Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Pharmacy
 
chapter
Regulations Governing the Practice of Pharmacy [18 VAC 110 ‑ 20]
Action Pharmacy working conditions
Stage Emergency/NOIRA
Comment Period Ended on 11/22/2023
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11/17/23  3:37 pm
Commenter: Anonymous

Unprofessional Conduct Section - Proposal for updated language
 

6. Delegating a task within the practice of pharmacy to a person who is not adequately trained to perform such a task;

If this goes into effect I can see any technician who is up to date with pharmacy law using this, and it disproportionately affecting a pharmacists' licensure. I've noticed many knee jerk responses when I am asking a technician to do something and they say, "I wasn't adequately trained to perform a task." I know with proper training documentation this can be avoided, but I don't a pharmacist should be at risk for being sent to the BOP because they asked a technician to do something completely within the scope of their professional license, especially if there was adequate training.

Proposed updated language:

6. Delegating a task within the practice of pharmacy to another person outside of the practice of pharmacy who is not trained to perform such a task; This excludes tasks delegated to pharmacy technicians that are within their scope of practice.

 

CommentID: 220650