I Am Certain That You Guys Will Vote On This. Is WAG Too Far Out of the Box?

Jp Enlarged

You all know that I favor WAG because I worked part time for them for 6 years and they treated me well.  Regarding this new model, I don’t see how they could pull this off without some significant changes in the laws that govern the practice of pharmacy. Jay Pee

Hi Jim,

I thought you might be interested in this new study, which investigates Walgreens’ new pharmacy model and the risks it poses for increased medication error, patient privacy violations and breaches of drug security. Based on the study’s findings, a complaint has been filed with US Dept. of Health and Human Services alleging HIPAA violations.

This new model, dubbed “Well Experience,” puts the pharmacist out-in-front of their traditional work area—leaving no pharmacist in the room where prescriptions are filled. Our research, based on 100 store visits to Well Experience pharmacies, has identified fundamental problems with the model that could undermine the safe practice of pharmacy. For example, sensitive, HIPAA-protected patient information was left unattended or unsecured in 80% of store visits.

For Immediate Release

Study:  Walgreens’ New Pharmacy Model Increases Risks to Public Health, Patient Privacy and Medication Security

Complaint Filed with US Dept. of Health and Human Services Alleging HIPAA Violations;

Report Based on 100 “Well Experience” Store Observations

 Washington, DC, September 23, 2013—Walgreens’ attempts to revolutionize the pharmacy may increase risks of medication errors and patient privacy violations, according to a new study by Change to Win Retail Initiatives (CtW).  The report titled Behind the Desk uses data from 100 observations of Walgreens’ “Well Experience” pharmacy model in 50 stores located in Florida, Illinois, and Indiana.  Based on the study’s findings, CtW filed a complaint alleging numerous breaches of the Health Insurance Portability and Accountability Act (HIPAA) with the US Department of Health and Human Service’s Office of Civil Rights (OCR).

“The right to privacy is an essential element of quality health care, and Well Experience appears to have fundamental flaws in its design and execution that warrant regulatory action,” said Deborah C. Peel, MD, Founder and Chair of Patient Privacy Rights, a leading national health care privacy organization.  “As the nation’s largest drug chain, Walgreens should know that playing fast and loose with sensitive, protected patient information is not only wrong but also illegal.”

CtW’s investigation details significant problems with Well Experience, including:

Violations of patient privacy.  In 80 percent of stores visited, sensitive, HIPAA-protected patient information, such as medical histories, was left unattended and visible to customers in the pharmacy area.

Inadequate medication security. Prescription medicine—in one case hydrocodone—was left unattended and within the reach of customers in 46 percent of stores visited.

Increased pharmacist distractions.  Field researchers observed nearly 150 distractions and interruptions to pharmacists that were unique to the Well Experience pharmacy model’s design —over one third of the total number observed. Interruptions and distractions are associated with increased medication errors.

Low rates of patient counseling.  Field researchers observed an average consultation rate of 8.2 percent in surveyed Well Experience pharmacies, despite Walgreens’ claims that the model increases counseling. Academic studies of chain pharmacies using secret shoppers found rates of 27 to 53 percent, Pharmacists are required by law to offer counseling for new prescriptions.

 A key feature of Well Experience is the pharmacist sits in a work station in front of the pharmacy counter, and is typically not in the traditional prescription fill area. This relocates the pharmacist’s work station from a private space in the pharmacy to a public space.  The out-in-front pharmacist remotely monitors the pharmacy technicians and checks the accuracy of prescriptions using photos and video displayed on a computer screen.

 The OCR complaint raises additional privacy concerns stemming from the out-in-front pharmacist work station. Pharmacists’ computer screens and mobile devices, used to review prescription information, were sometimes observed to be unattended and visible to the public. The new format also enables shoppers to overhear sensitive telephone conversations about patients. Despite the vulnerabilities created by relocating the pharmacist to a public area, Walgreens’ policies and procedures appear to provide scant guidance on HIPAA compliance.

The report echoes the concerns of several state boards of pharmacy about Well Experience’s impact on the supervision of pharmacy technicians and the accuracy of prescription fills. For example, the Maryland board has rejected the model last year.

“Walgreens must not compromise pharmacists’ ability to perform their core duties of safely dispensing medication, counseling patients and protecting sensitive health information,” said Nell Geiser, Research Director of Change to Win Retail Initiatives.

About Change to Win Retail Initiatives

Change to Win Retail Initiatives is committed to making retailers more accountable and transparent to consumers, workers and all stakeholders.  For more information about its initiative to bring reforms to Walgreens, visit www.walgreenstrategywatch.org.





  1. AJ  •  Oct 9, 2013 @6:58 pm

    This is the beginning of the end for the retail pharmacist. Good ‘ole Wags couldn’t get it done with the POWER program. Here comes the next “program” which is nothing more than a thinly veiled attempt to show how a pharmacy can run without a pharmacist. Hello people…wake up!
    “The out-in-front pharmacist remotely monitors the pharmacy technicians and checks the accuracy of prescriptions using photos and video displayed on a computer screen.”
    Guess what? The pharmacist can remotely monitor pharmacy technicians from across the street, across the state or in India.
    Every thing Walgreen’s has done in the last 8 years has been geared to getting rid of the pharmacist. Wiz bang computer system that I quote from a mid level manager “is so sophisticated anyone with a high school diploma could verify scripts”, Pharmacists having to verify scripts for other stores, The POWER program and now this piece of shit.

  2. pharmacyslave2000  •  Oct 9, 2013 @7:32 pm

    That’s nice, there was a “study”. What everyone fails to understand is that no one cares how dangerous this may be or how it violates HIPPA. Guess what, every transaction processed through the drive-thru violates HIPPA. Every question answered at the register line of 10 people violates HIPPA. Pharmacists have been distracted for years and NO ONE counsels as they should as laid out by law. The public doesn’t care, the State Boards don’t care and the corporations don’t care because none of the above care! I said before that the true enemy of retail pharmacy is WAG. While CVS and RAD do stupid shit in front of everyone, WAG is quietly creating programs and technology to totally eliminate the need for pharmacists. All they need to do is convince the State Boards that this meets the minimal requirements to run the pharmacy, show Wall Street that it is a viable business plan and watch the profits roll in as they eliminate their highest paid employees.

  3. Wrong Aid  •  Oct 10, 2013 @12:37 pm


    BINGO!! You said everything I was going to. Can’t wait until pharmacies are ran by people too stupid to work for McDonalds. JP, did you ever think maybe they kissed your ass a bit since you were a public figure? A little free advertisement and all it cost was not treating you like an animal.
    Yes, I have had that thought.JP

  4. Drew  •  Oct 10, 2013 @8:46 pm

    Has anyone researched Wag’s WellTransitions program? I came across an article which states the AHA has endorsed this program. If I understand correctly, a Wag pharmacist visits patients in the hospital (prior to discharge) and discusses medication adherence. Thoughts?

  5. Pharmaciststeve  •  Oct 10, 2013 @9:02 pm

    One thought.. Pt’s freedom of choice ! Will these WAGS’ RPH’s manipulate these pts who are ill and care givers who are exhausted and harried .. to let WAGS fill their discharge Rxs… for the convenience of it all?

    Giving WAGS’ employees access to these pts being discharged.. could be considered anti-competitive and a violation of the pt’s freedom of choice…

    Don’t these hospitals have RPH’s on staff.. that could do this job/function? Normally, most businesses can do most functions with in-house staff cheaper rather than out-sourcing the function. So what is in it ($$$) for the hospital and/or WAGS??

  6. Barto  •  Oct 11, 2013 @9:09 am

    Pharmaciststeve, In northern California WAGs operates two large discharge pharmacies, one at Stanford and the other at UCSF medical centers. Both have extremely competent pharmacy departments. So why would they get in bed with WAG? Well one of the major problems and cost to a hospital is re-hospitialization which in the future CMS is going to really ding (take back $$$) and what is one of the top reasons for re-hospitalization non compliance to prescribed medications. The data shows that for many patients that are discharged with a 3 day supply and of medications and the Rx’s they never get the Rx’s filled or after a month or two of therapy for a chronic condition they just stop taking their meds. Same old compliance story. So WAGS can fill the Rx’s for more than 3 days route the script to the nearest WAGS by the patients home and enroll them in their auto refill program all good selling points that hospital administrators bought and got on board with.

    One other reason is that most hospitals hate dealing with the patients outpatient pharmacy coverage, PA’s and all that crap and would rather let WAG do it.

    I really think that independent pharmacy has for the most part missed the train on this and now what I see with the proposed FULs for reimbursement it may be time to add the lunch counter back into the pharmacy because that is the only way to generate enough profit to stay afloat.

    It is a sad state of affairs!

  7. Red_No_4  •  Oct 11, 2013 @9:40 am

    @PharmacySlave — truer words have never been spoken. One of my fantasies involves getting on the PA and letting Mrs. Smith know that her pills for genital herpes are ready.
    @PharmacistSteve –
    RIght now in my harried state WAGS has a program in place at some stores wherein they send a technician into local hospitals to ask if the patient wants their prescriptions filled at a local store. These techs are there at the hospitals’ invitation (it’s not like they are sneaking in to talk to patient’s, but that is a definite possibility in the future :) , and the patient is given the option to fill at a local WAGs.
    If the patient agrees to have their medications filled, the tech faxes the insurance info, payment info, and the prescriptions to the store. Scripts get filled, get billed and sold, then a courier brings them to the patient at the hospital. I have to admit it’s ridiculously convenient, and since most people value that above everything else, so be it.
    Pros — For the patient, they don’t have to leave the hospital and wait for their meds. For the pharmacists, it saves the half-crazed filling frenzy that inevitably arises when a patient is discharged at 9:30 pm, your store closes at 10, and they really really need their meds. All 10 of them. Even the stupid Protonix that every freaking patient is discharged with and that hardly any insurance covers. (Admit, docs — the only reason you prescribed Protonix 40 at discharge is because the patient was on it in the hospital; the only reason they were prescribed it in the hospital is because it’s standard orders for patients to be on a PPi, and the only reason you use Protonix is because it’s a direct convert from IV to PO. Suck it).
    Cons — I’ve been in stores where freaking C2s are faxed in, which, unless the patient is hospice, is a COMPLETE VIOLATION OF THE DAMN LAWS. Granted, the tech is coming with the hard copies, but still. (Though, come to think about it I doubt the BOP would do anything about it, so who cares? The corporations who sit on those boards are really making the rules at this point.) Another con for the pharmacist — you are supposed to call the patient up in the hospital and counsel them on their meds. Ever try making phone contact with a patient about to be discharged? And what if they are taking something at home or from a different pharmacy? The dumb are leading the blind, but they were tricked there by the idiots.
    As for what hospital pharmacists actually do, my experience is limited to what I saw during rotations. If I had to say something, at least as it relates to what happens when the patient leaves the hospital, it would be, ‘Not much.’ From what I saw, hospital pharmacists have their hands full filling prescriptions for demanding doctors, demanding nurses. They are trying to make sure the IVs aren’t going to kill people because of a miscalculation. Clinical pharmacists are walking drug references for doctors on rounds, and pretty much nothing more. The one hospital that I interned at that attempted drug reconciliation with patients (i.e. interviewing patients about what drugs they were taking, what OTCs, etc) used technicians. No pharmacists involved.
    What’s in it? Hospitals don’t have to open and staff a retail pharmacy on site. WAGs makes money and offers itself as a paradigm of patient-centered care. Win-win, right?

  8. pharmacyslave2000  •  Oct 11, 2013 @2:32 pm

    It’s very interesting to read about these WAG programs as I was unaware of their existence. WAG is a very shrewd company. They are out actively recruiting “patients”, i.e. customers. What better customers to recruit than the sickest of the bunch. These people will equate their “healthcare” with WAG while WAG builds their brand. Now that’s what I call marketing!

  9. Broncofan7  •  Oct 11, 2013 @8:13 pm

    Very helpful information about the WAGS hospital programs. As an independent it’s something else to focus on to help build a loyal patient base and since many of us already offer free home delivery ( and free mailing in some instances) it would fit in easily with our current model. Getting the attention if a hospital administrator will be the most difficult step.

  10. Pharmaciststeve  •  Oct 11, 2013 @8:23 pm

    Barto & Red No 4

    You know when my wife ends up in the hospital and at discharge.. I just asked one of the nursing staff to fax the Rxs to the community pharmacy that I use.. and low and behold… when I get to the pharmacy a hour or so later.. discharging is always hurry up and wait .. the Rxs are ready..

    It amazes me that the bureaucrats have always been very sensitive to pt’s freedom of choice.. It is part of Medicare/Medicaid law… that is.. until .. there is a possibility that it will save the bureaucrats some money.. then the pts have to accept and do what they are told.

  11. broncofan7  •  Oct 12, 2013 @10:49 am

    Here’s some additional pics (although 2 years old)of the new Walgreens layout


  12. broncofan7  •  Oct 12, 2013 @6:48 pm

    WAGs was leading the way in leveraging themselves to be a GLOBAL purchaser of drugs….and according to business analysts, it’s paying off handsomely……http://www.drugchannels.net/2013/10/breaking-wbad-update-on-walgreens.html#more

    “The $154 million synergy savings beat the high end of Walgreen’s initial estimates.

    Here’s a telling (verbatim) exchange between Goldman Sachs’s Robert Jones and Walgreen’s President and CEO Greg Wasson:

    Robert P. Jones: Thanks for the questions. I wanted to ask you about the ramp of synergies, they are going to see you’re calling for $350 million to $400 million in fiscal 2014. On the generic procurement side specifically, I was wondering if you guys could comment on whether or not the re-contracting with your generic manufacturers’ kind of where you are in that process, is that close to complete. And then as it relates to that, how should we be thinking about the ramp on the generic procurement side specifically? Is that something you expect within the overall bucket of synergies to come in a little bit faster or is that kind of pacing along with the other synergy areas of synergies?

    Gregory D. Wasson: Yeah, couple of things: there is one obviously, since we exceeded our goal this year, it hit $154 million and we effectively started at zero. That means by the end of the year you have to be close to $300 million. And so we continue to ramp that, that’s why we get the objectives and the goals for next year that we have pretty good visibility on.

    With respect to generics, our team who’s leading it, Jeff Berkowitz and John Donovan made a tremendous amount of progress. I think we’re not going to get too much detail on it, because I think it’s work that’s probably making this happening as we speak. But I would say that I think they are working with likely specifics to find really win-win relationships where we can bring a lot more business combined with the players and help them and they can help us. And so we are very confident that we are going to create lot of value there over time, but I’ll just leave it at that. (source)”

  13. broncofan7  •  Oct 12, 2013 @6:55 pm

    So employees of WAGs…what does this mean to you? When you hear your DM start talking about reduced TECH hours and they can’t afford a raise for you, remember this article.

    After a dreadful 2012 thanks to the ESI squabble, WAGs is on pace to make great profits by INCREASING their GROSS margins through GLOBAL purchasing power with their alignment with BOOTS Pharmacy.

  14. broncofan7  •  Oct 12, 2013 @6:57 pm

    For independents, it’s a violation of anti trust; for corporate America, it’s business as usual. Health Mart/ McKesson needs to step up and leverage our 3000+ stores with these generic manufacturers for chain store like pricing…..

    Here’s a great column explaining how ridiculous and outdated the anti trust law is in regards to independent Pharmacies…….http://www.theangrypharmacist.com/archives/2010/02/antitrust-chainpbms-independents-and-you.html

  15. Pharmaciststeve  •  Oct 12, 2013 @8:03 pm

    Broncofan7… all the PBM’s are licensed as insurance companies.. so they are exempt from Sherman Antitrust by McCarren/Ferguson act.

    They can discriminate because of this.. they can price fix.. because of this.. they can do just about anything that is ILLEGAL in the rest of the business world.. without repercussions.

    Health mart is not a single ownership.. like CVS/WAGS/Rite Aid.. it takes more than one individual/entity to collude. It is illegal to collude… unless you are an insurance company.

  16. Cathy Lane RPh  •  Oct 12, 2013 @9:47 pm

    I didn’t read the comments in-depth, so maybe got off on the wrong foot. I agree with Pharmacy Steve’s assessment of PBMs in the post at 8:03. There is something terribly wrong with what PBMs are getting away with. I follow up with the name at the bottom of a ‘free’ prescription drug card. I read news of Catamaran acquiring yet another company. There is NOT one registered pharmacist on the Board! Their only ethical responsibility is to stockholders! Why can’t someone sue PBMs for conflict of interest, practicing pharmacy without a license, arrogance, bad faith, and forming a monopoly over a public commodity e.g. ACA benefits?

  17. Broncofan7  •  Oct 12, 2013 @9:55 pm

    Steve, I realize that it is illegal CURRENTLY. It’s because we are being held to the standards of an antiquated law which was brought about in a time LONG BEFORE the large chain store and of course the PBM Industry. It’s time that the courts address the CURRENT Market forces that create an unequal playing field, which was the ENTIRE basis of the anti trust law to begin with.

  18. Pharmaciststeve  •  Oct 12, 2013 @11:00 pm

    Broncofan7… It will be Congress that has to repeal the McCarren/Ferguson act.. it was passed when insurance companies were not-for-profit to allow them to combine data to get better statistics — getting a larger pool of data – to get better underwriting data..

    When most of the insurance companies de-mutalized in the 90′s and became for profit public companies.. the McCarren Ferguson act should have been repealed and/or excluded those for profit insurance companies.

    BUT.. the insurance industry has very deep pockets to hire a army of lobbyist to fight such a effort to repeal and of course few in Congress has the balls to go against money..

    IMO.. it is another example that we have the best members of Congress that money can get elected and entitlements can get reelected.

  19. Broncofan7  •  Oct 13, 2013 @1:04 pm

    Great information Steve. Thank you.

  20. wellilbe  •  Oct 13, 2013 @9:32 pm

    I think pharmacist out front has potential ….IF AND ONLY IF… there is another pharmacist in the back actually supervising. But since Walgreens is too cheap to pay for 2 pharmacists its pretty much just going to end up taking the profession down yet another notch. Imagine it, a pharmacist in the back filling and supervising, and another roaming freely about the store speaking to patients as they try to select their otc, inviting them in a closed private room for counseling after their meds are picked up….but alas its not to be

  21. PharmacyStudent  •  Oct 29, 2013 @1:58 pm

    @wellilbe. Pretty much what I’ve been thinking too. It can only work if you have the pharmacist out front and another one inside.
    I mean how can one pharmacist outside verify input and rx’s if he has a line of patients in front of his cubicle wanting to talk to him? What would happen if a CII rx needs to be filled? What happens if the techs have questions?
    And what about the techs, if they’re given more responsibilities are they going to increase their salaries? That doesn’t save walgreens money.

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