Intern hours no longer required to work as a pharmacist in CA

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Lets make it clear here.

Before: a max of 600 hours from school rotations; 900 hours from work outside of school

Now: 1500 hours from school rotations (number of rotations is still the same). Work outside of school is no longer required.

How is this not a major change?
 
Lets make it clear here.

Before: a max of 600 hours from school rotations; 900 hours from work outside of school

Now: 1500 hours from school rotations (number of rotations is still the same). Work outside of school is no longer required.

How is this not a major change?

Noooooooooooooooo you read it wrong. I'm in a drive thru line so I'll wait til I get back to reply.
 
Lets make it clear here.

Before: a max of 600 hours from school rotations; 900 hours from work outside of school

Now: 1500 hours from school rotations (number of rotations is still the same). Work outside of school is no longer required.

How is this not a major change?

This is derived from the June 18, 2014 minutes of the licensing committee meeting of the state board of pharmacy (link: http://www.pharmacy.ca.gov/meetings/minutes/2014/14_jun_lic.pdf). Scroll down to page 5. This is where the initial motion to move the legislation up the chain was started.

The previous law as it was written as of 2014 is listed here:

1728. Requirements for Examination. (a) Prior to receiving authorization from the board to take the pharmacist licensure examinations required by section 4200 of the Business and Professions Code, applicants shall submit to the board the following: (1) Proof of 1500 hours of pharmacy practice experience that meets the following requirements: (A) A minimum of 900 hours of pharmacy practice experience obtained in a pharmacy. (B) A maximum of 600 hours of pharmacy practice experience may be granted at the discretion of the board for other experience substantially related to the practice of pharmacy. (C) Experience in both community pharmacy and institutional pharmacy practice settings. (D) Pharmacy practice experience that satisfies the requirements for both introductory and advanced pharmacy practice experiences established by the Accreditation Council for Pharmacy Education.


Look at section D, the board explicitly states that the 1500 hours MUST satisfy IPPE/APPE practice experiences established by ACPE. That is the law before SB590, that this thread is referring to, passed. The BOP regulations already recognized IPPE/APPE rotational experience that met ACPE standards concurrently met CA intern hour requirements.

So that 900 outside of school/600 on rotations was not the law. It was 900 "in a pharmacy" and 600 "whatever else related experience. As long as you were in a physically licensed pharmacy doing something, it counts (provenance doesn't matter).
 
I was a tech for a year and an intern for another year. Honestly compared to rotations and school the only thing it helped me learn was memorizing brand/generic names and recognize some common dosing.

And that is far more beneficial than some people realize.

It boggles my mind at how many people pursue this, or other professions, and have ABSOLUTELY.NO.IDEA what its practitioners really do, until they graduate and get tossed out into the big bad real world. That was true when I was in school 25 years ago, although not quite as prevalent.

My brother works in IT, and he's also noticed the phenomenon of a large percentage of people graduating from college with NO work experience of any kind (and no, job shadowing doesn't count, mmmmmmkay?).
 
I don't care about the legal jargon. The bottom line is students no longer required to earn 900 hours from work outside of school. All 1500 hours are automatically earned from their rotations without having to complete additional rotations.
 
Addendum: Page 31 is where the detailed minutes are for the discussion of SB590:

http://www.pharmacy.ca.gov/meetings/agendas/2014/14_jun_lic_mat.pdf

Copy/pasted for your convenience (i'll format later, maybe):

Expert from the April 2014 Board Meeting

a. Summary of Presentation Made to Committee on Requirements for Intern Experience in ACPE Approved School of Pharmacy Curricula


The Licensing Committee was asked to review the requirements for reporting intern hours experience required of students enrolled in ACPE-approved schools of pharmacy. Chair Veale reported that on March 19th Dr. Vlasses provided a presentation on ACPE’s requirements for intern experience in ACPE-approved schools of pharmacy. Dr. Vlasses highlighted that ACPE accredited schools of pharmacy curricula must contain “real world” pharmacy experience. Dr. Vlasses also reviewed the process by which students shadow pharmacists and work in pharmacies to gain hands on practice experience.

Chair Veale stated that the committee was particularly concerned with the preceptor screening and evaluation process and the hands-on knowledge students gain while in pharmacy school.

Chair Veale explained that she would report on agenda item d before opening the floor to board and public comments under agenda item e.

b. Summary of Presentation by the California Schools of Pharmacy on the Intern Experience Earned by Students in California Schools of Pharmacy and the Reporting of Intern Hours to the California Board of Pharmacy

Chair Veale stated that over the years, the board has been asked to change the reporting of intern hours to eliminate the specific requirement that 900 hours be earned in a pharmacy. Historically, the board has not agreed that such a change is in the public interest.

Chair Veale provided that the committee heard testimony stating that it is difficult for students to gain additional intern hours outside of the curriculum, as many of the jobs historically held by interns are now being filled by technicians.

Chair Veale noted that deans from various schools of pharmacy asked the committee to change the intern requirement to deem any student who graduated from an accredited school of pharmacy after 2007 as having fulfilled his or her required intern hours.

Chair Veale reported that the committee asked legal counsel if a regulatory change would be required in order to accept the proposal as brought before the board. Mr. Santiago stated that a regulation change would be required to allow the schools to sign off on the entire 1500 hours. The committee also asked if the board could eliminate the 1500 hour requirement and simply require graduation from an ACPE accredited school. Mr. Santiago confirmed that the board could choose to go that avenue, and stated that doing so would require a statutory change.

c. Discussion and Possible Action to Update the Pharmacist Interns Hour Requirements from Business and Professions Code section 4209 and 16 California Code of Regulations Section 1728 and the Intern Hours Affidavit Form 17A-29

Chair Veale reported that at the committee meeting Jon Roth offered CPhA’s legislative support to make any statutory changes deemed necessary to change the reporting of pharmacy intern hours.

Chair Veale explained that it was the committee’s desire to ensure that intern hour requirements are the same for all graduates of an ACPE accredited pharmacy program. The committee asked board staff and counsel to ensure any statutory or regulatory changes made achieved equality in intern hour reporting requirements for both in-state and out-of-state applicants.

Chair Veale noted that at the committee meeting the comment was made that it is easier for an out of state graduate to receive approval to sit for the board’s exam. Mr. Santiago stated that at the committee meeting the comments were not addressed because there was no licensing staff present.

Ms. Herold responded that the board does not probe into if the out-of-state applicant was getting paid during their internship and staff validates that a pharmacist signed off on the hours.

Mr. Room asked if the committee envisioned that statute would require that as part of the application, and applicant would have to submit a form signed by the dean of the school certifying that they completed the intern hours required in the ACPE curricula.

Chair Veale responded that graduating from an accredited school essentially indicates that they completed the necessary intern hours, the committee was looking to staff to determine is a certificate from the dean was necessary.

Mr. Room warned that with compounding the board was previously willing to accept an accreditation body’s approval in place of a board license and the board has sense found that this was not sufficient.

Chair Veale responded that unlike compounding accreditation there is only one entity (ACPE) that accredits all schools of pharmacy. Additionally she stated that the committee felt that ACPE was better able to monitor the programs and preceptors.

Mr. Room expressed that the board must be willing to accept any changes to the hourly requirements they may deem fit in the future – for example if they lower the requirement to 500 hours.

Chair Veale agreed and commented that perhaps the board should create a floor that the hours could not go under.

Ms. Herold noted that the board would need to consider that there are foreign graduates who are currently required to complete a number of hours in the United States.

Chair Veale responded that the committee would not change that requirement. Ms. Herold asked to clarify it proof of graduation or a separate letter from the dean would be required to fulfill the intern hour requirement.

Chair Veale stated that those details could be sent back to the committee and staff to work-out.

President Weisser commented that he is uncomfortable handing over the process to ACPE and worries that the importance of gaining hands on experience may be lost.

Chair Veale commented that previously she felt the same way; however after hearing the various presentations she learned that ACPE really closely monitors the schools and the preceptors.

Mr. Law commented that the board needs to require that the schools meet a certain hour requirement so that the scenario that Mr. Room described earlier could not occur.

President Weisser remarked that over the years he has wondered how much of an emphasis the pharmacy schools place on graduating students who have an appreciation for practice in community pharmacies vs. clinical practice.

Mr. Law responded that in top pharmacy schools 30% of graduates work in clinical settings and 70% of graduates work in community pharmacies.

Ms. Butler commented that like President Weisser, she was previously concerned about students gaining experience in community settings. However after the committee meeting she felt assured that ACPE accredited schools give students experience in all settings.

Dr. Wong commented that knowledge gained in clinical settings can be used in community pharmacy settings.

President Weisser agreed. Steve Gray, representing CSHP, commented that there is a perceived discrepancy in the requirements for California applicants and out-of-state applicants. Currently California applicants must have their hours signed off by the pharmacist who did the training or PIC of the location where they worked, however out-of-state applicants do not have to submit the same documentation.

Dr. Gray clarified that even if the board does not choose accept graduation in place of intern hours; they should review the licensing processes to ensure that the requirements are being implemented equally for all applicants.

Dr. Gray also commented that CSHP is worried that current graduates of pharmacy schools are not entering the workforce practice ready and have a lack of maturity (no work experience). He noted that many schools use simulations rather than real experience.

Dr. Gray stated that ACPE is currently designing the new standards for accreditation and encouraged the board to participate in the process.

Dr. Gray concluded that it is very difficult for current students to gain intern hours outside of their school. Chair Veale asked Dr. Gray to clarify if CSHP supports the request made by the various schools of pharmacy to change the intern hour reporting.

Dr. Gray confirmed that CSHP was in support of the proposal. At the request of Mr. Schaad,

Dr. Gray provided an overview of the use of simulations used in schools of pharmacy. Ms. Herold clarified that every applicant, regardless of state, signs their application stating that they have completed 900 hours of practice experience under the direct supervision of a pharmacist.

Dr. Gray responded that the board requires California students to submit affidavits signed by the pharmacist that supervised them, while out-of-state applicants to not have to provide such documentation.

Dr. Gray clarified that the difference in documentation required by the board is why CSHP feels that California students are being held to higher standard.

Holly Strom, former board member, commented that many graduates leave school and are not ready for practice. She added that when she was a board member she attended an ACPE accreditation and was very impressed with the rigor that the schools are held to and encouraged current board members to attend them if possible.

Sam Shimomura, Associate Dean of Western University School of Pharmacy, commented that many times students go back to the location they completed the intern hours and the PIC or supervising pharmacist has left the pharmacy.

Dr. Shimomura added that Western University finds simulations to be a helpful educational tool and recommend that board consider adding a simulation portion to the CPJE. At the request of Mr. Law, Dr. Shimomura explained that of the approximately 140 graduates about 30-40 students choose to study clinical pharmacy and the rest study community pharmacy.

Dennis McAllister, representing ACPE, reported that the draft ACPE standards are now available for review online and they will be reviewed at the NABP meeting in Phoenix. Dr. McAllister explained that ACPE changed their standards to allow students have 30 of their experience hours to be gained via simulation; the remaining 1,710 must be done in a pharmacy.

President Weisser asked Dr. McAllister (who currently serves on the Arizona Board of Pharmacy) if they have issues with pharmacists not conducting patient consultations. Dr. McAllister responded lack of consultation is hard to quantify but seems to be a common problem in all states. He added that six or seven years ago the Arizona board took the stance that any issue that that resulted in the patient needed to file a complaint with the board or caused patient harm and could have been prevented by proper consultation, would result in an automatic fine.

Mr. Law asked Dr. McAllister thought that ACPE would ever lower the number of experience hours a student needs to complete prior to graduation.

Dr. McAllister responded that he does not anticipate ACPE would ever lower the hour requirement as they understand how important quality experience is to graduating practice ready pharmacists.

Representatives from the University of California San Francisco, University of San Diego, Touro University and the University of the Pacific expressed their support of the proposal to change the intern hour requirements as presented to the board. The representatives also provided the board with insight into the pharmacy experience gained while in the various schools.

John Garret, pharmacy student at the University of San Diego, provided the board with insight into the experience gained in school by current pharmacy students. He noted that students face new hardships including increase in tuition fees and a decrease in the number of jobs available.

Ms. Butler asked if the representatives felt that students left the schools ready to practice pharmacy. It was clarified that the students were ready to sit for the CPJE exam.

Sam Shimomura, Associate Dean of Western University School of Pharmacy, commented that their preceptors receive training and continuing education opportunities.

Dr. Shimomuro added that schools have been expanding the number of clerkship hours required for students.

Ms. Herold suggested that staff provide different options to the board at the next meeting.

Chair Veale asked that the board vote on the committee recommendation to change the requirements, and then if the motion passes board staff can provide options on how to implement the change.

Dr. Castellblanch commented that he would like to receive more options from board staff and discuss the item again at future meetings.

Chair Veale responded that members who would like to receive more options rather than accepting graduation from an ACPE accredited school should vote the motion down so that the discussion can go back to committee.

Committee Recommendation (Motion): Direct staff to work with counsel to develop any statutory and regulatory changes necessary so that graduating from an ACPE accredited school of pharmacy meets the intern hours requirement for the application to the CPJE exam. Support: 9 Oppose: 1 Abstain: 2
 
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I don't care about the legal jargon. The bottom line is students no longer required to earn 900 hours from work outside of school. All 1500 hours are automatically earned from their rotations without having to complete additional rotations.

Dude...they were NEVER required to earn 900 out of school. Never. That law never existed. Bottom line is...everything is the same.

EDIT: I think you'd appreciate the discussion in the mins i linked above.
 
I feel like this was just a great click bait buzzfeed worthy thread, It hooked me from the start.
 
That is funny. Everyone in class had to do it but apparently we all misunderstood. The laugh is on us!
 
Dude...they were NEVER required to earn 900 out of school. Never. That law never existed. Bottom line is...everything is the same.

EDIT: I think you'd appreciate the discussion in the mins i linked above.
Dude...they were NEVER required to earn 900 out of school. Never. That law never existed. Bottom line is...everything is the same.

EDIT: I think you'd appreciate the discussion in the mins i linked above.

They did when I was in school.... You went to school out of state, perhaps it was different for you. Here is the discussion from your link on this:

" Historically, the board has not agreed that such a change is in the public interest. Chair Veale provided that the committee heard testimony stating that it is difficult for students to gain additional intern hours outside of the curriculum, as many of the jobs historically held by interns are now being filled by technicians. Dr. Gray responded that the board requires California students to submit affidavits signed by the pharmacist that supervised them, while out-of-state applicants to not have to provide such documentation. Dr. Gray clarified that the difference in documentation required by the board is why CSHP feels that California students are being held to higher standard."

They use the terminology of "outside of the curriculum". My school on day 1 of our class: 900 hours can NOT be have any affiliation with the school, ie: rotations, health fairs, etc. You have to get it on your on and have it signed via paid job, volunteering, etc. CAN NOT COME FROM THE SCHOOL!!!!!!!!!!!!!!!! So, we all went to look for jobs. If you didn't have a job by p2, something wrong with you!!!!

BTW, Gray has ties to KGI and is/was president of CPhA, basically a huge sell out.
 
My brother works in IT, and he's also noticed the phenomenon of a large percentage of people graduating from college with NO work experience of any kind (and no, job shadowing doesn't count, mmmmmmkay?).

Because no one hires. Unpaid internships are for the privileged and well connected.

They did when I was in school.... You went to school out of state, perhaps it was different for you. Here is the discussion from your link on this:

" Historically, the board has not agreed that such a change is in the public interest. Chair Veale provided that the committee heard testimony stating that it is difficult for students to gain additional intern hours outside of the curriculum, as many of the jobs historically held by interns are now being filled by technicians. Dr. Gray responded that the board requires California students to submit affidavits signed by the pharmacist that supervised them, while out-of-state applicants to not have to provide such documentation. Dr. Gray clarified that the difference in documentation required by the board is why CSHP feels that California students are being held to higher standard."

They use the terminology of "outside of the curriculum". My school on day 1 of our class: 900 hours can NOT be have any affiliation with the school, ie: rotations, health fairs, etc. You have to get it on your on and have it signed via paid job, volunteering, etc. CAN NOT COME FROM THE SCHOOL!!!!!!!!!!!!!!!! So, we all went to look for jobs. If you didn't have a job by p2, something wrong with you!!!!

BTW, Gray has ties to KGI and is/was president of CPhA, basically a huge sell out.

The comments don't jive with the law as it is written -- it's interesting because I think we graduated the same time. I'm not sure why they think OOS applicants did not have to submit affidavits. The licensing paperwork was VERY clear the 17A-29 form needed to be filled out and submitted, I had to meet requirements same as an in-state student, so I was paper chasing preceptors (in addition to my outside employer).

Nowhere in the law does it ever mention "outside of the curriculum" so it's crystal clear that "in a pharmacy" means "in a pharmacy." What people think it says is their interpretation of the law, but I reread it again and nowhere is there mention of "outside the curriculum."

Anyone know if this changed even before this ruling/legislation came around? I'm talking like... 1990's regulations.
 
Addendum: Page 31 is where the detailed minutes are for the discussion of SB590:

http://www.pharmacy.ca.gov/meetings/agendas/2014/14_jun_lic_mat.pdf

Copy/pasted for your convenience (i'll format later, maybe):

Expert from the April 2014 Board Meeting

a. Summary of Presentation Made to Committee on Requirements for Intern Experience in ACPE Approved School of Pharmacy Curricula


The Licensing Committee was asked to review the requirements for reporting intern hours experience required of students enrolled in ACPE-approved schools of pharmacy. Chair Veale reported that on March 19th Dr. Vlasses provided a presentation on ACPE’s requirements for intern experience in ACPE-approved schools of pharmacy. Dr. Vlasses highlighted that ACPE accredited schools of pharmacy curricula must contain “real world” pharmacy experience. Dr. Vlasses also reviewed the process by which students shadow pharmacists and work in pharmacies to gain hands on practice experience.

Chair Veale stated that the committee was particularly concerned with the preceptor screening and evaluation process and the hands-on knowledge students gain while in pharmacy school.

Chair Veale explained that she would report on agenda item d before opening the floor to board and public comments under agenda item e.

b. Summary of Presentation by the California Schools of Pharmacy on the Intern Experience Earned by Students in California Schools of Pharmacy and the Reporting of Intern Hours to the California Board of Pharmacy

Chair Veale stated that over the years, the board has been asked to change the reporting of intern hours to eliminate the specific requirement that 900 hours be earned in a pharmacy. Historically, the board has not agreed that such a change is in the public interest.

Chair Veale provided that the committee heard testimony stating that it is difficult for students to gain additional intern hours outside of the curriculum, as many of the jobs historically held by interns are now being filled by technicians.

Chair Veale noted that deans from various schools of pharmacy asked the committee to change the intern requirement to deem any student who graduated from an accredited school of pharmacy after 2007 as having fulfilled his or her required intern hours.

Chair Veale reported that the committee asked legal counsel if a regulatory change would be required in order to accept the proposal as brought before the board. Mr. Santiago stated that a regulation change would be required to allow the schools to sign off on the entire 1500 hours. The committee also asked if the board could eliminate the 1500 hour requirement and simply require graduation from an ACPE accredited school. Mr. Santiago confirmed that the board could choose to go that avenue, and stated that doing so would require a statutory change.

c. Discussion and Possible Action to Update the Pharmacist Interns Hour Requirements from Business and Professions Code section 4209 and 16 California Code of Regulations Section 1728 and the Intern Hours Affidavit Form 17A-29

Chair Veale reported that at the committee meeting Jon Roth offered CPhA’s legislative support to make any statutory changes deemed necessary to change the reporting of pharmacy intern hours.

Chair Veale explained that it was the committee’s desire to ensure that intern hour requirements are the same for all graduates of an ACPE accredited pharmacy program. The committee asked board staff and counsel to ensure any statutory or regulatory changes made achieved equality in intern hour reporting requirements for both in-state and out-of-state applicants.

Chair Veale noted that at the committee meeting the comment was made that it is easier for an out of state graduate to receive approval to sit for the board’s exam. Mr. Santiago stated that at the committee meeting the comments were not addressed because there was no licensing staff present.

Ms. Herold responded that the board does not probe into if the out-of-state applicant was getting paid during their internship and staff validates that a pharmacist signed off on the hours.

Mr. Room asked if the committee envisioned that statute would require that as part of the application, and applicant would have to submit a form signed by the dean of the school certifying that they completed the intern hours required in the ACPE curricula.

Chair Veale responded that graduating from an accredited school essentially indicates that they completed the necessary intern hours, the committee was looking to staff to determine is a certificate from the dean was necessary.

Mr. Room warned that with compounding the board was previously willing to accept an accreditation body’s approval in place of a board license and the board has sense found that this was not sufficient.

Chair Veale responded that unlike compounding accreditation there is only one entity (ACPE) that accredits all schools of pharmacy. Additionally she stated that the committee felt that ACPE was better able to monitor the programs and preceptors.

Mr. Room expressed that the board must be willing to accept any changes to the hourly requirements they may deem fit in the future – for example if they lower the requirement to 500 hours.

Chair Veale agreed and commented that perhaps the board should create a floor that the hours could not go under.

Ms. Herold noted that the board would need to consider that there are foreign graduates who are currently required to complete a number of hours in the United States.

Chair Veale responded that the committee would not change that requirement. Ms. Herold asked to clarify it proof of graduation or a separate letter from the dean would be required to fulfill the intern hour requirement.

Chair Veale stated that those details could be sent back to the committee and staff to work-out.

President Weisser commented that he is uncomfortable handing over the process to ACPE and worries that the importance of gaining hands on experience may be lost.

Chair Veale commented that previously she felt the same way; however after hearing the various presentations she learned that ACPE really closely monitors the schools and the preceptors.

Mr. Law commented that the board needs to require that the schools meet a certain hour requirement so that the scenario that Mr. Room described earlier could not occur.

President Weisser remarked that over the years he has wondered how much of an emphasis the pharmacy schools place on graduating students who have an appreciation for practice in community pharmacies vs. clinical practice.

Mr. Law responded that in top pharmacy schools 30% of graduates work in clinical settings and 70% of graduates work in community pharmacies.

Ms. Butler commented that like President Weisser, she was previously concerned about students gaining experience in community settings. However after the committee meeting she felt assured that ACPE accredited schools give students experience in all settings.

Dr. Wong commented that knowledge gained in clinical settings can be used in community pharmacy settings.

President Weisser agreed. Steve Gray, representing CSHP, commented that there is a perceived discrepancy in the requirements for California applicants and out-of-state applicants. Currently California applicants must have their hours signed off by the pharmacist who did the training or PIC of the location where they worked, however out-of-state applicants do not have to submit the same documentation.

Dr. Gray clarified that even if the board does not choose accept graduation in place of intern hours; they should review the licensing processes to ensure that the requirements are being implemented equally for all applicants.

Dr. Gray also commented that CSHP is worried that current graduates of pharmacy schools are not entering the workforce practice ready and have a lack of maturity (no work experience). He noted that many schools use simulations rather than real experience.

Dr. Gray stated that ACPE is currently designing the new standards for accreditation and encouraged the board to participate in the process.

Dr. Gray concluded that it is very difficult for current students to gain intern hours outside of their school. Chair Veale asked Dr. Gray to clarify if CSHP supports the request made by the various schools of pharmacy to change the intern hour reporting.

Dr. Gray confirmed that CSHP was in support of the proposal. At the request of Mr. Schaad,

Dr. Gray provided an overview of the use of simulations used in schools of pharmacy. Ms. Herold clarified that every applicant, regardless of state, signs their application stating that they have completed 900 hours of practice experience under the direct supervision of a pharmacist.

Dr. Gray responded that the board requires California students to submit affidavits signed by the pharmacist that supervised them, while out-of-state applicants to not have to provide such documentation.

Dr. Gray clarified that the difference in documentation required by the board is why CSHP feels that California students are being held to higher standard.

Holly Strom, former board member, commented that many graduates leave school and are not ready for practice. She added that when she was a board member she attended an ACPE accreditation and was very impressed with the rigor that the schools are held to and encouraged current board members to attend them if possible.

Sam , Associate Dean of Western University School of Pharmacy, commented that many times students go back to the location they completed the intern hours and the PIC or supervising pharmacist has left the pharmacy.

Dr. added that Western University finds simulations to be a helpful educational tool and recommend that board consider adding a simulation portion to the CPJE. At the request of Mr. Law, Dr. Shimomura explained that of the approximately 140 graduates about 30-40 students choose to study clinical pharmacy and the rest study community pharmacy.

Dennis McAllister, representing ACPE, reported that the draft ACPE standards are now available for review online and they will be reviewed at the NABP meeting in Phoenix. Dr. McAllister explained that ACPE changed their standards to allow students have 30 of their experience hours to be gained via simulation; the remaining 1,710 must be done in a pharmacy.

President Weisser asked Dr. McAllister (who currently serves on the Arizona Board of Pharmacy) if they have issues with pharmacists not conducting patient consultations. Dr. McAllister responded lack of consultation is hard to quantify but seems to be a common problem in all states. He added that six or seven years ago the Arizona board took the stance that any issue that that resulted in the patient needed to file a complaint with the board or caused patient harm and could have been prevented by proper consultation, would result in an automatic fine.

Mr. Law asked Dr. McAllister thought that ACPE would ever lower the number of experience hours a student needs to complete prior to graduation.

Dr. McAllister responded that he does not anticipate ACPE would ever lower the hour requirement as they understand how important quality experience is to graduating practice ready pharmacists.

Representatives from the University of California San Francisco, University of San Diego, Touro University and the University of the Pacific expressed their support of the proposal to change the intern hour requirements as presented to the board. The representatives also provided the board with insight into the pharmacy experience gained while in the various schools.

John Garret, pharmacy student at the University of San Diego, provided the board with insight into the experience gained in school by current pharmacy students. He noted that students face new hardships including increase in tuition fees and a decrease in the number of jobs available.

Ms. Butler asked if the representatives felt that students left the schools ready to practice pharmacy. It was clarified that the students were ready to sit for the CPJE exam.

Sam Shimomura, Associate Dean of Western University School of Pharmacy, commented that their preceptors receive training and continuing education opportunities.

Dr. Shimomuro added that schools have been expanding the number of clerkship hours required for students.

Ms. Herold suggested that staff provide different options to the board at the next meeting.

Chair Veale asked that the board vote on the committee recommendation to change the requirements, and then if the motion passes board staff can provide options on how to implement the change.

Dr. Castellblanch commented that he would like to receive more options from board staff and discuss the item again at future meetings.

Chair Veale responded that members who would like to receive more options rather than accepting graduation from an ACPE accredited school should vote the motion down so that the discussion can go back to committee.

Committee Recommendation (Motion): Direct staff to work with counsel to develop any statutory and regulatory changes necessary so that graduating from an ACPE accredited school of pharmacy meets the intern hours requirement for the application to the CPJE exam. Support: 9 Oppose: 1 Abstain: 2

Great read especially about how pharmacy students are having a hard time finding internship sites outside of school. Hmm...I wonder why? Then all of these pharmacy school reps jumped in and supported getting rid of the 900 hours of internship hours.
 
That is funny. Everyone in class had to do it but apparently we all misunderstood. The laugh is on us!

I go to school in a different state but 50% of my school is from CA and they all want to go back. Many have been getting their hours signed off by their APPE preceptors. Are they committing fraud?
 
Dr Grey: students are having a hard time finding rotation sites!

Dr. Shimomura from Western: well duh! There used to be just 4 pharmacy schools and there are now 12.

Rep from UCSF: also blame it on USC because they increased the class size from 185 to 200!

Rep from UCSD: hey, we were put on probation because we didn't want to pay for sites like some new schools. So what if we continued to collect 4th year tuition! That is our money.

Rep from Touro: so what? We need these sites in order to get accredited.

Rep from UOP: let's get rid of this stupid 900 hours of internship requirement!

YEA! yes! Done! passed
 
Dr Grey: students are having a hard time finding rotation sites!

Dr. Shimomura from Western: well duh! There used to be just 4 pharmacy schools and there are now 12.

Rep from UCSF: also blame it on USC because they increased the class size from 185 to 200!

Rep from UCSD: hey, we were put on probation because we didn't want to pay for sites like some new schools. So what if we continued to collect 4th year tuition! That is our money.

Rep from Touro: so what? We need these sites in order to get accredited.

Rep from UOP: let's get rid of this stupid 900 hours of internship requirement!

YEA! yes! Done! passed

haha! Just glad that I am on the WesternU side 🙂
 
I go to school in a different state but 50% of my school is from CA and they all want to go back. Many have been getting their hours signed off by their APPE preceptors. Are they committing fraud?

No that is not fraud. The form and law is very clear.... in-school rotation hours count.

Though I've always wondered to myself what action the State of California can take against a pharmacist that has no ties, license, or anything within the state.
 
Dr Grey: students are having a hard time finding rotation sites!

Dr. Shimomura from Western: well duh! There used to be just 4 pharmacy schools and there are now 12.

Rep from UCSF: also blame it on USC because they increased the class size from 185 to 200!

Rep from UCSD: hey, we were put on probation because we didn't want to pay for sites like some new schools. So what if we continued to collect 4th year tuition! That is our money.

Rep from Touro: so what? We need these sites in order to get accredited.

Rep from UOP: let's get rid of this stupid 900 hours of internship requirement!

YEA! yes! Done! passed

lol. ok i laughed.
 
They use the terminology of "outside of the curriculum". My school on day 1 of our class: 900 hours can NOT be have any affiliation with the school, ie: rotations, health fairs, etc. You have to get it on your on and have it signed via paid job, volunteering, etc. CAN NOT COME FROM THE SCHOOL!!!!!!!!!!!!!!!! So, we all went to look for jobs. If you didn't have a job by p2, something wrong with you!!!!

Okay I did my best and this is the furthest back I can go:

2011: http://pharmacy.ucsd.edu/current/docs/intern_hours_affidavit.pdf
Still no mention of "outside of the curriculum."

2003: http://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=200320040SB1913
Still no mention of obtaining hours outside of a curriculum. In fact, the text is there stating that:

2003-2004 revisions to B&P 4200 said:
2003-2004 revisions to B&P 4200 said:
Section 4209 is added to the Business and Professions Code, to read:


4209.
(a) (1) An intern pharmacist shall complete 1,500 hours of pharmacy practice before applying for the pharmacist licensure examination.
(2) This pharmacy practice shall comply with the Standards of Curriculum established by the Accreditation Council for Pharmacy Education or with regulations adopted by the board.
(b) An intern pharmacist shall submit proof of his or her experience on board-approved affidavits, or another form specified by the board, which shall be certified under penalty of perjury by a pharmacist under whose supervision such experience was obtained or by the pharmacist-in-charge at the pharmacy while the pharmacist intern obtained the experience.
(c) An applicant for the examination who has been licensed as a pharmacist in any state for at least one year, as certified by the licensing agency of that state, may submit this certification to satisfy the required 1,500 hours of intern experience. Certification of an applicant’s licensure in another state shall be submitted in writing and signed, under oath, by a duly authorized official of the state in which the license is held.

So if there ever was a regulation, it predates 2003 (and the modern PharmD era), and that could explain why even some board members and your school are/were under the impression that outside hours are required.

EDIT: I searched back to 1999 (the furthest leginfo will go) for any amendments/proposals to amend B&P 4200 and nothing relating to intern hours.
 
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Our school (in Washington State) made it clear 300 hours had to be unpaid, outside of the curriculum hours when I graduated in 2011. Looking at the board website (well, 'commission' nowadays 😛 ) they seem to still be saying the same thing. Might just be state to state variation, but notable that there are only two schools here.

ImageUploadedBySDN1454974556.491626.jpg
 
Okay I did my best and this is the furthest back I can go:

2011: http://pharmacy.ucsd.edu/current/docs/intern_hours_affidavit.pdf
Still no mention of "outside of the curriculum."

2003: http://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=200320040SB1913
Still no mention of obtaining hours outside of a curriculum. In fact, the text is there stating that:



So if there ever was a regulation, it predates 2003 (and the modern PharmD era), and that could explain why even some board members and your school are/were under the impression that outside hours are required.

EDIT: I searched back to 1999 (the furthest leginfo will go) for any amendments/proposals to amend B&P 4200 and nothing relating to intern hours.

There was a restriction that only 600 hours of the 1500 hours could come from anything affiliated from the school.
Okay I did my best and this is the furthest back I can go:

2011: http://pharmacy.ucsd.edu/current/docs/intern_hours_affidavit.pdf
Still no mention of "outside of the curriculum."

2003: http://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=200320040SB1913
Still no mention of obtaining hours outside of a curriculum. In fact, the text is there stating that:



So if there ever was a regulation, it predates 2003 (and the modern PharmD era), and that could explain why even some board members and your school are/were under the impression that outside hours are required.

EDIT: I searched back to 1999 (the furthest leginfo will go) for any amendments/proposals to amend B&P 4200 and nothing relating to intern hours.

Seems to be a California pharmacy school occurrence, as you can see everyone who went to a CA school can attest to having to earn 900 hours outside of any school affiliation and maximum # of hours that a school could contribute was 600. As you can read from the meeting summary that you provided, school officials from CA had the same notion in 2014. I don't have the law book or an app from 5 years ago, however. here are some references that affirm this:
"California pharmacy students earn the 600 hours for school required experiential training (clinical clerkship)".
http://www.pharmacy.ca.gov/meetings/minutes/2006/06_mar_lic.pdf

I also have Fred Weissman's A Guide to California Community Law from 2009-2011, which i used to study. page 37 that describes requirements to get license.: "A maximum of 600 hours may be granted by the board through participation in internship and clerkship programs provided by a school of pharmacy"
 
Dr Grey: students are having a hard time finding rotation sites!

Dr. Shimomura from Western: well duh! There used to be just 4 pharmacy schools and there are now 12.

Rep from UCSF: also blame it on USC because they increased the class size from 185 to 200!

Rep from UCSD: hey, we were put on probation because we didn't want to pay for sites like some new schools. So what if we continued to collect 4th year tuition! That is our money.

Rep from Touro: so what? We need these sites in order to get accredited.

Rep from UOP: let's get rid of this stupid 900 hours of internship requirement!

YEA! yes! Done! passed

When you put it like that, this does sound like an awful decision.
 
There was a restriction that only 600 hours of the 1500 hours could come from anything affiliated from the school.


Seems to be a California pharmacy school occurrence, as you can see everyone who went to a CA school can attest to having to earn 900 hours outside of any school affiliation and maximum # of hours that a school could contribute was 600. As you can read from the meeting summary that you provided, school officials from CA had the same notion in 2014. I don't have the law book or an app from 5 years ago, however. here are some references that affirm this:
"California pharmacy students earn the 600 hours for school required experiential training (clinical clerkship)".
http://www.pharmacy.ca.gov/meetings/minutes/2006/06_mar_lic.pdf

I also have Fred Weissman's A Guide to California Community Law from 2009-2011, which i used to study. page 37 that describes requirements to get license.: "A maximum of 600 hours may be granted by the board through participation in internship and clerkship programs provided by a school of pharmacy"

I respect Weissman a great deal, but where the hell did that interpretation come from I wonder?

And how the hell have all these students I've worked with graduate and get licensed? I know many very well and clinical rotations were their only form of in pharmacy experience for CPJE qualification.

And why didn't the board force the pharmacist to delineate between rotation vs outside hours on the affidavit?

Seems like some students worked on one assumption and others on another set.
 
^^ I don't know why you keep on fighting this. It has been settled.
 
There was a restriction that only 600 hours of the 1500 hours could come from anything affiliated from the school.


Seems to be a California pharmacy school occurrence, as you can see everyone who went to a CA school can attest to having to earn 900 hours outside of any school affiliation and maximum # of hours that a school could contribute was 600. As you can read from the meeting summary that you provided, school officials from CA had the same notion in 2014. I don't have the law book or an app from 5 years ago, however. here are some references that affirm this:
"California pharmacy students earn the 600 hours for school required experiential training (clinical clerkship)".
http://www.pharmacy.ca.gov/meetings/minutes/2006/06_mar_lic.pdf

I also have Fred Weissman's A Guide to California Community Law from 2009-2011, which i used to study. page 37 that describes requirements to get license.: "A maximum of 600 hours may be granted by the board through participation in internship and clerkship programs provided by a school of pharmacy"


That link to the licensing committee minutes does not restrict the 900 hours "in a pharmacy" to extra-curricular time.

The 600 hours non-in-pharmacy hours is permissive. An applicant can complete 1500 hours "in a pharmacy" and not have to be concerned with the 600 hour allowance for non-pharmacy time.

Anyone with a more recent Weismann book want to check if that got updated recently?
 
^^ I don't know why you keep on fighting this. It has been settled.

No it hasn't, it means 2/3 of my students were being licensed without appropriate credentials if all these interpretations were correct.

Anyone with a brain can see that the law as written and the interpretations by some SOP's, Weismann, and some board members are not congruent.

I just wanna know where these assumptions came from. No one has posted actual law yet, just opinions.
 
There was a restriction that only 600 hours of the 1500 hours could come from anything affiliated from the school.
"

^^ I don't know why you keep on fighting this. It has been settled.

Okay so I'll turn the thread at this point since it becomes just a legal battle.

Are we all in agreement that the best pharmacists for the workforce complete their ~1700 hours of in-school clinical rotations and earn >1500 hours of actual, paid, work experience on top of that?
 
No it hasn't, it means 2/3 of my students were being licensed without appropriate credentials if all these interpretations were correct.

Anyone with a brain can see that the law as written and the interpretations by some SOP's, Weismann, and some board members are not congruent.

I just wanna know where these assumptions came from. No one has posted actual law yet, just opinions.

Obviously you are very good at researching legal documents.

Personally, I don't really care about seeing what was the law 2 years ago or care enough to search for it. Makes zero difference to me, i am already licensed. It would proly rank #1 on my list of biggest waste of time.

What's interesting to me is could the deans of the 4-6 CA schools and the current president of CA pharmacist association be wrong about the law, as you can clearly see based on what they said in your meeting summary? What about BOP officials and Weissman as seen in my examples? I guess anything is possible... To me and at this point, I'd rather turn to my attention to more important thing.

Anyhow, take care.
 
Personally, I don't really care about seeing what was the law 2 years ago or care enough to search for it. Makes zero difference to me, i am already licensed. It would proly rank #1 on my list of biggest waste of time.

Didn't you just do that though, 2 posts up?
 
Didn't you just do that though, 2 posts up?

I did a simple google search and looked in my only source of pharmacy law reference that I own. That's enough for me. At this point, looking into it further would classified as an immense waste of time.

My motivation for doing so was completely different than yours. I thought to myself am I completely wrong to have thought that 900 hours of interns hours have had to come from outside school's curriculum and made this up? The answer is an resounding no. The actual term used at the meeting that you provided a summary of had a dean use the same terminology, "outside of the curriculum". Heck, 4 other deans were under the same impression. The only distinctive law scholar that we have and the associate dean of USC wrote the same damn thing in his book. That's enough for me
 
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I can corroborate with the claims that rotation hours have been counted as part of the 1500 required hours to sit for the board exam.
I did in fact get my own hours, but I submitted rotation hours as well. The very original intention for this 1500 hour rule to include or not include rotation experience as already required by PharmD programs may very well have been lost by now, over years of unclear interpretation - which is why I suspect the (much needed) clarifcation by the BOP. But at least in the past, the BOP has, in practice, been allowing rotation hours to count towards the 1500 hours, intentional or not.
 
The problem was that APPEs might not actually be "in a pharmacy," i.e., related to distribution, not clinical pharmacy, not managed care, not drug manufacturing, not management. It is clear in these meeting minutes: http://www.pharmacy.ca.gov/meetings/minutes/2008/08_dec_lic.pdf

Under current law, an intern must possess 1,500 hours of intern experience under the supervision of a pharmacist before he or she can be made eligible to take the pharmacist licensure examinations.

More specifically, board regulations specify that a minimum of 900 hours of pharmacy experience must be earned under the supervision of a pharmacist in a pharmacy. The remaining 600 hours can be granted for experience under the supervision of a pharmacist substantially related to the practice of pharmacy, but not specifically within a pharmacy. California pharmacy students typically earn the 600 “discretionary” hours for school-required experiential training (clinical clerkship).

At the March 2006 Licensing Committee Meeting, pharmacy students from USC and other pharmacy schools presented a proposal requesting that the Board of Pharmacy amend its requirements that allow for an additional 400 hours (for a total of 1,000 hours of the required 1,500 hours required) which an intern can earn for pharmacy-related experience (under the supervision of a pharmacy) outside a pharmacy.

According to the students, opportunities for pharmacists have expanded beyond the traditional areas of community and hospital practice settings. Many students would like the opportunity to gain experience in the pharmaceutical industry, managed care, regulatory affairs and association management, but are unable to do so because they cannot earn intern hours for this experience, which impedes their experience as students and future development as pharmacists.

If a student got all of his IPPE and APPE experience in retail or in an institutional pharmacy, then it would be possible to have satisfied this requirement, but generally pharmacy programs do not allow this because of requirements to rotate in clinical pharmacy and am care, which are not in a pharmacy. This is why programs like UCSF told students to seek intern hours outside the curriculum in distribution settings ("in a pharmacy").
 
The problem was that APPEs might not actually be "in a pharmacy," i.e., related to distribution, not clinical pharmacy, not managed care, not drug manufacturing, not management. It is clear in these meeting minutes: http://www.pharmacy.ca.gov/meetings/minutes/2008/08_dec_lic.pdf



If a student got all of his IPPE and APPE experience in retail or in an institutional pharmacy, then it would be possible to have satisfied this requirement, but generally pharmacy programs do not allow this because of requirements to rotate in clinical pharmacy and am care, which are not in a pharmacy.

That's true. I never thought about that. I'm supposing rotations like FDA rotations or managed care/drug-policy type rotations would not be able to be counted, though I doubt that the BOP has the wherewithal to validate the hours signed off came from a bona fide pharmacy (inpatient/community/clinic etc.)
 
I respect Weissman a great deal, but where the hell did that interpretation come from I wonder?

You are not an attorney. Weissman is. He wrote the law book for heaven's sake. The minutes you posted supported this 900 hours of internship requirement. Why do you think the pharmacy schools got together and got this change if it wasn't a requirement in the first place?

Man, you are like one of those new graduates who focus on the smallest of details and miss the whole picture.
 
My out-of-state school told us that they would sign for the full 1500 hours to meet the CA requirements. If we didn't earn enough hours from interning, then we would have to pick our rotations accordingly to make sure that we were able to meet the 900 hour requirement in a pharmacy.

It seems that the rule of 900 hours outside of school applies only to students who have attended school in CA.
 
Or your school was just ignorant of California law
 
You are not an attorney. Weissman is. He wrote the law book for heaven's sake. The minutes you posted supported this 900 hours of internship requirement. Why do you think the pharmacy schools got together and got this change if it wasn't a requirement in the first place?

Man, you are like one of those new graduates who focus on the smallest of details and miss the whole picture.

He wrote the law book, not the law. The laws and forms are clear that 900 = "in a pharmacy " not "outside of a school of pharmacy."

Just because someone is a lawyer doesn't make their interpretation and opinion correct. Same with people talking at a meeting, no matter who it is.

What whole picture? I'm talking whole picture, not made up interpretations of laws that in-state schools have promulgated to their students. The only thing I can think of is if a school can't guarantee their clinical rotations will occur in a licensed pharmacy, hence the whole "go out and get it yourself" message.

It's clear as day on 17A-29, in a pharmacy, or not in a pharmacy? Check the box, and we're done.
 
That's true. I never thought about that. I'm supposing rotations like FDA rotations or managed care/drug-policy type rotations would not be able to be counted, though I doubt that the BOP has the wherewithal to validate the hours signed off came from a bona fide pharmacy (inpatient/community/clinic etc.)

The enforcement mechanism is that a pharmacist is stating, under penalty of perjury, that X student did the work in a pharmacy (or not in a pharmacy). However, not much State of CA can do to, say, a Maryland based pharmacist (who might not even be licensed, depending on work environment).
 
Hey check this out:

http://forums.studentdoctor.net/threads/california-pharmacist-license.710788

Someone quoted UCSF's website and they're clear that 900 in a pharmacy/600 related to pharmacy is the split, but that the school will sign off 600 while the 900 is up to the discretion of the preceptor if they want to declare under penalty of perjury that you did work in a pharmacy.

This is the text here:

The California Board of Pharmacy requires completion of 1,500 hours for licensure; 900 of which must be completed in licensed pharmacies (hospital and community). The other 600 of these internship hours may be completed in experiences substantially related to the practice of pharmacy.

Upon graduation, we will certify that you have completed 600 hours in experience substantially related to the practice of pharmacy. Students in the Pharmaceutical Care Pathway may earn up to 120 hours of intern experience for experiences associated with CP 147, the Community Pharmacy Practice APPE. Approval of intern hours for experiences in CP 147 is at the discretion of the precepto(r)
 
The enforcement mechanism is that a pharmacist is stating, under penalty of perjury, that X student did the work in a pharmacy (or not in a pharmacy). However, not much State of CA can do to, say, a Maryland based pharmacist (who might not even be licensed, depending on work environment).

I actually forgot that there's a field that requires the pharmacy license number, which non-pharmacy sites would not have anyways, so it should be a non-issue.

The real issue was confusion with preceptors whether or not rotation sites could sign off on hours. If you're a student who needed those rotation hours because you didn't have enough of your own outside of rotation and your preceptors interpreted pharmacy law to state that those hours had to come from non-clerkship experience, then you were screwed (I knew some students who this happened to). Yet on the other hand, if your preceptors did sign off on those hours, the BOP had no issue with it. So basically students were at the mercy of interpretation of unclear language, which is why this clarification was much needed.

Those saying that this clarification would remove the requirement for outside hours aren't entirely wrong - in effect, many students and preceptors had interpreted the language to mean that they needed outside hours as well, regardless of the true intention behind the language, thus forcing students to get those outside hours even though the clarification now lets us know that that wasn't the case.
 
I actually forgot that there's a field that requires the pharmacy license number, which non-pharmacy sites would not have anyways, so it should be a non-issue.

The real issue was confusion with preceptors whether or not rotation sites could sign off on hours. If you're a student who needed those rotation hours because you didn't have enough of your own outside of rotation and your preceptors interpreted pharmacy law to state that those hours had to come from non-clerkship experience, then you were screwed (I knew some students who this happened to). Yet on the other hand, if your preceptors did sign off on those hours, the BOP had no issue with it. So basically students were at the mercy of interpretation of unclear language, which is why this clarification was much needed.

Those saying that this clarification would remove the requirement for outside hours aren't entirely wrong - in effect, many students and preceptors had interpreted the language to mean that they needed outside hours as well, regardless of the true intention behind the language, thus forcing students to get those outside hours even though the clarification now lets us know that that wasn't the case.

Ahh beautifully explains de facto vs. de jure.
 
Except that rule doesn't exist, it never existed.

There have been at least two students who said that their schools (both located in CA) would provide only a certain number of hours. The students had to make up the remaining hours through paid work or volunteering.
 
No it hasn't, it means 2/3 of my students were being licensed without appropriate credentials if all these interpretations were correct.
Ah, good, a temporary fix to the oversupply: dozens of pharmacists with invalid licenses!

NY had no such requirement, but if you had enough intern hours you could take the Part 3 exam during your P3 year, or early P4 year rather than after graduation. If not, no biggie, we did over 1600 APPE hours anyway, in addition to IPPE.
 
I don't see how this is a problem, as Confetti points out, the hours are still there, they are coming from rotations. Many states have & always have had less than 1500 hours. When I graduated in IL, only 600 hours were needed, and rotations (externships as they were called back then) the last semester of pharmacy school satisfied those 600 hours. Out of curiosity I checked current IL requirements, and they are 1200 hours (which rotations satisfy.) I just can't see CA's change as some sinister move.
 
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