4.1 Pharmacy Interns: Licensure, Hours & Preceptors
Key Takeaways
- A pharmacy intern licence requires standing as a student in the first professional year of an approved college of pharmacy and current enrolment in a PharmD programme (247 CMR 8.01(2)).
- Licensure as a pharmacist requires 1,500 Board-approved internship hours: at least 1,000 in a pharmacy or pharmacy-related setting and at least 500 in clinical pharmacy, a demonstration project, manufacturing, or analytical/industrial pharmacy.
- A graduate of an ACPE-accredited college may instead satisfy the whole 1,500 hours through experiential pharmacy education.
- An intern may not receive more than 12 hours of internship credit in a day, and a preceptor may not directly supervise more than two interns at one time.
- An intern may supervise pharmacy technicians while acting under the direct supervision of a preceptor, and must notify the Board within 14 days of withdrawing from a PharmD programme.
Pharmacy Interns: Licensure, Hours & Preceptors
The pharmacy intern is a licensed category in Massachusetts, sitting alongside — not inside — the technician tiers. Everything about interns is in 247 CMR 8.01.
Eligibility for an Intern Licence — 247 CMR 8.01(2)
To be eligible for a pharmacy intern licence an individual shall:
- have achieved standing as a student in the first professional year in an approved college or school of pharmacy (or in a foreign school of pharmacy that has arranged internship experiences in collaboration with an approved college/school);
- be currently enrolled in a Doctor of Pharmacy (PharmD) programme; and
- be of good moral character.
[!WARNING] "Standing as a student in the first professional year" is not "having completed the first professional year." A student becomes eligible on attaining P1 standing, not on finishing P1. The application must include a certified statement from the college confirming that standing and PharmD enrolment.
A graduate of a non-approved college or school of pharmacy must, before beginning an internship in Massachusetts, hold NABP authorisation to sit the FPGEE issued within the preceding year, and must give the Board a copy of that authorisation (247 CMR 8.01(7)).
A PharmD graduate from an approved school who accepts a residency in Massachusetts must either hold a Massachusetts pharmacist licence or hold a Massachusetts intern licence and be supervised by a pharmacist (247 CMR 8.01(8)). And an intern who has graduated may continue to act as an intern until licensed as a pharmacist (8.01(10)).
The 1,500 Hours — 247 CMR 8.01(1)
Massachusetts specifies not only how many internship hours are required but where they must come from. There are two routes:
Route A — composed hours. At least 1,500 hours of Board-approved internship experience, of which:
- at least 1,000 hours are acquired in a pharmacy or pharmacy-related setting approved by the Board; and
- at least 500 hours are acquired in any one or any combination of Board-approved internships in:
- clinical pharmacy;
- a demonstration project;
- manufacturing; or
- analytical or industrial pharmacy.
Route B — experiential education. At least 1,500 intern hours acquired through experiential pharmacy education, provided the student is a graduate of an ACPE-accredited college or university. In practice this is the route most PharmD graduates take, because IPPE and APPE rotations are certified by the school.
Structural limits on hours
| Rule | Citation |
|---|---|
| No more than 12 hours of internship credit per day | 247 CMR 8.01(4) |
| Hours may be acquired throughout a calendar year | 247 CMR 8.01(5) |
| Out-of-state internship hours may be credited where the other jurisdiction certifies approval | 247 CMR 8.01(11) |
| Massachusetts schools must submit written descriptions of demonstration projects and clinical programmes for the Board to decide whether hours count | 247 CMR 8.01(12) |
Supervision and Scope
An intern shall work under the direct supervision of a registered pharmacist preceptor (247 CMR 8.01(3)). Two supervision rules are heavily tested:
- An intern may supervise pharmacy technicians while acting under the direct supervision of a registered pharmacist preceptor (247 CMR 8.01(15)). This is a genuine grant of authority — technicians can be working to an intern, provided the preceptor is supervising the intern.
- A preceptor may not directly supervise more than two pharmacy interns at one time (247 CMR 8.01(16)).
[!IMPORTANT] Interns are not outside the ratio. A recurring misconception is that interns "do not count" toward pharmacy staffing limits. In Massachusetts the opposite is true: interns are support personnel under 247 CMR 8.06(3), and an intern is one of the two credentials (the other being a certified pharmacy technician) that unlock the larger ratios. See section 4.3.
Identification and notification
- An intern must wear a name tag with the intern's name and the words "pharmacy intern" (247 CMR 8.01(14)).
- An intern must give the Board written notification within 14 days of withdrawing from an approved college/school of pharmacy or PharmD programme (247 CMR 8.01(18)).
- An intern found to have violated federal or state law may be barred from taking the licensure examination, in addition to other sanctions (247 CMR 8.01(17)).
Where Interns Sit Relative to Technicians
| Function | Intern | Certified pharmacy technician | Pharmacy technician |
|---|---|---|---|
| Receive a new oral prescription for a Schedule VI drug | Yes | Yes, with the pharmacist's approval | No |
| Request/accept a refill authorisation (nothing changed) | Yes | Yes | Yes, with pharmacist approval |
| Transfer a Schedule VI prescription | Yes | Yes, with pharmacist approval | No |
| Perform prospective DUR | Yes | No | No |
| Counsel a patient | Yes | No | No |
| Final dispensing process validation | No | No | No |
| Handle hydrocodone-only ER, non-abuse-deterrent | Yes | No | No |
| Supervise pharmacy technicians | Yes | No | No |
The last two rows are Massachusetts-specific and are exactly the kind of detail the MPJE builds items around. 247 CMR 8.05(3) bars every technician tier from handling hydrocodone-only extended-release products that are not in an abuse-deterrent form, while expressly permitting interns under direct supervision to handle them. And final dispensing process validation is reserved to the pharmacist under 247 CMR 9.04 — an intern cannot perform it either.
A second-year PharmD student wishes to obtain a Massachusetts pharmacy intern licence. Under 247 CMR 8.01(2), what academic standing must the applicant demonstrate?
A Massachusetts intern is documenting hours under the composed-hours route of 247 CMR 8.01(1)(a). How must the 1,500 hours be distributed?
A preceptor pharmacist at a busy teaching hospital is asked to take on a third pharmacy intern for the summer. What does Massachusetts law permit?