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Pharmacy technician-to-pharmacist ratios: A state-driven safety and quality decision D. Todd Bess, Jason Carter, Lindsey DeLoach, and Carol L. White

Abstract Objective: To discuss the policy of pharmacy technician-to-pharmacist ratios by comparing Florida as an example of legislative-led authority versus Tennessee as an example of board of pharmacy-led ruling. Summary: Over the past 2 years, the Florida legislature has debated the issue of pharmacy staffing ratios, initially leaving the Florida Board of Pharmacy with little authority to advocate for and enact safe technician staffing ratios. Anticipating this situation, the Tennessee Board of Pharmacy created rules to meet pharmacy staffing needs while protecting the authority of the pharmacist-in-charge and promoting patient safety. Before enacting rules, members of the board toured the state and talked about proposed rule changes with pharmacists. The final rule sets the pharmacy technician-topharmacist ratio at 2:1 but permits a 4:1 ratio based on public safety considerations and availability of at least two Certified Pharmacy Technicians. Conclusion: Pharmacists and leaders within the profession should conduct further research on appropriate and safe ratios of pharmacy technicians to pharmacists, with a focus on safety and quality of care. Keywords: Pharmacy technician, pharmacist, ratio, safety, quality, workload, medication errors, personnel management, technician supervision, pharmacy staffing. J Am Pharm Assoc. 2014;54:648–651. doi: 10.1331/JAPhA.2014.14032

Received February 19, 2014, and in revised form May 28, 2014. Accepted for publication June 11, 2014. Published online in advance of print October 24, 2014. D. Todd Bess, PharmD, BCPS, is Assistant Dean for Middle Tennessee and Director, Nashville Clinical Education Center & Statewide Community Pharmacy Residency Program, College of Pharmacy, University of Tennessee Health Science Center, Memphis; and Past President, Tennessee State Board of Pharmacy. Jason Carter, PharmD, is Chief Pharmacist and State Opioid Treatment Authority, Tennessee Department of Mental Health and Substance Abuse Services, and Associate Professor, College of Pharmacy, University of Tennessee Health Science Center, Memphis. Lindsey DeLoach is third-year student pharmacist, College of Pharmacy, University of Tennessee Health Science Center, Memphis. Carol L. White, PharmD, BCPS, CGP, is Assistant Professor, College of Pharmacy, University of Tennessee Health Science Center, Memphis. Correspondence: D. Todd Bess, PharmD, BCPS, 193 Polk Ave., Suite 2D, Nashville, TN 37210. Fax: 615-532-3399. E-mail: [email protected] Disclosure: The authors declare no conflicts of interest or financial interests in any product or service mentioned in this article, including grants, employment, gifts, stock holdings, or honoraria. Acknowledgments: Christian M. Muenyi, MS.

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s pharmacy practice evolves, pharmacy managers and practitioners must seek ways to increase efficiency at the practice site without compromising patient safety. Different methods may be used to achieve this balance, including increasing pharmacy technician staff to shift certain responsibilities from the pharmacist and create opportunities for clinical service development. According to the National Association of Boards of Pharmacy (NABP) Survey of Pharmacy Law, many states allow a maximum technician-to-pharmacist ratio of 3:1, with other states allowing 1:1, 2:1, 4:1, 6:1 or unlimited ratios.1,2 These ratios may be challenged by entities both within and outside the realm of pharmacy. In this article, we discuss the development, concerns, and ultimate demise of such a challenge within the Florida State Legislature, along with a description of how the Tennessee Board of Pharmacy worked to address pharmacy technician-to-pharmacist ratios to protect patients and providers within the state.

Legislative and regulatory history In April 2013, the Florida State House of Representatives passed a bill that revised the approved pharmacy technician-to-pharmacist ratio from 3:1 to 6:1.3,4 The Senate version of the bill also considered increasing the pharmacy technician-to-pharmacist ratio by sixfold without board of pharmacy approval.5 Opponents to the bill raised concerns at the interference with the Florida Board of Pharmacy’s authority in its mission to improve the quality and safety of patient care.6,7 Critics claimed the legislation was geared more towards quantity over quality of staff provided to phar-

At a Glance

Synopsis: Using the experiences in Florida and Tennessee regarding technician-to-pharmacist ratios, the authors compare and contrast legislative- versus regulatory-driven approaches to this important but controversial aspect of pharmacy practice. The Florida Legislature, after much input by practicing pharmacists and affected corporations, ultimately left the final decision to that state’s Board of Pharmacy. The Tennessee Board of Pharmacy used a grassroots approach to ensure broad input before settling on ratios of 2:1 or 4:1 when the additional pharmacy technicians are certified. Analysis: As pharmacy practice evolves, pharmacists must continue to advocate for quality and safety while increasing efficiencies in the provision of health care. Pharmacists and leaders within the profession must consider further research on these issues, focusing on safety and quality as the foundation for decisions impacting practice.

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macists and patients.8 Proponents of the bill, including the Florida Retail Federation, argued that giving the pharmacist more technician assistance would allow pharmacists to conduct better patient-centered care.9 Ultimately, the 2013 legislation was not passed, leaving pharmacists and legislators in Florida to renew the debate over staffing ratios in the 2014 legislative session. In the Florida Board of Pharmacy meeting in February 2014, the motion to support a 3:1 ratio was approved; any ratio above 3:1 was subject to approval from the board.10 As of May 2014, the Florida House of Representatives’ bill, amended by the Florida Senate, passed into law that a pharmacist can supervise more than one technician only if authorized under the guidelines set by the Florida Board of Pharmacy.2,11 The debate in Florida is echoed across the country, and concerns over the relationship between increased pharmacist workload and patient safety are validated in the literature. According to an article by Bond and Raehl,12 workload is directly related to dispensing errors; as prescription orders per hour increased, the number of errors significantly increased. These authors also found that staffing variables and staff training were among the top two causes for dispensing errors. Leape et al.13 reported approximately 12% of errors occur during the order-verification process, while an additional 11% occur during preparation and dispensing processes. A study conducted at the University of Arizona Tucson College of Pharmacy found increased pharmacist workload, prescription volume, and total pharmacy staffing were associated with significantly increased rates of dispensing drugs with potential drug–drug interactions.14 In a nationwide survey of Certified Pharmacy Technicians, the broad area of staffing issues was identified as a major factor associated with medication-preparation errors.15

Implications for patients and pharmacists In addition to the increased safety risks for patients, pharmacists can be liable or even prosecuted criminally for the actions of technicians under their supervision. In a well-known case from Ohio, a pharmacist served a prison sentence, completed mandatory community service, and had his pharmacist’s license revoked.16,17 The risk of drug diversion must also be considered. While drug diversion within pharmacies continues to increase, unlimited staffing ratios decrease the level of supervision the pharmacist can provide to prevent and detect diversion.18 Thus, the legal consequences associated with medical errors and drug diversion generate increased concern about increasing the technician ratio without sufficient safety and quality standards. Because of the political turmoil in Florida, the Tennessee Board of Pharmacy decided to address this issue. Before 2007, the pharmacy technician-to-pharmacist ratio was 2:1 in Tennessee, but this could be increased to j apha.org

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3:1 if at least one technician was a Certified Pharmacy Technician.19 Through the rule-making process in 2007, the leadership of the Tennessee Board of Pharmacy advocated for addressing the technician-to-pharmacist ratio with special consideration given to quality and safety. As part of this discussion, the board of pharmacy reinforced that any changes would be directed toward improving patient safety rather than business gain. Before the rule-making process, members from the board toured the state to discuss proposed ratio changes with pharmacists, allowing face-to-face dialogue. At the rule-making hearing, the board members defined the pharmacy technician-to-pharmacist ratio as 2:1. The pharmacist-in-charge has the option to increase the ratio to 4:1 based on public safety considerations and if the additional technicians are certified.20 In addition, board members acknowledged the responsibility of the pharmacist-in-charge for ensuring the quality and safety of services provided. The final rule granted the pharmacist-in-charge, rather than the owner(s) of a pharmacy or pharmacy corporation, the autonomy to petition the board for changing staff ratios beyond 4:1.20 The pharmacistin-charge must submit the written request, providing the following information: pharmacy technician’s experience, skill, knowledge, and training; workload at the specific practice site; detailed information concerning the number of pharmacy technicians and their responsibilities/duties; and validation that patient safety and quality of services could be sustained at that specific pharmacy.19 The request must be officially reviewed and granted written approval before changes in staffing ratios are implemented.20 When addressing the issue of staffing ratios, the challenge is finding the balance between providing the pharmacist necessary operational and dispensing assistance while not overpowering the pharmacist with too many staff to supervise. From investigating staffing ratios specific to different types of pharmacies to understanding the needs of different states, further research is warranted. Identifying risks and potential solutions related to staffing ratios and pharmacist workload could provide guidance to pharmacy corporations and government agencies to develop metrics to promote patient safety and operational efficiency.21

Conclusion As pharmacy practice evolves, pharmacists must continue to advocate for quality and safety while increasing efficiencies in the provision of health care. As evidenced in the legislative debate in Florida, corporations and lawmakers may further challenge the boundaries currently set by state boards of pharmacy. Evidence suggests a relationship between increased pharmacist workload and an increase in medication errors. To address pharmacy technician-to-pharmacist ratios for Tennessee pharma650 JAPhA | 5 4:6 | NOV /DE C 2 0 1 4

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cists, the Tennessee Board of Pharmacy created rules to meet individual pharmacy staffing needs while protecting the authority of the pharmacist-in-charge and preserving the overall quality and safety of pharmacistprovided services. Pharmacists and leaders within the profession must continue to collaborate with legislators, focusing on safety and quality as the foundation for decisions affecting practice. References 1. National Association of Boards of Pharmacy. Survey of pharmacy law 2014. Licensing law; status of pharmacy technicians, table 13, page 39. 2. La Rosa, Health and Human Services Committee. Florida House of Representatives staff analysis. http://www. my fl o r i d a h o u s e. g ov / S e c t i o n s / D o c u m e n t s / l o a d d o c . aspx?FileName=h0323c.HHSC.DOCX&DocumentType=Anal ysis&BillNumber=0323&Session=2014. Accessed May 9, 2014. 3. Palombo J. House approves letting pharmacists oversee six times as many technicians. http://news.wfsu.org/post/house‐ approves‐letting‐pharmacists‐oversee‐six‐times‐many‐technicians. Accessed May 30, 2013. 4. Hutson T, Campbell D. Florida State House of Representatives. HB 671: Pharmacy technicians. http://www.myfloridahouse. gov/Sections/Bills/billsdetail.aspx?BillId=4989. Accessed May 30, 2013. 5. Garcia R. Florida State Senate. SB 818: Pharmacy technicians. http://www.myfloridahouse.gov/Sections/Bills/billsdetail. aspx?BillId=49959. Accessed May 30, 2013. 6. National Association of Boards of Pharmacy. Bill to increase technician-to-pharmacist ratio under consideration by Florida legislature. 2013 (Apr 24). http://www.nabp.net/news/bill‐to‐increase‐technician‐to‐pharmacist‐ratio‐under‐consideration‐by‐ florida‐legislature. Accessed February 13, 2014. 7. Florida administrative register and administrative code. View rule 64B16–27.410. https://www.flrules.org/gateway/ruleno. asp?id=64B16‐‐27.410. Accessed May 30, 2013. 8. McQuone M. Thursday’s letters: pharmacy bill puts patient safety at risk. Tampa Bay Times. http://www.tampabay.com/opinion/ letters/thursdays‐letters‐pharmacy‐bill‐puts‐patient‐safety‐at‐ risk/2115653. Accessed May 30, 2013. 9. Hatter L. Florida Retail Federation backing tax holidays, proposals to expand pharmacist duties. WFSU. 2014 (Jan 28). http://news.wfsu.org/post/florida‐retail‐federation‐backing‐ tax‐holidays‐proposals‐expand‐pharmacist‐duties. Accessed February 13, 2014. 10. Meeting Minutes Department of Health Board of Pharmacy Full Board Meeting. Feb 2014. http://floridaspharmacy.gov/ Meetings/Minutes/2014/02‐february/021214‐board‐minutes. pdf. Accessed May 9, 2014. 11. Grimsley D. Florida State Senate. SB278: Pharmacy Technicians.http://www.flsenate.gov/Session/Bill/2014/0278. Accessed May 9, 2014. 12. Bond CA, Raehl CL. Pharmacists’ assessment of dispensing errors: risk factors, practice sites, professional functions, and satisfaction. Pharmacotherapy 2001;21:614–626.

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13. Leape LL, Bates DW, Cullen DJ, et al. Analysis of adverse drug events. JAMA. 1995;274:35–43. 14. Malone DC, Abarca J, Skrepnek GH, et al. Pharmacist workload and pharmacy characteristics associated with the dispensing of potentially clinically important drug-drug interactions. Med Care. 2007;45(5):456–462. 15. Desselle SP. Certified pharmacy technicians’ views on their medication preparation errors and education needs. Am J Health-Syst Pharm. 2005;62:1992–1997. 16. Grasha EM. Discovering pharmacy error: must reporting, identifying, and analyzing pharmacy dispensing error create liability for pharmacists? Ohio State Law J. 2002;63:1419. http://moritzlaw.osu.edu/students/groups/oslj/files/2012/03/63.5.grasha. pdf. Accessed July 8, 2013. 17. Vivian JC. Criminalization of medical errors. US Pharm. 2008;34(11):66–68.

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18. Martin ES, Dzierba SH, Jones DM. Preventing large-scale controlled substance diversion from within the pharmacy. Hosp Pharm. 2013;48(5):406–412. 19. Rules of the Tennessee Board of Pharmacy, Chapters 1140-02.01 Pharmacists and pharmacy interns 1140-02-.02 Pharmacy technicians. Revised November 2002. http://www.state.tn.us/ sos/rules/1140/1140‐02.20100323.pdf. Accessed February 13, 2014. 20. Rules of the Tennessee Board of Pharmacy, Chapters 1140-02.01 Pharmacists and pharmacy interns 1140-02-.02 Pharmacy technicians. Revised April 2012. http://www.state.tn.us/sos/ rules/1140/1140‐02.20100323.pdf. Accessed May 14, 2014. 21. Khandoobhai A, Weber RJ. Issues facing pharmacy leaders in 2014: suggestions for pharmacy strategic planning. Hosp Pharm. 2014;49:295–302.

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Pharmacy technician-to-pharmacist ratios: a state-driven safety and quality decision.

To discuss the policy of pharmacy technician-to-pharmacist ratios by comparing Florida as an example of legislative-led authority versus Tennessee as ...
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