3.3 Pharmacist-in-Charge / Pharmacist Manager
Key Takeaways
- Connecticut’s PIC equivalent is the pharmacist manager (managing pharmacist) in CGS § 20-597(b): every pharmacy must be managed by a pharmacist practicing there on a full-time basis, and no pharmacist may manage more than one pharmacy at the same time.
- The pharmacy licensee must immediately notify the Commission when the manager ceases management and immediately enroll the new manager’s name, address, and license number, with the $90 filing fee in CGS § 20-601(7); the departing manager must also immediately notify the Commission.
- RCSA § 20-576-23 requires a first-time Connecticut pharmacist manager to appear before the Commission for a personal interview before being authorized to manage, except a hardship delay until the next Commission meeting; COVID-era email-only processing was temporary.
- If a manager is absent more than 16 consecutive days the licensee reports the absence and names an acting manager; absence exceeding 42 consecutive days is treated as cessation of management (RCSA § 20-576-22).
- DEA Form 224 uses “pharmacist-in-charge” for federal controlled-substance registration; that federal PIC concept is related to, but not a substitute for, Connecticut’s one-pharmacy pharmacist-manager rule.
3.3 Pharmacist-in-Charge / Pharmacist Manager
Quick Answer: Connecticut does not use “PIC” as its statutory title. CGS § 20-597 requires every licensed pharmacy to be managed by a pharmacist practicing at that pharmacy on a full-time basis. No pharmacist may manage more than one pharmacy at the same time. Changes in management are reported immediately to the Commission with the § 20-601 fee. First-time managers appear before the Commission under RCSA § 20-576-23.
MPJE Competency 1.1.1 asks who is legally responsible for a pharmacy. Federal DEA paperwork says pharmacist-in-charge. Connecticut Chapter 400j and RCSA 20-576 say pharmacist manager or managing pharmacist. Use Connecticut’s words on Connecticut items.
The statutory manager — CGS § 20-597
CGS § 20-597(a) first requires a pharmacy license and direct on-premises supervision by a pharmacist, except to the extent regulations allow a pharmacy to remain open when a pharmacist is not present. That daily supervising pharmacist is not automatically the manager.
CGS § 20-597(b) then adds the management layer:
- The pharmacy shall be managed by a pharmacist practicing at the pharmacy on a full-time basis.
- That pharmacist is listed as manager on the § 20-594 pharmacy-license application or enrolled with the Commission under subsection (c).
- The managing pharmacist may also act as the supervising pharmacist.
- No pharmacist may manage more than one pharmacy at the same time.
That last sentence is the published numeric limit. Connecticut does not authorize a regional PIC to “cover” an unlimited chain. If a question asks whether one manager may reasonably cover unlimited sites, the statute answers no: the cap is one pharmacy.
RCSA § 20-576-21 requires the name of the pharmacist manager to be conspicuously posted within the prescription department or in immediate proximity to it. RCSA § 20-576-13 requires a pharmacy to be open at least 35 hours per week unless a class-of-pharmacy regulation says otherwise. Hours, posted manager name, technician ratios, and controlled-substance compliance are operational duties that sit on the manager even when staff pharmacists share the daily supervising-pharmacist role.
Change of manager — notice, fee, and dual notification
CGS § 20-597(c) is a two-notice rule:
- The person to whom the pharmacy license was issued (the owner/licensee) shall immediately notify the Commission when the manager ceases management and shall immediately enroll the name, address, and license number of the pharmacist who assumes management.
- That notice of change in management is accompanied by the filing fee in § 20-601.
- The pharmacist who ceases management shall also immediately notify the Commission of that fact.
CGS § 20-601(7) sets the fee for filing notice of a change in name, ownership, or management of a pharmacy at $90, plus a $50 late fee if notice is not given within ten days of the change. DCP currently processes the change through eLicense License Maintenance on the pharmacy (PCY) account—not on the individual pharmacist account—except that a first-time manager’s request to appear is filed from the pharmacist (PCT) license.
Do not treat the departing manager’s personal notice as optional. UConn and DCP teaching materials flag a recurring inspection failure: Store A reports that Jordan is replacing Alex, DCP’s record still shows Morgan as manager because nobody notified the last two changes, and the person who actually left months ago never sent the departing-manager notice. The MPJE tests the dual duty.
CGS § 20-597(d) (ownership or name change) is a related but separate notice, also with the § 20-601 fee. Ownership change is a facility event for Chapter 18; mention it here only so you do not file a manager change when the stem is actually an ownership transfer.
Absence of the manager — 16 days and 42 days
RCSA § 20-576-22 is a favorite numbers item:
| Consecutive absence | What the regulation requires |
|---|---|
| More than 16 consecutive days | Licensee immediately reports the absence; names the acting pharmacist manager within five days after the sixteenth consecutive day |
| More than 42 consecutive days | The absent pharmacist is deemed to have ceased to be the pharmacist manager; licensee files a change of manager under § 20-597 with the § 20-601 fee; the pharmacist who ceased management also notifies the Commission |
A two-week vacation is not automatically a manager vacancy. A six-week medical leave is cessation of management under the 42-day rule. The acting manager named after day 16 is not a second concurrent manager of another pharmacy; the one-pharmacy cap in § 20-597(b) still applies to whoever is the manager.
First-time manager interview — RCSA § 20-576-23
RCSA § 20-576-23 requires a pharmacist designated as manager who has not previously managed a Connecticut pharmacy to appear before the Commission for a personal interview about knowledge and responsibilities as a pharmacist manager. The interview shall take place before the pharmacist is authorized to manage, except that in cases of hardship the pharmacist shall appear at the first Commission meeting held after the date the pharmacist commences work as manager.
DCP’s current First-Time Manager page is even stricter in operational language: pharmacists who have never served as a pharmacy manager must first appear before the Commission, and the appearance must take place before they assume the role. Repeat managers who already appeared do not interview again. During the COVID-19 public-health emergency, DCP temporarily processed some manager designations without an in-person appearance (email-only). That was a temporary operational workaround, not a repeal of § 20-576-23. Teach the current rule: personal interview, generally before assuming the role, hardship exception in the regulation only.
Manager compliance duties that the MPJE clusters here
The manager is the Commission’s named full-time responsible pharmacist. Concrete Connecticut duties include:
- Technician training records. Community pharmacy technician regulations, as published by DCP, make the pharmacist manager responsible for determining initial technician training, assuring continuing in-service competency, and keeping a written training record (name of the trainee, date(s), topics, supervisor, and signatures of the trainee and the manager). When the manager changes, the new manager reviews and signs that document.
- Hours and posting. Pharmacy open at least 35 hours/week unless a waiver/class rule applies; manager’s name posted in or next to the prescription department.
- Ratios and personnel. Community and institutional technician ratios (Chapter 4) are compliance obligations of the pharmacy under the manager’s watch.
- Controlled-substance inventory. Connecticut pharmacies and institutional pharmacies must maintain a perpetual inventory of Schedule II controlled substances (CGS § 20-633e / Public Act 18-16). The manager is the full-time pharmacist responsible for the pharmacy’s compliance systems, including that perpetual CII record.
- Change reporting. Immediate notice of manager change; five-day reports of the manager’s own name, home-address, or employment changes under RCSA §§ 20-576-10 and 20-576-11 (section 3.4).
DEA “pharmacist-in-charge” compared with Connecticut’s manager
DEA Form 224 (new pharmacy application for a DEA controlled-substance registration) identifies a pharmacist-in-charge for the registered location. That federal PIC is the person DEA holds out as responsible for the federal controlled-substance registration at that address. Connecticut still requires a pharmacist manager on the state pharmacy license.
The same human often fills both roles, but the rules are not interchangeable:
- Connecticut forbids managing more than one pharmacy at the same time.
- DEA registration is location-specific; each registered pharmacy has its own 224/224a file and a designated PIC for that DEA registration.
- Passing a DEA 224 PIC listing does not enroll the pharmacist as Connecticut’s manager, and a Connecticut manager designation does not by itself complete DEA registration.
If a stem says “PIC,” map it to pharmacist manager for Chapter 400j questions and to DEA 224 PIC for federal registration questions. Do not answer a Connecticut one-site management item with a federal “you can be PIC at several stores if you visit monthly” theory. Connecticut’s statute is one manager, one pharmacy.
Realistic Connecticut scenario
A chain district manager who already manages a Waterbury pharmacy is named manager of a new Naugatuck store “on paper” while remaining manager in Waterbury. That dual listing violates § 20-597(b) the day it is enrolled. A first-time manager who starts next Monday and plans to “catch the Commission next month” also fails the default § 20-576-23 timing unless a documented hardship exception applies. A manager out on a 50-day leave without a filed change of manager has, by regulation, ceased to be manager on day 42.
Official anchors
- CGS § 20-597.
- DCP change in pharmacy manager and first-time manager.
- RCSA §§ 20-576-21, 20-576-22, 20-576-23.
How many Connecticut pharmacies may one pharmacist manage at the same time under CGS § 20-597(b)?
When a Connecticut pharmacist manager leaves a pharmacy, who must notify the Commission of Pharmacy?
A pharmacist manager is absent from the pharmacy for 20 consecutive days, then remains out through day 45. What does RCSA § 20-576-22 require?