3.2 Pharmacist-in-Charge Responsibilities

Definition and Statutory Basis

Every Pennsylvania pharmacy permit must name a pharmacist-in-charge (PIC) — also called the pharmacist manager — who is the licensed pharmacist responsible for the pharmacy's compliance with the Pharmacy Act and 49 Pa. Code Chapter 27. The role is defined in 49 Pa. Code §§ 27.1 (definitions) and 27.11 (pharmacy permit). The PIC is the person the Board will look to first when a permitted pharmacy violates law or regulation.

The PIC is not merely a title. By accepting the role, the pharmacist assumes affirmative duties: maintaining records, ensuring staff supervision, securing controlled substances, complying with labeling and counseling rules, and answering to the Board for the pharmacy's day-to-day practice. The PIC may be subject to vicarious liability — cited for violations occurring at the pharmacy even when they are not physically present, especially when inadequate supervision contributed to the violation.

Appointment, Removal, and Board Notification

When a pharmacy permit is issued, the permit holder names the PIC on the application. If the PIC leaves, the permit holder must notify the Board in writing of the change. A pharmacy cannot operate without a designated PIC; if the PIC departs suddenly, the permit holder must arrange for another qualified pharmacist to assume responsibility and file the change promptly.

A PIC may not serve as the pharmacist-in-charge for more than one pharmacy at the same time without Board approval. The Board may grant approval where the pharmacist demonstrates they can fulfill duties at each location — typically limited situations such as small or satellite operations. The default rule is one PIC, one pharmacy.

On-Duty Requirement

A Pennsylvania-licensed pharmacist must be on duty and in charge at all times the pharmacy is open. "On duty" means physically present at the permitted location and exercising professional supervision. If only one pharmacist is on duty, that pharmacist is functioning as the PIC for the shift even if another pharmacist holds the PIC designation formally.

If the pharmacy is open and no pharmacist is on the premises, the pharmacy is operating illegally — this is a frequently tested scenario. Technicians and interns may perform supportive tasks under supervision, but they cannot substitute for the presence of a licensed pharmacist.

Oversight of Technicians and Interns

The PIC is responsible for the supervision of all supportive personnel — both pharmacy technicians/technician trainees (under 49 Pa. Code §§ 27.701–27.705, effective June 28, 2025) and pharmacy interns (under § 27.26).

For each technician, the PIC or pharmacist-manager must maintain a written protocol under 49 Pa. Code § 27.12. The protocol describes the tasks the technician may perform, the training they have completed, and the supervision the pharmacist will provide. There is no fixed numeric pharmacist-to-technician ratio — the proposed 1:2 ratio was deleted in final rulemaking — but the pharmacist must provide "direct and immediate personal supervision."

Interns also act under direct and immediate personal supervision of a pharmacist (§ 27.12(c)). The PIC is responsible for ensuring interns practice only within their authorized scope and that intern hours are properly documented toward licensure.

Controlled-Substance Responsibilities

The PIC is the person the Board holds accountable for controlled-substance compliance at the permitted location. Specific duties include:

• Maintaining the initial and biennial controlled-substance inventories required by federal and Pennsylvania law.
• Ensuring DEA Form 222 (CII order forms) and DEA Form 41 (destruction/return) are executed and retained.
• Reporting theft or significant loss of controlled substances on DEA Form 106 within one business day of discovery.
• Maintaining PDMP (ABC-MAP) query compliance — dispensers must submit Schedules II–V dispensing data by close of the next business day, and prescribers/dispensers must query the PDMP the first time a controlled substance is dispensed to a new patient and each time an opioid or benzodiazepine is prescribed.
• Overseeing e-prescribing compliance — Pennsylvania has mandated electronic prescribing for CII–CV controlled substances since October 24, 2019.
• Ensuring the pharmacy's security requirements are met (controlled-substance storage, alarm systems where required, limited access).

Recordkeeping and Compliance

The PIC ensures that prescription files, dispensing records, inspections, and CE/training records for staff are maintained for the retention periods in 49 Pa. Code Ch. 27 (typically two years for prescription records and compounding records). The PIC also ensures compliance with patient counseling offer requirements — Pennsylvania requires an offer to counsel for all new prescriptions, stricter than OBRA '90 (Medicaid outpatients only).

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PIC Duties Summary