Please thoughtfully consider the addition of Tech-Check-Tech within Part X regulating Unit Dose Dispensing Systems.

Tech-Check-Tech programs have been in existence since 1978 and are currently approved for use in 12 states. In a 2009 NABP survey California, Colorado, Idaho, Iowa, Kansas, Kentucky, Michigan, Minnesota, Montana, North Dakota, South Carolina, and Washington indicated that they allowed pharmacy technicians to check the work of other technicians in hospital and institutional or community settings. Studies have demonstrated the value of these programs in providing safe and effective care in the institutional setting. They have demonstrated that a technician's accuracy of final dispensing checks is comparable to a pharmacist’s accuracy in performing final dispensing checks. Allowance for implementation of Tech-Check-Tech programs would maintain the accuracy of the checking process and facilitate a pharmacists' involvement in providing direct patient care services.

Please consider addition to the Virginia Board of Pharmacy regulations the allowance for Tech-Check-Tech processes within Part X.  Language found in Kansas law clearly identifies the requirements for technicians who would qualify as a checking technician as well as a process for training technicians and evaluating their competency once they have met the criteria to qualify ( http://www.sos.ks.gov/pubs/kar/2013/068_68-Board%20of%20Pharmacy,%202013%20KAR%20Supp.pdf ):

"...a pharmacy technician in a medical care facility may check the work of another pharmacy technician in filled floor stock, a crash cart tray, a unit dose cart, or an automated dispensing machine if the checking pharmacy technician meets each of the following criteria:

(1) Has a current certification issued by the pharmacy technician certification board or a current certification issued by any other pharmacy technician certification organization approved by the board. Any pharmacy technician certification organization may be approved by the board if the board determines that the organization has a standard for pharmacy technician certification and recertification not below that of the pharmacy technician certification board;

(2) has either of the following experience levels:

(A) One year of experience working as a pharmacy technician plus at least six months experience working as a pharmacy technician in the medical care facility at which the checking will be performed; or

(B) one year of experience working as a pharmacy technician in the medical care facility at which the checking will be performed; and

(3) has successfully completed a written training program and related examination designed by the pharmacist-in-charge of the medical care facility pharmacy to demonstrate competency in accurately checking whether floor stock, a crash cart tray, and an automated dispensing machine have been properly filled."

Respectfully submitted for your consideration!