Should pharmacy managers be tested?
Monday, November 16, 2015
Should a pharmacist who becomes the manager — also known as the pharmacist-in-charge (PIC) — be required to pass a separate exam to prove he/she understands what is expected in this new position? According to the New Hampshire Board of Pharmacy (BOP), the answer is yes.
Starting Dec. 31, every PIC in the state must complete and pass (80 percent correct) a 25-question test. According to a statement on the New Hampshire BOP website, the need to institute this exam has arisen based upon their experience investigating and acting upon pharmacy disciplinary issues:
"Based on discipline that the Board has issued over the last couple years, it would appear that some pharmacists have either not kept up to date on pharmacy law/rule changes or in some cases do not know the pharmacy laws/rules. The Board felt that in some cases, if the pharmacist had been familiar with laws and rules, they would not have put themselves in a position that could possibly lead to discipline against their license."
Apparently, by requiring an exam, the BOP feels they are better promoting the health and ensuring the safety of the citizens of New Hampshire: "The PIC Exam is one way the Board can ensure that it is meeting its legal responsibility of protecting the public." The authority to administer such an exam has been written into the Pharmacy Standards of Practice laws in the State (Ph 704.11).
What should we, as pharmacists, think about another exam like this being issued in order to serve as a pharmacy manager (PIC)?
On the one hand, as someone who has worked for more than 15 years as a PIC in Connecticut and Massachusetts for three different employers, I appreciate that it is easy to get a bit "rusty" on some of the nuances of pharmacy regulations. Pharmacy is arguably the most regulated industry in healthcare. Keeping abreast of the relevant regulations that include federal and state laws and policies, as well as related policies and procedures from your own employer is no easy task.
On the other hand, I feel that exam to test the knowledge of the PIC is more of an exposure of the failure of the BOP than a failure of the pharmacist. Here's why:
1. The BOP, through their experience, know the types of laws and regulations that seem to be forgotten or improperly carried out. Therefore, rather than creating an "exam" that only forces the pharmacist to "guess" which laws are going to be reviewed, why not just provide a document that reviews them all?
Why not say, "Here are the top 10 most frequent infractions that lead to disciplinary action in our state"? Folks, the goal here is to educate one another, not hide the facts and try to expose ignorance through a test.
2. A one-time, 25-question test is unlikely to improve things in the long term. Think about it. When a pharmacist passed his/her state pharmacy license exam, they probably knew the pharmacy law much better than they know it today. Over time, depending on your practice site, the details will fade.
Why will taking a one-time test be any different? Eventually the same problems will likely resurface.
3. A better approach to educating all pharmacists and especially the PIC would be through communication and information. Why not pick up the phone and call the PIC in every pharmacy at least once a year.
According to data on the NH BOP website, there are only about 300 pharmacies in the state. The average busy retail pharmacist talks to that many patients in a day! Surely they could manage to talk to 300 PICs in a year. Say something like, "Hey, we appreciate the work you are doing as a pharmacist. We know it isn't easy. We also know it isn't easy to keep up with all the laws and rules. We'll be sending you an email reviewing some of the most important ones and want you to know we are here for you if you have any questions."
How long would that take?
4. Finally, if this is really an issue that is resulting in frequent disciplinary action, why not offer an annual CE opportunity instead? Title it "2015 Disciplinary Issues Reviewed." Change it every year to reflect the most current challenges.
I am opposed to laws and regulations that seem to only serve to pit the pharmacist against the BOP. We are on the same team. We are here to protect the public and promote their health. But far too often it feels as though we are at war with each other.
Put your guns down. Let's work together. Most pharmacists I know actually want to follow the law and do the right thing. We should be allies, not adversaries in this profession.
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