In order to ensure that all patients benefit from comprehensive medication management provided by a pharmacist who is part of a health care team, Pharmacist-in-charge must be part of Section 18VAC110-60-170.

To encourage research and discovery that enhances patient care, Section 18VAC110-60-220. A.2 and A.4 should support delivery to laboratories for use in research. 

Currently, pharmacy students are allowed to perform all the duties of a pharmacist as long as they are under a pharmacist's supervision. We suggest you revise sections regarding pharmacist-on-duty and pharmacist-in-charge to allow pharmacy students to work under the supervision of a pharmacist at all facilities that have received a pharmaceutical processor permit.