The proposed regulation involving the requirement of 5 hours of live CE out of 15 required hours for pharmacist license renewal will put an undue burden on federal employees and contribute to workplace dysfunction.  As a federal employee, I work regularly with pharmacists who are licensed in different states.  We have limited opportunities to attend live CE presentations, as these opportunities are often granted on a rotating basis for fairness and to ensure adequate pharmacist coverage.  When live CE events are announced, multiple pharmacists are usually interested and depending on the number of pharmacists employed at the institution, as well as seniority, a single pharmacist may only be approved to attend 1-2 live CE events per year. 

If this regulation is approved, it creates a situation where federal pharmacists licensed in Virginia MUST attend live CE events to maintain licensure and therefore employment.  Thus, there will be pressure on management to allow pharmacists like myself to attend these events preferentially over those who have no such requirement.  This may contribute to a sense of inequity and lead to strained workplace relationships.

Although I understand that live CE is desirable in many ways, this requirement is impractical and will create unnecessary personnel conflicts for those of us employed in federal institutions where many competing CE interests and various requirements are already in play.  Live CE should continue to be optional toward the requirement to maintain pharmacist licensure in the Commonwealth of Virginia.