MINIMUM EDUCATIONAL QUALIFICATION STANDARDS FOR PHARMACISTS

To support minimum educational qualification standards for pharmacists to practice pharmacy that are consistent with the licensing standards of state boards of pharmacy; further,

To oppose the basic education requirement within the Office of Personnel Management Classification & Qualifications - General Schedule Qualification Standards - Pharmacy Series, 0660, requiring a Doctor of Pharmacy or Doctor of Philosophy degree as the minimum qualification to practice pharmacy.

Rationale

In September 2017, the U.S. Office of Personnel Management (OPM) issued a new qualification standard for pharmacists, GS-0660. The new standard lists the basic educational requirement for pharmacists as a Doctor of Pharmacy (Pharm.D.) or Doctor of Philosophy (Ph.D.) degree. To set this requirement, OPM must have determined that pharmacy cannot be performed by persons without one of these degrees, because Title 5 U.S.C. 3308 permits the establishment of minimum educational requirements only when OPM has determined that the work cannot be performed by persons who do not possess the prescribed minimum education.

All 50 states currently allow pharmacists with a bachelor’s degree in pharmacy (B.S.Pharm.) to obtain licensure and practice pharmacy, which indicates that all state legislatures or regulators have concluded that pharmacists with a B.S.Pharm. degree can practice pharmacy safely and effectively. In the U.S., the B.S.Pharm. degree was awarded until 2005; in 2006, the Pharm.D. degree became the only entry-level degree awarded. A 2014 survey of the pharmacy workforce found that only 40% of pharmacists had earned a Pharm.D. The minimum educational requirements set by OPM would automatically disqualify 60% of pharmacists from entering the federal government workforce, an inequitable practice not seen outside the federal sector. The OPM minimum educational requirement also creates a monumental challenge to building and maintaining the pharmacist workforce the Department of Defense needs to support U.S. warfighting efforts and take care of veterans. ASHP recognizes that pharmacists must possess the education, training, and experience required to effectively, efficiently, and responsibly fulfill their roles. Further, ASHP supports licensure by a state board of pharmacy as the minimum requirement for pharmacy practice in its Minimum Standard for Pharmacies in Hospitals.