pharmacy business practice rules overview

Pharmacy Business Practice Rules Overview

State WorkloadPerformance Metrics and Quotas

Meals and Breaks

Quality ControlSpace for

Consultation & Clinical Services

Transfer Incentives

Accountability

AL ✔ ✔ ✔ ✔ ✔AZ ✔CA ✔ ✔CT ✔DC ✔FL ✔ ✔IA ✔IN ✔MA ✔MD ✔ME ✔MS ✔ ✔ ✔MT ✔NC ✔NE ✔ ✔NJ ✔OK ✔OR ✔ ✔ ✔ ✔TN ✔ ✔TX ✔ ✔VA ✔ ✔ ✔ ✔VT ✔WV ✔ ✔WY ✔

August 2019

StateWorkload Performance Metrics and Quotas Meals and Breaks Quality Control Space for Consultation

& Clinical ServicesTransfer Incentives Accountability

AL

Disciplinary action for Phy and RPh to agree to practice under terms or conditions that interfere with or impair prof judgment and skill; deteriorate quality; require consent to unethical conduct

RPh absence w/o closing Phy: if security of CS will be maintained.During RPh absence: Rx's may be provided to patient only if new or refill that has been checked by RPh, released, and determined no consultation req'd; techs/interns may continue to perform non‐discretionary duties.Time: 30 minute limit; RPh must remain w/in facility during breaks.

Private Consultation Areas: large enough to accommodate participants; not a storage room; must be accessible by patients without traversing a stock room or Phy area; private to both sounds and viewing; away from checkout areas and flows of traffic.

RPh and Phy should never offer a financial award or benefit to induce any individual to transfer a prescription.

If actions of Phy deemed to contribute to or cause a violation, the Board may hold the Phy permit holder responsible and/or absolve the supervising RPh from responsibility.

Disciplinary action against Phy for subverting authority of supervising RPh by impeding compliance with pharmacy laws.

AZ

Each Phy shall implement or participate in a CQIP.‐ Medication error data generated by the CQIP utilized and reviewed on a regular basis;‐ Policies and procedures reviewed biennially and revised if necessary;‐ Indentify and document medication errors; analyze data to assess causes and contributing factors;‐ At least annual communication with Phy personnel of CQIP findings and changes to Phy policies, procedures, systems or processes as a result;‐ Board oversight limited to inspection of CQIP policies and procedures and enforcing compliance with those policies and procedures;‐ Phy's compliance with the rule is mitigating factor in investigation and evaluation of a medication error.

Pharmacy Business Practices Detail

1



CA

RPh absence w/o closing Phy: if security of dangerous drugs and devices will be maintained.During RPh absence: Only refills may be provided to patient if checked by RPh, released, and determined no consultation req'd; techs/interns may continue to perform non‐discretionary duties; interns may not perform discretionary duties.Time: Breaks=minimum allowed under Sec 512 of Labor Code; Meals=30 min limit; RPh not req'd to remain w/in Phy area during breaks.

Each Phy shall establish or participate in a CQIP.‐ An investigation of each dispensing error shall commence no later than 2 days from date error is discovered;‐ All dispensing errors shall be subject to a quality assurance review to assess the cause and any contributing factors;‐ Phy shall inform personnel of changes to policy, procedure, systems, or processes made as a result of CQIP recommendations;‐Phy's compliance with the rule is a mitigating factor in the investigation of a dispensing error.

CT

Each Phy shall perform a quality assurance review for each dispensing error no later than 2 days from date error is discovered; the record shall contain recommended changes to Phy policy, procedure, systems or processes.

DCIf only one RPh, Phy shall be closed during RPh's meals and breaks.

FL

Time: 30 min limit for meals; RPh must remain on premises.During RPh absence: sign posted of RPh meal hours; only Rx's with RPh final certification may be delivered; Patients verbally informed they may request RPh contact them after meal break; Tech actuvities during breaks are considered to be under direct supervision if RPh is on premises.

Quality Related Events = dispensing errors + DUR errorsEach Phy shall establish a CQIP which contains at minimum:‐ CQI Committee‐ Committee review of Quality Related Events at least every 3 months;‐ Process to record, measure, assess and improve quality of care;‐ Procedure for reviewing Quality Related Events‐ Review shall consider effects on quality due to staffing levels, workflow, and technological support.

2



IA

See Iowa Admin Code 657.6PIC may designate techs to perform technical or nontechnical functions, except for prohibited activities. Temp absence not to exceed 2 hours.Activities prohibited during RPh absence:1. Dispensing2. Tech‐Check‐Tech3. Transferring Rx's

Each Phy shall implement or participate in a CQIP.‐ PIC may delegate program admin but maintains ultimate responsibility for validity and consistency of program activities;‐ At least quarterly meeting with pharmacy personnel to review CQIP findings and inform of changes to Phy policies, procedures, systems or processes as a result;‐ PIC or designee shall be informed of and review each dispensing error;‐ Dispensing errors shall be documented no more than 3 days following discovery;‐ PIC or designee shall analyze data to assess cause and any factors, including workflow, technology, training, and staffing levels and make recommendations for remedial changes.

IN

PIC shall assure that data are collected to monitor stability of existing medication use processes; identify opportunities for improvement; and identify changes that will lead to and sustain improvement.Quality related events shall be cause for intensive analysis of causal factors and plans for corrective actions;CQI Committee shall consider effects on quality due to staffing levels, workflow and technology;PIC shall summarize efforts to improve process on a semiannual basis.

3



MA

RPh absence w/o closing Phy: if security of dangerous drugs and devices will be maintained.During RPh absence: refills may be provided to patients only if checked by RPh and determined no consultation req'd; New Rx's checked and DUR done may be provided if log is kepatient and RPh calls patient to counsel upon return; support staff may perform non‐discretionary duties; RPh managers may, at their discretion, allow techs and interns to receive telephone Rx orders unless prohibited by law.If 2 or more RPh's: stagger breaks and meal periods.Time: not to exceed 30 minutes; RPh not req'd to remain in Phy area but must remain on premises; total absence shall not exceed 30 minutes during any 6 hour period.

MD

A Phy shall establish and maintain an ongoing CQIP.‐ A Phy shall analyze records of the CQIP at least every 3 months, describe system's weaknesses and actions to remedy;‐ Each Phy shall conduct an analysis of its medication delivery system at least ever 6 months to determine which medications are high‐alert medications; remedial actions taken and any dispensing errors relating to high‐alert medications.

ME

Vaccine Administration Clinic: must be located in sanitary, well‐maintained, adequately‐equipped space, appropriately sized for patient volume; facilitates interaction among clinic staff and patients.

4



MS

If quotas or forumulas such as Rx volume are used to set staffing, conditions such as peak workload periods, workplace design and training must be taken into consideration.

All staff should have opportunity to take periodic breaks and/or meal periods to relieve fatigue and stress; Phy not req'd to close.

Repeated transfers of Rx's between Phy's compromises patient care.

Phy's are prohibited from offering incentives of any kind for the transfer of prescriptions; RPh's and Phy's have no obligation to transfer prescriptions; transfer of CS prescriptions is not acceptable.

MT

RPh absence w/o closing Phy: if security of prescripatiention drugs will be maintained; signs postedDuring RPh absence: No new Rx's or counseling may be provided to Patients; refills previously checked may be provided to patients if counseling offered ‐ patient may wait or give phone #; Techs and interns may perform non‐discretionary duties; no telephone new Rx's accepted; new hardcopy Rx's may be accepted, but not dispensed.If 2 or more RPh's: stagger breaks and meal periodsTime: not to exceed 30 minutes per shift; RPh must remain on premises if Rx area remains open.

NC

Phy shall not require RPh to work > 12 hrs/dayRPh working > 6 hrs = 30 min meal + 15 min break

NE

Staffing: sufficient number of staff to meet patient needs

Disciplinary action against Phy for discrimination or retaliation against patient or employee who submitted complaint to DHHS.

5



NJ

Time: restroom breaks + 30 minute meal break; RPh shall remain in PhyDuring RPh break: A Phy employee must remain present to receive new written Rx's and dispense Rx's which have been checked by the RPh; sign posted.

OK

Staffing: Adequate staffing is the responsibility of the Phy, the Phy manager and the RPh.Phy Responsibility: Adequate number of RPh's to perform practice of pharmacy with reasonable safety; provide and review staffing report forms; Phy review and address issues and document corrective action taken or justification for inaction. Director of Pharmacy Responsibility: adequate staffing with sufficient number of addt'l RPh's to operate Phy competently, safety and adequately meet needs of patients.RPh Responsibility: Complete staffing report form when concerned regarding staffing due to inadequate number of support persons or excessive workload.

OR

Disciplinary action against Phy for failure to provide working environment that protects health, safety and welfare of patient, including:Staffing: sufficient personnel to prevent fatigue, distraction or other conditions that interfere with RPh's ability to practice with reasonable competency and safety;Time: adequate time for RPh to complete professional responsibilities, including DUR, counseling Rx verification, et al.

Disciplinary action against Phy for introducing external factors such as productivity or production quotas that interfere w/ ability to provide professional services to the public.

Disciplinary action against Phy for failure to provide working environment that protects health, safety and welfare of patient, including appropriate opportunities for uninterrupatiented rest periods and meal breaks.

Disciplinary action against Phy for incenting or inducing the transfer of a prescription absent professional rationale.

6



TN

RPh shall not agree to practice under terms and conditions which tend to interfere with or impair prof judgment and skill; deteriorate quality; or require RPh to consent to unethical conduct.Staffing: PIC shall be supported by a sufficient number of additional RPh's, techs and interns. All activities of Phy shall be supervised by sufficient number of RPh's to ensure competence, safety and no risk of harm to patients. Rate: RPh's, Techs and Interns may only compound at dispense Rx's at a rate, based on actual number of orders per hour or per day, that does not pose danger to public health.

Time: RPh permitted 1 temp absence not exceeding 1 hr/dayDuring RPh absence: sign posted; no Rx's may be compounded or dispensed; Rx department closed off by floor to ceiling barrier.

TX

Staffing: PIC shall be assisted by sufficient number of addt'l RPh's to operate Phy competently, safely and adequately meet needs of patients.

Owner of Class A Phy responsible for all admin and operational functions. PIC may advise owner.

VA

Staffing: PIC of no more than 2 Phy'sWorking Hours: RPh to work no more than 12 hrs/day; 6 hrs off between shifts; RPh working > 6 hrs = 30 minute break.

RPh working > 6 hrs = 30 min break Unprofessional Conduct: Advertising or soliciting in a manner that may jeopardize health, safety and welfare of a patient, including incentivizing or inducing the transfer of a prescription absent professional rationale by use of coupons, rebates, or similar offerings. is unprofessional conduct.

PIC or RPh On Duty shall control all aspects of practice of pharmacy.

Disciplinary action against Phy for any decision overriding such control of PIC or RPh On Duty.

7



VT

RPh absence w/o closing Phy: up to 30 mins if security of prescription drugs will be maintained; sign posted.During RPh absence: Only support personnel directly involved in dispensing process may remain in Rx Dept; Support personnel may perform non‐discretionary duties; No dispensing of new Rx's or counseling; Refills may be picked up by patients if RPh checked and counseling offered ‐ patient may wait or give phone #; No new telephone Rx's accepted; Refills by telephone or in person may be accepted, but not dispensed; New written Rx's may be accepted, but not dispensed.If 2 or more RPh's: stagger breaks and meal periodsTime: RPh shall not work > 8 hrs w/o a meal/rest break; RPh must remain on premises.

WV

Working Hours: RPh not more than 12 hrs in 24 hr period w/o 8 hrs off, except in emergency and documentedStaffing: Phy dispensing > 15 Rx's/hr must have Tech or TNTRPh shall not interfere in the provison of services under terms or conditions which tend to impair prof judgment and skill of anoher RPh.

Notice: RPh On Duty or Phy shall notify PIC whenever Rx error, loss of drugs, or statute/rule violation occurs when the PIC is not present.

PIC responsible for practice of pharmacy. Phy responsible for all other functions, admin and operational. PIC may advise Phy in writing on admin and operational matters. PIC not legally responsible if Phy does not follow written advice.

PIC not sanctioned for violation if gave written notice to Phy permit holder and Board of potential violations ‐ Phy permit holder is responsible for such violations.

WY

Consultation Area: "Private Space" means area separated from Phy that is no less than 48 sq ft and at least 6 ft tall partition; partition cannot be a curtain.

8

Task Force Reports

Report Date Task Force Recommendations Action Rules Revised11/18/2008 Task Force on Class C Pharmacies Preliminary Recommendations:

* change law to allow Tech‐Check‐Tech for filling floor stock and unit‐dose distribution systems* adopt rules regarding what activities should be allowed in Tech‐Check‐Tech* change law to allow Techs to work unsupervised in Class C facility of less than 50 beds* amend Pharmacy Act to require Techs to complete a Board‐approved educational program beginning 2015 * allow distributions of medications without double‐check if bar coding used

5/5/2009 Task Force on Class C Pharmacies Final Recommendations:* eliminate in‐process check of bulk compounding* Amend Pharmacy Act to allow Tech perform certain duties in rural hospital staffed by Tech: ‐ enter medication order and drug distribution info in data processing system ‐ preparing, packaging, compounding, or labeling prescription drugs ‐ filling medication cart ‐ distributing routine orders for stock supplies to patient care areas ‐ accesssing and restocking automated medication supply cabinets* require Techs to complete a Board approved educational program beginning in 2015* allow Tech‐Check‐Tech for filling floor and ward stock and unit dose distribution systems in hospitals with ongoing clinical pharmacy program

Proposed Amendments to 291.72 ‐ 291.76Proposed Amendments to 291.72‐291.76 approved Adopted 8/11/2009

8/11/2009 Task Force on Class C PharmaciesProposed Amendments to 291.133 (tech duties include garb and cleaning for sterile compounding) Proposed Amendments to 291.133 approved Adopted 11/9/2009

2/10/2010 Task Force on Pharmacies in Rural HospitalsProposed Amendments to 291.72‐291.75

Proposed Amendments to 291.72‐291.75 approved with changes Adopted 5/5/2010

8/7/2012 Task Force on Long Term Care PharmaciesProposed Amendments to 291.31‐291.34 (do not include any specific provisions regarding Techs)

Amendments to be presented at future Board Meeting

8/6/2013 Task Force on Compounding of Sterile PreparationsRequire Techs to obtain 40 hours of training from ACPE accredited provider and 40 hours on‐the‐job training in sterile compoundingTechnicians engaged in low and medium risk sterile compounding must obtain 2 hours CE each renewal periodTechnicians engaged in high risk compounding must obtain 4 hours CE each renewal period

Proposed Amendments and New Rules approved 291.33, 291.36, 291.54, 291.56, 291.74, 291.76, 291.77, 291.104, 291.106 and 291.133 Adopted 11/4/2013

Report Date Task Force Recommendations Action Rules Revised

5/6/2014 Task Force to Review Pharmacy Technician Practice Final Recommendations:* Continue requiring techs to take and pass one national certification exam* Allow Trainee renewal for total time to be 4 years* Better define "non‐judgmental" duties; seek legislation to amend definition in Pharmacy Act* Establish training program that a tech must complete prior to performing "expanded duties"* Allow training exemptions for required training for expanded duties in rural areas* Grandfather currently registered technicians from requirement to complete ASHP accredited education program after 2020 when PTCB will require it* Amend rules or seek legislation to expand tech duties to include: ‐ Expanding Tech‐Check‐Tech in Class C Pharmacies and allowing Tech‐Check‐Tech in Class A pharmacies for stocking medication carts; checking the prepacking of drugs, and stocking automated dispensing systems ‐ Allowing techs to: tranfer refill prescriptions for dangerous drugs; data enter prescriptions outside the prescription department prior to opening of pharmacy; perform final check on a refill.* Elimination of RPh‐Tech ratio

Task Force report accepted as presented

2/7/2017 Task Force on Pharmacy Technician Qualifications and Duties

Final Recommendations:* Continue requiring techs to take and pass one national certification exam* Allow Trainee renewal for total time to be 4 years* Redefine duties involving professional judgment (must be performed by RPh)* Expand duties of Techs to include: ‐ transferring Rx's by fax or electronic means ‐ performing final check on refill in a Class A Phy or subsequent fills in a Class C (provided program is similar to that allowed by Idaho) ‐ data entering Rx's in a phy or area other than Phy (home) provided Tech is directly supervised by RPh by physical or electronic means ‐ clarifying certain missing elements on a Rx with the prescriber's office (dates, strength, quantity, Pt info) * Establish guidelines for training programs that must be completed prior to performing expanded duties* Grandfather currently registered technicians from requirement to complete ASHP accredited education program after 2020 when PTCB will require it* Amend rules to clarify that Techs and Trainees are responsible for their actions when performing duties* Seek legislation to expand ability of Techs to Tech‐Check‐Tech in hospital pharmacies and allowing such in community pharmacies including: stocking medication carts; checking the prepacking of drugs; and stocking automated dispensing systems* Increase ratio of RPh's to Techs in certain settings (LTC pharmacies)* Seek legislation to allow Techs to perform certain duties without direct supervision

Staff to bring back information from Pharmacy Technician Stakeholder Consensus Conference on 2/14/2017 for review.

8/1/2017 ‐ Presentation re: Pharmacy Technician Stakeholder Consensus Conference

Adopted Rules

Rule Description of Rule ChangesOrigin of Rule Change

(e.g. Task Force Report, Discussion, and/or Legislation)Proposed Adopted

297.3Registration requirements for Techs to include criminal background check and fingerprinting

8/5/2008 11/18/2008

291.33291.34

Allows techs to load prescriptions in an automated storage and distribution device under direct supervision

2/10/2009 Final Report re: Wal‐Mart Pilot Project 2/10/2009 5/20/2009

291.72 ‐ 291.76Delete need for in‐process checking of prepacking and technicians; Allow Technicians to restock medication supply cabinets

5/5/2009 Final Report ‐ Task Force on Class C Pharmacy Rules 5/5/2009 8/11/2009

291.133 Sterile Compounding rules for Techs include garbing, cleaning and disinfecting 5/5/2009 Final Report ‐ Task Force on Class C Pharmacy Rules 8/11/2009 11/9/2009

291.72 ‐ 291.75Tech‐Check‐Tech in Class C pharmacies for filling of floor stock and unit dose distribution systems

HB 1924 (81st Session) 11/9/2009 2/10/2010

281.9 Disciplinary Action for Techs and Trainees SB 1853 (81st Session) 2/10/2010 5/5/2010

291.72 ‐ 291.75Allows technicians in a rural hospital to perform certain duties without the direct supervision of a pharmacist

2/10/2010 Final Report ‐ Task Force on Pharmacies in Rural HospitalsHB 1924 (81st Session)

2/10/2010 5/5/2010

291.153Creates new Class G Pharmacy classDesignate duties Techs may perform1:6 ratio of RPh‐Techs

11/9/2009 DiscussionHEB Pilot Project

5/5/2010 8/10/2010

291.72291.73

Requires RPh to be on duty at all times for pharmacy clinical programs using Tech‐Check‐Tech

8/10/2010 11/9/2010

291.74Clarifies requirements for when Techs/Trainees may stock automated medication supply systems

2/9/2011 6/8/2011

291.153 Remote verification of data entry by Tech in Class G Pharmacies 2/8/2011 6/8/2011

281.9Disciplinary Action for Techs and Trainees ‐ adds accessing prescription drugs with a revoked or suspended registration

6/8/2011 8/9/2011

291.32 Tech Duties ‐ grammatical updates 2/14/2012 5/8/2012291.153 1:6 Ratio of On‐Site RPh to Techs/Trainees in Class G Pharmacies 2/14/2012 5/8/2012

291.74Allow techs in Class C pharmacies to restock automated medication supply systems ‐ adds tamper evident packaging as one of the 3 requirements

8/7/2012 11/6/2012

297.8 CE for Technicians to include 1 hr of Texas Law 2/5/2013 5/7/2013



291.77291.133

Tech duties for Sterile Compounding8/6/2013 Final Report ‐ Task Force on Compounding of Sterile Preparations

8/6/2013 11/4/2013

291.32291.3

291.153

Change RPh‐Tech ratio from 1:3 to 1:4 in Class A&BChange RPh‐Tech ratio from 1:6 to 1:8 in Class G

2/5/2013 and 5/7/2013 Board discussions 11/4/2013 2/11/2014

291.133 Clarify training requirements for techs in ASHP accredited programs8/6/2013 Final Report ‐ Task Force on Compounding of Sterile Preparations

5/6/2014 8/5/2014

291.72 Redefining Bed Size for Class C Pharmacy in a Facility of 101+ Beds 5/6/2014 Board discussion + Seton Petition 8/5/2014 11/4/2014

297.11 New rule to allow Temporary Emergency Pharmacy Technician Registration HB 746 re Volunteer Registry 2/3/2015 5/5/2015

297.3 Fingerprint and Criminal Background Checks for Technician Renewals 2/3/2015 5/5/2015297.8 Decrease in‐service hours allowed for CE from 10 to 5 hours. 5/5/2015 8/4/2015297.3297.10

Eliminate provisions allowing for Taxpayer ID # in lieu of SSN because SSN required to process criminal background checks

2/2/2016 5/3/2016

297.3Removed PTCB as the exclusive examination approved by the Board, thereby allowing the Board to approve one or more additional examinations.

11/1/2016 Board member‐initiated discussion during Rule Review 11/1/2016 2/7/2017

297.7297.8297.10

Removes references to the Pharmacy Technician Certification Board; Clarifies continuing education requirements

8/1/2017 11/7/2017

291.121 Tech duties for remote dispensing sites of telepharmaciesSB 1633HB 2561 (85th Session)

8/1/201711/7/2017

(with changes)

291.33Allows Techs/Trainees to load automated storage and distribution devices; errors cannot be overridden by Techs

2/6/2018 5/1/2018

305.2 Recognizing Tech training programs are jointly accredited by ASHP and ACPE 5/1/2018 8/7/2018

291.31291.32291.33

Allows Techs/Trainees to load prepackaged containers into an automated storage and distribution device; Allows Techs/Trainees to stock or load automated dispensing systems

5/1/2018 8/7/2018

291.121Allows Techs/Trainees to stock/load Remote Pharmacy Dispensing Systems under direct supervision of RPh

11/6/2018 2/5/2019



291.32291.123291.153

Technicians Working Remotely in Class A Pharamacies; Class A, C or E Central Processing Facilities; and Class G Pharmacies

2/5/2019 Letter from Robert Morris with Proposed Amendments 2/5/2019 5/7/2019

Proposed and Withdrawn Rules


(e.g. Task Force Report, Discussion, and/or Legislation) Proposed Withdrawn

291.72 ‐ 291.75

Allowing technicians in a rural hospital to perform certain duties without the direct supervision of a pharmacist

HB 1924 (81st Session) 8/11/200911/9/2009

Task Force Appointed

291.32Specifying only techs and tech trainees may stock prescription drugs, return precriptions not picked up to shelves and sell non‐prescription insulin.

Discussion at 8/10/2010 Board Meeting 11/9/2010 2/8/2011

291.32291.53291.153

Change RPh‐Tech ratio from 1:3 to 1:4 in Class A and Class B and from 1:6 to 1:7 in Class G

Discussion at 2/5/2013 and 5/7/2013 Board Meetings 8/6/20138/6/2013

Language revised to eliminate ratios

291.32291.53291.153

Eliminates RPh‐Tech ratios in Class A, B and G Pharmacies Discussion at 2/5/2013 and 5/7/2013 Board Meetings 8/6/201311/4/2013

Ratios Revised &Task Force Appointed

Discussions and Actions

Date Rule Description Discussion Action

11/18/2008 Pharmacy Technician Certification Exams Discussion re: ICPT request for approval of their examinationBoard appointed Committee to determine if one or two examinations should be used

2/10/2009 291.33 Automated Storage and Dispensing DevicesDiscussion re: Wal‐Mart Pilot Project approved by the Board in August 2006. Board approved for proposal amendments to 291.33

5/20/2009 291.9 Prescription Pick‐Up LocationsDiscussion re: CVS Letter outlining procedure for Tech to pick up and drop off prescriptions to a business

Board directed staf to prepare suggested language to clarify 291.9 to clarify such procedure is allowed

5/20/2009 291.32 RPh‐Tech Ratio in Call Centers

Metronic request for change in RPh‐Tech ratio to 1:15 in Class A pharmacies that deal with a very limited number of prescription drugs

Board approved proposal of amendments to 291.32 to allow a 1:5 ratio if Class A pharmacy dispenses no more than 20 drugs

8/11/2009 Remote Verification of Prescription Data EntryDiscussion re: Prescription Solutions letter regarding remote verification of Tech data entry by RPh working in another state

Board directed staff to survey other states concerning use of this model and draft proposed rule language

11/9/2009

HEB Pilot Project on RPh‐Tech Ratio for Central Processing Pharmacies with No Prescription Drugs On Site

HEB presented report on Pilot Project to have 1:6 RPh‐Tech ratio in call center.

Pilot project continued through time needed to adopt new rules for new class of pharmacy for call centers and Board directed staff to suggest rule language

11/9/2009 291.32 RPH‐Tech Ratios in Class A Pharmacies

Discussion in response to letter from Texas Federation of Drug Stores advocating increasing the RPh‐Tech ratio for Class A pharmacies and appoint task force to review ratio based on advances in technology and Tech education No action taken

8/10/2010 Tech Duties

Staff presented chart of duties a Tech can perform; Staff suggested additional clarification needed as to duties a tech can perform and dutes a cahsier or clerk cannot perform

Staff to develop suggested rule language for tech duties to include: stocking/restocking shelves; selling insulin with RPh supervision

2/5/2013 RPh‐Tech RatioExpress Scripts Presentation with history of ratios; Walgreens statement that no need to operate above current ratio.

Staff to schedule further discussion at May 2013 Board Meeting


5/7/2013 RPh‐Tech RatioStaff presentation on TX history and ratios in other states, Express Scripts White Paper, pubic comments

Staff directed to propose amendments to 291.32 to change ratio to 1:4 RPh‐Techs with 1:2 RPh‐Trainees for Class A and Class B; and 1:8 ratio for Class G.

5/6/2014 291.72Electronic Supervision of Techs in Class C Pharmacy in a Facility with 101 Beds or More

Petition from Seton Family of Hospitals to waive rules concerning hospitals with 101 Beds or more; Requesting 18 month Pilot Program with electronic supervision of Techs in 3 hospitals

Board members familiar with hospital systems to meeting with Seton and DSHS to discuss how facility bed size is determined; bring information back for review

11/4/2014 Tech‐Check‐Tech Pilot Program

Presentation re: Iowa Pilot Program Concerning Tech‐Check‐Tech (no handouts in Board notebooks)

Board asked staff to review laws and rules to determine if legislation needed to allow a Tech‐Check‐Tech Pilot Project in Texas.

2/3/2015Amendments to Pharmacy Act to Allow Tech‐Check‐Tech in Class A Pharmacies

Board Counsel explained language in current draft of proposed legislation would allow Tech‐Check‐Tech in Class A Pharmacies

Board directed ED to work with interested parties to deveop language that would allow a Pilot Project that would allow waiver of certain laws.

2/3/2015 CE Requirements for Techs

Staff recommended amending rule to greatly reduce in‐service training and eliminate provision allowing Techs who maintain PTCB certification from not being subject to CE audit.

Staff directed to bring back rule amendments for consideration

2/3/2016RPh‐Tech Ratio when Tech is Student from Tech School

RPh requested Board review need to have RPh's work with Tech students in Class A pharmacies without staffing restrictions, said current ratio restriction creates obstacle when attempting to place tech student in a pharmacy for their training rotation.

Board directed staff to survey other states and bring additional information for consideration.

5/3/2016 PTCB Exam and Training Requirements

Concern expressed by Board member that PTCB's requirement for ASHP/ACPE accredited training programs could impact availability of Techs, time and cost could be barrier for many prospective Techs; Report from Ascend Learning on tech education and job placement in TX; Comments re TX should accept PTCB‐only or PTCB + ExCPT

Board directed staff to continue to monitor PTCB's implementation of changes to certification program.

8/2/2016Review of 2014 Final Report of Task Force to Review Pharmacy Technician Practice

Report was presented at 5/6/2014 Board meeting and a Board member requested it be presented again for review No action taken


8/2/2016 Pharmacy Technician Certification ExamsPresentation re ASHP/ACPE and PCTB, public comments about Texas accepting PTCB and ExCPT exams.

Board directed staff to convene Task Force to review technician education issues.

8/1/2017 291.133Training for Techs Compounding Sterile Preparations

Ms. Dodson presented information on current standards of training No action taken

8/1/2017 291.33Use of Automated Checking and Dispensing Devices by Techs in Class A Pharmacies

Review of current rule and Board member recommending review of rules concerning technology

Board directed staff to review rules concerning technology and bring information back to the Board

11/7/2017Use of Automated Checking and Dispensing Devices by Techs in Class A Pharmacies

Board member presentation on advances in automation; recommended allowing techs to do refills using automated system with RPh supervision

Board requested staff bring suggested rule language concerning the use of an automated system when doing refills

5/1/2018 Tech Certification Testing RFQReview of scores from 2 psychometricians contracted to score the bid proposals submitted by PTCB and NHA Both PTCB and NHA exams approved

2/5/2019

291.32291.123291.153 Techs Working Remotely

Letter from Roger MorrisProposed Amendments to 291.32, 291.123 and 291.153

Board approved Proposed Amendments to 291.32, 291.123 and 291.153

Technician Roles Found in Other States

Registration

State Retail Hospital Retail HospitalAccept Telephone

Rx'sTransfer Rx's Verifications Remote data entry Immunizations

Duties allowed with no direct supervision

Counseling Degree Req'd Training Req's Exam Req'd Different Classifications

AL1:3

(1 CPhT)1:3 No No No No None No 3 hrs ACPE‐T CE License

AK Yes High School/GEDOn‐the‐job

PTCB License

AZ Refills only

only electronic, non‐controlled between phy's under common

ownership

NoPTCBExCPT

License

AR 1:3 1:3Refills w/ no changes

onlyHigh School/GED

RegistrationCertification

CA1:1 RT for 1st RPh

1:2 RT for each addt'l RPh1:1 RPh‐Tech Trainee

1:2 No None License

CO

No more than 1:6If 1:3, at least 1 must meet

training req'sIf < 1:3, majority must meet training req's

1:6

only electronic between compatible

systems and no changes

CPhT, Gradute of accredited training program, or 500 hrs on the job training

Not registered or licensed

CT1:2 if 2 RT's

1:3 if 2 RT's + 1 CPhT1:2 outpatient1:3 inpatient

Refills of non‐controls w/ no changes only

No NoOn‐the‐job

PTCB (Certification)License

Certification

DEtraining program under direct

supervision of RPh

PTCB or ExCPT(optional)

Not registered or licensed

DCRefills of non‐controls w/ no changes only

None No High School/GED PTCB or ExCPTRegistrationTechnician

Technician Trainee

FL

1:1 unless specifically allowed by rule

1:3 ‐ sterile compounding1:6 ‐ other, not sterile

compounding1:8 ‐ non‐dispensing phy's

and areas

only refill authorizations

No No None No

Registered Pharmacy Technicians (RPT)

Pharmacy Technicians in Training (PTT)

GA1:3

(1 must be CPhT)may exceed 1:3 upon

approvalNone High School/GED

PTCB or ExCPT(optional)

Registered Pharmacy Technician

GURegistered Pharmacy

Technician

HINot registered or

licensed

IDCPhT

NonePrescribing authority for Naloxone

High School/GED PTCB or ExCPTCertified TechnicianTechnician in TrainingStudent Technician

IL None

Limited to obtaining medication history, offering counseling by RPh, acquiring

patient allergies and health conditions

High School/GED

Nationally accredited training program

(CPhT) or On the job training (CPhT and RT)

PTCB or ExCPT(CPhT)

Certified TechnicianRegistered Technician

Education & TrainingRPh‐Tech Ratio Tech‐Check‐Tech (TCT) Technician Duties

1

Registration






IN 1:2 or 1:3 No No(refills only)

No No

Education and training program approved by the

Board

Certification exam by nationally recognized

body

Certified TechnicianTechnician in Training

IA 1:3 if using TCT 1:3 if using TCT(refills) (non‐controls)

Designated duties during temporary absence of RPh

No offering or accepting refusal on

behalf of RPh

PCTB or ExCPTCertified TechnicianTechnician Trainee

KS1:2

1:3 if 2 are CPhT

1:21:3 if 2 are CPhT1:1 if electronic supervision

No

filled floor stock, a crash cart tray, a unit

dose cart, or an automated

dispensing machine

(refills only)No High School/GED PTCB or ExCPT Pharmacy Technician

KY

CPhT may certify for delivery unit dose mobile transport systems refilled by

another tech

(refills)No

CPhT can perform duties under general

supervisionRT must perform duties

under immediate supervision

PCTB or ExCPT(CPhT)


LA

1:1 Candidates1:2 Technicians

1:3 Technicians if no Candidates

1:3(CPhT)

(CPhT, non‐controls only)

No

CPhT ‐ stocking automatic dispensing system on‐site if bar code verification used

No High School/GED

Nationally accredited training program or 600 hours practical experience in LA

PCTB or ExCPT

Certified Pharmacy Technician

Pharmacy Technician Candidate

MA1:4 if 2 are CPhT and/or

Interns1:3 if 1 is CPhT or Intern

1:4 if 2 are CPhT and/or Interns

1:3 if 1 is CPhT or InternNo No New ‐ CPhT only

Refills ‐ CPhT and RTCPhT ‐ refill, non‐controlled only

No No No High School/GED

Board approved training program or 500 hours as Tech

Trainee

Certified Pharmacy Technician


Pharmacy Technician Trainee

ME

Pharmacy is responsible for ensuring that the number of Techs on duty can be

satisfactorily supervised by PIC/RPh's on duty.

Pharmacy is responsible for ensuring that the number of Techs on

duty can be satisfactorily supervised by PIC/RPh's

on duty.

New or refill if authorized by RPh on

duty

Only non‐controls and only in receiving

Phy

Final check by Tech if no RPh on site at

point of care location and drug dispensed by automated

pharmacy system

No No Pharmacy Technician

MD No High School/GEDBoard approved training program

PCTB or ExCPTRegistered Pharmacy

Technician

MICannot accept verbal orders for controlled

substances

Cannot transfer controlled substances

Must be under the supervision of a pharmacist

High School/GED

Training Program and Exam Approved by the Board of

Pharmacy

Licensure by exam (PCTB or ExCPT)

Pharmacy Technician License

MN

1:2 (or 1:3 if one tech is certified or board

approves)1:3 for unit dose

packaging, prepackaging, compounding, IV admixture prep

1:2 (or 1:3 if one tech is certified or board

approves)1:3 for unit dose

packaging, prepackaging,

compounding, IV admixture prep

yes No High School/GED

Board approved training program or employer‐based

training program w/ 240 hours

Board of Pharmacy does not require certification


2

Registration






MS 1:3 1:3 no

Pharmacy Technicians in an institutional

setting may conduct patient medication histories without the direct supervision of a

pharmacist.

no High School/GED noPCTB or ExCPT

required for renewalRegistered Pharmacy

Technician

MO(non‐controlled only) (non‐controlled only)

noPIC may decide duties, must be supervised

directly by a pharmacistno no

Must be trained for sterile compounding

noRegistered Pharmacy

Technician

MT 1:3 (Board may increase) 1:3 (Board may increase) yes no High School/GEDPCTB, ExCPT, or Board

Approved

Certified Pharmacy Technician and Pharmacy Technician in Training

NE1:2 (May ask Board to

increase)1:2 (May ask Board to

increase)no no no no

Director with the recommendation of the

board may waive limitations for purposes of a scientific study.

no High School/GEDPTCB. ExCPT, or other

Board approved programs


NV 1:3 1:3 no no noWithin a store

computer network only

no High School/GED An option

Pharmaceutical Technician and Pharmaceutical

Technician in Training

NH (CPhT only) Yes, for non‐control

Reduce to writing a prescription left on a

recording or message line

Clarification of an original prescription or

drug order with a practitioner or their

agent.

High School/GED or working towards

Registered Pharmacy Technician, Certified

Pharmacy Tech (expanded duties), New ‐Advanced Pharmacy

Technician

NJ1:2 (May ask Board to

increase)1:2 (May ask Board to

increase)no no no no Pharmacy Technician

NM To be determined by PIC To be determined by PIC no no no no no yes none no PCTB or ExCPT

Non‐certified and Certified Pharmacy Technician (have one

year to obtain certification)

NY 1:2 1:2 Unlicensed Assistant

NC1:2 (unless board approves

increase ‐ must be certified)

1:2 (unless board approves increase ‐ must be certified)

(CPhT only)(CPhT only)

HSD or GED or enrolled

Pharmacist‐manager must provide

training

CPhT ‐ PCTB or ExCPT or Board Approved

Certified Pharmacy Technician and Pharmacy

Technician

ND1:4 (1:5 if closed door

pharmacy) Effective 10/191:4 (Effective 10/19)

Pharmacy must have policies and procedures ‐documented

training required ‐ PIC and pharmacy

are liable

Pharmacy must have policies and procedures ‐

documented training required ‐ PIC and pharmacy are liable

Yes, for non‐controlPharmacist must

checkno HSD or equivalent

ASHP accredited academic program and ASHP accredited on‐the‐job training

PTCB and National Healthcare

Association (NHA)

Registered Pharmacy Technician is licensed

and Pharmacy Technician in Training is registered.

3

Registration






OH(CPhT only)

(CPhT, non‐controlled only)

CPhT can contact a prescriber to obtain clarification if does

not require professional judgement.

Diagnostic lab testing (CPhT)

CphT may stock an automated drug

dispensing unit or floor stock at a location

licensed as a terminal distributor of

dangerous drugs if a pharmacist is unable to

provide direct supervision under certain conditions.

HSD, GED or foreign equivalent

Non‐employer and employer‐based

NHA (ExCPT) and PTCB for CPhT

Certified Pharmacy Technician, Registered Pharmacy Technician, Pharmacy Technician

Trainee

OK 1:2 no noHigh School Diploma

or a GED

Must complete a pharmacy technician on‐the‐job training

program in a licensed Oklahoma

pharmacy.

✔

Pharmacy Technician (requires permit from

the board) also a Certified Pharmacy Technician (Board approved pharmacy

technician certification)

OR No no no no High school diploma

or GEDPIC must provide and document training

Certified ‐ PTCB or National Healthcareer Association (NHA) ‐

ExCPT

Pharmacy Technician license leading up to Certified Oregon

Pharmacy Technician

PADoes not require

registration or licensing

PR 1:5 1:5 (Retail only) no High School

(1,000 hour internship + Board exam + Complete

pharmacy technician course in an educational institution)

Board Approved Pharmacy Technician Certification Exam or

PTCB

Certificate of Pharmacy Technician

RI

PT II only with approval of

pharmacist on duty


pharmacist on duty


pharmacist on duty

PT II only with approval of pharmacist

on dutyno

High school diploma or GED

Board approved training program

PTCE or ExCPT or equivalent

Pharmacy Technician I and Pharmacy Technician

II (Certified)

SC 1:3? no yes(CPhT only)

(Non‐controlled only)

(CPhT only)(Non‐controlled

only)

High school diploma or GED

Certified Pharmacy Technician requires board ‐approved training program plus 1,000 hours of

practice in a pharmacy under a licensed pharmacist

No exam for Pharmacy Technician but to become a

Certified Pharmacy Technician requires PTCB or ExCPT.

Registered Pharmacy Technician and State Certified Registered Pharmacy Technician

(CPhT)

SD 1:3 Determined by PIC no no

Ok, with audio‐visual link to central

pharmacy staffed by pharmacist

no no High school diploma

or GED

Board‐approved or employer‐based

pharmacy technician training.

Must be nationally certified and passed a

board ‐approved certification exam accredited by NCCA.


4

Registration






TN

1:2 (But may be 1:4 if additional techs are

certified) Also, PIC may request a modifcation of the ratio from the Board in

writing.

1:2 (But may be 1:4 if additional techs are

certified) Also, PIC may request a modifcation of the ratio from the Board

in writing.

(CPhT only) (CPhT only)no

Non‐employer and employer‐based

noRegistered Pharmacy

Technician and Certified Pharmacy Technician

TX1:4 Class A and B (Possibly

1:5)No

Must apply to TSBP and receive approval

High school diploma or GED or working

towardsyes PTCB or ExCPT

Registered Pharmacy Technician and

Technician Trainee

UT no No yes

May accept new prescription drug orders left on voicemail for a

pharmacist to review

For OTCs and supplements under

direction of supervising pharmacist

Formal Training Program Required

PCTB or ExCPTLicensed Pharmacy

Technician

VT no no no no no

The pharmacy technician may input the prescription drug

order or refill request so that coordinating

pharmacist may perform a

prospective drug utilization review and verify the prescription

information prior to authorizing

dispensing from the remote site.

noHigh School Graduate or

Equivalent for CPhT

Not for Registered, but CPhT requires a minimum of 2,000 hours of experience

as a registered pharmacy technician

National Pharmacy Technician

Certification for CPhT

Registered Pharmacy Technician and Certified Pharmacy Technician

VA 1:4 1:4 no no no nono, just good moral

characterApproved Training Program with ExCPT

PCTB or ExCPT/Training


WA 1:3 1:3

Following verification of the drug order by a

licensed pharmacist, a pharmacy

technician may check unit‐dose

medication cassettes filled by another

pharmacy technician or pharmacy intern

in pharmacies serving facilities licensed under chapter 70.41, 71.12, 71A.20 or

74.42 RCW.

no

The board may give conditional approval for pilot or demonstration projects for innovative applications in the

utilization of pharmacy ancillary personnel.

no

No formal training or education required for a

pharmacy assistant

Graduation from, or completion of, a

Pharmacy Commission‐

approved technician training program

•Pharmacy law study•Affidavit of eight hours of pharmacy

law study

Technician must pass approved exam accredited by

National Commission for Certifying

Agencies (NCCA).

Registered Pharmacy Assistant and Certified Pharmacy Technician

5

Registration






WV 1:4 1:4 considering no no no no High school diploma

or GED

Completed an approved pharmacy technician training

program

PCTB or ExCPT, or graduation from a competency‐based pharmacy technician education program


WIPilot Program or 1:4 (unless higher ratio authorized by board)

Pilot Program or 1:4 (unless higher ratio authorized by board)

Pilot Program Pilot Programyes, if conversation

recorded and verified by RPh

Transfer to the patient or agent after pharmacist provides a patient

consultation

no no noNo licensure requirements

WY 1:3 1:3 no

Transfer electronically or via

fax to another pharmacy with consent of supervising pharmacist.

(non‐controlled only)

no no High school diploma

or GEDyes, on‐the‐job PCTB or ExCPT

Pharmacy Technician in Training is registered and Pharmacy Technicianis

Licensed

6

41

13. Status of Pharmacy Technicians

Does State:

State Designation

LicenseTech-nicians?

RegisterTech-nicians?

Require Certification?

Technician Registration Fee

Registration Renewal Schedule

Alabama Pharmacy Technician No Yes No $60 Biennial IIAlaska Pharmacy Technician Yes No No $50 HH, UU BiennialArizona Pharmacy Technician Yes No Yes RRR $72, $50 trainee Biennial BArkansas Pharmacy Technician No Yes No $70 II; $35 YY BiennialCalifornia Pharmacy Technician Yes No No $140 BiennialColorado Pharmacy Technician No No No N/A N/AConnecticut Pharmacy Technician No Yes No $100 Annual - 3/31Delaware Pharmacy Technician No No No None N/ADistrict of Columbia Ancillary Personnel No BBB Yes BBB Yes BBB $50 AnnualFlorida Pharmacy Technician Yes No Yes $105 BiennialGeorgia Pharmacy Technician No Yes No $100 BiennialGuam Pharmacy Technician No Yes No J JHawaii Pharmacy Technician No No No N/A N/AIdaho Pharmacy Technician No Yes M Yes LLL $35 AnnualIllinois Pharmacy Technician Yes No Yes SSS $40 initial; $25 renewal AnnualIndiana Pharmacy Technician Yes AAA No Yes FFF $25 WW BiennialIowa Pharmacy Technician No Yes Yes PPP $40, $20 trainee ZKansas Pharmacy Technician No Yes Yes A4 † $20 BiennialKentucky Pharmacy Technician No Yes Yes GGG $25 AnnualLouisiana Pharmacy Technician Yes No Yes B4 $100 AnnualMaine Pharmacy Technician Yes G4 — — $25 AnnualMaryland Pharmacy Technician No Yes Yes NNN $45 Biennial GMassachusetts Pharmacy Technician Yes No No $60 Biennial GMichigan Pharmacy Personnel Yes No No † $58.30 —Minnesota Pharmacy Technician No Yes No TTT $37.50 AnnualMississippi Pharmacy Technician L No Yes Yes A † $55 AnnualMissouri Pharmacy Technician No Yes No $35 W AnnualMontana Pharmacy Technician No Yes Yes AA $50 initial; $30 renewal AnnualNebraska Pharmacy Technician No Yes Yes MMM $25 Biennial RRNevada Pharmaceutical Technician L No Yes No $40 BiennialNew Hampshire Pharmacy Technician No Yes No $50 AnnualNew Jersey Pharmacy Technician No Yes No $70 BiennialNew Mexico Pharmacy Technician N No Yes Yes A $30 BiennialNew York Unlicensed Person No No No N/A N/ANorth Carolina Pharmacy Technician No Yes No EEE $30 AnnualNorth Dakota Registered Pharmacy Technician No Yes Yes DDD $35 Annual

Ohio Pharmacy Technician No Yes LL Yes C4 $25 Trainee; $50 Registered and Certified Biennial

Oklahoma Pharmacy Technician No Yes O No $40 GGOregon Pharmacy Technician Yes WWW No Yes JJJ $50 VV BiennialPennsylvania Pharmacy Technician No No No N/A N/APuerto Rico Pharmacy Technician No Yes Yes $50 3 yearsRhode Island Pharmacy Technician Yes No RRR $25 AnnualSouth Carolina Pharmacy Technician No Yes No $40 initial; $15 renewal AnnualSouth Dakota Pharmacy Technician No Yes Yes CCC $25 Annual Tennessee Pharmacy Technician No Yes No $75 biennial CyclicalTexas Pharmacy Technician No Yes Yes KKK $83 initial; $80 renewal BiennialUtah Pharmacy Technician Yes No No $60 TT BiennialVermont Pharmacy Technician No Yes No $50 BiennialVirginia Pharmacy Technician No Yes No QQQ $25 AnnualWashington Pharmacy Technician No No Yes $60 initial; $50 renewal AnnualWest Virginia Pharmacy Technician No Yes Yes $25 W, X BiennialWisconsin Pharmacy Technician No No No — —Wyoming Registered Pharmacy Technician K Yes KK Yes KK Yes DDD, RRR $50 Annual

Colored text denotes change from 2018 edition.† Other comments noted in 2018 edition no longer apply.— Indicates information is not available.

The 2019 Survey of Pharmacy Law is trademark and copyright protected. ©2018 by the National Association of Boards of Pharmacy

42

13. Status of Pharmacy Technicians (cont.)Maximum Ratio of Technician(s) to Pharmacist in an:

State

Technician Training Requirements

Technician CPE Requirements

Technician Examination Requirement

Can Board Deny, Revoke, Suspend, or Restrict Technician Registration?

Ambulatory Care Setting

Institutional Care Setting

Alabama No Yes 3 hrs/yr MM — Yes 3:1* 3:1*Alaska Yes S Yes 10 hrs/2 yrs No Yes None NoneArizona Yes NN Yes FF Yes None NoneArkansas No None No Yes 3:1 3:1California Yes CC No No CC Yes Varies* 2:1Colorado No N/A No N/A 6:1 6:1Connecticut Yes S No No Yes 2:1* or 3:1 3:1*Delaware Yes N/A No N/A None NoneDistrict of Columbia Yes BBB Yes BBB Yes BBB Yes — —Florida Yes Q Yes 20 hrs/2 yrs No Yes 3:1* 3:1*Georgia No None No Yes 3:1* 3:1*Guam No J None J No Yes None J None JHawaii No No No No None NoneIdaho Yes OO Yes Yes Yes None NoneIllinois Yes PP No Yes QQ Yes None NoneIndiana Yes No No U Yes 6:1* 6:1*Iowa Yes H No No Yes None NoneKansas Yes Yes YYY Yes A4 † Yes 2:1 or 3:1* 2:1 or 3:1*Kentucky No None No Yes None NoneLouisiana Yes Yes 10 hrs OOO Yes FF Yes 3:1* 3:1*Maine Yes UUU No No Yes None NoneMaryland Yes Yes Yes Yes None NoneMassachusetts Yes No BB Yes Yes 4:1 4:1Michigan Yes D4 Yes E4 Yes F4 Yes None NoneMinnesota Yes Yes No Yes 3:1 3:1 Mississippi No † No No Yes 3:1 3:1Missouri Yes HHH None No Yes None* None*Montana Yes** T Yes SS Yes AA Yes 3:1* 3:1*Nebraska Yes** I No No Yes ZZZ 3:1 3:1Nevada Yes Yes Y No Yes 3:1* 3:1New Hampshire Yes Yes P Yes P Yes None NoneNew Jersey No No No Yes Varies VariesNew Mexico Yes** None Yes AA Yes None NoneNew York No No No No 2:1 2:1North Carolina Yes None No Yes 2:1* 2:1*North Dakota Yes R Yes 10 hrs/1 yr Yes Yes 3:1 4:1Ohio Yes Yes 20 hrs/2 yrs Yes P Yes None NoneOklahoma Yes None Yes Yes JJ 2:1 2:1Oregon Yes III Yes P, H4 Yes P Yes None NonePennsylvania Yes ZZ None No N/A None NonePuerto Rico Yes F Yes 20 hrs/3 yrs Yes Yes 5:1 5:1Rhode Island Yes Yes BB Yes V Yes None NoneSouth Carolina Yes DD Yes 10 hrs/yr EE Yes DD Yes 4:1* Varies*South Dakota Yes D None Yes D Yes 3:1 None Tennessee No None No Yes 2:1* 2:1*Texas Yes C Yes 20 hrs/2 yrs XXX Yes Yes 3:1* NoneUtah Yes Yes 20 hrs/2 yrs Yes E Yes * *Vermont No J No J No Yes None NoneVirginia Yes V Yes 5 hrs/yr Yes V Yes 4:1 4:1Washington Yes VVV Yes XX Yes VVV Yes 3:1* 3:1*West Virginia Yes I, K None Yes Yes 4:1 4:1Wisconsin No — — — 4:1 4:1Wyoming Yes ZZ Yes 6 hrs Yes FF Yes 3:1 3:1

* See “Footnotes (*)” on page 45.** Contact the state board of pharmacy office to obtain requirements.Colored text denotes change from 2018 edition.† Other comments noted in 2018 edition no longer apply.— Indicates information is not available.


43

LEGEND13. Status of Pharmacy Technicians (cont.)

A — All new pharmacy technicians have one year after initial licensure to obtain national certification.

B — Technician trainee receives a three-year non-renewable license.

C — A person may be a technician trainee for no more than two years while seeking certification. Contact the Board for specific training requirements.

D — Same as PTCB requirements. E — PTCB examination or the ExCPT and Utah

law examination. F — 1,000 hours of internship under direct

supervision of a registered pharmacist and passing an examination prepared by the Board are required for certification. Designated pharmacy technician intern for three years maximum.

G — Biennial at birthday. (MD – First renewal 10 CE, all other renewals 20 CE.)

H — Technicians must be under direct pharmacist supervision, unless in an approved telepharmacy. Technician training must be documented and maintained. Additional training required for telepharmacy technicians.

I — Training requirements developed by training pharmacies and approved by the board. (WV – PTCB or National Healthcareer Association certified pharmacy technician certification. As of July 1, 2014, technician must have graduated from a competency-based pharmacy technician training and education program or completed training requirements stated above.)

J — The Board is proposing/developing regulations.

K — Designated as a “technician-in-training” prior to meeting requirements for licensure.

L — The term “Support Personnel” is also used. M — May register as “technician-in-training”

while working towards certification. This registration is good for two years.

N — A “Pharmacy Technician” is a subset of “Supportive Personnel.”

O — Technicians are not considered “registered,” but are issued a “permit.”

P — Required for certified pharmacy technicians, but not pharmacy technicians. (OR – Must become certified by the second June 30.)

Q — Pharmacy technicians may register in Florida if they complete a Board-approved training program.

R — Technicians must complete ASHP-accredited program.

S — On-the-job training by PIC appropriate to technician’s duties.

T — Technician utilization plan filed with Board or didactic course.

U — Passage of the PTCB examination is one way to become certified as a technician in this state. Must also file application for licensure.

V — To be eligible for registration a pharmacy technician must either hold current PTCB certification or must have passed a training program and examination approved by the Board.

W — Plus a fingerprint fee paid to a contracted agency.

X — $25 initial; $30 renewal/2 years.

Y — However, technicians must complete six hours of in-service training per year and one hour of jurisprudence as do pharmacists. (NV – See Section 11, Continuing Pharmacy Education Requirements.)

Z — Biennial by birth month; trainee registration valid for up to one year and may not be renewed or extended.

AA — PTCB or ExCPT certification required. BB — However, “certified pharmacy

technicians” must maintain certification. CC — Educational training and/or is certified

by a pharmacy technician-certifying organization offering a pharmacy technician certification program accredited by the National Commission for Certifying Agencies that is approved by the Board.

DD — To be certified as a pharmacy technician an individual must have worked for 1,000 hours under the supervision of a licensed pharmacist as a technician and must have completed a Board of Pharmacy-approved technician course as provided for in subsection (D); a high school diploma or equivalent; and passed the National Pharmacy Technician Certification Examination or a Board of Pharmacy-approved examination and has maintained current certification; and fulfilled CE requirements as provided for in Section 40-43-130(G).

EE — As a condition of registration renewal, a registered pharmacy technician shall complete 10 hours of ACPE-accredited CE or CME Category I each year. A minimum of four hours of the total hours must be obtained through attendance at lectures, seminars, or workshops.

FF — Requires PTCB examination. (AZ and LA – Or another Board-approved exam.)

GG — Annual (by birth month). HH — Plus one-time application fee of $50. II — Odd numbered years. JJ — Revoked 28 pharmacy technician permits,

0 probations, 0 suspensions, and 0 fines. KK — “Technicians-in-Training” are registered

until they meet the requirements for licensure. The technician-in-training permit is valid for no more than two years from date of issue.

LL — Registration effective April 6, 2018. MM — One hour must be live CE. No carry-over

hours. NN — Twenty hours, of which two hours

must be pharmacy law ACPE or Board-approved providers.

OO — Must be 16 years of age unless waived; a high school graduate unless waived or in school-supervised employment.

PP — Refer to 225 ILCS 85/9.5 and 85/17.1 and 68 Illinois Administrative Code Sections 1330.210 and 1330.220.

QQ — Beginning on January 1, 2010, within two years after initial registration as a registered technician, must become certified by successfully passing the PTCB or other Board-approved

Legend continued on page 44


44

13. Status of Pharmacy Technicians (cont.)

examination and registering as a certified pharmacy technician with the department. Does not apply to pharmacy technicians registered prior to January 1, 2008. Refer to 225 ILCS 85/9.

RR — Biennial, January 1 of odd years. SS — Must comply with CE requirements of

certifying entity. TT — Additional $40 for criminal background check. UU — Application fees are reevaluated June of even-

numbered years. VV — Plus fingerprinting fee. Effective January 1,

2019, the fingerprint fee will be $41.25. WW — Indiana State Police collect an additional fee

for a background check. XX — Beginning in 2013-2014 renewal cycle. 10

hours of CE credit with one hour in law/ethics. YY — Even numbered years. ZZ — On-the-job training in permitted activities. AAA — As of July 1, 2014, switched from certification.

Must still hold technician-in-training permit or be PTCB- or ExCPT-certified prior to licensure.

BBB — D.C. Law §17-99.CCC — Does not apply to those registered prior to July

1, 2011.DDD — PTCB only.EEE — North Carolina recognizes PTCB certification,

which allows pharmacy technician to perform additional duties.

FFF — See IC 25-26-19-5.GGG — Required to perform certain functions.HHH — For sterile compounding.III — See OAR 855-025-0025(6).JJJ — For initial license as a certified technician,

but not for license renewal. Not required for nonrenewable technician license.

KKK — Applicants for pharmacy technician registration must have taken and passed a certification examination approved by the Board and have a current certificate. Contact Board for additional requirements.

LLL — With grandfather exemption.MMM — Regulations pending.NNN — Or provide satisfactory proof to the Board

of successful completion of a pharmacy technician training program approved by the Board.

OOO — Must be technician-specific and ACPE accredited.

PPP — One-year technician trainee registration permitted.

QQQ — Only required to be actively certified through PTCB or ExCPT at time of initial application if using this option for application of registration. 18VAC110-20-101.

RRR — Only for pharmacy technicians. Not required for pharmacy technician trainees. (RI – National certification required for pharmacy technician II, not for pharmacy technician I.)

SSS — See 225 ILCS 85/9.TTT — However, if at least one technician is

certified, a pharmacy can exceed the base technician-to-pharmacist ratio by having one additional technician on duty within the pharmacy.

UUU — See Maine Pharmacy Rules 02 392, Chapter 7, Section 2, Training.

VVV — Pharmacy technicians must hold a high school diploma or GED and complete a Commission-approved program (academic/formal or on-the-job). The program must include didactic training and practical experience. Technicians trained out-of-state must demonstrate that their training and education are similar to a Commission-approved program. After 2007, all new pharmacy technicians must pass a Commission-approved national standardized examination. The Commission recognizes exams administered by organizations accredited by the National Commission for Certifying Agencies. The Commission does not require technicians once certified to maintain national certification.

WWW — All new pharmacy technicians have up to two years/the second June 30 after initial licensure to obtain national certification. Pharmacy technician licenses are nonrenewable. A one-time extension may be granted pursuant to OAR 855-025-0010(3).

XXX — One hour must be related to Texas pharmacy laws or rules.

YYY — Twenty hours (approved) per biennial renewal period. No carry-over. Must be earned in prior registration period.

ZZZ — Board recommends to Department of Health and Human Services, Division of Public Health.

A4 — All technicians initially registered after July 1, 2017, shall be required to pass the PTCB or ExCPT certification exam prior to their first registration renewal (approximately two years). Does not apply to technicians registered prior to July 1, 2017, unless the registration lapses. A one-time, six-month extension may be granted for good cause shown.

B4 — Three eligibility options for Pharmacy Technician Candidate (PTC) Registration – (a) Proof of enrollment in a nationally-accredited and board-approved pharmacy technician training program; (b) Proof of successful completion of a board-approved pharmacy technician certification examination; (c) Credential issued by another state board of pharmacy with practice for at least one year as a technician in that state plus proof of successful completion of a board-approved pharmacy technician certification examination.

LEGEND — cont.

NABPLAW Online Search Terms Status of Pharmacy Technicians (type as indicated below) technician certificationtechnician feeNote: “ancillary personnel”; “non-licensed personnel”; and “support personnel” can be substituted for “technician.”

technician requirements technician training

technician registration technician renewal

technician license



45

Once issued, PTC registration is valid for a maximum of two years, during which time the PTC shall earn at least 600 hours of practical experience in a LA-licensed pharmacy, or the number of hours required by the curriculum of the nationally-accredited and board-approved pharmacy technician training program.

C4 — Only for certified pharmacy technicians.D4 — A one-time training in identifying victims

of human trafficking per Rule 338.3659 for initial licenses beginning 2021 and for renewals in 2018.

E4 — 20 hours of CPE required. No more than 12 hours may be earned during a 24-hour period; no credit for program identical to program already used in the same renewal period; 5 credits must be in live courses, programs, or activities; 1 hour must be in pain and symptom management relating to practice of pharmacy; 1 hour must be in patient safety; 1 must be in pharmacy law; and 17 in listed subjects. May take a proficiency examination in lieu of CE.

F4 — PTCB, or examination given by the National Healthcareer Association, or nationally recognized and administered certification examination approved by the Board, or an employer-based training program examination approved by the Board.

G4 — Pursuant to Department Statute, license is defined as License, Registration, or Certificate.

H4 — 20 hours every two-year cycle. Footnotes (*)

AL — 3:1 if one technician is PTCB-certified. All technicians must be at least 17.

CA — In community pharmacy, the ratio is 1:1 for the first pharmacist on duty, then 2:1 for each additional pharmacist on duty. 2:1 if pharmacy services patients of skilled nursing facilities or hospices. A pharmacist may also supervise one pharmacy technician trainee gaining required practical experience.

CT — Refer to Section 20-576-36 of the Regulations of Connecticut State Agencies. In summary, ratio not to exceed 2:1 when both technicians are registered. Ratio of 3:1 permitted when there are two registered technicians and one certified technician. However, a pharmacist is permitted to refuse the 3:1 ratio for the 2:1 ratio. In an institutional outpatient pharmacy, ratio is 2:1. The pharmacist manager may petition the Commission to increase ratio to 3:1 in a licensed or institutional outpatient pharmacy. Inpatient pharmacy ratio is 3:1 generally, but pharmacy can petition for ratio of up to 5:1; satellite pharmacy 3:1, but can petition for up to 5:1.

FL — Rule 64B16-27.410 outlines the acceptable ratios as follows:

Three to one (3:1) ratio: Any pharmacy

or any pharmacist engaged in sterile compounding shall not exceed a ratio of up to three (3) registered pharmacy technicians to one (1) pharmacist (3:1).

Six to one (6:1) ratio: Any pharmacy or any pharmacist may allow a supervision ratio of up to six (6) registered pharmacy technicians to one (1) pharmacist (6:1), as long as the pharmacist or pharmacy is not engaged in sterile compounding.

Eight to one (8:1) ratio: (a) Non-dispensing pharmacies. Any pharmacy which does not dispense medicinal drugs, and the pharmacist(s) employed by such pharmacy, may allow a supervision ratio of up to eight (8) registered pharmacy technicians to one (1) pharmacist (8:1), as long as the pharmacy or pharmacist is not involved in sterile compounding.

(b) Dispensing pharmacies. A pharmacy which dispenses medicinal drugs may utilize an eight to one (8:1) ratio in any physically separate area of the pharmacy from which medicinal drugs are not dispensed. A “physically separate area” is a part of the pharmacy which is separated by a permanent wall or other barrier which restricts access between the two areas.

GA — One of the three pharmacy technicians must be certified. Board may consider and approve an application to increase the ratio in a hospital pharmacy.

ID — Ratio includes technicians, technicians-in-training, and student pharmacists. No longer allowed cashiers/clerks in pharmacy.

IN — Technicians must be under the immediate and personal supervision of the pharmacist.

KS — The ratio may be 3:1 if at least two of the pharmacy technicians have a current certification issued by PTCB or a current certification issued by any other pharmacy technician certification organization approved by the Board.

LA — If pharmacy technician candidate is present, then maximum ratio for technicians is 2:1. If not, then the maximum ratio for technicians is 3:1.

MO — Technician must be under the direct supervision and responsibility of a pharmacist.

MT — Ratio is 3:1. Licensee may ask Board for variance based on established criteria or greater upon Board approval.

NC — Ratio may be increased above 2:1 if additional technicians are certified and the Board approves the increase in advance.

NV — Technician to pharmacist ratio is now 3:1; however, initial prescription data input can now only be done by a registered pharmaceutical technician or a pharmacist. A clerk may enter demographic and insurance data only on new prescriptions.

SC — The PIC shall develop and implement written policies and procedures to specify the duties to be performed by


LEGEND — cont.

Footnotes continued on page 46


46


FOOTNOTES — cont.

pharmacy technicians. The duties and responsibilities of these personnel shall be consistent with their training and experience. These policies and procedures shall, at a minimum, specify that pharmacy technicians are to be personally supervised by a licensed pharmacist who has the ability to control and who is responsible for the activities of pharmacy technicians and that pharmacy technicians are not assigned duties that may be performed only by a licensed pharmacist. One pharmacist may not supervise more than four pharmacy technicians at a time; at least two of these four technicians must be state certified. If a pharmacist supervises only one or two pharmacy technicians, these technicians are not required to be state certified. Pharmacy

technicians do not include personnel in the prescription area performing only clerical functions, including data entry up to the point of dispensing, as defined in Section 40-43-30(14).

TN — Up to 4:1 if two technicians are certified. TX — 4:1 if at least one of the technicians is not

a pharmacy technician trainee.UT — Pharmacist determined for licensed

pharmacy technicians, only one technician-in-training per supervising pharmacist.

WA — A pharmacy may use more technicians than the standard 3:1 ratio if its service plan is approved by the Commission. The Commission is considering amending the rule that establishes a standard pharmacist to technician ratio. Contact Commission for updates.


47

14. Pharmacy Technicians in Hospital/Institutional Setting

May Pharmacy Technicians in the Hospital/Institutional Setting:

State

Accept Called-in Prescription From Physician's Office?

Enter Prescription Into Pharmacy Computer?

Check the Work of Other Technicians? If Yes, Is There a Requirement for Technology?

Alabama No Yes NoAlaska No Yes G NoArizona No Yes B Yes, Yes QQArkansas No Yes No KKCalifornia No Yes E Yes E, BB, NoColorado No Yes G Yes G, NoConnecticut No K Yes NoDelaware No Yes E NoDistrict of Columbia No Yes G NoFlorida No Yes NoGeorgia No Yes NoGuam No Yes E, G No Hawaii No Yes E, G NoIdaho Yes Yes Yes SIllinois Yes E Yes E No Indiana No † Yes † No PPIowa Yes G Yes G Yes O, No Kansas No Yes G Yes G, BB, NoKentucky No K Yes E No XLouisiana Yes Yes NoMaine No J Yes J No JMaryland No Yes No Massachusetts Yes AA Yes G NoMichigan Yes G Yes G Yes G, LLMinnesota No Yes No CMississippi No Yes E, G NoMissouri Yes E, G Yes E, G NoMontana Z, DD Yes No ONebraska No Yes No CNevada No Yes NoNew Hampshire Yes U Yes G NoNew Jersey No Yes G NoNew Mexico No Yes NoNew York No Yes G NoNorth Carolina Yes U Yes No IINorth Dakota Yes Yes Yes G, NoOhio Yes U Yes G NoOklahoma No Yes NoOregon No Yes Yes EEPennsylvania No Yes E, G NoPuerto Rico No N Yes N NoRhode Island Yes G, U Yes NoSouth Carolina Yes Y, AA Yes E Yes MSouth Dakota No Yes G No CTennessee Yes U Yes G NoTexas No Yes Yes V, NoUtah No GG Yes G, I Yes BBVermont No Yes E NoVirginia No Yes G NoWashington No † Yes Yes HHWest Virginia No Yes E, G No E, GWisconsin Z Yes NoWyoming No Yes E, G No

Colored text denotes change from 2018 edition.† Other comments noted in 2018 edition no longer apply.


48

14. Pharmacy Technicians in Hospital/Institutional Setting (cont.)

May Pharmacy Technicians in the Hospital/Institutional Setting:

State

Call Physician for Refill Authorization?

Compound Medications for Dispensing?

Transfer Prescription Orders?

Alabama No H Yes G No Alaska Yes D, G Yes G NoArizona Yes B Yes B, FF Yes YArkansas Yes D Yes NoCalifornia Yes E Yes E NoColorado Yes D Yes G NoConnecticut Yes D Yes E NoDelaware No Yes F NoDistrict of Columbia No G Yes G NoFlorida Yes Yes CC NoGeorgia No No W NoGuam No Yes E, G No Hawaii No Yes E, G NoIdaho Yes Yes Yes Illinois Yes E Yes E No Indiana Yes Yes NoIowa Yes G Yes G No MM

Kansas Yes D Yes G NoKentucky Yes E, D Yes E NoLouisiana Yes Yes E Yes YMaine Yes J Yes J No JMaryland Yes Yes G NoMassachusetts Yes Yes B, G NoMichigan No Yes G Yes QMinnesota Yes Yes P NoMississippi Yes E, G Yes E, G NoMissouri Yes E, G Yes E, G Yes E, G, YMontana Yes D, DD Yes DD NoNebraska Yes Yes BB NoNevada Yes Yes NoNew Hampshire Yes U Yes G NoNew Jersey Yes D Yes E, G NoNew Mexico Yes D Yes NoNew York No No NoNorth Carolina Yes U Yes E Yes UNorth Dakota Yes Yes G YesOhio Yes U Yes E, JJ Yes OOOklahoma Yes D Yes L NoOregon Yes D Yes NoPennsylvania No Yes E, F, G NoPuerto Rico No Yes N Yes NRhode Island Yes Yes G Yes ISouth Carolina Yes M, Y Yes E Yes M, YSouth Dakota Yes Yes G NoTennessee Yes G Yes G Yes UTexas Yes D Yes E, R NoUtah Yes D Yes G NoVermont No Yes A, B NoVirginia Yes D, Z Yes E, G NoWashington Yes D Yes T NoWest Virginia Yes D Yes G, T NoWisconsin D, Z Yes B, G NoWyoming Yes D, E, G Yes E, G, FF Yes Y

Colored text denotes change from 2018 edition.


49

A — Activities not addressed in statutes or regulations.

B — Subject to approved policy and procedure manuals, pharmacy technician training, and pharmacist final verification and initialing.

C — Only after obtaining a variance from the board. (In limited situations.)

D — If there are any changes to the prescription and/or if professional discretion and consultation is involved, the pharmacist must handle the call. (OR – For controlled substances.)

E — Allowed activity must be under the direct supervision of a licensed pharmacist. (HI – “Immediate supervision.” KY – Direct supervision if technician is not certified by the PTCB; if certified, then technician may perform activity under indirect supervision. LA – “Direct and immediate” supervision.)

F — Compounding is the responsibility of the pharmacist or pharmacy intern under the direct supervision of the pharmacist. The pharmacist may utilize the assistance of supportive personnel under certain conditions. Contact the board for requirements.

G — Pharmacist must verify, check, and/or is responsible for allowed activities. (DC – Pharmacist must call for refill authorization for Schedule III through V. Pharmacist must receive oral prescription for Schedule II. RI – Except in the case of Schedule II controlled substances, only a pharmacist may receive an oral prescription.)

H — If there are any changes to the prescription and/or if professional consultation is involved, the pharmacist must handle the call. May fax a refill request to a physician’s office if approved by the pharmacist. A refill is considered to be an authorization for a new prescription. Technicians may not take verbal orders from an agent or a physician for a new prescription.

I — Allowed activity must be under the general supervision of a licensed pharmacist.

J — May accept call-ins for refill approvals or denials.

K — Allowed activity limited to pharmacist interns.

L — Bulk compounding allowed. M — A supervising pharmacist may authorize

a certified pharmacy technician to (1) receive and initiate verbal telephone orders; (2) conduct one-time prescription transfers; (3) check a technician’s refill of medications if the medication is to be administered by a licensed health care professional in an institutional setting; and (4) check a technician’s repackaging of medications from bulk to unit dose in an institutional setting.

N — Pharmacy Act allows pharmacy technicians to perform the tasks assigned by the pharmacist under his or her direct supervision. Puerto Rico Supreme Court has recognized that only pharmacists are prepared to do patient counseling.

O — Board approval required before implementation of tech-check-tech program.

P — Stage checking required for certain high-risk compounded products.

Q — If there are policies and procedures in place that allow delegation and that comply with Board Administrative Rules 338.490 and 338.3162.

R — Must have special training. Contact the Board for training requirements.

S — There is no technology requirement for hospital/institutional settings. If performed in a community setting, the technician must use electronic verification systems.

T — Bulk compounding and intravenous preparation are allowed, but “extemporaneous” compounding is not allowed.

U — Certified technicians only. V — Contact the Board for requirements. W — May compound IV admixtures only if

pharmacist verifies the final product for accuracy, efficacy, patient utilization, and has a mechanism to verify the measuring of active ingredients added to the IV mixture.

X — Limitation 201 KAR 2:045. Y — Non-controlled only. (AZ – May only

do electronic transfers of non-controlled


LEGEND

NABPLAW Online Search Terms Pharmacy Technicians in Hospital/Institutional Setting (type as indicated below) technician duties hospital technician registration hospital technician requirements hospital technician training hospital

Note: “ancillary personnel,” “non-licensed personnel,” and “support personnel” can be substituted for “technician”; “institutional” can be substituted for “hospital.”



50

drugs between pharmacies owned by the same company using a common or shared database.)

Z — Can accept refills if no changes. (WI – New prescriptions must be recorded.)

AA — Certified technicians only with supervising pharmacist authorization.

BB — Board allows for a specifically trained technician to check the work of another technician in an acute care hospital under certain conditions. (UT – Only in hospital pharmacy.)

CC — The pharmacy technician may only assist with compounding under the direct supervision of a pharmacist.

DD — Technicians can work up to 30 minutes alone in the pharmacy while a pharmacist has a mandatory lunch break (up to 30 minutes) on the premises.

EE — Hospitals may apply to the Board for approval of technician checking validation programs that meet certain conditions. This is available for unit-dose drug distribution systems, including automated distribution carts and nonemergency kits and trays.

FF — Technicians only. Technician trainees cannot compound.

GG — (1) may take refill orders; (2) may accept new prescription drug orders telephonically or electronically submitted for a pharmacist to review; and (3) may not receive new verbal prescriptions or medication orders, clarify prescriptions or medication orders, nor perform a drug utilization review.

HH — Hospitals may apply to the Commission for approval of specialized functions

for pharmacy technicians; such as, technicians checking other technicians filling unit dose casettes when the proposal meets required conditions.

II — Board rule allows technicians with an AAS degree in pharmacy technology to check other technicians’ work in certain non-patient-specific distributive functions at inpatient hospitals.

JJ — Certified technicians may perform sterile and nonsterile compounding; registered technicians may only perform nonsterile compounding.

KK — Except one pilot program. LL — A pharmacy technician may only

perform activities of functions described in Section 17739 of the Public Health Code, MCL 333.17739, under the supervision and personal charge of the pharmacist or dispensing prescriber.

MM — Iowa is planning to amend rules to allow CPhTs to be involved in the transfer of non-controlled substance prescriptions in 2019.

NN — Technicians may not perform the final check of a prescription.

OO — Certified technicians only can transfer non-controlled prescription orders. Technicians must be approved by supervising pharmacist to transfer prescription orders.

PP — Technicians may not perform the final check of a prescription.

QQ — Only technicians; not trainees in compliance with Board rule.


LEGEND — cont.


51

15. Pharmacy Technicians in Community Setting

May Pharmacy Technicians in the Community Setting:

State

Accept Called-in Prescription From Physician's Office?

Enter Prescription Into Pharmacy Computer?

Check the Work of Other Technicians?

Alabama No Yes NoAlaska No Yes E NoArizona No Yes B Yes ZArkansas No Yes NoCalifornia No Yes D NoColorado No Yes E Yes EConnecticut No Yes D, E NoDelaware No Yes D NoDistrict of Columbia No Yes E NoFlorida No Yes NoGeorgia No Yes NoGuam No Yes D, E NoHawaii No Yes D, E NoIdaho Yes Yes Yes GGIllinois Yes I Yes I No Indiana No G Yes No JJIowa Yes E Yes E Yes X †Kansas No G Yes E NoKentucky No H Yes D NoLouisiana Yes Yes NoMaine No S Yes S No SMaryland No Yes NoMassachusetts Yes R Yes E NoMichigan Yes E Yes E Yes EMinnesota No Yes NoMississippi No Yes D, E NoMissouri Yes D, E Yes D, E NoMontana No Yes I, V NoNebraska No Yes NoNevada No Yes NoNew Hampshire Yes R Yes E NoNew Jersey No Yes E NoNew Mexico No Yes NoNew York No Yes E NoNorth Carolina Yes R Yes NoNorth Dakota Yes Yes Yes EOhio Yes R Yes E NoOklahoma No H Yes NoOregon No Yes NoPennsylvania No Yes D, E NoPuerto Rico Yes O Yes O NoRhode Island Yes R Yes NoSouth Carolina Yes K, R Yes D Yes TSouth Dakota No Yes D NoTennessee Yes E, R Yes E NoTexas No Yes NoUtah No DD Yes E NoVermont No Yes NoVirginia No Yes E NoWashington No † Yes Yes FFWest Virginia No Yes D, E No D, EWisconsin M, Y Yes NoWyoming No Yes D, E No

Colored text denotes change from 2018 edition.† Other comments noted in 2018 edition no longer apply.


52

15. Pharmacy Technicians in Community Setting (cont.)

May Pharmacy Technicians in the Community Setting:

State

Call Physician for Refill Authorization?

Compound Medications for Dispensing?

Transfer Prescription Orders?

Alabama No Q Yes E NoAlaska Yes E, M Yes E NoArizona Yes B Yes B, EE Yes AAArkansas Yes M Yes D, E NoCalifornia Yes D Yes D, E NoColorado Yes Yes E NoConnecticut Yes M Yes D, E NoDelaware No Yes F NoDistrict of Columbia No E Yes E NoFlorida Yes Yes BB NoGeorgia No No NoGuam No Yes D, E No Hawaii No Yes D, E NoIdaho Yes Yes Yes Illinois Yes I Yes I NoIndiana Yes Yes NoIowa Yes E Yes E No IIKansas Yes Yes E NoKentucky Yes D, M Yes D NoLouisiana Yes Yes D Yes KMaine Yes S Yes S No SMaryland Yes W Yes E NoMassachusetts Yes U Yes E Yes CCMichigan No Yes E Yes CMinnesota Yes Yes NoMississippi Yes D, E Yes D, E NoMissouri Yes D, E Yes D, E Yes D, E, KMontana Yes M, V Yes L, V NoNebraska Yes Yes BB NoNevada Yes Yes NoNew Hampshire No Yes E NoNew Jersey Yes M Yes D, E NoNew Mexico Yes E Yes NoNew York No No NoNorth Carolina Yes R Yes E Yes RNorth Dakota Yes Yes E YesOhio Yes R Yes D, HH Yes JOklahoma Yes M Yes L NoOregon Yes M Yes No ZPennsylvania No Yes D, E, F NoPuerto Rico Yes O Yes O Yes ORhode Island Yes Yes E Yes ISouth Carolina Yes K, R Yes D Yes K, TSouth Dakota Yes Yes E NoTennessee Yes Yes E Yes RTexas Yes M Yes D, N NoUtah Yes M Yes E NoVermont No Yes A, B NoVirginia Yes M Yes D, E NoWashington Yes M Yes P NoWest Virginia Yes D, E, M Yes D, E, P NoWisconsin Yes M, Y Yes B NoWyoming Yes D, E, M Yes D, E Yes K, EE

Colored text denotes change from 2018 edition.


53


A — Activities are not addressed in laws or statutes.

B — Subject to approved policy and procedure manuals, pharmacy technician training, and pharmacist final verification and initialing.

C — Yes, if there are policies and procedures in place that allow delegation and that comply with Board Administrative Rules 338.490 and 338.3162.

D — Allowed activity must be under the direct supervision of a licensed pharmacist. (HI – “Immediate supervision.” KY – Direct supervision if technician is not certified; if certified by the PTCB, then technician may perform activity under indirect supervision. LA – “Direct and immediate” supervision.)

E — Pharmacist must verify, check, and/or is responsible for allowed activities. (DC – pharmacist must obtain oral authorization for Schedule III through V refill. Pharmacist must receive oral prescription for Schedule II.)

F — Compounding is the responsibility of the pharmacist or pharmacy intern under the direct supervision of the pharmacist. The pharmacist may utilize the assistance of supportive personnel under certain conditions. Contact board for requirements.

G — Unless it is regarding a refill. H — Allowed activity limited to pharmacists

and interns. (KY – Under direct supervision.)

I — Allowed activity must be under the supervision of a licensed pharmacist.

J — Certified technicians only can transfer non-controlled prescrition orders. Technicians must be approved by supervising pharmacist to transfer prescription orders.

K — Non-controlled only. L — Bulk compounding allowed. M — If there are any changes to the

prescription and/or if professional discretion and consultation is involved, the pharmacist must handle the call.

N — Must have special training. Contact the Board for training requirements.

O — Pharmacy Act allows pharmacy technicians to perform the tasks assigned

by the pharmacist under his or her supervision. Puerto Rico Supreme Court has recognized that only pharmacists are prepared to do patient counseling.

P — Bulk compounding and intravenous preparation are allowed, but “extemporaneous” compounding is not allowed.

Q — If there are any changes to the prescription and/or if professional consultation is involved, the pharmacist must handle the call. May fax a refill request to a physician’s office if approved by the pharmacist. A refill is considered to be an authorization for a new prescription. Technicians may not take verbal orders from an agent or a physician for a new prescription.

R — If technician is certified. (SC – Only with supervising pharmacist authorization.)

S — New rules regarding allowed activities for technicians expected in 2014.

T — A supervising pharmacist may authorize a certified pharmacy technician to (1) receive and initiate verbal telephone orders; (2) conduct one-time prescription transfers; (3) check a technician’s refill of medications if the medication is to be administered by a licensed health care professional in an institutional setting; (4) check a technician’s repackaging of medication from bulk to unit dose in an institutional setting.

U — Provided no change in therapy. V — Technicians can now work up to 30

minutes alone in the pharmacy while a pharmacist has a mandatory lunch break (up to 30 minutes) on the premises.

W — Pharmacy technician may call for refills for prescriptions other than controlled dangerous substances. May not accept refill authorization that changes the order.

X — Tech-check-tech currently allowed only under approved pilot programs. Iowa Code amended in 2018 to allow Technician Product Verification in the community setting. Rules will be promulgated late 2018 or early 2019.

LEGEND

NABPLAW Online Search TermsPharmacy Technicians in Community Setting (type as indicated below) technician duties technician registration technician requirements technician training Note: “ancillary personnel,” “non-licensed personnel,” and “support personnel” can

be substituted for “technician.”



54

Y — Refills only with no changes. New prescriptions must be recorded.

Z — May assist pharmacist. AA — Only electronic transfers of non-

controlled drugs between pharmacies owned by the same company using a common or shared database.

BB — The pharmacy technician may only assist with compounding under the direct supervision of a pharmacist.

CC — A certified pharmacy technician may assist in the transfer of a refill for a Schedule VI prescription (Massachusetts considers all drugs not in Schedule II-V to be Schedule VI) upon request by a consumer.

DD — (1) may take refill orders; (2) may accept new prescription orders telephonically or electronically submitted for a pharmacist to review; and (3) may not receive new verbal prescriptions or medication orders, nor perform a drug utilization review.

EE — Technicians only. Technician trainees cannot compound.

FF — Pharmacy may apply to the Commission for approval of tech-check-tech programs that meet certain conditions. This is available for unit-dose drug distribution systems.

GG — To perform final verification in a community setting, a technician must use an electronic verification system. A certified technician who attains training may also administer vaccines.

HH — Certified technicians may perform sterile and nonsterile compounding; registered technicians may only perform nonsterile compounding.

II — Iowa is planning to amend rules to allow CPhTs to be involved in the transfer of non-controlled substance prescriptions in 2019.

JJ — Technicians may not perform the final check on any prescription.


LEGEND — cont.


One CVS Drive Woonsocket, RI 02895

July 15, 2019

Texas State Board of Pharmacy

Allison Benz

Director of Professional Services

333 Guadalupe Street, Suite 3600

Austin, TX 78701

RE: TAC 22-281.5 Initiating Proceedings Before the Board

Dear Ms. Benz,

Pursuant to Rule 281.5, CVS Health is providing this petition to aid in the prospective promulgation of amendments to Texas Administrative Code geared towards enabling Texas pharmacists to leverage technicians to perform non-judgmental, non-clinical tasks.

Rule 281.5(a)(1); Exact wording of the amended proposed rule

TAC 22-291.32(c) Pharmacists.

(1) General.

…

(2) Duties. Duties which may only be performed by a pharmacist are as follows:

(A) receiving oral prescription drug orders and reducing these orders to writing, either

manually or electronically;

(AB) interpreting prescription drug orders;

(C) selecting drug products;

(D) performing the final check of the dispensed prescription before delivery to the patient to

ensure that the prescription has been dispensed accurately as prescribed;

(E) communicating to the patient or patient's agent information about the prescription drug or

device which in the exercise of the pharmacist's professional judgment, the pharmacist deems

significant, as specified in §291.33(c) of this title;

(F) communicating to the patient or the patient's agent on his or her request information

concerning any prescription drugs dispensed to the patient by the pharmacy;

(G) assuring that a reasonable effort is made to obtain, record, and maintain patient medication

records;

(H) interpreting patient medication records and performing drug regimen reviews;

(I) performing a specific act of drug therapy management for a patient delegated to a

pharmacist by a written protocol from a physician licensed in this state in compliance with the

Medical Practice Act; and

(J) verifying that controlled substances listed on invoices are received by clearly recording

his/her initials and date of receipt of the controlled substances; and

(K) transferring or receiving a transfer of original prescription information on behalf of a

patient.

TAC 22-291.32(d) Pharmacy Technicians and Pharmacy Technician Trainees.

(1) General.

(A) All pharmacy technicians and pharmacy technician trainees shall meet the training

requirements specified in §297.6 of this title (relating to Pharmacy Technician and Pharmacy

Technician Trainee Training).

(B) Special requirements for compounding. All pharmacy technicians and pharmacy

technician trainees engaged in compounding non-sterile preparations shall meet the training

requirements specified in §291.131 of this title.

(2) Duties.

(A) Pharmacy technicians and pharmacy technician trainees may not perform any of the duties

listed in subsection (c)(2) of this section.

(B) Pharmacy technician trainees may not perform any of the duties listed in part (E) of this

subsection.

(BC) A pharmacist may delegate to pharmacy technicians and pharmacy technician trainees

any nonjudgmental technical duty associated with the preparation and distribution of prescription

drugs provided:

(i) unless otherwise provided under §291.33 of this subchapter, a pharmacist verifies the

accuracy of all acts, tasks, and functions performed by pharmacy technicians and pharmacy

technician trainees;

(ii) pharmacy technicians and pharmacy technician trainees are under the direct supervision

of and responsible to a pharmacist; and

(iii) only pharmacy technicians and pharmacy technician trainees who have been properly

trained on the use of an automated pharmacy dispensing system and can demonstrate

comprehensive knowledge of the written policies and procedures for the operation of the system

may be allowed access to the system.

(CD) Pharmacy technicians and pharmacy technician trainees may perform only

nonjudgmental technical duties associated with the preparation and distribution of prescription

drugs, as follows:

(i) initiating and receiving refill authorization requests;

(ii) entering prescription data into a data processing system;

(iii) taking a stock bottle from the shelf for a prescription;

(iv) preparing and packaging prescription drug orders (i.e., counting tablets/capsules,

measuring liquids and placing them in the prescription container);

(v) affixing prescription labels and auxiliary labels to the prescription container;

(vi) reconstituting medications;

(vii) prepackaging and labeling prepackaged drugs;

(viii) loading bulk unlabeled drugs into an automated dispensing system provided a

pharmacist verifies that the system is properly loaded prior to use;

(ix) loading prepackaged containers previously verified by a pharmacist or manufacturer's

unit of use packages into an automated dispensing system in accordance with

§291.33(i)(2)(D)(III) of this subchapter;

(x) compounding non-sterile prescription drug orders; and

(xi) compounding bulk non-sterile preparations.

(E) In addition to the duties listed in subsection (D), Pharmacy technicians may perform the

following:

(i) receiving oral prescription drug orders or receiving clarification on existing drug orders,

and reducing these orders to writing, either manually or electronically.

(ii) transferring or receiving a transfer of original prescription information on behalf of a

patient.

Rule 281.5(a)(2); specific reference to amended rules

Title 22, Part 15, Chapter 291, Subchapter B, Rule 291.32(c)(2) and (d)(2)

Rule 281.5(a)(3); justification for the proposed action

At the May 7, 2019 Texas State Board of Pharmacy meeting, the Board entered into a meaningful discussion around efforts that can be undertaken from a Board perspective to alleviate constraints that impact community pharmacists in their efforts to provide safe and effective pharmacy care. Within this discussion, members of the Board and public pinpointed the underutilization of

technicians as a major contributing factor that impacts pharmacist’s time spent on clinical patient care.

The proposed amendments within this request are geared towards enabling a pharmacist to delegate additional non-judgmental actions to a registered technician. Specifically, the proposed amendments enable a Texas pharmacist to entrust a registered technician, under their supervision, to receive new verbal orders and clarification of existing orders from a prescriber or prescriber’s agent, and to perform the act of communicating or receiving prescription transfer information between pharmacies.

The existing rules mandating a pharmacist take part in the transfer of prescription information inevitably removes the pharmacist from their focus on clinical tasks such as drug utilization review, and direct patient care. For reference, the actions of accepting verbal prescriptions, obtaining prescription order clarification and transferring prescription information have been safely performed by registered pharmacy technicians in multiple jurisdictions for over 40 years.

To supplement this rationale, I have included a research publication, performed by the University of Pittsburgh, which encompasses these actions. Additionally, you will find duties detailed that would work towards the same goal of freeing up more time for the pharmacist to focus on their clinical responsibilities, though current statutory constraints limit the Board to these few roles. The greatest example being pharmacy technician based immunization administration.

CVS Health thanks the Board for their consideration of our request, and for the open discussion geared towards improving pharmacy practice in the community setting. Improving pharmacist working conditions requires a holistic approach by employers, academia, legislators and regulators. The Board has the ability to make strides in the right direction by enabling registered pharmacy technicians to perform the non-judgmental tasks outlined in these petitioned amendments. If you have any questions or need additional information, please contact me directly at 617-599-9091.

Sincerely,

John N. Rocchio PharmD. RPh. Sr. Director, Pharmacy Regulatory Affairs

PHARMACY TECHNICIAN ROLE EXPANSIONAN EVIDENCED-BASED POSITION PAPER

July 2018

1

EDITORSUniversity of Pittsburgh School of Pharmacy

Lucas A. Berenbrok, PharmD, MS, BCACP

Joni C. Carroll, PharmD, BCACP

Kim C. Coley, PharmD, FCCP

Melissa Somma McGivney, PharmD, FCCP, FAPhA

University of Pittsburgh Health Sciences Library System

Michele Klein Fedyshin, MSLS, BA, BSN, RN

CONTRIBUTORSUniversity of Pittsburgh School of Pharmacy

Hailey Mook, Student Pharmacist Class of 2021

Thai Nguyen, Student Pharmacist Class of 2021

EXECUTIVE SUMMARYIncreasing access to healthcare significantly improves patient care, health outcomes, quality and efficiency,

and diminishes gaps in the current healthcare delivery system.1 As the most accessible healthcare destinations,

community pharmacies increase patient access to healthcare in local communities.2 Community pharmacists

provide high quality, accessible patient care services including medication management, immunizations, preventive

screenings, and chronic care management. Despite a growing need for increased access to patient care services,

community pharmacists spend only 21% of their professional time performing patient care services that are not

associated with dispensing prescriptions.3

To further enhance and optimize patient care services delivered at community pharmacies, leveraging and expanding

current roles of the pharmacy technician should be considered in the community pharmacies. This means working

towards a unified vision for advanced pharmacy technician practice, which includes expanded technician roles

and responsibilities when dispensing medications and supporting patient care services.4 Expanding the roles

of pharmacy technicians to include administrative and supportive tasks for pharmacist-provided patient care

services5 will allow pharmacists to more effectively and efficiently provide for patients’ medication-related needs.

This report would not have been possible without the financial support of the National Association of Chain Drug Stores.

2

PURPOSEThe purpose of this paper is to provide evidence that supports the expanded roles of pharmacy technicians,

including additional administrative and supportive tasks, that enhance and optimize pharmacist-provided patient

care.

METHODSA professional clinical medical librarian (MKF) designed and conducted two searches using the PubMed and

EMBASE databases. Controlled vocabulary terms from the MeSH and Emtree thesauri along with text words were

searched to retrieve many variations for the concepts of Pharmacy Technician, Community Pharmacy, and Scope

of Practice. Adjacency searches provided additional terminology where enabled by database syntax. Boolean

operators were used to combine the concepts. Results spanned the years 2000 through October 27, 2017. Only

English language articles were included. The retrievals were downloaded into an EndNote Library for screening.

Using DistillerSR (Evidence Partners, Ottawa, Canada) the articles identified above were reviewed by three faculty

members and two student pharmacists from the University of Pittsburgh School of Pharmacy. Articles were

included in an annotated bibliography if they demonstrated robust and generalizable evidence. Commentaries and

opinion pieces were excluded. A panel of academic experts reviewed the annotated bibliography to confirm the

completeness of evidence and to identify additional articles for inclusion. These academic experts plus a panel of

leaders from community pharmacy chain organizations were convened by telephone on two occasions to provide

feedback and ultimately consensus on the position statements below.

POSITIONSIn conventional community pharmacy practice models, pharmacy technicians perform administrative and

supportive tasks almost exclusively related to medication dispensing. Evidence-based studies of contemporary

practice models in several U.S. states demonstrate that technicians can also perform administrative and supportive

tasks for pharmacy patient care services in the following ways.

3

POSITION 1

REALLOCATION OF PHARMACIST TIME TO OPTIMIZE PATIENT CARE

Community pharmacists spend only 21% of their professional time performing patient care services not associated with medication dispensing.3 To further optimize the pharmacist’s role in delivering patient-centered, collaborative care in communities, pharmacists must effectively reallocate their time, resources, and utilization of pharmacy technicians.

TIME REALLOCATION | TECHNICIAN PRODUCT VERIFICATION6

Technician product verification has the potential to reallocate pharmacist time spent dispensing medications to

performing patient care services. A pilot study in several community pharmacies in Iowa illustrated that pharmacy

technicians are as accurate as pharmacists when performing final product verification. Both pharmacists and

technicians recorded accuracy rates of over 99%, suggesting uncompromised patient safety when technician

product verification is implemented in community pharmacies. In addition, pharmacist time spent performing

patient care services increased by approximately 19%. Patient care services were defined as but not limited

to medication reviews, medication synchronization appointments with patients, and medication therapy

management.

TIME REALLOCATION | ADVANCED PATIENT CARE ROLES7

Trained and experienced pharmacy technicians can assume administrative tasks, and some clinical tasks, when

appropriately delegated to do so by a pharmacist. A two-part study determined the appropriateness and proportion

of work at Veterans Affairs anticoagulation clinics that could be shifted from pharmacists to pharmacy technicians.

A modified Delphi process was used to categorize administrative and clinical tasks as appropriate units of work for

minimally qualified certified pharmacy technicians (MQ-CPT) and advanced-practice pharmacy technicians (AP-

CPT). Appropriate administrative tasks for both MQ-CPTs and AP-CPTs included triaging drug-drug and drug-food

interactions calls to the pharmacist, obtaining transfer information from outside providers, and entering outside

laboratory values into the electronic medical record among others. Appropriate clinical tasks for both MQ-CPTs

and AP-CPTs included calling patients found to have an in-range international normalized ratio (INR) to conduct

an interview, fill out a consultation note, and designate a pharmacist cosigner. Additionally, appropriate clinical

tasks for AP-CPTs only extended to performing point-of-care finger-stick assays for INR and calling patients within

0.1 percent of goal INR to conduct interview, document, and designate a pharmacist cosigner. The results of

the time study indicated that 21% and 41% of pharmacist work could be completed by MQ-CPTs and AP-CPTs

respectively. The investigators concluded that a trained pharmacy technician can help free up pharmacist hours

to spend time with more complex patients in an anticoagulation clinic setting.

4

POSITION 2

TECHNICIAN ASPIRATION FOR EXPANDED ROLES

Most states limit the pharmacy technician’s scope of practice to certain aspects of the medication dispensing process. However, many pharmacy technicians have positive attitudes towards performing administrative and supportive tasks that further optimize patient care services in the community pharmacy setting. Technicians involved with these tasks are professionally satisfied in expanded roles. Broadening the pharmacy technician’s scope of practice may further advance the pharmacy technician’s role as an important contributor to the healthcare team.

TECHNICIAN ATTITUDES8

Pharmacy technicians report positive attitudes toward performing administrative and supportive tasks that can help

pharmacists deliver patient care services. A cross-sectional survey assessed U.S. pharmacy technicians’ attitudes

and self-efficacy performing current and emerging roles in hospitals and in community pharmacies. Technicians

from 8 states representing all four geographic regions were included. Community pharmacy technicians reported

relatively high levels of involvement, self-efficacy in, and positive attitudes toward many tasks, many of which

included prescription receipt and dispensing processes. Technicians reported positive attitudes with performing

tasks related to communicating lifestyle changes to patients, discussing effectiveness of treatment plans for

returning patients, collaborating with other health professionals to monitor drug therapy effectiveness, providing

information to providers and patients on medication issues, transferring prescriptions, and administering

immunizations. These findings provide further evidence for leveraging the maturation of technicians and their

education and professionalization, including the potential for work redesign so that pharmacists can optimize

accessible, quality healthcare in communities.

TECHNICIANS WITH EXPANDED ROLES9

Many community pharmacy technicians are more satisfied with their professional work when they can assist

with administrative and supportive tasks related to medication therapy management (MTM). A prospective,

observational study assessed the impact of technicians’ involvement with MTM services in community pharmacies.

Identification of MTM opportunities was the most commonly reported role of pharmacy technicians. In addition,

40% of technicians were more satisfied with their professional work after engaging in tasks related to MTM and

44% of pharmacists were satisfied with the technician’s expanded role.

5

POSITION 3

TECHNICIAN SUPPORT FOR PHARMACY PATIENT CARE SERVICES

Historically, pharmacy technicians have been utilized for administrative and supportive tasks throughout the medication dispensing process (i.e. medication preparation, payment adjudication, and customer service). Expanding the role of pharmacy technicians to assume time- and resource-intensive administrative and supportive tasks for pharmacy patient care services redistributes pharmacists’ time to further optimize patient care.

MEDICATION MANAGEMENT SERVICES | ADMINISTRATIVE10

Pharmacists want pharmacy technicians to provide administrative support by coordinating, documenting, and

billing for medication management services. A 2009 survey of pharmacists was conducted to uncover perceived

barriers to implementing medication therapy management services in a supermarket chain pharmacy. More than

75% of responding pharmacists (n=98) reported a desire for pharmacy technician assistance with scheduling,

billing, and patient correspondence; however, only 21%, 19%, and 20% of technicians were currently assisting

with these processes, respectively. Nearly 42% of responding pharmacists also stated a need for help with clerical

patient care documentation, but only 6% of technicians were helping with this task. The investigators concluded

that differentiating pharmacist and technician roles may permit efficient, safe, and cost-effective provision of

pharmacy patient care services. Furthermore, incorporation of pharmacy technicians to provide administrative

support to medication therapy management may reduce barriers to the implementation of patient care services.

IMMUNIZATIONS | ADMINISTRATIVE AND SUPPORTIVE11

Pharmacy technicians can provide administrative support for pharmacist immunization services by assisting with

billing, documentation, and reporting adverse events. A review of relevant literature revealed that community

pharmacy technicians can help with clerical duties for immunization services including documentation, billing,

and assisting in adverse event reporting. Additionally, pharmacy technicians can facilitate communications

about immunizations between the pharmacy and physician office practices (i.e. acquire immunization records or

notify physician office upon receipt of immunization). Based on the findings of this literature review, the authors

concluded that pharmacy technicians can assist pharmacists in community pharmacy immunization services and

help remove barriers to optimizing care.

6

POSITION 4

TECHNICIAN SCREENING FOR PATIENT CARE SERVICES

Pharmacy technicians are uniquely positioned to identify and engage patients who would benefit from pharmacist patient care services given that patients frequently approach pharmacy technicians before interacting with the pharmacist. In settings where expanded technician roles are championed, patients receive comprehensive care through screening, identification, and referral of the patient’s medication-related needs to the pharmacist.

IMMUNIZATIONS | PATIENT IDENTIFICATION12

Pharmacy technicians can help identify patients who are eligible for pharmacist immunization services. An

immunization screening program by pharmacists and pharmacy technicians was successfully implemented at an

independent pharmacy with multiple locations. Pharmacy technicians, especially those physically positioned in the

pharmacy to facilitate patient interactions, were instrumental in identifying patients eligible for immunizations

recommended by the Advisory Committee on Immunization Practices.

PHARMACIST EXTENDERS13

Pharmacy technicians can extend the reach of pharmacists by identifying potential medication-related problems

and referring patients for pharmacist intervention. A transitions of care program at a large healthcare system

utilized pharmacy technicians in a broader role as community health workers. Functioning as pharmacist

extenders, certified pharmacy technicians provided telephone follow-up and home visit services to patients

following hospital discharge. Technicians were trained in motivational interviewing, communication skills, teach-

back techniques, basic disease state management, and recording medication history. The health system saw an

increase in the number of home visits and telephone follow-up rates. Pharmacy technicians successfully identified

and referred potential medication-related problems to pharmacists to target medication management services.

The authors concluded that pharmacy technicians accurately identified patients for pharmacist intervention and

collected information to assist with care plans.

SCREENING AND FACILITATION14

Pharmacy technicians can collect clinical information from a patient and screen patients for pharmacist intervention

in the outpatient setting. At five primary care outpatient practices within a large integrated health system, the

pharmacy technician’s performance in supporting a multi-site team of pharmacists providing post-fracture care

was assessed. The pharmacy technician screened patients for adherence with osteoporosis recommendations,

identified patients requiring pharmacist intervention, and collected patient-specific clinical information from the

electronic health record. A review of patient cases demonstrated pharmacist agreement with the technician’s

determination of the need for intervention in 93% of cases. As a result of technician support, pharmacists spent

less time reviewing patient cases not requiring intervention. Technician support also reduced the average time

pharmacists required to develop care plans. Conclusions support that pharmacy technicians can accurately screen

patients for pharmacist intervention and collect clinical information to facilitate and optimize patient care.

7

POSITION 5

TECHNICIAN SUPPORT OF MEDICATION DISPENSING

Retrieving, clarifying, and transcribing prescription information from the prescriber or the prescriber’s agent does not require clinical judgement; instead it requires competency in verbal and written communication. Often, the prescriber’s agent is administrative support staff who perform these tasks at the discretion of the physician. Similarly, pharmacy technicians can receive, clarify, and transcribe prescriptions at the discretion of the pharmacist in permitting states. Fifteen states allow pharmacy technicians to accept verbal prescriptions, and 12 states allow pharmacy technicians to transfer prescriptions from one community pharmacy to another.15 In other pharmacy practice models, pharmacy technicians may also enter prescriptions for pharmacist review and play significant roles in detecting and preventing electronic prescribing errors. Pharmacy technicians should be recognized by state laws and regulations as competent team members who can support these medication dispensing tasks.

SAFETY IN E-PRESCRIBING16

Community pharmacy technicians play an essential role in detecting and preventing electronic prescription errors.

Observations, interviews, and focus groups were conducted to understand the role of pharmacy technicians

in electronic-prescribing (e-prescribing). Fourteen pharmacy technicians and thirteen pharmacists from five

community pharmacies in Southwest Wisconsin participated. The pharmacy technician took responsibility for

reviewing all steps prior to the pharmacist’s e-prescription review. Technicians played a primary role in detecting

and preventing e-prescription errors as the first individual to receive and review new prescriptions in the

community pharmacy.

PRESCRIPTION CLARIFICATION17

In many practice models, pharmacy technicians may contact prescriber offices to clarify prescriptions. At five

independent community pharmacies in Connecticut, pharmacists and pharmacy technicians used a standardized

tool to document number, type, and reason for prescription clarification and time spent to resolve prescriptions

necessitating clarification prior to dispensing. The most common reasons for prescription clarification were prior

authorization and missing information. The average time to resolve clarifications ranged from 6 minutes to

greater than 2 weeks. Utilizing pharmacy technicians for prescription clarification supports the pharmacist in the

medication dispensing process to further optimize pharmacy care.

8

POSITION 6

TECHNICIAN PRODUCT VERIFICATION

Medication product verification, the final non-clinical review of a medication product to be dispensed, can be performed safely by pharmacy technicians who are given privileges to do so through state laws and regulations. Evidence suggests that pharmacy technicians are equally or more accurate than pharmacists when performing medication product verification. Utilizing technicians for medication product verification may save pharmacist time, further optimizing patient care. Evidence supports the safe and effective implementation of technician product verification in community pharmacies.

PHARMACIST AND TECHNICIAN PERCEPTIONS18

Pharmacists and pharmacy technicians have confidence that pharmacy technicians can perform final medication

product verification. A literature review assessed technicians’ and pharmacists’ perceptions on technician-check-

technician (TCT) models in community pharmacy settings. Five studies demonstrated evidence from theoretical

TCT models, and two studies demonstrated evidence from implemented TCT practice models. In one theoretical

TCT model in New Zealand, 73% of surveyed pharmacists and 89% of surveyed technicians agreed that some

technicians could act competently as a product verification technician. Following one implemented TCT practice

model in New Zealand, all surveyed pharmacists and all but one surveyed technician responded “very confident”

that pharmacy technicians had the skills and knowledge to perform final product verification checks following

training.

COMPARATIVE ERROR RATES19,20 With the assistance of barcode scanning technology, pharmacy technicians can perform final medication product

verification accurately. Barcode product verification performed by pharmacy technicians was evaluated as an

alternative to visual product verification by pharmacists in the final stage of the dispensing process in a hospital

pharmacy. The amount of pharmacist time that could potentially be reallocated to patient care services using

this process was also assessed. A total of 2,015 medication doses dispensed during the study period were

included in the analysis. The error rate when technicians conducted final product verification using barcode

scanning was significantly lower than when pharmacists conducted final verification by a visual check (0% vs.

0.7%). Pharmacist visual product verification time was approximately 6 seconds per checked prescription. This

would result in over 1,200 pharmacist hours that could be reallocated annually to patient care at this institution

if technician barcode product verification was implemented. Pharmacy technician barcode product verification

is a safe alternative to pharmacist visual product verification. The time saved by the technician barcode product

verification process can permit reallocation of pharmacist time to optimize patient care services.19

Additionally, published literature of state-authorized programs permitting final product verification of medication

orders by pharmacy technicians report that technicians can accurately perform final dispensing product verification

comparable to pharmacists. Error detection rates between tech-check-tech and pharmacists were similar (99.6%

vs. 99.3%). Several of these studies also found significant differences in accuracy/error detection rates favoring

tech-check-tech. In the states that have active tech-check-tech practices or pilot programs, pharmacists reported

saving as much as 30 hours per pharmacist per month, enabling them to provide more patient care. All 9 states

that allow tech-check-tech require special training for participating technicians.20

9

POSITION 7

TECHNICIAN-OBTAINED MEDICATION HISTORIES

Pharmacy technicians have a greater understanding of patients’ medication lists and medication-taking behaviors than non-pharmacy healthcare professionals. Multiple studies demonstrate that pharmacy technicians are more accurate than nurses and other non-pharmacy personnel in obtaining patient medication histories. Utilization of pharmacy technicians to obtain medication histories allows pharmacists to more effectively prevent, identify, and resolve drug therapy problems. Reassigning supportive tasks such as obtaining medication histories to pharmacy technicians can optimize patient care.

MEDICATION HISTORIES | ACCURACY22

Pharmacy technicians can collect accurate medication histories. A comparison of medication history error rates of

pharmacy technicians with that of nurses in the emergency department (ED) resulted in more accurate medication

histories obtained by the pharmacy technician than emergency department nurses. Pharmacy technician-obtained

medication histories had an error rate of 5.6% compared to an 86% error rate for nurses. Additionally, pharmacy

technicians were more likely to identify medication dosing errors (e.g. wrong dose or frequency) when conducting

medication histories.

MEDICATION HISTORIES | PATIENT SAFETY23

Medication histories collected by pharmacy technicians in the emergency department (ED) improve patient safety.

Medication histories collected by pharmacy technicians were found to have a 15% error rate compared to a

65% error rate for nurses and other non-pharmacy personnel, a 50% absolute risk reduction. The investigators

concluded that engaging trained pharmacy technicians to conduct medication histories in the ED improves

patient safety during patient care transitions.

MEDICATION HISTORIES | REDUCING ERRORS24

Pharmacy technicians contribute to patient safety by reducing errors. A randomized controlled trial of 306 inpatients

compared the admission medication history (AMH) error reduction rates of pharmacist-supervised pharmacy

technicians, pharmacists, and usual care. AMH errors and resultant admission medication order (AMO) errors were

independently identified and rated. Pharmacists and pharmacist-supervised pharmacy technicians reduced AMH

errors by more than 80%. No differences between pharmacist and pharmacist-supervised pharmacy technician

outcomes were found. This study provides evidence that pharmacy technicians can safely and effectively perform

clerical and supportive activities that have traditionally been the responsibility of pharmacists, thereby freeing up

pharmacist time to further optimize patient care through advanced patient care services.

10

POSITION 8

TECHNICIAN IMMUNIZATION ADMINISTRATION

Pharmacy technicians perform administrative tasks to support pharmacist-led immunization services. In Idaho, certified pharmacy technicians have begun administering immunizations, a task that is largely considered technical. Permitting pharmacy technicians to administer immunizations has the potential to increase the impact of pharmacist-led immunization services in local communities across the country.

IMMUNIZATIONS | ADMINISTRATION21

Pharmacy technicians are capable of administering immunizations. In Idaho, a small pilot group of pharmacy

technicians went through an immunization training program that included both home-study and live components.

All technicians who completed the home-study portion passed the home-study assessment (greater than 70%

correct) on the first attempt. In the 6-month period following training, technicians gave 953 immunizations with

adverse events reported at rates similar to that of other immunizing healthcare providers.

11

ACKNOWLEDGEMENTSJohn DeJames, RPh

Senior Manager of Clinical Programs

Giant Eagle, Inc.

Tomson George, RPh

Senior Manager of Professional Affairs

Walgreen Co.

Kenneth C. Hohmeier, PharmD

Assistant Professor

Director of Community Affairs

Department of Clinical Pharmacy

The University of Tennessee Health Science Center

College of Pharmacy

Kimberly McKerinan, PharmD, BCACP

Clinical Assistant Professor, Pharmacotherapy

Washington State University

College of Pharmacy

Brian W. Salvas, PharmD, RPh

Director of Pharmacy Operations

CVS Health

Jon C. Schommer, MS, PhD, RPh

Associate Department Head and Professor

Department of Pharmaceutical Care & Health Systems

University of Minnesota

College of Pharmacy

Jeff Shorten, PharmD

Director of Pharmacy Operations

Thrifty White Pharmacy

Meredith K. Sparks, PharmD Class of 2018

University of Pittsburgh

School of Pharmacy

12

REFERENCES1. Office of disease prevention and health promotion. Healthy People 2020 topics and objectives: access

to health services. https://www.healthypeople.gov/2020/topics-objectives/topic/Access-to-Health-

Services#1. Accessed June 16, 2018.

2. NACDS. RxImpact; March 2015 Volume 4. http://www.nacds.org/pdfs/RxImpact_March%202015.pdf.

Accessed June 15, 2018.

3. Gaither CA, Schommer JC, Doucette WR, et al. Final report of the 2014 National Sample

Survey of the Pharmacist Workforce to determine contemporary demographic, practice

characteristics and quality of work-life. https://www.aacp.org/sites/default/files/

finalreportofthenationalpharmacistworkforcestudy2014.pdf. Accessed May 21, 2018.

4. Zellmer WA, McAllister EB, Silvester JA, et al. Toward uniform standards for pharmacy technicians:

Summary of the 2017 Pharmacy Technician Stakeholder Consensus Conference. Am J Health Syst Pharm.

2017;74(17):1321-1332.

5. Adams AJ. Advancing technician practice: Deliberations of a regulatory board. Research in Social

and Administrative Pharmacy. 2018;14(1):1-5. http://www.sciencedirect.com/science/article/pii/

S1551741117301018.

6. Andreski M, Myers M, Gainer K, et al. The Iowa new practice model: Advancing technician roles to

increase pharmacists’ time to provide patient care services. J Am Pharm Assoc (2003). 2018.

7. Kuhn H, Park A, Kim B, et al. Proportion of work appropriate for pharmacy technicians in anticoagulation

clinics. Am J Health Syst Pharm. 2016;73(5):322-327.

8. Desselle SP, Hoh R, Holmes ER, et al. Pharmacy technician self-efficacies: Insight to aid future

education, staff development, and workforce planning. Res Social Adm Pharm. 2017. doi: 10.1016/j.

sapharm.2017.07.005.

9. Lengel M, Kuhn CH, Worley M, et al. Pharmacy technician involvement in community pharmacy

medication therapy management. J Am Pharm Assoc (2003). 2018;58(2):179-185.e172.

10. Bright DR, Lengel AJ, Powers MF. Pharmacists’ perceptions of barriers to implementing medication

therapy management and the role of pharmacy technicians in overcoming the barriers. J Pharm Technol.

2009;25(6):361-367.

11. Powers MF, Hohmeier KC. Pharmacy technicians and immunizations. J Pharm Pract. 2011;27(3):111-116.

12. Rhodes LA, Branham AR, Dalton EE, et al. Implementation of a vaccine screening program at an

independent community pharmacy. J Am Pharm Assoc (2003). 2017;57(2):222-228.

13. Bailey JE, Surbhi S, Bell PC, et al. SafeMed: Using pharmacy technicians in a novel role as community

health workers to improve transitions of care. J Am Pharm Assoc (2003). 2016;56(1):73-81.

14. Irwin AN, Heilmann RM, Gerrity TM, et al. Use of a pharmacy technician to facilitate postfracture care

provided by clinical pharmacy specialists. Am J Health Syst Pharm. 2014;71(23):2054-2059.

15. Frost TP, Adams AJ. Expanded pharmacy technician roles: Accepting verbal prescriptions and

communicating prescription transfers. Res Social Adm Pharm. 2017;13(6):1191-1195.

16. Odukoya OK, Schleiden LJ, Chui MA. The hidden role of community pharmacy technicians in ensuring

patient safety with the use of e-prescribing. Pharmacy (Basel). 2015;3(4):330-343.

17. Smith M, Sprecher B. Pharmacy communications with physician offices to clarify prescriptions. J Am

Pharm Assoc (2003). 2017;57(2):178-182.

18. Frost TP, Adams AJ. Pharmacist and technician perceptions of tech-check-tech in community pharmacy

practice settings. J Pharm Pract. 2018;31(2):190-194.

13

19. Wang BN, Brummond P, Stevenson JG. Comparison of barcode scanning by pharmacy technicians and

pharmacists’ visual checks for final product verification. Am J Health Syst Pharm. 2016;73(2):69-75.

20. Adams AJ, Martin SJ, Stolpe SF. “Tech-check-tech”: A review of the evidence on its safety and benefits.

Am J Health Syst Pharm. 2011;68(19):1824-1833.

21. McKeirnan KC, Frazier KR, Nguyen M, et al. Training pharmacy technicians to administer immunizations. J

Am Pharm Assoc (2003). 2018;58(2):174-178.e171.

22. Markovic M, Mathis AS, Ghin HL, et al. A comparison of medication histories obtained by a pharmacy

technician versus nurses in the emergency department. P t. 2017;42(1):41-46.

23. Rubin EC, Pisupati R, Nerenberg SF. Utilization of pharmacy technicians to increase the accuracy of

patient medication histories obtained in the emergency department. Hosp Pharm. 2016;51(5):396-404.

24. Pevnick JM, Nguyen C, Jackevicius CA, et al. Improving admission medication reconciliation with

pharmacists or pharmacy technicians in the emergency department: a randomised controlled trial. BMJ

Qual Saf. 2017.

14

APPENDIX 1.

POSITION 1

REALLOCATION OF PHARMACIST TIME TO OPTIMIZE PATIENT CARE

Community pharmacists spend only 21% of their professional time performing patient care services not

associated with medication dispensing.3 To further optimize the pharmacist’s role in delivering patient-centered,

collaborative care in communities, pharmacists must effectively reallocate their time, resources, and utilization

of pharmacy technicians.

POSITION 2

TECHNICIAN ASPIRATION FOR EXPANDED ROLES

Most states limit the pharmacy technician’s scope of practice to certain aspects of the medication dispensing

process. However, many pharmacy technicians have positive attitudes towards performing administrative and

supportive tasks that further optimize pharmacy patient care services in the community pharmacy setting.

Technicians involved with these tasks are professionally satisfied in expanded roles. Broadening the pharmacy

technician’s scope of practice may further advance the pharmacy technician’s role as an important contributor

to the healthcare team.

POSITION 3

TECHNICIAN SUPPORT FOR PHARMACY PATIENT CARE SERVICES

Historically, pharmacy technicians have been utilized for administrative and supportive tasks throughout the

medication dispensing process (i.e. medication preparation, payment adjudication, and customer service).

Expanding the role of pharmacy technicians to assume time- and resource-intensive administrative and

supportive tasks for pharmacy patient care services redistributes pharmacists’ time to further optimize patient

care.

POSITION 4

TECHNICIAN SCREENING FOR PATIENT CARE SERVICES

Pharmacy technicians are uniquely positioned to identify and engage patients who would benefit from

pharmacist patient care services given that patients frequently approach pharmacy technicians before

interacting with the pharmacist. In settings where expanded technician roles are championed, patients receive

comprehensive care through screening, identification, and referral of the patient’s medication-related needs

to the pharmacist.

15

POSITION 5

TECHNICIAN SUPPORT OF MEDICATION DISPENSING

Retrieving, clarifying, and transcribing prescription information from the prescriber or the prescriber’s agent

does not require clinical judgement; instead it requires competency in verbal and written communication.

Often, the prescriber’s agent is administrative support staff who perform these tasks at the discretion of the

physician. Similarly, pharmacy technicians can receive, clarify, and transcribe prescriptions at the discretion of

the pharmacist in permitting states. Fifteen states allow pharmacy technicians to accept verbal prescriptions, and

12 states allow pharmacy technicians to transfer prescriptions from one community pharmacy to another.15 In

other pharmacy practice models, pharmacy technicians may also enter prescriptions for pharmacist review and

play significant roles in detecting and preventing electronic prescribing errors. Pharmacy technicians should

be recognized by state laws and regulations as competent team members who can support these medication

dispensing tasks.

POSITION 6

TECHNICIAN PRODUCT VERIFICATION

Medication product verification, the final non-clinical review of a medication product to be dispensed, can be

performed safely by pharmacy technicians who are given privileges to do so through state laws and regulations.

Evidence suggests that pharmacy technicians are equally or more accurate than pharmacists when performing

medication product verification. Utilization of pharmacy technicians for medication product verification may

save pharmacist time further optimize patient care. Evidence supports the safe and effective implementation

of technician product verification in community pharmacies.

POSITION 7

TECHNICIAN-OBTAINED MEDICATION HISTORIES

Pharmacy technicians have a greater understanding of patients’ medication lists and medication-taking behaviors

than non-pharmacy healthcare professionals. Multiple studies demonstrate that pharmacy technicians are more

accurate than nurses and other non-pharmacy personnel in obtaining patient medication histories. Utilizing

pharmacy technicians to obtain medication histories allows pharmacists to more effectively prevent, identify,

and resolve drug therapy problems. Reassigning supportive tasks such as obtaining medication histories to

pharmacy technicians can optimize patient care.

16

POSITION 8

TECHNICIAN IMMUNIZATION ADMINISTRATION

Pharmacy technicians perform administrative tasks to support pharmacist-led immunization services. In Idaho,

certified pharmacy technicians have begun administering immunizations, a task that is largely considered

technical. Permitting pharmacy technicians to administer immunizations has the potential to increase the

impact of pharmacist-led immunization services in local communities across the country.

OCCUPATIONS CODE

TITLE 3. HEALTH PROFESSIONS

SUBTITLE J. PHARMACY AND PHARMACISTS

CHAPTER 562. PRACTICE BY LICENSE HOLDER

SUBCHAPTER A. PRESCRIPTION AND SUBSTITUTION REQUIREMENTS

. . .

Sec. 562.004. PRESCRIPTION TRANSMITTED ORALLY BY

PRACTITIONER. A pharmacist to whom a prescription is

transmitted orally shall:

(1) note on the file copy of the prescription the

dispensing instructions of the practitioner or the

practitioner's agent; and

(2) retain the prescription for the period specified

by law.

Acts 1999, 76th Leg., ch. 388, Sec. 1, eff. Sept. 1, 1999.

. . .

OCCUPATIONS CODE

TITLE 3. HEALTH PROFESSIONS

SUBTITLE J. PHARMACY AND PHARMACISTS

CHAPTER 554. BOARD POWERS AND DUTIES; RULEMAKING AUTHORITY

SUBCHAPTER A. POWERS AND DUTIES

. . .

Sec. 554.052. IMMUNIZATIONS AND VACCINATIONS; PHYSICIAN

SUPERVISION. (a) The board by rule shall require a pharmacist

to notify a physician who prescribes an immunization or

vaccination within 24 hours after the pharmacist administers the

immunization or vaccination.

(b) The board shall establish minimum education and

continuing education standards for a pharmacist who administers

an immunization or vaccination. The standards must include

Centers for Disease Control and Prevention training, basic life

support training, and hands-on training in techniques for

administering immunizations and vaccinations.

(c) Supervision by a physician is adequate if the

delegating physician:

(1) is responsible for formulating or approving an

order or protocol, including the physician's order, standing

medical order, or standing delegation order, and periodically

reviews the order or protocol and the services provided to a

patient under the order or protocol;

(2) except as provided by Subsection (c-1), has

established a physician-patient relationship with each patient

under 14 years of age and referred the patient to the

pharmacist;

(3) is geographically located to be easily accessible

to the pharmacy where an immunization or vaccination is

administered;

(4) receives, as appropriate, a periodic status

report on the patient, including any problem or complication

encountered; and

(5) is available through direct telecommunication for

consultation, assistance, and direction.

(c-1) A pharmacist may administer an influenza vaccination

to a patient over seven years of age without an established

physician-patient relationship.

(d) The Texas Medical Board by rule shall establish the

minimum content of a written order or protocol. The order or

protocol may not permit delegation of medical diagnosis.

Acts 1999, 76th Leg., ch. 388, Sec. 1, eff. Sept. 1, 1999.

Amended by:

Acts 2009, 81st Leg., R.S., Ch. 375 (H.B. 1409), Sec. 1,

eff. September 1, 2009.

. . .

http://www.legis.state.tx.us/tlodocs/81R/billtext/html/HB01409F.HTM

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July 31, 2019 Allison Benz Executive Director Texas State Board of Pharmacy 333 Guadalupe, #3 Austin, TX 78701 By Fax: 512-305-8082 By Email: [email protected] RE: Texas Board Discussion on Expanding Technician Duties – D.6 – TAB 36 Dear Ms. Benz: On behalf of our 22 member companies operating more than 2800 retail pharmacies in Texas, the National Association of Chain Drug Stores (NACDS) wants to provide Board members with our initial recommendations on expanding the role of pharmacy technicians to help enhance public safety and access health care services. Given the growing demand for pharmacist-provided patient care services in community pharmacies, there is a corresponding need to deploy pharmacy technicians for administrative and non-judgmental duties. Furthermore, elimination of technician to pharmacist ratios will enable pharmacists to focus more on counseling patients, performing MTM, providing disease management programs, engaging in other important patient care services, and collaborating with other health care professionals, thus integrating more fully in a patient’s care. These services also help patients better adhere to their medication regimens and ultimately serve to improve patients’ health and wellness and reduce our nation’s health care costs. While your current rules specify tasks pharmacy technicians may perform, the non-judgmental duties are limited. NACDS strongly supports pharmacists practicing at the top of their profession to allow for optimal patient care and improved health outcomes. When considering an enhanced role for pharmacy technicians in collaborative health settings, several duties can be reasonably delegated from these two categories: (1) medication dispensing support; and (2) technical support for clinical services provided by pharmacists and other health professionals. We recommend that the Board strongly considers adopting changes that would allow pharmacy technician to perform the following duties:

mailto:[email protected]

2 | P a g e

1. Medication Dispensing:

Some pharmacist duties related to medication dispensing can be delegated to pharmacy technicians, thus allowing pharmacists to devote more time to patient care. The following tasks are related to medication dispensing and can be performed by a technician:

• Accepting a verbal prescription: Allows the technician to accept a verbal prescription by phone. Currently, 16 states permit this activity for certified technicians.1

• Transferring a prescription: Allows the technician to transfer a patient’s prescription to another pharmacy. Currently, 13 states permit this activity for certified technicians.2

• Contacting a prescriber for clarifications: When information on a prescription is incomplete, a pharmacy technician can contact the prescriber and appropriately obtain the needed information. However, if the inquiry regarding the missing information requires the professional judgment of a pharmacist, then the pharmacist would contact the prescriber. Currently, six states permit this activity for certified technicians.3

2. Assisting with Clinical Services:

The following are potential tasks that may be delegated to a technician with proper training to augment the role of pharmacists in providing direct patient care services. It is important to note that these tasks would not allow technicians to perform clinical services, but to perform steps that are part of a clinical service that do not require professional judgment. Except for Idaho, which now allows technicians to administer vaccines, these tasks are not expressly allowed in any state. However, it has been suggested that pharmacy technicians can be trained to perform the following:

• Administer vaccines: Prescribers routinely delegate vaccine administration to healthcare paraprofessionals. Similarly, there is an opportunity to allow pharmacists to delegate this task to a properly trained and certified pharmacy technician. In Idaho, technicians who are appropriately trained and certified may administer vaccines.4

1 Currently allowed in ID, IL, IA, LA, MA, MI, MO, NH, NC, ND, OH, PR, RI, SC, TN, and WI. National Association of Boards of Pharmacy; Survey of Pharmacy Law; 2018; pp. 50. 2 Currently allowed in AZ, ID, LA, MA, MI, MO, NC, ND, PR, RI, SC, TN, and WY. Id. at 51. 3 Currently allowed in DE, IL, ID, IA, MI and SD. 4 Rules of the Idaho State Board of Pharmacy, 27.01.01.330.02(b)(3)

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Conclusion We thank the Board for the opportunity to provide input in advance of the discussion at the upcoming meeting on August 6th. We look forward to working with you to ensure that patients in Texas continue to receive optimal healthcare at their community pharmacy. If you have any questions or need additional information, please contact me at [email protected] or 817-442-1155. Sincerely,

Mary Staples Regional Director, State Government Affairs

mailto:[email protected]

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