5.2 Pharmacist-in-Charge Duties

5.2 Pharmacist-in-Charge Duties

Quick Answer: Under 225 ILCS 85, the pharmacist-in-charge (PIC) is the licensed pharmacist whose name appears on a pharmacy license and who is responsible for all aspects of the operation related to the practice of pharmacy. 68 Ill. Adm. Code 1330.660 requires a designated PIC who is routinely and actively involved, sets multi-site 8 hours/week average expectations, assigns core supervision/security/record duties, and mandates 30-day written notice of PIC changes by the departing PIC and the pharmacy license holder, plus an incoming PIC controlled-substance inventory on the change date.

Area 1.1.1 of the NABP competency map (PIC/pharmacist qualifications and scope) is pure Illinois operational law. Treat the PIC as the named compliance owner of the pharmacy’s practice systems—not merely the highest-paid pharmacist on the schedule.

Statutory Definition (225 ILCS 85)

The Practice Act definition is short and testable:

• PIC = the licensed pharmacist whose name appears on a pharmacy license
• Responsibility = all aspects of the operation related to the practice of pharmacy

No pharmacy license issues without a designated PIC. The face of the pharmacy license identifies that person. When ownership, staffing, or multi-site management blur lines, return to the name on the license and the practice-of-pharmacy scope of responsibility.

Section 1330.660 — The Operating Rule

Designation and active involvement

1330.660 establishes:

Exam contrast: Some states allow only one PIC assignment with almost no multi-site flexibility. Illinois allows multi-site PIC service if the 8-hour weekly average (and documentation when not verifying/dispensing) is met. Do not import a “one pharmacy only forever” rule from another jurisdiction.

Core PIC responsibilities (d)

The responsibilities of the PIC shall include:

1. Supervision of all activities of all employees as they relate to the practice of pharmacy
2. Establishment and supervision of the method and manner for storage and safekeeping of pharmaceuticals, including security when the pharmacy is closed (see 1330.600)
3. Establishment and supervision of the recordkeeping system for the purchase, sale, delivery, possession, storage, and safekeeping of drugs

These three bullets are the skeleton of most PIC vignettes. Expand them in practice to policies and procedures, technician training and duty assignment, inventory integrity, CS security culture, computer and hard-copy records, and a compliance culture that does not punish legitimate patient-safety reporting.

Dual responsibility with the owner (e)

Operations of the pharmacy and establishment and maintenance of security provisions are the dual responsibility of the PIC and the owner of the pharmacy. Owners cannot hide behind “the PIC handles clinical stuff.” PICs cannot claim “corporate security is not my problem.” Exam answers that assign 100% of security solely to corporate or 100% solely to a staff pharmacist who is not the PIC are usually wrong when the stem is about pharmacy-level security systems.

Change of PIC — Notification, Inventory, Consequences

Who notifies, and when?

1330.660(f): Within 30 days after a change of PIC, the Division shall be notified in writing by:

1. the departing PIC, and
2. the pharmacy license holder

Statute-level PIC change duties in the Practice Act are aligned with this dual-notification concept (departing PIC and owner/license holder responsibilities). IDFPR compliance communications have repeatedly flagged failure of the departing PIC to notify as a common violation—use the pharmacy reporting tools on the IDFPR site rather than assuming HR emailed “someone.”

Incoming PIC controlled-substance inventory

In addition to the 30-day notice, the incoming PIC shall, on the effective date of the change, inventory:

The pharmacy license holder is equally responsible for ensuring the inventory is completed (1330.660(g)(3)). That inventory is the closing inventory of the departing PIC and the initial inventory of the incoming PIC, and the record must be preserved in the pharmacy for 5 years (1330.660(h)).

If the departing PIC refuses, is incapacitated, or is deceased, the incoming PIC still completes an initial inventory and is not responsible for discrepancies that existed before that initial inventory (1330.660(j)).

Failure to notify

1330.660(i): Failure of a pharmacy to provide the required PIC-change notification is grounds for denying an application or renewal application for a pharmacy license or for disciplinary action against a pharmacy.

Policy, Training, and Patient-Safety Culture

PIC duty is not only inventory night. Across Part 1330 and the Act, the PIC (often jointly with the pharmacy) is accountable for systems such as:

• Written policies and procedures specifying duties of each employee and ensuring adequate training (staffing rules in facility-type sections reinforce PIC training duties)
• Technician registration compliance and supervision standards (no fixed statewide numeric tech ratio—judgment and rule-based supervision; details in Chapter 6)
• Counseling systems and DUR workflows that staff cannot lawfully bypass
• Security and after-hours access limited to appropriate registrants/licensees
• Record retention for legend drugs and CS invoices (on-site for at least one year; overall retention concepts tied to Section 18 of the Act and 5-year invoice themes in 1330.660(l))
• Service-type changes: when a pharmacy intends to change or add listed pharmacy service types, notify the Division no less than 30 days prior (1330.660(m))

Temporary closure > 72 hours

Under 225 ILCS 85/16, if a pharmacy temporarily closes for more than 72 hours, it is the duty of the PIC and the owner to report to the Department (with customer notification/signage expectations taught in operations chapters). This is a classic dual-duty stem: both names appear in the statute’s duty language.

Joint responsibility for tech training / patient safety alerts

The Act and rules repeatedly pair pharmacy + PIC when training and safety are at issue—for example, ensuring staff (including supportive staff) are trained on counseling protocols, recordkeeping, safety, and privacy in specific operational settings, and filing patient-safety termination reports under 225 ILCS 85/30.1 (detailed in Section 5.4). On the exam, if a tech was never trained on a high-risk process, expect the fact pattern to pull PIC systems responsibility even when a staff pharmacist made the last click.

Common Exam Vignettes

Action Checklist for Section 5.2

1. Define PIC from 225 ILCS 85 (name on pharmacy license; practice-of-pharmacy operational responsibility).
2. Memorize 1330.660 multi-site 8 hr/week, 90-day leave, and one named PIC who is routinely/actively involved.
3. Recite the three core duty categories: employee practice supervision, storage/security, drug record systems.
4. Drill 30-day dual notification + incoming CS inventory (II exact; others estimated; 5-year record).
5. Keep dual PIC/owner responsibility ready for security, closure, and training stems.

PIC competence is the bridge from licensure theory to daily pharmacy operations—and the next section shows what happens when those duties fail.