Pharmacy Technicians Rules - ORR 2022-02 LR  
Public Comment Summary  
Rules Committee’s Recommendations and Board Decisions regarding April 6, 2023, Public Comments  
Testimony/Comments Received:  
Rose Baran, Ferris  
Deeb Eid, CVS Pharmacy  
Farah Jalloul, Michigan Pharmacists Association  
Jonathan McLachlan, AllianceRx Walgreens Pharmacy  
Charlie Mollien, Meijer  
Renee Smiddy, Michigan Health & Hospital Association  
Maria Young, University Pharmacy  
Rule 338.3651a  
Rule Numbers  
Section (2)  
Pharmacy Technician Licensure; eligibility; examination.  
Commenter  
Jalloul  
Comment  
Change the reference to R 338.7005 to R 338.7004, as R 338.7005 has been rescinded.  
Rules Committee The Rules Committee agrees with the comment to update the reference to the General Rules.  
Response  
Board Response  
The Board agrees with the comment to update the reference to the General Rules.  
R 338.3651a Pharmacy technician licensure; eligibility; examination.  
Rule 1a. (1) An applicant for licensure by examination shall submit a completed application on a form provided by the  
department, together with the appropriate fee, unless the applicant is exempt from filing under any of the following  
exemptions pursuant to section 17739a(4) of the code, MCL 333.17739a:  
(a) A student, while the student is enrolled in a pharmacy technician program approved by the board under R 338.3655.  
(b) A licensee who holds a temporary pharmacy technician license under R 338.3652 and section 17739b of the code, MCL  
333.17739b.  
(c) A licensee who holds a limited pharmacy technician license under section 17739c of the code, MCL 333.17739c.  
May 3, 2023  
(2) In addition to meeting the requirements of R 338.7001 to R 338.7005 338.7004, any other rule promulgated under the  
code, and section 16174 of the code, MCL 333.16174, an applicant shall comply with all of the following requirements:  
(a) Have graduated from an accredited high school or comparable school or educational institution or passed the general  
educational development test or the graduate equivalency examination.  
(b) Have passed, and provided proof to the department of passing, any of the following examinations:  
(i) The certified pharmacy technician examination given by the PTCB or the NHA.  
(ii) A nationally recognized and administered pharmacy technician certification examination that has been approved by the  
board under R 338.3654.  
(iii) An employer-based training program examination that has been approved by the board under R 338.3654.  
(c) An applicant shall submit proof of having completed the 1-time training in identifying victims of human trafficking as  
required in R 338.3659 and section 16148 of the code, MCL 333.16148.  
Rule 338.3653  
Rule Numbers  
Section (2)  
Licensure by endorsement.  
Commenter  
Comment  
Change the reference to R 338.7005 to R 338.7004, as R 338.7005 has been rescinded.  
Jalloul  
Rules Committee The Rules Committee agrees with the comment to update the reference to the General Rules.  
Response  
Board Response  
The Board agrees with the comment to update the reference to the General Rules.  
R 338.3653 Licensure by endorsement.  
Rule 3. (1) An applicant who has never held a pharmacy technician license in this state, but who is licensed in another state,  
may apply for licensure by endorsement shall by submitsubmitting a completed application on a form provided by the department,  
together with the requisite fee.  
(2) An applicant is presumed to meet the requirements of section 16186 of the code, MCL 333.16186, who meets if they meet  
the requirements of R 338.7001 to R 338.7005 338.7004, any other rule promulgated under the code, and section 16174 of the  
code, MCL 333.16174, as well as all of the following requirements: of this rule is presumed to meet the requirements of section  
16186 of the code, MCL 333.16186.  
(2) An applicant shall satisfy all of the following requirements:  
(a) HaveHas graduated from an accredited high school or comparable school or educational institution, or passed the general  
educational development test or the graduate equivalency examination.  
2
(b) SatisfySatifies the requirements in section 16174(2) of the code, MCL 333.16174, which includes verification from the issuing  
entity showing that disciplinary proceedings are not pending against the applicant and sanctions are not in force at the time of  
application.  
(c) HoldHolds a pharmacy technician license or registration by examination in another state that is active and in good standing.  
(d) SubmitSubmits proof that the applicant passed 1 of the approved examinations specified in R 338.3651a(2)(b).  
(e) Submits proof of having completed the 1-time training in identifying victims of human trafficking as required in R 338.3659  
and section 16148 of the code, MCL 333.16148.  
(3) In addition to meeting the requirements of subrules (1) and (2) of this rule, an applicant’s license must be verified, on a form  
provided by the department, by the licensing agency of any state in which the applicant holds a current license or ever held a license as  
a pharmacy technician. Verification must be sent directly to the department from the licensing agency and include the record of any  
disciplinary action taken or pending against the applicant.  
(f) Discloses each license, registration, or certification in a health profession or specialty issued by another state, the United  
States military, the federal government, or another country on the application form.  
Rule 338.3654  
Rule Numbers  
Section (2)  
Examination requirements; board approval; approval process.  
Commenter  
Comment  
Young  
Require employer based training program examinations that are submitted to the Board for  
approval under MCL 333.17739a(1)(d)(iv) to include 100 questions, to have a larger assortment of  
questions in each category, and no true or false questions.  
The reason for the request is to prepare students to take the national exams and be prepared for the  
time allotted. Both national exams (PTCE and ExCPT) have 100 questions and are timed.  
MCL 333.17739a(1)(d)(iv)  
(iv) An employer-based training program examination that is approved by the board and covers job  
descriptions, pharmacy security, commonly used medical abbreviations, routes of administration,  
product selection, final check by pharmacists, guidelines for the use of pharmacy technicians,  
pharmacy terminology, basic drug information, basic calculations, quality control procedures, state  
and federal laws and regulations regarding pharmacy technician duties, pharmacist duties,  
pharmacy intern duties, prescription or drug order processing procedures, drug record-keeping  
requirements, patient confidentiality, and pharmacy security and drug storage.  
3
Section (2)  
Section (8)  
Young  
Eid  
Can a program that has a Board approved examination offer the examination to someone who is not  
in the pharmacy’s program but holds a temporary license? Or is a board approved pharmacy  
program only allowed to give their examination to students in their program? The rule states, “An  
employer-based training program proficiency examination must be offered in association with a  
specific employer-based training program … .”  
CVS Health recommends that number (8) in Rule 4 be struck from the proposed rules.  
Rationale: Referencing national standards, exams such as the PTCB or NHA certification exams  
no longer use percentile-based scoring. More modern-day psychometric standards call for scaled  
scoring where a passing percentage is not stagnant. Holding other “board approved proficiency  
exams” to an arbitrary 70% standard is not consistent with other parts of the regulation which allow  
for national standards. To fall in line with these standards, it is suggested to remove and not include  
an arbitrary passing % number that is not backed by evidence or examination standards nationally.  
Rules Committee (2): The Rules Committee does not agree with the comment to require pharmacy technician program examinations to  
Response  
include a minimum of 100 questions and not include T/F questions, as the decision was previously made by the Board to  
not require a minimum number of questions and instead require questions pertinent to the practice of pharmacy as  
determined by the pharmacy.  
The Rules Committee believes that clarification of who may sit for a pharmacy technician proficiency examination is not  
necessary as section (2) already states that a proficiency examination must be offered with a specific program.  
Therefore, only students who are in the pharmacy training program may take the associated pharmacy training program  
examination.  
(8): The Rules Committee agrees with the comment to delete (8) as the Rules Committee is concerned that the program  
has a scoring process in place, not that it has a specific minimum score. The Rules Committee has added language that  
clarifies a pharmacy technician program must include a proficiency examination scoring procedure with their proficiency  
examination application, which will be reviewed with the examination.  
Board Response  
(2): The Board does not accept the comment to require examinations to include a minimum of 100 questions  
and not include T/F questions, as the Board is concerned that the questions are pertinent to the practice of  
pharmacy and not as concerned with the number of questions.  
4
The Board does not accept the comment that clarification of who may sit for a pharmacy technician proficiency  
examination is necessary as section (2) already states that a proficiency examination must be offered with a  
specific program. Therefore, only students who are in the pharmacy training program may take the associated  
pharmacy training program examination.  
(8): The Board accepts the comment to delete (8) and adds rule language that a pharmacy technician program  
must include a proficiency examination scoring procedure with their proficiency examination application, which  
will be reviewed by the Board with the examination, as the Board is concerned that the program has a scoring  
process in place, not that it has a specific minimum score.  
R 338.3654 Examination requirements; board approval; approval process.  
Rule 4. (1) Except for the PTCB and NHA examinations, a nationally recognized pharmacy technician proficiency certification  
examination and an employer-based training program proficiency examination must be approved by the board.  
(2) An employer-based training program proficiency examination must be offered in association with a specific employer-based  
training program and cover the topics specified in section 17739a(1)(d)(iv) of the code, MCL 333.17739a.  
(3) An entity that offers a nationally recognized pharmacy technician proficiency certification examination shall submit to the  
department a completed application on a form provided by the department with proof of current national accreditation in order to be  
approved by the board. If the examination is nationally accredited, after the department processes the application, it shallmust be  
considered approved by the board. If national accreditation is lost, the examination will no longer be approved by the board.  
(4) An entity that offers an employer-based training program proficiency examination shall submit to the department a completed  
application on a form provided by the department and a copy of the examination with the correct answers clearly identified for each  
question.  
(5) An entity that offers an employer-based training program proficiency examination shall submit a modification to a proficiency  
examination during its approval term to the department on a form provided by the department pursuant to the requirements of this rule.  
(6) Beginning July 1, 2022, Except for PTCB and NHA, a nationally recognized certification proficiency examination or employer-  
based training program proficiency examination approved by the board before July 1, 2022, shall submit an application consistent with  
this rule for approval by December 31, 2023, or the program will no longer be listed as a board-approved program.  
(7) Beginning July 1, 2022, the The board’s approval of an examination expires 5 years after the date of approval.  
(8) One year after the effective date of this subrule, a board-approved program must include a proficiency examination  
grading procedure with the proficiency examination application. proficiency examination must have a minimum passing score  
of 70%.  
5
Rule 338.3655  
Rule Numbers  
Section (2)(a)  
Approved pharmacy technician programs.  
Commenter  
Comment  
Young  
Young  
Smiddy  
Mollien  
Should the Board require a program at a community college, which is being added to the rules, to  
be accredited and approved automatically, or treat it similarly to a program at a proprietary school,  
and require the program to be reviewed by the Board?  
Section (3)  
Section (6)  
Section (7)  
The requirements for a training program at a proprietary school and community college do not  
mention a hands-on teaching component. Can a proprietary school or community college place  
students in a pharmacy for hands-on training under the supervision of the pharmacist?  
The MHA requests clarification regarding R 338.3655 (6) A student in a board-approved pharmacy  
technician program is exempt from, and not eligible for, licensure while in the program. Will  
students still be eligible to receive temporary licenses while in a training program?  
I support allowing those less than age 18 to enroll in board-approved pharmacy technician training  
programs. If the board adopts this rule change, please work with the Department of Labor and  
Economic Opportunity to change the listed prohibition for individuals aged 16 or 17 to work in  
“Pharmacies and Prescription Drug Delivery” work activities. I also recommend you change this  
rule to align with DLEO to only permit individuals 16 or 17 years old to participate in practical  
training in the pharmacy.  
See https://www.michigan.gov/leo/-  
/media/Project/Websites/leo/Folder23/whd_9934_Youth_Employment_Hazardous_Table.pdf?re  
v=4a03c2e42cb1420082df1f738b50129b&hash=3EB19CA5DD2240849A407FA0D68D52EAfor  
Work Activities Prohibited or Restricted by Department Review under MCL409.103.  
The MHA requests clarification regarding R 338.3655 (7) and how to define practical training.  
Smiddy  
Smiddy  
Section (8)  
The MHA recommends the board clarify the reasoning for requiring all existing board approved  
pharmacy technician programs to be rereviewed by the board before December 31, 2023. To reduce  
unnecessary administrative burden, especially during the unwinding of the COVID-19 public health  
emergency, the MHA recommends pharmacy technician programs be reevaluated within one-  
year of the rules set promulgation date. This will allow program administrators and community  
partners additional time to communicate the reevaluation timeframe with stakeholders.  
6
Section (9)  
Mollien  
Mollien  
Clarify the how the program has an opportunity to demonstrate the program is not deficient with  
the board, not just the Department.  
Does this rule mean new students are prohibited from enrolling in the program? Only students who  
completed the program, but are not yet licensed are eligible for licensure? Will students enrolled,  
but who have not completed the program that is withdrawn approval be considered displaced? The  
rule is unclear on what happens.  
Section (10)  
Young  
Under what circumstances would the Board allow a student to take the examination in a program if  
the Board has withdrawn approval?  
Rules Committee (2)(a): The Rules Committee does not believe clarification is necessary regarding the application process for community  
Response  
colleges, as (1)(b) already allows an education program that is accredited by ASHP/ACPE or by an agency accredited by  
the United States Department of Education to be approved administratively. If an education program is not accredited, it  
must be reviewed by the Board under (2).  
(3): The Rules Committee does not believe that the rules should address a hands-on component for programs as the Code  
does not require a hands-on component. It is up to the community college or proprietary school if they want to include a  
hands-on component in their program.  
(6): The Rules Committee agrees with the comment that (6) should be clarified by deleting “and not eligible for” to  
clarify that a student in a pharmacy program can get a temporary license.  
(7): The Rules Committee agrees with the comment to modify the provision to limit the provision to allow those  
individuals 16 years or older to participate in training in a pharmacy and agrees that “practical training” should be  
clarified to “practical hands-on training.” The Rules Committee noted that there are employment limitations regarding  
minors and pharmacies must follow those limitations.  
(8): The Rules Committee agrees with the comment that the date to require reevaluation of a program should be delayed  
until 1 year after promulgation of the rules to give programs more time to adjust to any new requirements in the rules.  
(9): The Rules Committee agrees with the comment that the rules needs clarification so it is clear that if the Department  
determines that the deficiencies are not resolved, that the Board will determine if the deficiencies exist and if approval  
should be withdrawn.  
(10): The Rules Committee does not agree that the comments that the rule needs clarification, as a student can not  
continue in a program if the program is closed. In addition, the last provision of the rule states that a student can sit for  
an approved licensure examination. This means that they can sit for a licensure examination other than the one offered  
by the closed program. A closed program can not offer their examination.  
7
Board Response  
(2)(a): The Board does not accept the comment that clarification is necessary regarding the application process  
for community colleges, as (1)(b) already allows an education program that is accredited by ASHP/ACPE or by  
an agency accredited by the United States Department of Education to be approved administratively. If an  
education program is not accredited, it must be reviewed by the Board under (2).  
(3): The Board does not accept the comment that the rules should address a hands-on component for programs as  
the Code does not require a hands-on component. It is up to the community college or proprietary school if they  
want to include a hands-on component in their program.  
(6): The Board accept the comment that (6) should be clarified by deleting “and not eligible for” to clarify that a  
student in a pharmacy program can get a temporary license.  
(7): The Board accepts the comment to allow those individuals 16 years or older to participate in training in a  
pharmacy and agrees that “practical training” should be clarified to “practical hands-on training.” The Board  
noted that there are employment limitations regarding minors and pharmacies must follow those limitations as  
well as be aware that a minor may finish a program before they are able to qualify for a license at 18.  
(8): The Board accepts the comment that the date to require reevaluation of a program should be delayed until 1  
year after promulgation of the rules to give programs more time to adjust to any new requirements in the rules.  
(9): The Board accepts the comment that if the Department determines that the deficiencies are not resolved that  
the Board will determine if the deficiencies exist and if approval should be withdrawn.  
(10): The Board does not accept the comment that clarification is needed to this rule, as a student cannot  
continue in a program if the program is closed. In addition, the last provision of the rule states that a student can  
sit for an approved licensure examination. This means that they can sit for a licensure examination other than  
the one offered by the closed program. A closed program cannot offer an examination.  
R 338.3655 Approved pharmacy technician programs.  
Rule 5. (1) The following pharmacy technician programs are considered board-approved after a completed application on a form  
provided by the department along with proof of accreditation is submitted to and reviewed by the department:  
(a) A pharmacy technician program including an employer-based training program that is accredited by the American Society of  
Health-System Pharmacists/Accreditation Council for Pharmacy Education ASHP/ACPE Pharmacy Technician Accreditation  
Commission (ASHP/ACPE).  
(b) A pharmacy technician program that is offered by an education program that is accredited by the ASHP/ACPE Pharmacy  
Technician Accreditation Commission or by an agency accredited by the United States Department of Education.  
8
(2) If eitherany of the following pharmacy technician programs do not meet the requirements in subrule (1) of this rule, the program  
may apply for board approval by submitting an application to the department on a form provided by the department, along with an  
attestation form that verifies compliance with the information required in subrule (3) of this rule.:  
(a) A comprehensive curriculum-based pharmacy technician education and training program conducted by a community college  
under the community college act of 1966, 1966 PA 331, MCL 389.1 to 389.195 or a school that is licensed pursuant tounder the  
proprietary schools act, 1943 PA 148, MCL 395.101 to 395.103.  
(b) A pharmacy technician training program utilized by a pharmacy that includes training in the functions, specified in section  
17739(1) of the code, MCL 333.17739, and R 338.3665, required to assist the pharmacist in the technical functions associated with the  
practice of pharmacy.  
(3) The contents of the training programs offered under subrule (2) of this rule must include all of the following:  
(a) The duties and responsibilities of the pharmacy technician and a pharmacist, including the standards of patient confidentiality,  
and ethics governing pharmacy practice.  
(b) The tasks and technical skills, policies, and procedures related to the pharmacy technician’s position pursuant to the duties  
specified in section 17739(1) of the code, MCL 333.17739, and R 338.3665.  
(c) The pharmaceutical-medical terminology, abbreviations, and symbols commonly used in prescriptions and drug orders.  
(d) The general storage, packaging, and labeling requirements of drugs, prescriptions, or drug orders.  
(e) The arithmetic calculations required for the usual dosage determinations.  
(f) The essential functions related to drug, purchasing, and inventory control.  
(g) The recordkeeping functions associated with prescriptions or drug orders.  
(4) The pharmacy technician program shall maintain a record of a student’s pharmacy technician training and education, specified in  
this rule, for 3 years after a student completes or leaves the program, whichever is earlier, that must include all of the following:  
(a) The full name and date of birth of the pharmacy technician student.  
(b) The starting date of the pharmacy technician program and date the student successfully completed the program.  
(c) The program syllabus and activities performed in the program.  
(5) A student shall complete a board-approved pharmacy technician program within 2 years of beginning the program in order to  
maintain his or herthe student’s exemption from licensure in subrule (6) of this rule, and R 338.3651a.  
(6) A student in a board-approved pharmacy technician program is exempt from, and not eligible for, licensure while in the program.  
(7) A student who is less than 18 at least 16 years of age, in a board-approved pharmacy technician program, may participate  
in practical hands-on training in the pharmacy.  
(78) Beginning July 1, 2022, a A pharmacy technician program that was board approved before July 1, 2022, mustshall reapply and  
meet the requirements of this rule by December 31, 2023, no later than 1 year after these rules are promulgated, or the program  
9
will no longer be listed as a board-approved program. Beginning July 1, 2022, theThe board’s approval of a program expires 5  
years after the date of approval. After 5 years, upon review by the department, a pharmacy technician program may be reapproved if it  
has maintained its accreditation.  
(9) 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.  
(10) 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.  
Rule 338.3662  
Rule Numbers  
Section (f)  
Format of acceptable continuing education for licensees.  
Commenter  
Comment  
Smiddy  
The MHA supports the proposal to allow students enrolled in a pharmacy technician program who  
are less than 18 years of age to train in a pharmacy, and the MHA also supports adding the 70%  
passing score of a board-approved proficiency exam. However, the MHA has concerns regarding  
the proposal to reduce the maximum allowable continuing education (CE) hours earned outside of a  
licensee’s regular job description from 10 hours to 2 hours. The MHA recognizes the good  
intentions in limiting CEs outside of one’s job description, but the MHA opposes the proposed  
change based on the feasibility of enforcing the rule and the negative repercussions of  
pharmacy technicians self-selecting to limit growth and education opportunities to meet this  
requirement.  
Rules Committee The Rules Committee does not agree with the comment that a licensee should be able to earn up to 10 hours of credit for  
Response  
presenting a CE program that is not a regular part of their job description because they should only get credit for  
presenting the program once, otherwise they are receiving credit for the same activity multiple times in 1 renewal cycle.  
Board Response  
The Board does not accept the comment that a licensee should be able to earn up to 10 hours of credit for  
presenting a CE program that is not a regular part of their job description. A licensee should only get credit for  
presenting the program once, otherwise they are receiving credit for the same activity multiple times in 1  
renewal cycle.  
10  
R 338.3662 Format of acceptable continuing education for licensees.  
Rule 12. Effective for applications for renewal that are filed for the renewal cycle that begins 1 year or more after the effective  
date of this subrule, the The board shall consider all of the following as acceptable continuing education:  
FORMAT OF ACCEPTABLE CONTINUING EDUCATION ACTIVITIES  
Type of Activity  
Number/Maximum Hours  
Earned  
(a) Completion of an approved continuing  
education course or program related to the  
The number of continuing  
education hours earned will be the  
practice of pharmacy. A continuing education number of hours approved by the  
course or program is approved, regardless of  
the format in which it is offered, if it is  
approved or offered for continuing education  
credit by any of the following:  
sponsor or the approving  
organization.  
If the activity was not approved  
for a set number of hours, then 1  
credit hour for every 50 minutes of  
participation may be earned.  
A pharmacy program accredited by  
the ASHP/ACPE Pharmacy  
Technician Accreditation  
Commission or the Canadian Council  
for Accreditation of Pharmacy  
Programs (CCAPP).  
No limitation on the number of  
hours earned.  
A continuing education sponsoring  
organization, institution, or individual  
approved by the ASHP/ACPE.  
Another state board of pharmacy.  
If audited, a licensee shall submit to the  
department a copy of a letter or certificate of  
completion showing the licensee’s name,  
number of continuing education hours  
11  
earned, sponsor name or the name of the  
organization that approved the program or  
activity for continuing education credit, and  
the date on whichthat the program was held,  
or activity completed.  
(b) Completion of pharmacy practice or  
administration courses offered for credit in a  
pharmacy program accredited by the  
Twelve hours of continuing  
education will be credited for each  
academic quarter credit earned and  
18 hours will be credited for each  
academic semester credit earned.  
ASHP/ACPE Pharmacy Technician  
Accreditation Commission or the CCAPP.  
If audited, a licensee shall submit to the  
department an official transcript that reflects  
completion of the postgraduate pharmacy  
practice or administration course and number  
of semester or quarter credit hours earned.  
No limitation on the number of  
hours earned.  
(c)  
Participation in a home study program  
offered through an ASHP/ACPE-approved  
provider or other instructional approaches  
that include an evaluation component  
including, but not limited to, on-lineonline  
continuing education programs and journal  
articles.  
One hour of continuing  
education will be earned for each  
hour devoted to a home study  
program.  
A maximum of 20 hours may be  
earned per renewal period.  
If audited, a licensee shall submit to the  
department an affidavit attesting to the  
number of hours the licensee spent  
participating in the home study program that  
includes a description of the activity.  
(d) Renewal of a pharmacy technician license  
held in another state that requires continuing  
Twenty hours of continuing  
education will be earned.  
12  
education for license renewal that is  
substantially equivalent in subject matter and A maximum of 20 hours may be  
total amount of required hours to that  
required in these rules if the licensee resides  
and practices in another state.  
earned in each renewal period.  
If audited, a licensee shall submit to the  
department proof of current licensure in  
another state and a copy of a letter or  
certificate of completion showing all of the  
following: the licensee’s name, number of  
continuing education hours earned, the  
sponsor’s name or the name of the  
organization that approved the program or  
activity for continuing education credit, and  
the date on whichthat the program was held  
or the activity was completed.  
(e) Initial publication of an article or a chapter  
related to the practice of pharmacy in either  
of the following:  
Ten hours of continuing  
education will be earned per  
publication.  
A pharmacy textbook.  
A maximum of 10 continuing  
education hours may be earned in  
each renewal period.  
A peer reviewedpeer-reviewed  
journal.  
If audited, a licensee shall submit to the  
department a copy of the publication that  
identifies the licensee as the author or a  
publication acceptance letter.  
(f) Presentation of a continuing education  
program approved by the board under R  
Two continuing education hours  
will be earned for every 50  
338.3663 or subdivision (a) of this rule that is minutes devoted to presenting the  
13  
not a part of the licensee’s regular job  
description.  
program.  
A maximum of 102 hours may be  
earned in each renewal period.  
This change is effective starting  
If audited, a licensee shall submit to the  
department a copy of the curriculum and a  
letter from the program sponsor verifying the with the next full license cycle  
length and date of the presentation.  
(g) Attendance at a pharmacy-related program,  
that is approved by the board pursuant to R  
338.3663.  
after promulgation of this rule.  
The number of continuing  
education hours earned will be the  
number of hours approved by the  
sponsor or the approving  
If audited, a licensee shall submit to the  
department a copy of a letter or certificate of  
completion showing the licensee’s name,  
organization.  
If the activity was not approved  
number of hours earned, sponsor name or the for a set number of hours, then 1  
name of the organization that approved the  
program or course for continuing education  
credit, and the date on whichthat the program  
was held or the activity was completed.  
credit hour for every 50 minutes of  
participation may be earned.  
No limitation on the number of  
hours earned.  
Rule 338.3665  
Rule Numbers  
Section (b)(ii)(A)  
Performance of activities and functions; delegation.  
Commenter  
Baran  
Comment  
Do not delete “limited.”  
The limited license technician is not equivalent to a full pharmacy technician license because the  
limited license technician was exempt form the examination requirement required for a full license  
pharmacy technician and was also exempt from providing proof of graduating from an accredited  
high school or comparable school or that they passed the general educational development test or  
other graduate equivalency examination. They are also restricted to act as a pharmacy technician  
only at the pharmacy they were employed at on December 22, 2014. If the employer operates  
14  
multiple pharmacies than at any of the employer locations in Michigan.  
There are over 1000 limited pharmacy technicians according to the Department’s count as of  
December 6, 2022. Limited pharmacy technicians are no longer granted because of the restrictions  
placed in 333.17739c.  
Section (b)(ii)(B)  
and (B)(1)  
Baran  
(b)(ii)(B)(1): Change to “holds a current full pharmacy technician license only” (The basis for the  
comment is above.)  
(b)(ii)(B): Change “1 of the following” to “all of the following requirements.”  
Allowing an individual to meet either (B)(1) or (2) allows an individual to only accrue not less than  
1,000 hours of pharmacy technician work experience while training in the state. This would mean  
an individual in training (with no license) could complete the 1000 hours, get a license and  
immediately start doing final product verification. Only completing (1), the training hours, puts the  
public health at risk because the 1000 hours of training allowed in (1) does not require any training  
in final product verification.  
Require the individual to meet both (1) and (2) before performing final product verification.  
The above changes to this rule would necessitate the following changes in bold: “A pharmacist  
using professional judgment may choose to delegate technology-assisted final product verification  
after ensuring full licensed pharmacy technicians have completed and documented a final product  
verification training program and work experience.”  
Delete (c) because if the technician is allowed to receive prescriptions at a location that is not  
licensed as a pharmacy, this would not meet the requirement in MCL 333.17722(c) which requires  
a location to be licensed as a pharmacy to receive prescriptions.  
Section (b)(ii)(G)  
Section (c)  
Baran  
Baran  
333.17722 Michigan board of pharmacy; duties generally.  
Sec. 17722. In addition to the functions set forth in part 161, except as otherwise provided in this  
part, the board shall do the following:  
(a) Regulate, control, and inspect the character and standard of pharmacy practice and of drugs and  
devices manufactured, distributed, prescribed, dispensed, administered, or issued in this state and  
procure samples and limit or prevent the sale of drugs and devices that do not comply with this  
15  
part.  
(b) Prescribe minimum criteria for the use of professional and technical equipment and references  
in the compounding and dispensing of drugs and devices.  
(c) Grant a pharmacy license for each separate place of practice in which the compounding or  
dispensing of prescription drugs or devices, or both, or the receiving of prescription orders in this  
state is to be conducted.  
(d) Grant a drug control license for the place of practice of a dispensing prescriber who meets the  
requirements for the license.  
(e) Grant a license to a manufacturer, wholesale distributor, or wholesale distributor-broker that  
meets the requirements for the license.  
Section (c)(i)  
Jalloul  
Regarding subsection (c)(i), which specifies “a pharmacy technician remotely performing the  
tasks…must be supervised by a licensed pharmacist,” the rule does not specify whether the  
supervising pharmacist is required to be in the pharmacy. MPA would like to urge the Board to  
include that the supervising pharmacist must be in the dispensing pharmacy.  
Rule 338.3665(c)(ii)(B) says the supervising pharmacist is “fully responsible” for the remote  
technician’s practice and accuracy. As written, this appears to permit the board to discipline a  
supervising pharmacist for an error or behavior of the pharmacy technician in all situations. This  
level of responsibility misapplies and exceeds statutory requirements under MCL 333.16215. The  
pharmacist’s responsibility and the pharmacy technician’s performance of a delegated task  
responsibility are not the same. Instead, line (c)(ii)(B) of this rule should be deleted since  
MCL333.16215 already applies or changed to reflect and not exceed the responsibilities under  
MCL 333.16215.  
Section (c)(ii)(B)  
Mollien  
Sections (c)(iii)(A) McLachlan  
(c)(iii)(B)  
(c)(iii)(C)  
The proposed language is strong, and largely achieves the Board’s goal in safely facilitating remote  
technician practice. However, there are some considerations related to the tasks called out in (iii)  
that I would like to point out to ensure that current practice that is allowable is not limited by the  
language.  
(c)(iii)(D)  
(c)(iii)(E)  
Many mail-service providers, ARxWP included, utilize non-licensed trained support staff to handle  
items including scheduling of deliveries, collection of demographic and payment information,  
securing access to financial assistance, coordinating prior authorizations, and other functions not  
associated with the actual processing and dispensing of prescriptions. With this in mind, I’d like to  
offer the below amended language for consideration:  
16  
(iii) Delegated tasks related to prescription processing functions include but are not limited to the  
following:  
(A) Entry of a patient’s medication history and allergy information  
(B) Prescription Data Entry  
(C) Claims Adjudication  
(D) Handling phone calls related to verbal prescriptions for non-controlled substances or  
prescription clarifications  
(E) Processing refill requests to or from prescribers or their agents  
(F) Technology-assisted final product verification  
(G) Transferring prescriptions for non-controlled substances.  
Section (c)(iii)(G) Jalloul  
Section (b) and (c) Eid  
Under R 338.3665 subsection (c)(iii), transferring prescriptions for non-controlled substances is  
identified as prescription processing functions. MPA suggests restricting to electronic prescriptions  
and not verbal transfers.  
CVS Health is in support of the proposed changes to this rule as written.  
Rationale: Simplification of technician final product verification as proposed is in alignment with  
ambitious standards and trends in other states. The proposed simplification in letter (b) will provide  
clarity for licensees and ensure evidence backed safety standards as supported in over 25+  
publications, posters, and 40+ years of evidence on this topic1 . CVS Health also supports the  
proposed changes to letter (c.) which clarify delegation of tasks to pharmacy technicians to perform  
remotely. The proposed rules are in alignment with trends happening in other states, allow for  
expansion of safe work practices proven by jurisdictional successes, and clarify for licensees’  
allowances of delegation of remote work.  
Rules Committee (b)(ii)(A): The Rules Committee does not agree with the comment that a limited licensee should not be able to provide  
Response  
final product verification as limited licensees can have similar experience to someone with a full license and the decision  
to delegate is still made by the pharmacist who should evaluate whether the pharmacy technician can handle the function.  
Therefore, the Rules Committee recommends the rule be clarified to make it clear that a full pharmacy technician also  
includes a limited licensed pharmacy technician by adding “The licensed pharmacy technician holds a current full or  
limited pharmacy technician license in this state.”  
(b)(ii)(B): The Rules Committee does not agree with the comment that a pharmacy technician should have both 1000  
hours of work experience and a separate final product verification training program before performing final product  
verification as the decision to delegate is still made by the pharmacist who should evaluate whether the pharmacy  
17  
technician can handle the function. The Rules Committee recommends that “full or limited licensed pharmacy  
technician” be added for consistency with (b)(ii)(A).  
(b)(ii)(B)(1): The Rules Committee does not agree with the comment that the 1000 hours of training should not be  
acquired under a temporary or limited license or while a student is in a training program. Some training programs  
provide training in final product verification and the decision to delegate is still made by the pharmacist who should  
evaluate whether the pharmacy technician can handle the function.  
(b)(ii)(G): The Rules Committee does not agree with the changes to this provision based on its previous  
recommendations.  
(c): The Rules Committee does not agree with the comment to delete (c) as the functions listed in (c)(iii) that may be  
handled remotely are not considered receiving prescriptions and therefore, the provision is not inconsistent with MCL  
333.17722(c) which requires a location to be licensed as a pharmacy to receive prescriptions.  
(c)(i): The Rules Committee does not agree with the comment to include that the supervising pharmacist must be in the  
dispensing pharmacy while a pharmacy technician is functioning remotely, as this will be left up to the pharmacist and  
the type of actions being handled by the pharmacist.  
(c)(ii)(B): The Rules Committee agrees with the comment to delete (B) that the supervising pharmacist is “fully  
responsible” for the remote technician’s practice and accuracy, as the pharmacist will be delegating to the pharmacy  
technician so they are responsible to be sure the pharmacy technician is trained to handle the function and the rule also  
speaks to the oversight required by the pharmacist.  
(c)(iii)(A)  
(c)(iii)(B)  
(c)(iii)(C)  
(c)(iii)(D)  
(c)(iii)(E): The Rules Committee does not agree with the comment to modify these sections as the remote functions do  
not limit others from performing similar functions in another capacity.  
(c)(iii)(G): The Rules Committee does not agree with the comment to restrict transferring prescriptions for non-  
controlled substances to electronic prescriptions and not verbal transfers as it has not identified a benefit to the public for  
doing so.  
Board Response  
(b)(ii)(A): The Board does not accept the comment that a limited licensee should not be able to provide final  
product verification, and therefore the rule should be modified to make it clear that a full pharmacy technician  
also includes a limited licensed pharmacy technician by adding “The licensed pharmacy technician holds a  
18  
current full or limited pharmacy technician license in this state.” A limited licensees can have similar experience  
to someone with a full license and the decision to delegate is still made by the pharmacist who should evaluate  
whether the pharmacy technician can handle the function  
(b)(ii)(B): The Board does not accept the comment that a pharmacy technician should be required to have both  
1000 hours of work experience and a separate final product verification training program before performing final  
product verification. The decision to delegate is still made by the pharmacist who should evaluate whether the  
pharmacy technician can handle the function and the Board does not want to make it more difficult for a  
pharmacy technician to handle this function but instead wants to be sure the pharmacy technician is handling the  
function with either work experience or training.  
The Board also does not accept the comment that a limited licensee should not be able to provide final product  
verification, and therefore the rule should be modified by adding “full or limited licensed pharmacy technician”.  
A limited licensee can have similar experience to someone with a full license and the decision to delegate is still  
made by the pharmacist who should evaluate whether the pharmacy technician can handle the function.  
(b)(ii)(B)(1): The Board does not accept the comment to exclude acquiring the 1000 hours of training while  
under a temporary, limited license, or a student in a training program. Therefore, clarification is necessary, so it  
is clear that the training may be acquired under the full, temporary, limited license, or while a student. Some  
training programs provide training in final product verification and the decision to delegate is still made by the  
pharmacist who should evaluate whether the pharmacy technician can handle the function.  
(b)(ii)(G): The Board does not accept the comments to limit the function to a full license and to require both  
work experience and training, both as previously discussed.  
(c): The Board does not accept the comment to delete (c) as the functions listed in (c)(iii) that may be handled  
remotely are not considered receiving prescriptions and therefore, the provision is not inconsistent with MCL  
333.17722(c) which requires a location to be licensed as a pharmacy to receive prescriptions.  
(c)(i): The Board does not accept the comment to include language that the supervising pharmacist must be in  
the dispensing pharmacy while a pharmacy technician is functioning remotely, as this will be left up to the rules  
that regulate the pharmacist and the type of actions being handled by the pharmacist.  
(c)(ii)(B): The Board accepts the comment to delete (B) that the supervising pharmacist is “fully responsible” for  
the remote technician’s practice and accuracy, as the pharmacist will be delegating to the pharmacy technician so  
they are responsible to be sure the pharmacy technician is trained to handle the function and the rule also speaks  
to the oversight required by the pharmacist.  
19  
(c)(iii)(A)  
(c)(iii)(B)  
(c)(iii)(C)  
(c)(iii)(D)  
(c)(iii)(E): The Board does not accept the comment to modify these sections as the remote functions do not limit  
others from performing similar functions in another capacity.  
(c)(iii)(G): The Board does not accept the comment to restrict transferring prescriptions for non-controlled  
substances to only electronic prescriptions and not verbal transfers, as it has not identified a benefit to the public  
for doing so.  
R 338.3665 Performance of activities and functions; delegation.  
Rule 15. In addition to performing the functions described in section 17739(1) of the code, MCL 333.17739, a licensed pharmacy  
technician may also engage in the following tasks, under the delegation and supervision of a licensed pharmacist:  
(a) ReconstitutingReconstitute non-sterile dosage forms consistent with approved labeling provided by the manufacturer of a  
commercially available product.  
(b) Technology-assistedProvide technology-assisted final product verification, which includes all the following:  
(i) A properly trained pharmacy technician performing final product verification with the use of bar coding or another  
error prevention technology. A second licensed pharmacy technician verifies the work of the first licensed pharmacy technician to  
perform final product verification.  
(ii) The first-licensed pharmacy technician processes a medication order or prescription.  
(iii) The first-licensed pharmacy technician processes the medication order or prescription using bar coding or another board-  
approved error prevention technology.  
(iv) A pharmacist verifies the first-licensed pharmacy technician’s processing of the medication order or prescription.  
(vii) The second licensed pharmacy technician providing technology-assisted final product verification is subject to all of the  
following requirements:  
(A) The licensed pharmacy technician holds a current full or limited pharmacy technician license in this state, not a temporary or  
limited license.  
(B) The licensed pharmacy technician performing technology-assisted final product verification has completed a board approved  
pharmacy technician program under R 338.3655.  
(CB) TheBefore performing final product verification the full or limited licensed pharmacy technician performing technology-  
assisted final product verification hasmeets 1 of the following:  
20  
(1) Has accrued not less than 1,000 hours of pharmacy technician work experience in the same kindtype of pharmacy practice  
site in whichwhere the technology-assisted final product verification is will be performed while he or shethe pharmacy technician  
holds a current full pharmacy technician license, in this state, not a temporary license, or a limited license, or is in training in this  
state.  
(2) Has completed a final product verification training program that includes at least all of the following:  
(i) The role of a pharmacy technician in the product verification process.  
(ii) The legal requirements and liabilities of a final verification technician.  
(iii) The use of technology assisted verification systems.  
(iv) The primary causes of medication errors and misfills.  
(v) The identification and resolution of dispensing errors.  
(DC) The practice setting where a licensed pharmacy technician performs technology-assisted final product verification has in  
place policies and procedures including a quality assurance plan governing pharmacy technician technology-assisted final product  
verification.  
(E) The licensed pharmacy technician uses a technology-enabled verification system to perform final product verification.  
(FD) The technology enabled verification system must document and electronically record each step of the prescription process  
including which individuals complete each step.  
(GE) A licensed pharmacy technician shall not perform technology-assisted final product verification for sterile or nonsterile  
compounding.  
(HF) Technology-assisted final product verification by a licensed pharmacy technician is not limited to a practice setting.  
(I) Except for a remote pharmacy that is regulated under sections 17742a and 17742b of the code, MCL 333.17742a and MCL  
333.17742b, a pharmacy technician shall not participate in technology-assisted final product verification remotely. Technology-  
assisted product verification must be done on-site.  
(JG) A pharmacist using his or her professional judgment may choose to delegate technology-assisted final product verification  
after ensuring licensed pharmacy technicians have completed and documented relevant training and educationor work experience.  
(c) Access the electronic database of a pharmacy from inside or outside of 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.  
(i) A pharmacy technician remotely performing the tasks in paragraph (iii) of this subdivision must be supervised by a  
licensed pharmacist.  
(ii) 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 all the following:  
21  
(A) 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 the performance of functions.  
(B) Is fully responsible for the practice and accuracy of the remote technician.  
(C) Has established predetermined procedures and drug protocol governing any activity performed remotely including  
protection of patient confidentiality.  
(iii) Delegated tasks relating to prescription processing functions include, but are not limited to, the following:  
(A) Verification of a patient’s medication history.  
(B) Data entry regarding processing prescription data and patient data.  
(C) Claims adjudication.  
(D) Handling phone calls regarding processing prescription data and patient data.  
(E) Processing refill requests.  
(F) Technology-assisted final product verification.  
(G) Transferring prescriptions for non-controlled substances.  
22  
Archived: Thursday, May 11, 2023 12:29:36 PM  
From: BPL-BoardSupport  
Sent: Monday, March 27, 2023 4:22:21 PM  
To: Ditschman, Andria (LARA)  
Subject: FW: Public Comment on Rule Set 2022-2 LR  
Response requested: No  
Sensitivity: Normal  
Attachments:  
PTRuleComment.docx
From: Rose M Baran <RoseBaran@ferris.edu>  
Sent: Monday, March 27, 2023 3:23 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Public Comment on Rule Set 2022-2 LR  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
To whom it may concern:  
Please find attached comments on rule set 2022-2 LR.  
Sincerely,  
Rose Baran Pharm. D.  
This email message and any attachments are for the confidential use of the intended recipient. Please notify me if you have  
received this message by mistake and delete this message and any attachments.  
Public Comment on Administrative Rules for Pharmacy Technicians  
Rule Set 2022-2 LR  
Rose Baran Pharm. D.  
Comments on rule set 2022-2LR  
Final product verification and practice setting are lacking definitions.  
Comments on rule 338.3665  
Limited technician licenses still exist, and limited licenses are issued with restrictions and less  
requirements for licensure than a full technician license. Current draft of rule 338.3665 states:  
“R 338.3665 Performance of activities and functions; delegation.  
Rule 15. In addition to performing the functions described in section 17739(1) of the code,  
MCL 333.17739, a licensed pharmacy technician may also engage in the following tasks, under  
the delegation and supervision of a licensed pharmacist:  
(a) ReconstitutingReconstitute non-sterile dosage forms consistent with approved labeling  
provided by the manufacturer of a commercially available product.  
(b) Technology-assistedProvide technology-assisted final product verification, which includes  
all the following:  
(i) A properly trained pharmacy technician performing final product verification with  
the use of bar coding or another error prevention technology. A second licensed pharmacy  
technician verifies the work of the first licensed pharmacy technician to perform final product  
verification.  
(ii) The first-licensed pharmacy technician processes a medication order or prescription.  
(iii) The first-licensed pharmacy technician processes the medication order or prescription  
using bar coding or another board-approved error prevention technology.  
(iv) A pharmacist verifies the first-licensed pharmacy technician’s processing of the  
medication order or prescription.  
(vii) The second licensed pharmacy technician providing technology-assisted final product  
verification is subject to all of the following requirements:  
(A) The licensed pharmacy technician holds a current full pharmacy technician license in this  
state, not a temporary or limited license.  
(B) The licensed pharmacy technician performing technology-assisted final product  
verification has completed a board approved pharmacy technician program under R 338.3655.  
(CB) TheBefore performing final product verification the licensed pharmacy technician  
performing technology-assisted final product verification hasmeets 1 of the following:  
(1) Has accrued not less than 1,000 hours of pharmacy technician work experience in the  
same kindtype of pharmacy practice site in whichwhere the technology-assisted final product  
verification is will be performed while he or shethe pharmacy technician holds a current full  
pharmacy technician license, in this state, not a temporary or limited license, or is in training in  
this state.  
(2) Has completed a final product verification training program that includes at least  
all of the following:  
(i) The role of a pharmacy technician in the product verification process.  
(ii) The legal requirements and liabilities of a final verification technician.  
(iii) The use of technology assisted verification systems.  
(iv) The primary causes of medication errors and misfills.  
(v) The identification and resolution of dispensing errors.”  
Limited license is used twice in the rule. The “or limited” should be added back in  
338.3655(b)(ii)(A) and in 338.3655(b)(ii)(B)(1). The limited license technician is not equivalent  
to a full pharmacy technician license because the limited license technician was exempt form the  
examination requirement required for a full license pharmacy technician and was also exempt  
from providing proof of graduating from an accredited high school or comparable school or that  
they passed the general educational development test or other graduate equivalency examination.  
They are also restricted to act as a pharmacy technician only at the pharmacy they were  
employed at on December 22, 2014. If the employer operates multiple pharmacies than at any of  
the employer locations in Michigan.  
There are over 1000 limited pharmacy technicians according to the Department’s count as of  
December 6, 2022. Limited pharmacy technicians are no longer granted because of the  
restrictions placed in 333.17739c.  
Change 338.3655(b)(ii)(A) to read: (A) The licensed pharmacy technician holds a current full  
pharmacy technician license in this state, not a temporary or limited license. And change  
338.3655(b)(ii)(B)(1) to read (1) 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 only.  
Change 338.3655(b)(ii)(B) to 1 of the following to all of the following requirements. If the  
individual only has to comply with “(1) Has accrued not less than 1,000 hours of pharmacy  
technician work experience in the same kindtype of pharmacy practice site in whichwhere the  
technology-assisted final product verification is will be performed while he or shethe pharmacy  
technician holds a current full pharmacy technician license, in this state, not a temporary or  
limited license, or is in training in this state” would mean an individual in training (with no  
license) could complete the 1000 hours, get a license and immediately start doing final product  
verification. Only completing (1) puts the public health at risk because the 1000 hours of  
training in (1) does not require any training in final product verification.  
Change 338.3655(b)(ii)(B) to:  
Before performing final product verification, the licensed pharmacy technician meets all of  
the following:  
(1) 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,  
not a temporary or limited license.  
(2) Has completed a final product verification training program that includes at least  
all of the following:  
(i) The role of a pharmacy technician in the product verification process.  
(ii) The legal requirements and liabilities of a final verification technician.  
(iii) The use of technology assisted verification systems.  
(iv) The primary causes of medication errors and misfills.  
(v) The identification and resolution of dispensing errors.  
These changes would necessitate a change in Rule 338.3665(b)(ii)(G) to “A pharmacist using  
professional judgment may choose to delegate technology-assisted final product verification after  
ensuring full licensed pharmacy technicians have completed and documented a final product  
verification training program and work experience.”  
Section 333.17722 states “In addition to the functions set forth in part 161, except as otherwise  
provided in this part, the board shall do the following:  
(a) Regulate, control, and inspect the character and standard of pharmacy practice and of drugs  
and devices manufactured, distributed, prescribed, dispensed, administered, or issued in this state  
and procure samples and limit or prevent the sale of drugs and devices that do not comply with  
this part.  
(b) Prescribe minimum criteria for the use of professional and technical equipment and  
references in the compounding and dispensing of drugs and devices.  
(c) Grant a pharmacy license for each separate place of practice in which the compounding or  
dispensing of prescription drugs or devices, or both, or the receiving of prescription orders in this  
state is to be conducted.”  
(d) Grant a drug control license for the place of practice of a dispensing prescriber who meets  
the requirements for the license.  
(e) Grant a license to a manufacturer, wholesale distributor, or wholesale distributor-broker that  
meets the requirements for the license.  
Rule 338.3665(c) states  
(c) Access the electronic database of a pharmacy from inside or outside of 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.  
(i) A pharmacy technician remotely performing the tasks in paragraph (iii) of this  
subdivision must be supervised by a licensed pharmacist.  
(ii) 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 all the following:  
(A) 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 the performance of functions.  
(B) Is fully responsible for the practice and accuracy of the remote technician.  
(C) Has established predetermined procedures and drug protocol governing any activity  
performed remotely including protection of patient confidentiality.  
(iii) Delegated tasks relating to prescription processing functions include, but are not  
limited to, the following:  
(A) Verification of a patient’s medication history.  
(B) Data entry regarding processing prescription data and patient data.  
(C) Claims adjudication.  
(D) Handling phone calls regarding processing prescription data and patient data.  
(E) Processing refill requests.  
(F) Technology-assisted final product verification.  
(G) Transferring prescriptions for non-controlled substances.  
If the technician is allowed to receive prescriptions at a location that is not licensed as a  
pharmacy, this would not meet the requirement in 333.17722(c) which requires a location to be  
licensed as a pharmacy to receive prescriptions. Remove rule 338.3665(c) from the revision.  
Archived: Thursday, May 11, 2023 12:31:04 PM  
From: Eid, Deeb D  
Sent: Monday, April 3, 2023 11:29:32 AM  
To: BPL-BoardSupport; Ditschman, Andria (LARA)  
Cc: Johnston, Mark D.  
Subject: RE: CVS Health Public Comments for Pharmacy Technicians - General Rules (MOAHR #2022-02 LR)  
Sensitivity: Normal  
Attachments:  
CVS Health Comments on Pharmacy Technician Rules-MI 2023.pdf
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Andria,  
Please see the attached letter which contains public comments for Pharmacy Technician General Rules. Looking forward to  
discussing further and thanks for all of the hard work that has gone into these!  
Let me know if you have any questions.  
Thank you for your time!  
Deeb D. Eid, PharmD, RPh | One CVS Drive | Mail Code 2325 | Woonsocket, RI 02895 | T: 616-490-7398  
March 24th, 2023  
Andria Ditschman, JD  
Senior Policy Analyst  
Bureau of Professional Licensing, Michigan Department of Licensing and Regulatory Affairs (LARA)  
611 W. Ottawa St. PO Box 30670 Lansing, MI 48909  
Telephone: 517-241-9255  
DitschmanA@michigan.gov  
Re: CVS Health Comments Rules Public Hearing for Pharmacy Technician Rules (2022-2 LR)  
Dear Andria and Board Members:  
I am writing to you in my capacity as Senior Advisor of Regulatory Affairs for CVS Health and its family of pharmacies.  
CVS Health, the largest pharmacy health care provider in the United States, is uniquely positioned to provide diverse  
access points of care to patients in Michigan through our integrated offerings across the spectrum of pharmacy care.  
CVS Health appreciates the opportunity to submit comments on the proposed rules for Pharmacy Technician  
regulations. We would also like to thank the Department and Board for their vigilance to continuously improve the  
laws and regulations that guide pharmacists, pharmacy interns, and pharmacy technicians serving Michigan’s  
patients.  
After review, CVS Health has comments for the Department and Board to consider strengthening and better align  
with national trends, improve patient safety, and overall outcomes. These recommended changes are in the  
Appendix section below which highlights the rules, comments, proposed language, and any citations or additional  
information or questions to consider.  
CVS Health appreciates the opportunity to submit comments for the Board’s review. Please contact me directly at  
616-490-7398 if you have any questions.  
Sincerely,  
Deeb D. Eid, PharmD, RPh  
Sr. Advisor, Pharmacy Regulatory Affairs  
CVS Health  
deeb.eid@cvshealth.com  
Deeb D. Eid, PharmD, RPh | One CVS Drive | Mail Code 2325 | Woonsocket, RI 02895 | T: 616-490-7398  
Appendix  
1. Suggested Rule Language Changes:  
Rule 4  
R338.3654 Examination requirements; board approval; approval process.  
(8) One year after the effective date of this subrule, a board-approved proficiency examination must have a  
minimum passing score of 70%.  
Comment: CVS Health recommends that number (8) in Rule 4 be struck from the proposed rules.  
Rationale: Referencing national standards, exams such as the PTCB or NHA certification exams no longer use  
percentile-based scoring. More modern-day psychometric standards call for scaled scoring where a passing  
percentage is not stagnant. Holding other “board approved proficiency exams” to an arbitrary 70% standard is not  
consistent with other parts of the regulation which allow for national standards. To fall in line with these standards, it  
is suggested to remove and not include an arbitrary passing % number that is not backed by evidence or examination  
standards nationally.  
2. Suggested Rule Language Changes:  
Rule 15  
R338.3665 Performance of activities and functions; delegation.  
Comment: CVS Health is in support of the proposed changes to this rule as written.  
Rationale: Simplification of technician final product verification as proposed is in alignment with ambitious standards  
and trends in other states. The proposed simplification in letter (b) will provide clarity for licensees and ensure  
evidence backed safety standards as supported in over 25+ publications, posters, and 40+ years of evidence on this  
topic1. CVS Health also supports the proposed changes to letter (c.) which clarify delegation of tasks to pharmacy  
technicians to perform remotely. The proposed rules are in alignment with trends happening in other states, allow for  
expansion of safe work practices proven by jurisdictional successes, and clarify for licensees’ allowances of delegation  
of remote work.  
Citations1:  
1. Adams, Alex J., et al. “‘Tech-Check-Tech’: A Review of the Evidence on Its Safety and Benefits.” American  
Journal of Health-System Pharmacy: AJHP: Official Journal of the American Society of Health-System  
Pharmacists, vol. 68, no. 19, Oct. 2011, pp. 1824–33. PubMed, doi:10.2146/ajhp110022.  
2. Frost, Timothy P., and Alex J. Adams. “Tech-Check-Tech in Community Pharmacy Practice Settings.” The  
Journal of Pharmacy Technologyꢀ: JPTꢀ: Official Publication of the Association of Pharmacy Technicians, vol. 33,  
no. 2, Apr. 2017, pp. 47–52. PubMed Central, doi:10.1177/8755122516683519.  
3. Andreski, Michael, et al. “The Iowa New Practice Model: Advancing Technician Roles to Increase Pharmacists’  
Time to Provide Patient Care Services.” Journal of the American Pharmacists Association, vol. 58, no. 3, May  
2018, pp. 268-274.e1. www.japha.org, doi:10.1016/j.japh.2018.02.005.  
4. Gatwood J, Martin H, Newsome R, Hohmeier KC. Economic viability of tech-check-tech in an independent  
community pharmacy. J Am Pharm Assoc (2003). 2019 Jul-Aug;59(4):570-574. doi:  
10.1016/j.japh.2019.02.013. Epub 2019 Apr 9. PMID: 30979577.  
5. Shorthand citations for technician product verification:  
a. Stafford et al. (1991)  
b. Anderson et al. (1997)  
c. Enderlin et al. (2008)  
Deeb D. Eid, PharmD, RPh | One CVS Drive | Mail Code 2325 | Woonsocket, RI 02895 | T: 616-490-7398  
d. Ambrose et al. (2002)  
e. Brouner et al. (Poster) (2018)  
f. Becker et al. (1978)  
g. Miller et al. (2018)  
h. Douglas et al. (1994)  
i. Gmerek et al. (1990)  
j. Watt et al. (2015)  
k. Grogan et al. (1978)  
l. Klammer et al. (1994)  
m. Jones et al. (2002)  
n. Ness et al. (1994)  
o. Spooner et al. (1994)  
p. Hohmeier et al. (2019)  
q. Feely et al. (Poster) (2018)  
r. Tarver et al. (2017)  
s. Andreski et al. (Poster) (2018)  
t. Hickman et al. (2018)  
u. Wang et al. (2016)  
Archived: Thursday, May 11, 2023 12:31:49 PM  
From: BPL-BoardSupport  
Sent: Thursday, April 6, 2023 11:34:50 AM  
To: Ditschman, Andria (LARA)  
Subject: FW: Pharmacy Tech Public Comments  
Response requested: No  
Sensitivity: Normal  
Attachments:  
Pharmacy Tech Rules Comments.pdf
From: Farah Jalloul <fjalloul@michiganpharmacists.org>  
Sent: Thursday, April 6, 2023 11:21 AM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Pharmacy Tech Public Comments  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Good morning,  
Please see attached comments from the Michigan Pharmacists Association on the Pharmacy Technician Draft Rules.  
Thank you for the opportunity to provide feedback.  
Farah  
Farah Jalloul, B.S., Pharm.D., M.B.A.  
Director of Professional Development  
State Pharmacy Emergency Preparedness Coordinator  
Michigan Pharmacists Association  
408 Kalamazoo Plaza, Lansing MI 48933  
ph (517) 377-0224  
c (313) 766-3151  
fx (517) 484-4893  
Michigan Pharmacists Association: Working together to strengthen the profession and advance pharmacy practice  
This email is not providing legal advice but our interpretation of the Public Health Code and our understanding of how the Board of Pharmacy currently enforces the statute and other provisions. For legal advice, contact an  
attorney.  
April 6, 2023  
Department of Licensing and Regulatory Affairs  
Bureau of Professional Licensing  
Boards and Committees Section  
PO Box 30670  
Lansing, MI 48909-8170  
Dear Policy Analyst,  
The Michigan Pharmacists Association (MPA) would like to thank the Michigan Board of Pharmacy  
within the Michigan Department of Licensing and Regulatory Affairs for allowing us to submit our  
comments on the proposed administrative rules 2022-2 LR, Pharmacy Technicians Rules governing  
the rules for pharmacy technicians. MPA represents pharmacists, pharmacy technicians, and student  
pharmacists across the state. We are strong proponents of offering increased access to care to all  
Michiganders in a safe and effective way. We would like to take this opportunity to provide comments  
on the following:  
1. Under R 338.3651a(2) and 3653(2) the Rules reference R 338.7001 through 7005. However, R  
338.7005 has been rescinded.  
2. Regarding R 338.3665 subsection (c)(i), which specifies “a pharmacy technician remotely  
performing the tasks…must be supervised by a licensed pharmacist.” The rule does not specify  
whether the supervising pharmacist is required to be in the pharmacy. MPA would like to urge  
the Board to include that the supervising pharmacist must be in the dispensing pharmacy.  
3. Under R 338.3665 subsection (c)(iii), transferring prescriptions for non-controlled substances  
is identified as prescription processing functions. MPA suggests restricting to electronic  
prescriptions and not verbal transfers.  
Again, the Michigan Pharmacists Association would like to thank you for taking the time to review  
our concerns. If you have any additional questions, I can be reached at the information below.  
Sincerely,  
Farah Jalloul, B.Sc, Pharm.D., MBA  
Director of Professional Development  
Michigan Pharmacists Association  
313-766-3151  
Farah@MichiganPharmacists.org  
Archived: Thursday, May 11, 2023 12:36:43 PM  
From: BPL-BoardSupport  
Sent: Monday, April 3, 2023 12:43:00 PM  
To: Ditschman, Andria (LARA)  
Subject: FW: Attn - Departmental Specialist - Comments for Pharmacy Technician Rules  
Response requested: No  
Sensitivity: Normal  
Attachments:  
Michigan Tech WFH Comments.pdf
From: McLachlan, Jonathan <jonathan.mclachlan@alliancerxwp.com>  
Sent: Monday, April 3, 2023 12:38 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Attn - Departmental Specialist - Comments for Pharmacy Technician Rules  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Good afternoon,  
Please see attached. I will likely attend the hearing and will definitely be on the subsequent Rules Committee Work Group  
meeting to discuss any questions the Board or Department has in regard to these comments.  
Thanks,  
Jonathan McLachlan, PharmD, R.Ph., CSP  
Manager, Professional Practices  
AllianceRx Walgreens Pharmacy | Clinical and Professional Services  
41460 Haggerty Cir S, Canton, MI 48188  
Eastern Time Zone  
Desk 734.477.9891  
Member of Walgreens Boots Alliance  
This email message, including attachments, may contain information that is proprietary, confidential, privileged and/or  
exempt from disclosure. Please hold it in confidence to protect privilege and confidentiality. If you are not the intended  
recipient, then please notify the sender and delete this message. Any viewing, copying, publishing, disclosure, distribution  
of this information, or the taking of any action in reliance on the contents of this message by unintended recipients is  
prohibited and may constitute a violation of the Electronic Communications Privacy Act.  
Michigan Board of Pharmacy  
c/o Michigan Department of Licensing and Regulatory Affairs  
Bureau of Professional Licensing – Boards and Committees Section  
PO Box 30670  
Lansing, MI 48909-8710  
Attention: Departmental Specialist  
Transmitted via email to BPL-BoardSupport@michigan.gov  
April 3, 2023  
To Whom it May Concern:  
AllianceRx Walgreens Pharmacy (ARxWP), a wholly owned subsidiary of Walgreens, is among the  
country’s leading mail service pharmacy providers. We operate both traditional mail service pharmacies  
and specialty mail service pharmacies across the country – including our specialty site in Canton Township  
in Wayne County. In our practice model, we have been able to successfully leverage remote work options  
for our front end (data entry, non-dispensing) technician team members in our other operating states that  
do allow for remote technician work – Texas, Florida, Arizona and Pennsylvania. This has helped keep  
our team members safe during the pandemic and helped us retain high-performing staff within the  
profession. As the Board and Department are aware, remote technician work has been prohibited since  
the allowances granted by the COVID executive orders were exhausted. Not having a remote work option  
available in Michigan has been a challenge from a staffing perspective and we are excited to work with the  
Board and Department on successful implementation of rules allowing remote practice with appropriate  
safeguards.  
For reference, below is the proposed language to be added to section 2 of Rule 338.3365:  
(c) Accessing the electronic database of a pharmacy from inside or outside of the pharmacy to perform  
delegated tasks related to prescription processing functions.  
(i) A pharmacy technician performing tasks remotely must be supervised remotely by a licensed pharmacist.  
(ii) Remote supervision means that a pharmacist directs and controls the actions of the remote technician  
using technology to ensure the supervising pharmacist does all of the following:  
(A) 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 the performance of function.  
(B) Is fully responsible for the practice and accuracy of the remote technician  
(C) Has established predetermined procedures and drug protocol.  
(iii) Delegated tasks related to prescription processing functions include but are not limited to the following:  
(A) Verification of a patient’s medication history  
(B) Data Entry  
(C) Claims Adjudication  
(D) Handling phone calls  
(E) Processing refill requests  
(F) Technology-assisted final product verification  
(G) Transferring prescriptions for non-controlled substances.  
The above language is strong, and largely achieves the Board’s goal in safely facilitating remote technician  
practice. However, there are some considerations related to the tasks called out in (iii) that I would like to  
call out to ensure that current practice that is allowable is not limited by the language.  
Many mail-service providers, ARxWP included, utilize non-licensed trained support staff to handle items  
including scheduling of deliveries, collection of demographic and payment information, securing access to  
financial assistance, coordinating prior authorizations, and other functions not associated with the actual  
processing and dispensing of prescriptions.  
With this in mind, I’d like to offer the below amended language for consideration:  
(c) Accessing the electronic database of a pharmacy from inside or outside of the pharmacy to perform  
delegated tasks related to prescription processing functions.  
(i) A pharmacy technician performing tasks remotely must be supervised remotely by a licensed pharmacist.  
(ii) Remote supervision means that a pharmacist directs and controls the actions of the remote technician  
using technology to ensure the supervising pharmacist does all of the following:  
(A) 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 the performance of function.  
(B) Is fully responsible for the practice and accuracy of the remote technician  
(C) Has established predetermined procedures and drug protocol.  
(iii) Delegated tasks related to prescription processing functions include but are not limited to the following:  
(A) Entry of a patient’s medication history and allergy information  
(B) Prescription Data Entry  
(C) Claims Adjudication  
(D) Handling phone calls related to verbal prescriptions for non-controlled substances or prescription  
clarifications  
(E) Processing refill requests to or from prescribers or their agents  
(F) Technology-assisted final product verification  
(G) Transferring prescriptions for non-controlled substances.  
I wholeheartedly applaud the efforts that have been made thus far in this endeavor and look forward to  
further engagement with key stakeholders as we move forward.  
Sincerely,  
Jonathan McLachlan, PharmD, R.Ph., CSP  
Manager, Professional Practices  
AllianceRx Walgreens Pharmacy  
41460 Haggerty Cir S  
Canton, MI 48188  
(734) 477-9891  
Jonathan.mclachlan@alliancerxwp.com  
Archived: Thursday, May 11, 2023 12:37:52 PM  
From: BPL-BoardSupport  
Sent: Monday, March 13, 2023 9:40:12 AM  
To: Ditschman, Andria (LARA)  
Subject: FW: Public Comment for 2022-2 LR Ruleset Pharmacy Technicians  
Response requested: No  
Sensitivity: Normal  
From: Mollien, Charlie <Charlie.Mollien@meijer.com>  
Sent: Sunday, March 12, 2023 7:57 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Cc: Oss, Kristen <Kristen.Oss@meijer.com>; Mollien, Charlie <Charlie.Mollien@meijer.com>  
Subject: Public Comment for 2022-2 LR Ruleset Pharmacy Technicians  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
I am expressing my general support for all proposed rule changes. Below are specific concerns to address:  
1. For Rule 338.3655(7), I support allowing those less than age 18 to enroll in board-approved pharmacy technician training  
programs. If the board adopts this rule change, please work with the Department of Labor and Economic Opportunity to  
change the listed prohibition for individuals aged 16 or 17 to work in “Pharmacies and Prescription Drug Delivery” work  
activities. I also recommend you change this rule to align with DLEO to only permit individuals 16 or 17 years old to  
participate in practical training in the pharmacy.  
See https://www.michigan.gov/leo/-  
/media/Project/Websites/leo/Folder23/whd_9934_Youth_Employment_Hazardous_Table.pdf?  
rev=4a03c2e42cb1420082df1f738b50129b&hash=3EB19CA5DD2240849A407FA0D68D52EA for Work Activities  
Prohibited or Restricted by Department Review under MCL 409.103.  
2. For Rule 338.3655(9), Clarify the how the program has an opportunity to demonstrate the program is not deficient with  
the board, not just the Department.  
3. Clarify Rule 338.3655(10). Does this rule mean new students are prohibited from enrolling in the program? Only students  
who completed the program, but are not yet licensed are eligible for licensure? Will students enrolled, but who have not  
completed the program that is withdrawn approval be considered displaced? The rule is unclear on what happens.  
4. Rule 338.3665(c)(ii)(B) says the supervising pharmacist is “fully responsible” for the remote technician’s practice and  
accuracy. As written, this appears to permit the board to discipline a supervising pharmacist for an error or behavior of the  
pharmacy technician in all situations. This level of responsibility misapplies and exceeds statutory requirements under MCL  
333.16215. The pharmacist’s responsibility and the pharmacy technician’s performance of a delegated task responsibility  
are not the same. Instead, line (c)(ii)(B) of this rule should be deleted since MCL333.16215 already applies or changed to  
reflect and not exceed the responsibilities under MCL 333.16215.  
Charlie Mollien  
Archived: Thursday, May 11, 2023 12:38:14 PM  
From: Renee Smiddy  
Sent: Thursday, April 6, 2023 1:02:44 PM  
To: BPL-BoardSupport  
Cc: Ditschman, Andria (LARA)  
Subject: MHA Comments Administrative Rules for Pharmacy Technicians Rule Set 2022-2 LR  
Sensitivity: Normal  
Attachments:  
MHA Comments 2022-2 LR Pharmacy Technicians.pdf
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Good afternoon,  
Please see the attached comments for the Pharmacy Technicians Rule Set 2022-2 LR.  
Kind regards,  
Renée Smiddy, MS | Senior Director, Finance Policy  
Michigan Health & Hospital Association  
110 W. Michigan Avenue, Suite 1200 | Lansing, MI 48933  
(517) 285-0881 | rsmiddy@mha.org  
April 6, 2023  
Department of Licensing and Regulatory Affairs  
Bureau of Professional Licensing  
Boards and Committees Section  
P.O. Box 30670  
Lansing, Michigan 48909  
RE: Administrative Rules for Pharmacy Technicians Rule Set 2022-2 LR  
Departmental Specialist:  
On behalf of Michigan hospitals, the Michigan Health & Hospital Association (MHA) appreciates the  
opportunity to provide comments on Administrative Rules for Pharmacy Technicians. Pharmacy  
technicians are valuable team members in inpatient and outpatient hospitals, and the current labor  
shortages are negatively impacting delivery of care. Pharmacy technician shortages force operational  
changes, which force pharmacists to perform technician duties, reduce services and limit the expansion  
of new services. Hospitals and health systems are reporting difficulty recruiting and filling open pharmacy  
technician positions.  
BOARD APPROVAL AND APPROVAL PROCESS  
The MHA recommends the board clarify the reasoning for requiring all existing board approved pharmacy  
technician programs to be rereviewed by the board before December 31, 2023. To reduce unnecessary  
administrative burden, especially during the unwinding of the COVID-19 public health emergency, the  
MHA recommends pharmacy technician programs be reevaluated within one-year of the rules set  
promulgation date. This will allow program administrators and community partners additional time to  
communicate the reevaluation timeframe with stakeholders.  
APPROVED PHARMACY TECHNICIAN PROGRAMS  
The MHA requests clarification regarding R 338.3655 (6) A student in a board-approved pharmacy  
technician program is exempt from, and not eligible for, licensure while in the program. Will students  
still be eligible to receive temporary licenses while in a training program?  
The MHA requests clarification regarding R 338.3655 (7) and how to define practical training.  
CONTINUING EDUCATION AND EXAMINATION REQUIREMENTS  
The MHA supports the proposal to allow students enrolled in a pharmacy technician program who are  
less than 18 years of age to train in a pharmacy, and the MHA also supports adding the 70% passing  
score of a board-approved proficiency exam. However, the MHA has concerns regarding the proposal to  
reduce the maximum allowable continuing education (CE) hours earned outside of a licensee’s regular  
job description from 10 hours to 2 hours. The MHA recognizes the good intentions in limiting CEs outside  
of one’s job description, but the MHA opposes the proposed change based on the feasibility of  
MHA Comments – Pharmacy Technicians Rule Set 2022-2 LR  
April 6, 2023  
Page 2  
enforcing the rule and the negative repercussions of pharmacy technicians self-selecting to limit  
growth and education opportunities to meet this requirement.  
ACTIVITIES AND DELEGATION  
The MHA supports the proposed changes to allow pharmacists to delegate technology-assisted final  
product verification to a pharmacy technician working remotely.  
Please contact me at rsmiddy@mha.org, if any questions regarding these comments or if you need  
additional information.  
Sincerely,  
Renée Smiddy  
Sr. Director, Finance Policy  
Archived: Thursday, May 11, 2023 12:38:50 PM  
From: Maria Young  
Sent: Wednesday, April 5, 2023 9:50:47 PM  
To: Ditschman, Andria (LARA)  
Subject: public comment for tech rules  
Sensitivity: Normal  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Andria,  
Hope all is well. Please see below for the public comments on tech rules.  
These comments are submitted in my individual capacity as a pharmacist licensed to practice Pharmacy in the state of Michigan and are not  
being offered in my official capacity as a member of the Board of Pharmacy and do not represent the views of the Board.  
MI Rule R 338.3654.  
Examination requirements; board approval; approval process.  
MCL 333.17739a(1)(d)(iv) and R 338.3665  
It is requested to include:  
- A minimum of 100 questions on the pharmacy technician exam  
- To have a larger assortment of questions in each category  
- No true/ false questions on the exam.  
The reason for the consideration is to prepare for the technician for taking the national exams and be prepared for the time allotted. Both  
national exams (PTCE and ExCPT) have 100 questions and are timed.  
For questions or concerns please let me know.  
Thanks  
--  
Maria Young, RPh  
University Pharmacy  
"Your Pharmacy Solution"  
I hated every minute of training, but I said, 'Don't quit. Suffer now and live the rest of your life as a champion.'  
Muhammad Ali  
*****CONFIDENTIALITY NOTICE*****  
The documents accompanying this transmission contain protected health information belonging to the sender, which is legally  
privileged. This information is intended only for the use or entity named above. If you are not the intended recipient, you are  
hereby notified that any disclosure, copying, distribution, or action taken in reliance on the contents of these documents is strictly  
prohibited. If you have received this telecopy in error, please notify the sender immediately to arrange for return of these  
documents.  
Archived: Thursday, May 11, 2023 12:39:07 PM  
From: Maria Young  
Sent: Thursday, April 6, 2023 12:59:40 PM  
To: Ditschman, Andria (LARA)  
Subject: public comment for tech rules  
Sensitivity: Normal  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Andria,  
These comments are submitted in my individual capacity as a pharmacist licensed to practice Pharmacy in the state of  
Michigan and are not being offered in my official capacity as a member of the Board of Pharmacy and do not represent  
the views of the Board.  
1. Should a pharmacy technician program at a community college be accredited and automatically approved if accredited,  
or should it be treated more like a proprietary school program that comes to the Board for review?  
2. Do the rules need to address how students in a proprietary school or community college pharmacy technician program  
get their hands on training? Since they are students in an approved program can the program place them in a pharmacy  
that will agree to provide supervision so they can get hands-on experience?  
3. Can a program that has an approved examination offer that examination to someone who did not participate in a  
program but holds a temporary license? Or is a board approved pharmacy program only allowed to give their  
examination to students in their program?  
4. R 333.3655(10) – What circumstances would the Board allow a student to take the examination in a program if the Board  
withdraws approval?  
For any questions or concerns  
please let me know  
Thanks  
--  
Maria Young, RPh  
University Pharmacy  
"Your Pharmacy Solution"  
I hated every minute of training, but I said, 'Don't quit. Suffer now and live the rest of your life as a champion.'  
Muhammad Ali  
*****CONFIDENTIALITY NOTICE*****  
The documents accompanying this transmission contain protected health information belonging to the sender, which is legally  
privileged. This information is intended only for the use or entity named above. If you are not the intended recipient, you are  
hereby notified that any disclosure, copying, distribution, or action taken in reliance on the contents of these documents is strictly  
prohibited. If you have received this telecopy in error, please notify the sender immediately to arrange for return of these  
documents.  
;