Section 3.2: Pharmacy Technicians and Technician Trainees

Section 3.2: Pharmacy Technicians and Technician Trainees

In Texas, the support staff assisting in the technical aspects of drug preparation and distribution are divided into two distinct legal classes: Pharmacy Technicians and Pharmacy Technician Trainees. Under the Texas Pharmacy Act and TSBP Rule Chapter 297, anyone performing technical duties in a pharmacy must be registered with the board. Understanding the distinctions, registration requirements, renewal processes, and continuing education mandates for these two groups is critical for the MPJE.

1. Legal Distinctions and Registration Requirements

The primary difference between a technician and a technician trainee lies in national certification.

Pharmacy Technician Trainees

A trainee is an entry-level individual who has not yet passed a board-approved national certification exam.

• Eligibility: Must possess a high school diploma or a high school equivalency certificate (GED), or be currently enrolled in a program to obtain one (for a maximum of two years).
• Background Screening: Must complete a criminal history check, including fingerprinting through the board's designated vendor.
• Trainee Term Limits: Trainee registration is valid for exactly two years from the date of issuance.
• Non-Renewable Status: This registration is strictly non-renewable, non-extendable, and non-transferable. If a trainee fails to pass a national certification exam and register as a technician within these two years, their trainee registration expires, and they cannot legally perform any technician duties. A person can only hold a trainee registration once in their lifetime.

Registered Pharmacy Technicians

A registered technician is an individual who has successfully demonstrated competence by passing a national certification exam.

• Eligibility: Must possess a high school diploma or GED.
• National Certification: Must hold a current, active certification from a board-approved national program. Currently, TSBP recognizes the Pharmacy Technician Certification Exam (PTCE) administered by the Pharmacy Technician Certification Board (PTCB) and the Exam for the Certification of Pharmacy Technicians (ExCPT) administered by the National Healthcareer Association (NHA).
• Background Screening: Must complete fingerprinting and pass a criminal history check.
• Registration Term: Registration is valid for two years and must be renewed biennially.

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2. Continuing Education (CE) Requirements

Under 22 TAC §297.8, registered pharmacy technicians must complete continuing education to maintain their registration.

• Hours Required: Technicians must complete 20 contact hours of approved continuing education during each two-year renewal cycle.
• Mandatory Texas Law CE: Within the 20 hours, at least one contact hour must be related to Texas-specific pharmacy law. This law CE must be approved by the TSBP or be a law program specific to Texas.
• Compounding CE Requirements: If a technician is engaged in compounding sterile preparations, they must complete specific sterile compounding CE. This includes completing a board-approved training course (minimum 40 hours of instruction and hands-on experience) and at least 2 hours of sterile compounding-related CE during each renewal period. For non-sterile compounding, the technician must complete a minimum of 40 hours of initial training.
• PTCB Recertification Nuance: Maintaining national certification (PTCB or NHA) is not a state requirement for renewal of the TSBP registration, but if a technician chooses to maintain it, they can use their national CE hours toward the state's 20-hour requirement. However, they must still ensure they obtain the mandatory one hour of Texas-specific pharmacy law CE, which is not typically covered in national certification CE packages.

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3. Pharmacy Technician Training Manuals and Documentation

All pharmacies utilizing technicians or trainees must have a robust, site-specific training program.

• Written Training Manual: The PIC must develop, implement, and maintain a written policy and procedure manual that outlines the training program for technicians and trainees.
• Training Content: The training program must cover, at a minimum:
  1. Pharmacy terminology, drug abbreviations, and dosage forms.
  2. Basic pharmaceutical calculations.
  3. Data entry procedures and computer system operations.
  4. Prescription packaging, labeling, and storage requirements.
  5. State and federal laws regarding prescription filling, controlled substances, and patient confidentiality (HIPAA).
• PIC Documentation: The PIC must document that each technician or trainee has completed the training. This documentation must include the dates of training, specific topics covered, and the signature of both the technician/trainee and the PIC.
• Record Retention: Training records must be kept by the pharmacy for at least two years after the technician or trainee leaves employment at that facility.

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4. Exam Traps & Legal Nuances

• Working While Application is Pending: A candidate cannot perform any technician duties until they have been issued an active registration number by the TSBP. It is a common exam trap to suggest that a trainee can start working under direct supervision while their application is "in process" or after they have completed fingerprinting. Working without an active registration number on the TSBP website is a violation of law that will result in disciplinary action against the individual, the PIC, and the pharmacy permit holder.
• The Non-Renewability of Trainee Registration: If a trainee registration expires, there is no "grace period." If the trainee is scheduled to work the day after expiration, they must be taken off the schedule for any technical duties. They can only work in non-pharmacy roles (like cashiers) and cannot count, label, or enter prescriptions.
• The "Technician-in-Training" Misnomer: The board does not recognize the term "technician-in-training." On the exam, always look for the legal term Pharmacy Technician Trainee.
• Expired National Certification: While national certification is required for initial registration as a technician, the TSBP does not require technicians to maintain their national certification (PTCB/NHA) to renew their TSBP registration. However, many employers require it, and if it is allowed to lapse, the technician must still complete the 20 hours of CE (including 1 hour of Texas law) directly to renew their TSBP registration.