Can AJ and Bronco get together for a guerrilla action?

Jp Enlarged


One Pharmacist supervising three technicians simultaneously.  The “Metrics Maven”.

I saw this Comment from AJ and thought it appropriate to put it in  a more available space, with my thoughts.  JP

“Speaking of Boards of Pharmacy…for those of you in the great State of Texas do you know on November 4th The Texas State Board of Pharmacy will vote to raise and/or eliminate pharmacist to technician ratios? I see this as a bad thing. What say all of you?


AJ will be testifying AGAINST this change, in person, live at the meeting. He is a member of The Pharmacy Alliance and therefore eligible for help with expenses. Members of The Pharmacy Alliance who testify before their board, lobby
legislators or bring light to dark places with investigative journalists will be reimbursed up to $100.00 toward hotel. Gas money. Cost of two modest meals at a place like Chili’s. AJ, save your receipts. You can scan them and E-Mail to

Um, Broncofan…. maybe it is time for you and AJ to call a truce and tag team at this board meeting. Bring others with you. Go FULL FRONTAL with them. You both know that guys like Bronco are not behind this. You know, in the end it may not be a bad idea, but not like this. Not driven by the chains. They DO NOT run our industry.

I am serious, man. Both of you. As Joe Zorek said, “A pissing contest does us no good.” You are both smart, well-placed and
well-spoken. You guys certainly are not shy. Be like the United Nations. “Well, we have fundamental differences, but we have a common enemy”. Killing this proposal will show that pharmacists DO HAVE POWER. It will show that we are not brain-dead.

Bronco, I don’t recall if you are a member of The Pharmacy Alliance. You can join with dues of $100.00. Attend the meeting and get more than $100.00 reimbursed. Visit www.// You can find the JOIN button. Those of you who have not renewed, please do so. Renewal is $60.00. Just click on JOIN. You can figure it out.

Come on, you guys. Not just AJ and Bronco. All of you. You know, disturbing the shit can be fun. It also may do good.

Jay Pee

Halloween Day.  AJ and Broncofan are leading the discussion.  This is important stuff.  Visit “Comments” and say your view.  Is this like the hog led to slaughter?  He knows what is coming.  He can smell it.  They have him hogtied and are leading him to the guy with the gun-thing that will be pressed to the area below his ear.  Nothing can save him.  Nothing.  In Sicily, hogs live the life.  In the hills, feasting on chestnuts and grains that are spread out for them.  Their flesh will make the best prosciutto.  The killing is still awful.  

Pharmacists can see what is coming.  AJ and Bronco will tell you.  Will they slaughter you?  Is it that nothing can save you?  Is it hopeless?  You are NOT pigs.  You fuckers can change this.  You hold all of the aces.  You just gotta do something, for crissake.

Go for it, AJ. Kick some State Board of  Pharmacy Texas Ass.  To the rest of you.  AJ is taking ownership of our profession.  It is his profession just as Texas A & M is Johnny Football’s team.  The rest of you want in?  Not a problem.  Do SOMETHING.  You can start by asserting yourself in the pharmacy.  Take charge and “Watch me Now”.  ”What’d I say?”



  1. Whistleblower  •  Oct 30, 2013 @11:13 am

    United We Must Stand !!! I see a huge opportunity here…we can take back our profession one BOP at a time.

    Joe Zorek

  2. broncofan7  •  Oct 30, 2013 @12:43 pm


    Oppose TSBP Proposed Elimination of
    Pharmacy Tech Supervision Ratios

    BACKGROUND: Earlier today, the Texas Pharmacy Association submitted a formal comment letter to the Texas State Board of Pharmacy reiterating its strong opposition to the Agency’s proposed rules to eliminate the pharmacist-to-technician supervision ratio in class A, B and G pharmacies. If approved, there would be no limitations on the number of technicians to be supervised by a single pharmacist.

    As you are aware from a previous TPA alert, the proposed rules were published in the Texas Register on September 27, 2013, with a 30-day comment period through 5:00p.m., October 31. This deadline precedes the November 4 public hearing in Austin and the agency meeting on November 5.




    TPA’s recent letter includes additional rationale and information for TSBP to consider. Basically, TPA is supporting an interim change in the supervision ratio from 1:3 to 1:4, and opposing the overall elimination of a supervisory ratio. Click here for a copy of the Association’s letter and feel free to use portions of in your comments it as you wish.

    TPA’s official complete position is as follows: •That TPA [continue to] support and foster a comprehensive study regarding the education and scope of practice for Pharmacy Technicians;
    •And in order to protect public health and patient safety, [that] TPA oppose elimination of the pharmacist to pharmacy technician supervision ratio until such study has been completed and more comprehensive information is available; and
    •In the interim, based on the results of the Association’s survey of the membership, [that] TPA support a change in the supervision ratio from 1:3 to 1:4 [for class A and B pharmacies]
    Supporters of eliminating the ratio have been conducting a strong and effective write-in campaign to the Board to counter TPA’s efforts. Your continued and repeated input is critical. Please ask that the rules be modified or “pulled-down” pending further study. Click here for a complete copy of the rules. Thank you.

    ACTION REQUESTED: Please submit your written comments to the TSBP by 5:00 p.m., October 31, 2013, to:

    Allison Benz, R.Ph., M.S.

    Director of Professional Services

    Texas State Board of Pharmacy

    333 Guadalupe Street, Suite 3-600

    Austin, Texas 78701

    Fax (512) 305-8008

    If you wish to testify in person, plan to attend the scheduled TSBP public hearing as follows:

    1:00 p.m., Monday, November 4, 2013

    Health Professions Council Board Room

    333 Guadalupe Street, Tower II, Room 225

    Austin, Texas 78701.

    If you need more information or assistance, please do not hesitate to contact:
    •Joe A. DaSilva, TPA Chief Executive Officer, 512-836-8350, ext. 170
    •David Marwitz, TPA Legislative Consultant, 512-415-8469
    •Kim Roberson, R.Ph., TPA Director of Professional Services, 512-836-8350, ext. 142

  3. broncofan7  •  Oct 30, 2013 @5:36 pm

    The Texas Federation of Drug stores is behind this proposal…

  4. broncofan7  •  Oct 30, 2013 @6:05 pm


    The Federation communicates almost exclusively through email, except during the regular legislative session (January to May of even-numbered years), when they hold weekly conference calls that are generously funded by the National Association of Chain Drug Stores (NACDS).

    For more information about the Texas Federation of Drug Stores, contact us at (512) 472-8261

  5. Pharmaciststeve  •  Oct 30, 2013 @6:20 pm

    In Indiana we have a RPH as a Senator and a Representative.. the Senator owned a indy for 40 years and the Rep works for a Indy..

    I couple of years ago.. they are the ones that INTRODUCED a bill to change the RPH/tech ratio from 1:4 to 1:6..

    They were both in their first term at the time.. and it was about the same time that WAGS was granted an exception to alter about 20 stores to the Pharmacist out front format..

    as a concession.. they mandated that every tech had to be certified.. but any one can be a tech-in-training for one year.. at which time they must have passed one of two different written tests.. or they can no longer be a tech..

    What they didn’t think thru… there is no mandatory certified/tech-in-training ratios on duty.. so a RPH could be dealing with 6 techs-in-training and collectively they could have less than a year’s experience.

    Of course there is KY.. where there is no limit and techs only have to be registered.. never have to be certified.. and if you read the law.. the registration is required to prevent those convicted of drug diversion don’t work in a pharmacy AND.. the state gets $25/head to be registered.

    I temped for large national LTCP in KY and they would drag just about any warm body in off the street and making them a tech.. input techs were the worse… the RPH were expected to train them.. which usually meant .. they learned from mis-keys being sent back to them..

    One tech had a documented 25%+ keying error rate – after several months.. and when the RPH’s went to the PIC and said – FIRE the TECH and was told that they had too much money invested in the tech’s training.. IMO.. a tech that has a 25% keying error has not been trained ..

    Oregon or state of Wash just went to unlimited tech ratio.

  6. AJ  •  Oct 30, 2013 @7:24 pm

    Broncofan7 you can ride down to Austin with me. A 6 hour round trip gives us plenty of time to argue and gives everyone here a break from having to read it!
    I signed up at the State Board website to get their e-mails. The only way to combat this absurdity is to stay informed and stay involved. They publish their meeting minutes and post the proposed rule changes in the State Registrar. It’s on each of us to go out there and get the information and stay on top of it. No one at your big chair employer is going to tell you the State Board is proposing to change the rules and you are fixing to get screwed.

  7. AJ  •  Oct 30, 2013 @7:53 pm

    When I first read about this I was infuriated. I knew straight away without looking the big chains were behind it. As a former pharmacy manager for two major grocery store chains I know very well the problems faced by retail pharmacists. I lived it for 8 years.
    It was no surprise when I went to the State Board website and found many letters written by corporate middle managers for the big chains supporting the change. What I didn’t expect to find were all the letters written by rank and file pharmacists and pharmacy managers. People who should know better! Then I realized these are the institutionalized “prisoners of comfort” pharmacists JP has written about.
    The basic argument by every one of these pin heads is we need more help in the pharmacy and the State Board is restricting us from doing it by imposing a ratio. No idiots! The State Board does not regulate how many technicians can be in the pharmacy. You can have as many technicians as you want as long as there is no more than three per pharmacist! The blame for poor staffing does not fall on the State Board of Pharmacy. It falls on your shitty employer who is trying to save a buck on labor by under staffing the pharmacists.
    The solution is simple. If your volume is high enough to need four, five or six technicians it’s high enough to need another pharmacist.

  8. Broncofan7  •  Oct 30, 2013 @8:52 pm

    Damn. I agree with AJ 110%! ( however I’ll be in the desert overseeing a new VPN installation at 2 of my sites)

  9. Broncofan7  •  Oct 30, 2013 @8:53 pm

    AJ , please post the link to the TSBP website with the letters you write of.. Thanks!

  10. Broncofan7  •  Oct 30, 2013 @10:42 pm

    Here’s a link to those OPPOSED to the ratio being eliminated :

  11. Broncofan7  •  Oct 30, 2013 @10:46 pm

    Here’s the link for those who have written the board in support of the elimination of tech: Rph ratios

  12. Broncofan7  •  Oct 30, 2013 @11:21 pm

    Pure unadulterated hilarity from a WALMART regional ( non practicing pharmacist) in Dallas:

    ” My name is Kellye Moss and I am a Market Director for Wal-Mart pharmacy in the Dallas area. I had been a practicing pharmacist in Texas for 17 years before moving into the next level of management and have seen the profession undergo many changes and transformations. I would like to express my views on the pharmacist:technician ratio in Texas pharmacies. Before becoming a pharmacist, I worked as a technician while attending pharmacy school so I have seen both sides of the practice. I have managed many different pharmacy locations for Wal-Mart encompassing both ends of the spectrum of volume in my 17 years.
    When the topic arises about expanding or eliminating the pharmacist:technician ratio, many look at it as an opportunity to utilize less expensive employees to complete more of the workload and reduce the number of pharmacist needed at the retail level. As the practice of pharmacy has changed, we are no longer dispensers of medication. We have become pillars in patient care. We work closely with local physicians and our patients to oversee and attend to their medication therapy. We have taken counseling to a new level and expanded our role in the medical community. In order to continue to expand our roles in immunization therapy, healthcare screenings, and MTM, we desperately need to have the ability to work within the upper one-third of our license”

  13. Broncofan7  •  Oct 30, 2013 @11:34 pm

    I challenge anyone reading this blog to walk into 3 walmart pharmacies, speak to the pharmacists who work at these stores and ask them how much time they have to do MTM, immunizations let alone basic counseling. In midland/ Odessa those stores are prescription factories where just calling to get a transfer is a 10 minute wait…my personal belief is sure, get rid of the tech: Rph ratio … In it’s place put a limit on the number of Rxs that can be filled in a single 8 hour shift to 300/pharmacist. If a store averages 302/day then they’d better have 16 man hours of pharmacist help per day as a minimum! I’m forming my letter tonight to present just this.

  14. Broncofan7  •  Oct 30, 2013 @11:55 pm

    And it’s plainly obvious that H-E-B created a form letter that many koolaid drinking , soon to be exploited pharmacists put their names to in support of eliminating the tech: Rph ratio

  15. AJ  •  Oct 31, 2013 @7:49 am

    Broncofan7 you picked an excellent example of an idiot middle manager letter of support. A Wal-Mart middle manager…is there any opinion that as any less value in this discussion? I issue the same challenge. Go to any Wal-Mart and see how much of the “upper third” of their license the pharmacists are using. What a joke!

  16. AJ  •  Oct 31, 2013 @8:11 am

    Broncofan7, HEB is 100% behind this effort. For years they have been running a central fill facility. They lobbied in 2009 for a new class of pharmacy with a higher RPh to tech ration because of it. In 2010 they got the Board to create a new class of pharmacy, Class G. They are leading this effort so they can staff their central fill pharmacy with an unlimited amount of technicians. It’s been a brilliant under the radar effort that no one has paid attention to. The ramifications of a Class G pharmacy with no tech to RPh ratio will effect everyone. It will allow other corporate retail chains to follow suit. Namely Walgreens and thier idiotic programs like POWER and Project 1 will be able to operate with virtually no over-site from the Board of Pharmacy. Walgreens has to be bursting at the seems with excitement! If this passes they could have a central prescription data entry center with one pharmacist supervising 1000 techs doing data entry!
    What got my attention is the ramifications for PBM’s and other entities that process prior authorizations. A Class G pharmacy also includes any facility that processes prior authorizations for dispensing. If you think PBM’s are bad now just imagine all the decisions being made by pharmacy technicians or worse people with no license or healthcare experience.

  17. Cathy Lane RPh  •  Oct 31, 2013 @3:07 pm

    Having first started out at a VA with pre-packaged unit-dose bottles of drugs and filling machines, I saw nothing wrong with that sort of mechanization.

    I also spent time performing clinical services at a hospital where techs supervised a roomful of unit-dosing machinery packaging individual medication orders for in-patients, with equipment guaranteed by the company for 99.999% accuracy.

    However, I have worked for temp agencies holding high-volume retail contracts with pharmacies employing high RPh:tech ratios, in shops and towns where I’ve not worked before.

    So, I’ve done it (worked with a mess of techs as the only pharmacist). It’s not right. Frequently, in those situations, I felt as if the pharmacist was the impediment to business.

    At one time, it was against the law for shops to even open up without a legally employed registered pharmacist in the shop, the practice of pharmacy was limited to registered pharmacists due to conflict of interest with physicians, and the force of monopolization kept drug-related businesses local.

    We’ve seen new ideas with mainstream controls quickly go extreme lengths with legal abdication of our duty.

    In my hospital job, we try to organize patient drug therapies. There are three main shops in town and two of them are part of the same chain. However, the majority of our patients have prescriptions filled through a mail-out service as mandated by their employer, retirement plan, or the government programs. Most of the time (> 80%) patients arrive to the hospital with no idea of what medications they are taking, strengths, dosages, etc., PLUS they cannot tell from which mail-out service their drugs arrive in the mail.

    As the hospital pharmacist, we have no magic communication with ANY mail-out services. For the most part, there is a nearly impossible gauntlet of insurance dealers and techs and hurdles to jump through in order to talk with a pharmacist who has the legal responsibility to communicate with another pharmacist about our patient, details about prescriptions, history of the patient.

    Time? No pharmacist has time to wait 45 minutes on a phone to speak to another pharmacist, especially when the ER doctor is asking specific questions about the patient’s therapy.

    Whenever I work retail, I feel more inadequate because of obstructions placed in fulfilling my duty and perhaps a major effect is the RPh:tech ratio which in effect undermines everything that bears my initials.

    Sometimes, I think of how education empowers, and how as pharmacists, our profession has evolved; with education as a primary service we can provide. And then, I think of becoming empowered as I was trained to perform my duty in society.

    For example, with somewhat of a moral justification to limiting Plan B when first considered by FDA, I had a feeling in my gut, that what should be a matter of some serious consideration by patients and healthcare professional would become much more accessible than FDA advertised restrictions.

    Not too long after introduction of legislation, it was readily apparent that the big box shops I pulled shifts where techs at the pick-up window were selling Plan B to their friends. In the area of womenfolk’s rights, this stance supports child-trafficking at the local drugstore level, as well as increased levels of syphilis, gonorrhea, cytomegaloviral sterility.

    At one time, pharmacy-related initiatives affecting the health of the US citizens were either made by pharmacists or pharmacists played a major role in the decision-making.

    Now, it seems, the practice of the fragmented pharmacy is running amok among business people, chemists, and prescribers, without constant vigilance, letter-writing campaigns, and, involvement in the politics of our society.

  18. broncofan7  •  Oct 31, 2013 @5:10 pm

    To: Allison Benz R.Ph., M.S.
    Director of Profession Services, Texas State Board of Pharmacy Texas State Board of
    333 Guadalupe Street, Suite 3-600
    Austin, TX 78701

    Dear Ms. Benz:

    The proposed elimination of the Pharm Tech to Pharmacist ratio is a fantastic concept for me as a Chain Pharmacy, corporate bean counter! I can now hire 9 technicians to process the 600-800 prescriptions per day and now I don’t need to hire another couple of overpaid Pharmacists to do so! You just added $250,000(by virtue of the elimination of the need for 2 other RPhs) to my bottom line and although we will likely have to add in some additional retaining fees for attorneys due to the escalation in lawsuits, it’s a mere drop in the bucket compared with our new found savings!
    This elimination of the ratio coupled with the soon to be EIGHT pharmacy schools in Texas producing a glutton of new and eager, in debt graduates, will also allow me to put salary pressures on my existing Pharmacists and make them more amenable to meeting my profit derived desires! It’s truly going to be the golden age for corporate Pharmacy profits! Thank you Texas State Board of Pharmacy !

    The Texas Federation of Drug stores led by Herman-E-BUTT.

    Now for the TRUTH:
    The TRUTH IS that the ratio for Class A Pharmacies should likely be moved to 4:1 with a typical workflow being : 1 Tech at data entry, 2 Techs counting and filling and 1 Tech at the pickup or drive thru window. That is a safe work environment for a single Pharmacist to oversee.

    The TRUTH IS that the definition of a Class A Pharmacy needs to be streamlined to cover ONLY community outpatient Pharmacies. There are far too may scopes of practice under the Class A designation currently.
    The TRUTH IS when reading comments from middle managers who work for say the “Smiley faced Pharmacy” about how eliminating this Tech to Pharmacist ratio will “free their Pharmacists up to do more counseling, immunizations and MTM” is nothing more than a corporate talking point. I challenge anyone reading this to go to THREE “smiley faced Pharmacies” and talk to the Pharmacists working in these dispensing factories where an average day is 700 rxs how much time that they have for any task other than overseeing the filling process. How do I know? Have you ever called a “smiley faced pharmacy” for a Transfer and suffered through the inevitable 10 minute wait before the Pharmacist can catch their breath long enough to take the call? All that adding more technicians to this scenario would do is increase the number of Rx’s that these Pharmacists would have to verify. This proposal is tantamount to a traffic engineer attacking the traffic congestion issues on I-35 in Austin by adding UNLIMITED roads feeding directly onto I-35 in Austin. It’s ridiculous on its face.

    The TRUTH IS the BUTT of all Pharmacies obviously has a vested (Translation: FINANCIAL) interest in seeing this ratio done away with as evidenced by the disproportionate number of BUTT Pharmacists responding in the “PRO” position. I am personally humored by the myopic view point of these employees who clamor for more clinical responsibilities and duties. As employees they are obviously unaware that the business fundamentals of Clinical Pharmacy practice simply ARE NOT in existence currently. One cannot pay a single Pharmacist even one day’s salary consistently at a store by virtue of MTM or immunizations alone. Dispensing is STILL the underlying profit driver for Pharmacy. These Corporate,driven by profit Chain Pharmacies, are not going to have Pharmacists conducting clinical services at a LOSS. This is a FALSE argument being given by the Chain drug store owners.
    The TRUTH IS that the Affordable Care Act DOES NOT provide Pharmacists a model for profitability in providing clinical services. Our financial viability is still going to be defined by DISPENSING. See below for PROOF.
    “While the ACO final rule DOES NOT LIST PHARMACISTS as eligible professionals to form ACOs OR BE ELIGIBLE FOR SHARED SAVINGS, pharmacists can participate in ACOs. Asked if Walgreens pharmacists will somehow be able to participate financially in the new ACOs, Cohn said, “Walgreens as a whole will be participating in the savings, but we cannot provide more information about potential future financial elements of the ACOs at this time.”

    I continue to read that EMPLOYEE PHARMACIST proponents of the elimination of the Pharm Tech to Pharmacist ratio believe that it should be up to the Pharmacist on duty in each store to decide how many Technicians that they can safely supervise. The TRUTH IS that EMPLOYEE Pharmacists are NOT given much in the way of professional discretion and leeway and that most, if not all, are forced to accommodate their Chain Drug Store owner’s “Best Practices” workflow. I’ll give you one guess as to what the new “best practices workflow” model at chain stores will consist of if this ratio is eliminated? ANSWER: Many more Technicians and a lot LESS $125,000 per year Pharmacists.
    The TRUTH IS that many of these Employee Pharmacists working in a chain store environment already don’t have even a 3:1 Ratio at ALL times in their stores and it’s due to one thing, the corporate bottom line. These employee Pharmacists are already being told that they are at their Pharmacy department’s maximum payroll and are often asked to slash hours, so where is the additional revenue going to come from to pay for these unlimited Technicians if this proprosal is approved? I’ll give you one guess.
    The TRUTH IS that Pharmacists who are working in the Chain store environment and who have written letters in support of the elimination of the Pharm Tech to Pharmacist ratios aren’t able to see beyond the horizon of their personal Pharmacy counter. For those of us who can see past it, it’s readily apparent that this elimination of Tech to Pharmacist Ratios, coupled with the coming surge of new Pharmacy grads here in Texas, in addition to the ACA’s lawfully defined role for Pharmacists as not being able to “participate financially in ACO’s” is a recipe for employment disaster.
    The TRUTH IS that Pharmacists are already being asked to verify too many prescriptions in the Community Pharmacy Chain drug store setting. Instead of the Texas State Board of Pharmacy bringing to the table the elimination of Tech to Pharmacist ratios, the State board should strongly consider that for every 300 prescriptions filled, on average, at a store, that there needs to be AT LEAST 1 FTE Pharmacist. For example, if a store were to average 303 Rx’s a day, then that store would need to have AT LEAST 16 hours of Pharmacist coverage by 2 different Pharmacists. That is the SAFE and EFFECTIVE way to deal with the current work flow issues in community Class A Pharmacy. But OF COURSE the Lobbyists from the Texas Federation of Drug stores wouldn’t propose this. It’s BAD for their BOTTOM LINE.
    In conclusion, when Pharmacists willfully take steps to remove themselves from the PROFIT generating portion of their profession (and it’s STILL DISPENSING) while clinging to the Clinical Pharmacy practice dreams and wishes that we all heard of while attending Pharmacy school, Pharmacy will cease to be OUR profession and we will continue down the road of professional exploitation culminating in subpar working conditions and decreasing financial rewards that ultimately will result in a working environment that is unsafe for the Public.


  19. Peon  •  Oct 31, 2013 @10:12 pm

    I will comment on the Wal-Mart ‘Market Director’s’ statement about Wal-Mart and his stance on the pharmacy/tech ratio. As most of you probably know, I work for Wal-Mart. I have worked for them for about 20 years. Overall, I consider Wal-Mart a fairly good place to work. They seem to be pursuing some of the things that Kellye Moss said. However, a Wal-Mart pharmacy is not a ‘patient care’ facility. It is a pharmacy, like pharmacy has been for decades. The pharmacists are dispensers of medication. What the pharmacist’s mostly do is check the work of the inputting tech and verify that the filling techs have put the right medication in the bottle. The problem with increasing the tech to pharmacist ratio is that it will increase the number of prescriptions that the pharmacists must check and verify. My state has a 1:2 ratio. This is probably about the right mix because it does give us time to do the verifying and some counseling. As the ratio is increased, the pharmacist is going to be overwhelmed with checking and verifying, and counseling will have to be ‘thrown under the bus’. Kellye Moss is merely spouting the Wal-Mart ‘line’. I am not saying that Wal-Mart is not going in that direction or plans to go in that direction. I can say that it is not here today and I don’t see it changing anytime soon. We need to fight any changes to the pharmacy/tech ratio. We have been hearing about MTM for well over a decade and it is no where to be seen in Wal-Mart. Until our roles actually change, we don’t need the pharmacy/tech ratio changed.

  20. RalPh  •  Nov 1, 2013 @1:19 am

    Least encouraging comment I saw was from a tech in support of eliminating ratios: “The technicians are not properly trained. There was time to train me, because there were enough pharmcists and techs back in 2005 to do so. Now, I do not know what is going on.”


    In Oregon we don’t have ratios any more, but we used to. Where I work they hire a lot of part time techs, which I think is a worse deal than whether there is a ratio. I have too many different personalities and work ethics to watch, and it can be straining.

    I would agree that it’s more stressful having fewer techs, but all it takes is one of those extra techs to make a serious error filling a vial and you and the patient are toast. And it’s ludicrous the idea that if there is no ratio that automatically there will be enough help. The major thing here is DO NOT GIVE UP OUR GROUND. Without pharmacists supervising and determining what happens, we lose ground. Middle managers will have more untrained power to affect our livelihoods and to effect negative patient outcomes.

  21. AJ  •  Nov 1, 2013 @1:12 pm

    Texas Board of Pharmacy Members

    c/o, Allison Benz R.Ph., M.S.

    Director of Professional Services

    Texas State Board of Pharmacy

    333 Guadalupe Street, Suite 3-600

    Austin, Texas 78701
    Board of Pharmacy members,
    I ask you to carefully consider the implications and unintended consequences of changing the pharmacist to technician ratios. I also ask the Board to carefully consider the statements made in favor of changing the pharmacist to tech ratio in all classes of pharmacies. I have read many of the comments submitted in support of a change. An overwhelming majority of the comments in favor have been sent in by corporate retail chain pharmacists and middle managers. The central argument in nearly all these comments has been how dangerous it is to work with too little staff. The Board of Pharmacy does not limit the number of technicians that can work in a pharmacy. It limits the number of technicians one pharmacist can supervise in a pharmacy. The problem these pharmacists and middle managers have is with their respective companies and their refusal to provide an adequate number of pharmacists. It is not the ratio the Board of Pharmacy has set.
    Retail pharmacists have been pushed to their breaking point. There has never been more tasks, responsibilities and liability placed on pharmacists than there is now. I have personally experienced this as a PIC at two different grocery store chains in two different states. As the PIC I had absolutely no discretion concerning the staffing of the pharmacy. The staffing decisions were made by non-pharmacist corporate middle managers thousands of miles away. The staffing ratios outlined by the TSBP are the only protection a PIC has against dangerous and unsafe staffing. Removing this regulatory check will endanger the health safety and well being of the citizens of Texas.
    Pharmacy technicians are an invaluable part of the pharmacy team. There is no doubt they alleviate some of the massive workload forced onto pharmacists by corporate retail chain pharmacy management. Sub Chapter B, Rule 291 (C) states, “Pharmacists are solely responsible for the direct supervision of pharmacy technicians and pharmacy technician trainees and for designating and delegating duties”. Sub Chapter B, Rule 291, (2) Duties (i) states “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”. This alone is an enormous task for one pharmacist. Add to this the responsibility and liability of dispensing and counseling on 300 to 400 prescriptions in a 12 to 14 hour shift, immunizations, record keeping and ensuring compliance with state and federal law and it becomes impossible. Removing the ratio requirement and allowing more technicians into the pharmacy does nothing but increases the stress on the pharmacist and endanger the public.
    I ask the Board to carefully and thoughtfully evaluate the following question. Who benefits from a change in the pharmacist to technician ratio? The citizens of Texas certainly will not benefit. The pharmacists licensed by this board will not benefit. The only benefit will be to the big corporate pharmacy chains that have so aggressively lobbied you for this change. I believe it will be a huge mistake for the Board to ease and/or voluntarily give up regulatory control at a time when our health care system is undergoing a massive change with millions of people entering the system via the Affordable Care Act. This is a time for the Board to be ever more vigilant in order to protect the heath, safety and welfare of the citizens of Texas.
    Arden J. Hill, RPh, PharmD

  22. broncofan7  •  Nov 1, 2013 @1:25 pm

    The links to the “PRO” and “CON” comments on this subject are no longer functional..I wonder why?

  23. AJ  •  Nov 1, 2013 @1:52 pm

    Broncofan7…The comments submission closed yesterday at 5 pm. They’ve gathered everything together under a new PDF document so the link has change. I just checked and they are all there including yours.
    I received an e-mail from the Board concerning the Texas Registrars statement that people appearing before the Board are asked to submit a copy of the statement they will make to the board or bring 20 copies. She said there is no requirement for either unless you want the board to have your statement.
    Here is what I got “You don’t need to provide a statement in writing unless you want the board to have it. Because of the volume of individuals wanting to speak at the public hearing the board will be limiting the testimony to 5 minutes per person. If you have further questions, please contact me. Thanks”
    So it looks like I will make a 7 hour round trip to speak for 5 minutes. This is so important I would make a 15 hour round trip. This is how it starts. The only way to defend our profession from the idiot corporate middle managers is to fight fire with fire. They damn sure don’t miss these meetings and are usually the ones proposing the changes. In every State in the Union we need to have double the number of concerned pharmacists at every meeting and every public hearing to defeat these pin heads.

  24. Broncofan7  •  Nov 1, 2013 @2:31 pm And the NCPA comes out yet again in a PRO-Pharmacist position. They are THE best organization for promoting and supporting our profession Hands down.

  25. AJ  •  Nov 1, 2013 @5:23 pm

    85 letters submitted in opposition to the changes.
    Notable submissions in OPPOSITION:
    Texas Association of Independent Pharmacy Owners
    Chair of the New Mexico Board of Pharmacy
    Adjunct Professor of Pharmacy Texas Tech
    Multiple Independent Pharmacy Owners
    Director of The Georgia Pharmacy Association
    Past President of the Texas Pharmacy Association
    NCPA (National Community Pharmacists Association)
    50 letters in SUPPORT of the change.
    Notable submissions in SUPPORT of the change:
    Form letter with the names of 191 pharmacists
    Form letter with 58 technicians names on it
    Form letter with 27 CVS pharmacists names on it
    Form letter with 13 Walgreens Pharmacy Supervisors
    Texas Federation of Drug Stores
    NACDS (National Association of Chain Drug Stores)
    Express Scripts
    Prime Therapeutics
    HEB Pharmacy Contact Center Manager
    HEB Clinical manager, Pharmacy Professional Servic
    HEB – Multiple pharmacists and pharmacy managers
    CAPA (Capital Area Pharmacy Association)
    HEB – Multiple Regional Pharmacy Directors
    COSTCO Regional Pharmacy Supervisor
    Wal-Mart Health and Wellness Market Director
    Past President Tarrant County Pharmacy Association
    HEB Director of Pharmacy Compliance and Reg
    CostCo VP of Pharmacy

  26. Shane Quinlan  •  Nov 1, 2013 @5:25 pm

    From reading this blog and other material on the web, thank christ I’m not about to start practicing in the states. (I’m in my final year in Ireland doing the B.Sc. A year of interning then I get my M.Pharm.)

  27. RalPh  •  Nov 2, 2013 @1:04 am

    I need some opinions on this, but I am wondering whether there is ANY traction on the idea that, in my state, the following rule might preclude non-pharmacy staff (grocery managers, other staff outside the pharmacy) from supervising techs on things like “dropping everything to answer the phone or help the front”. (They are promoting person-centered customer service rather than task-centered, which means, Don’t have allegiance to a task you have started, but rather you should drop it if another customer approaches even before you finish the task.)

    Anyway, Here is the rule from the Board… esp. (1) and (3) and (5) and (6).

    “General Responsibilities of a Pharmacist

    [xxx] states that “the practice of pharmacy in the State of [xx] is declared a health care professional practice affecting the public health, safety and welfare”. Pharmacy practice is a dynamic patient-oriented health service that applies a scientific body of knowledge to improve and promote patient health by means of appropriate drug use, drug-related therapy, and communication for clinical and consultative purposes. A pharmacist licensed to practice pharmacy by the Board has the duty to use that degree of care, skill, diligence and professional judgment that is exercised by an ordinarily careful pharmacist in the same or similar circumstances.

    (1) A pharmacist while on duty must ensure that the pharmacy complies with all state and federal laws and rules governing the practice of pharmacy.

    (2) A pharmacist shall perform the duties of a pharmacist that include, but are not limited to, DUR, counseling, and final verification of the work performed by those under their supervision.

    (3) A pharmacist may not delegate any task that requires the professional judgment of a pharmacist. Such tasks include but are not limited to:

    (a) Counseling to a patient or patient’s agent, or other healthcare provider;

    (b) Verification;

    (c) Performing DUR;

    (d) Providing a CDTM, DRR, or MTM service;

    (e) Ordering, interpreting and monitoring of a laboratory test; and

    (f) Oral receipt or transfer of a prescription; except that

    (g) An intern under the supervision of a pharmacist may perform all the duties of a technician and the following:

    (A) Counseling;

    (B) Performing DUR;

    (C) Oral receipt or transfer of a prescription,

    (D) Immunizations if appropriately trained, and supervised by an immunization qualified pharmacist;

    (E) Other activities approved in writing by the Board.

    (4) A pharmacist who is supervising an intern is responsible for the actions of that intern, however, this does not absolve the intern from responsibility for their own actions.

    (5) A pharmacist on duty is responsible for supervising all pharmacy personnel, and ensuring that pharmacy personnel only work within the scope of duties allowed by the Board.

    (6) A pharmacist may not permit non-pharmacist personnel to perform any duty they are not licensed and trained to perform.”

  28. Pharmaciststeve  •  Nov 2, 2013 @7:13 pm

    Interruptions are the genesis of mistakes.
    The Rph is responsible for mistakes
    If any employee that does not have keys to the pharmacy and/or. Cannot legally open the pharmacy… Has no authority over what goes on in the pharmacy.
    IMO. The Rph on duty is the Rph in charge of the pharmacy’s total operation.

  29. RalPh  •  Nov 3, 2013 @1:30 am

    I think you’re right, PharmacistSteve, I just wish I knew for sure.

    I guess it’s one of those things: if they pressure me or threaten my practice, I am bound to ask for their authority and/or report them as a drug outlet violator, which we can do in my state. The drug outlet can be fined for multiple things.

    I ordered JP’s manual on Thriving as a Retail Pharmacist. I document everything now.


  30. Pharmaciststeve  •  Nov 3, 2013 @8:36 am

    Most practice acts … No one can be in the pharmacy without permission of the Rph on duty.. Is telling Rx dept staff what to do “being in the pharmacy” .. Is it “practicing pharmacy” what does “pharmacist in charge” really encompass in your state?
    Your supervisor doesn’t understand that just because your employer signs your paycheck.. Doesn’t allow them to dictate how you practice pharmacy and/or put your license at risk.
    Might be a point where your legal counsel send corporate legal that this new mandate will probably cause med errors and if the corporation wishes to indemnify you against the consequences of any med errors as a result of this mandate..
    Which they cannot legally do.. Because they can indemnify you against breaking the practice act… Which making a med error is.

  31. RalPh  •  Nov 3, 2013 @7:40 pm

    Where is an example from your practice act that exemplifies how making a med error is breaking the practice act? I just want to understand, because you sound sure. :)

  32. Pharmaciststeve  •  Nov 3, 2013 @9:18 pm

    In one state that I am licensed in.. Indiana… The practice act references the requirement of a pharmacist in the competent practice of pharmacy
    You give the pt a Rx that is wrong.. It is at the very least mislabeled .. Is a mislabeled Rx competently practicing pharmacy?
    When you violate practice act you also violate company policy .. That all employees will observe/obey all rules & regulations… State or federal
    So if the mistake is serious enough the corporation could claim no responsibility because you broke company policy.

  33. RalPh  •  Nov 4, 2013 @6:38 pm

    Steve, thanks. I understand now. I now need to figure out how to get ahold of our policies related to pharmacy. they are on our website.

  34. Pharmaciststeve  •  Nov 4, 2013 @6:44 pm

    @RalPh… the issue of ALL EMPLOYEES not breaking any rule/regulation.. It should be a general cover-all .. concerning all employees.. Every employee is capable of breaking some rule/regulation… Not just RPH’s

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