose or reason behind why live CE is better than CE that isn't live. I would like to know that reasoning and maybe it would change my perspective, but as of now, I feel this is more of a hindrance for not a lot of benefit and one more expense tied to a regulation that pharmacists or their respective businesses have to fund. 

Regarding the verbiage on the use of robotics with the specific wording mentioning RobotRX, there are many more pharmacy automation options available now---example, the Omnicell Carousel technology--which also has bar code scanning as a safety feature... Sovah Danville suggests more vague wording here to allow other available automation options---pending board approval.

Sovah Health Danville will remove our robot by the end of 2019 and move to the Omnicell Carousels. We will request Board review and approval of this technology so that the pharmacist will not need to check each individual dose dispensed. Thank you for the consideration.

I do not agree with the requirement of 5 live CEs. This is not feasible for many who have to work 40+ hours a week. There are not enough classes available for people to attend. The classes are not paid for by employers and most of them are biased so they are not even beneficial.