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NEW Pharmacy Technician
Administrative Rules Promulgated
Clarification around Licensure Requirements
Applicants will be required to submit proof of having graduated from an accredited high school (or comparable institution) or having passed the graduate equivalency examination. Additionally, they will have to provide proof of passing either:
- A national examination administered by PTCB or NHA
- A nationally recognized examination that has been approved by the Board of Pharmacy
- An employer-based training program examination approved by the Board of Pharmacy
As with other licensees, new applicants must provide proof of having completed the one-time training required in identifying victims of human trafficking. If the applicant holds any other license in another state, the US military, the federal government, or another country, they must disclose each license, registration, or certification they currently hold on the application. Additionally, they must show that they have no pending disciplinary actions against them and disclose any sanctions applied to their licenses in another jurisdiction.
Applicants who hold a pharmacy technician license in another state may apply for licensure by endorsement, which are now “presumed to meet the requirements… of the code, any other rule promulgated under the code…, as well as all of the [requirements listed above].” While the implementation of this clause and the degree to which an applicant by endorsement will be provided to prove compliance with the licensure requirements, it appears that the change in verbiage is aimed at making it easier for pharmacy technicians to reciprocate their license/registration from another state.
Expiration of Examination Approval and Examination Grading Procedure
Under the new rules, any board-approved examination (except for PTCB and NHA) that was recognized by the Board prior to July 1, 2022, must submit a new application for approval by Dec. 31, 2023, or it will no longer be listed as a board-approved program. Going forward (as stated in the previous version of the rules), the approval of an examination by the Board is valid for five years. By Oct. 2, 2023, “a board-approved program must include a proficiency examination grading procedure with the proficiency examination application, which will be reviewed by the board with the examination.”
Approved Pharmacy Technician Training Programs
Pharmacy technician training programs conducted by community colleges are now eligible for Board approval. The new rules also clarified that a student in an approved program “who is at least 16 years of age… may participate in practical hands-on training in the pharmacy.” This is to allow licensure candidates who participate in these programs to be eligible for examination and licensure at age 18 following the two years they are authorized under the rules to participate in an approved program.
A program approved prior to July 1, 2022, shall meet the requirements listed under R 338.3655 and reapply by Oct. 2, 2023. Similar to the examination requirements, Board approval of a training program lasts five years.
The new rules add two additional clauses on program deficiencies and withdrawal of Board approval:
- “If the department determines that a board-approved program is not meeting the standards of the code or these rules, the department may send written notice to the program stating which areas in the program are deficient. The program has 30 days to fix any deficiency and report back to the department. If the department determines that the deficiencies are not resolved, the board will evaluate the deficiencies and may withdraw approval.”
- “Withdrawal of board approval of a program for stated deficiencies that were not remediated does not make any bona fide student enrolled in the program, at the time of withdrawal of approval, ineligible to sit for an approved licensure examination.”
Clarification of Pharmacy Technician CE Requirements
Upon renewal, pharmacy technicians must complete 20 hours of continuing education (CE) per licensure period. These shall include: one hour in pharmacy ethics and jurisprudence (which may be completed in one or more courses); one hour in patient safety; and one hour in pain and symptom management, which includes, but is not limited to:
- Behavior management
- Psychology of pain
- Pharmacology
- Behavior modification
- Stress management
- Clinical applications as they relate to professional practice
At least five of the 20 hours must be live. The licensee is still required to have a one-time training in identifying victims of human trafficking and two hours of implicit bias training per license cycle. Though these courses do not have to be accredited for CE, they may count toward the 20-hour requirement if they have been appropriately accredited.
Technology Assisted Verification
The scope of activities and functions performed under delegation (R338.3665) have been modified related to technology-assisted final product verification. The rule now reads:
[A licensed pharmacy technician may, under the delegation and supervision of a licensed pharmacist] provide technology-assisted final product verification, which includes all the following:
- A properly trained pharmacy technician performing final product verification using barcoding or another error prevention technology.
- The licensed pharmacy technician providing final product verification is subject to all of the following requirements:
- The licensed pharmacy technician holds a current full or limited pharmacy technician license in this state.
- Before performing final product verification, the full or limited licensed pharmacy technician meets one of the following:
- Has accrued not less than 1,000 hours of pharmacy technician work experience in the same type of pharmacy practice site where the technology-assisted final product verification will be performed while the pharmacy technician holds a current full pharmacy technician license, a temporary license, a limited license, or is in training in this state.
- Has completed a final product verification training program that includes at least all of the following:
- The role of a pharmacy technician in the product verification process.
- The legal requirements and liabilities of a final verification technician.
- The use of technology-assisted verification systems.
- The primary causes of medication errors and misfills.
- The identification and resolution of dispensing errors.
- The practice setting where a licensed pharmacy technician performs final product verification has in place policies and procedures, including a quality assurance plan governing pharmacy technician technology-assisted final product verification.
- The technology-enabled verification system must document and electronically record each step of the prescription process, including which individuals complete each step.
- A licensed pharmacy technician shall not perform technology-assisted final product verification for sterile or nonsterile compounding.
- Technology-assisted final product verification by a licensed pharmacy technician is not limited to a practice setting.
- A pharmacist using professional judgment may delegate technology-assisted final product verification after ensuring licensed pharmacy technicians have completed and documented relevant training or work experience.
Further, related to the rules go on to state, regarding remote access to electronic databases, that:
Access the electronic pharmacy database from inside or outside the pharmacy to perform the delegated tasks in paragraph (iii) of this subdivision related to prescription processing functions outside of the personal charge of a pharmacist.
- A pharmacy technician remotely performing the tasks in paragraph (iii) of this subdivision must be supervised by a licensed pharmacist.
- The remote supervision in paragraph (i) of this subdivision means that a pharmacist directs and controls the actions of the remote technician using technology to ensure the supervising pharmacist does both of the following:
- Is readily and continuously available to answer questions, review the practice of the supervised pharmacy technician, provide consultation, review records, and educate the pharmacy technician in performing functions.
- Has established predetermined procedures and drug protocol governing any activity performed remotely, including protection of patient confidentiality.
- Delegated tasks relating to prescription processing functions include, but are not limited to, the following:
- Verification of a patient’s medication history.
- Data entry regarding processing prescription data and patient data.
- Claims adjudication.
- Handling phone calls regarding processing prescription data and patient data.
- Processing refill requests.
- Technology-assisted final product verification.
- Transferring prescriptions for non-controlled substances.
If you have any questions, please contact MPA at MPA@MichiganPharmacists.org.
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