From: eroath@michiganpharmacists.org Sent: Monday, January 22, 2024 9:30 AM To: Joint Committee on Administrative Rules Cc: eroath@michiganpharmacists.org Subject: JCAR Committee Comments Person Completing Form Name : Eric Roath Phone : 906-282-8930 Email Address : eroath@michiganpharmacists.org Rule : 23-85 Pharmacy - General Rules Comment : Members of the committee, I have previously reached out to ask that the changes to the Board of Pharmacy General Rules be refused as the Board approved a decision to remove the requirement for pharmacists to pass a law exam for initial licensure without that proposal being included in the draft available for public comment. We felt that this did not give stakeholders adequate time to address the impact of such a decision through the public comment process. One such stakeholder has reached out to the Michigan Pharmacists Association with a new, startling concern that I bring to your attention now. Please don't hesitate to reach out to either myself, or the individual identified below, if you require addition information. Quoted text: "Good Afternoon Eric; I heard that Michigan may be removing the MPJE testing as a prerequisite for licensure. I have some very serious concerns with the removal of the test. My first concern is that my site is licensed in 47 states (non-resident licenses), and at present all of these states but one require their pharmacists to have pasted the MPJE test. I believe this will cause an issue for myself along with multiple other pharmacies dispensing from Michigan to other states (i.e. Alliance, and Optum). We would have to change our current hiring practices and limit hiring pharmacists to those that have taken the NAPLEX exam. This will definitely limit our ability to hire Michigan pharmacy graduates for future positions. My second concern is that these tests are used for proof of competency to practice legally as a pharmacist. I believe that the lawyers and legal system will have a field day on these graduates. They would use the non-test to show a lack of minimal competency which in turn will jeopardize themselves and their employers. Thus, deem them not hire able. I really question if these graduates would even be able to purchase liability insurance from the current vendors, similar to the new rules for compounding, they will not cover a pharmacist under a general liability umbrella. Please call if you have additional questions. Sincerely Douglas Samojedny RPh Director of Specialty Pharmacy Henry Ford Pharmacy Advantage Southfield 1191 South Blvd E., Rochester Hills, MI 48307 248 528-4530 /800 456-2112 Email dsamoje1@hfhs.org" This email was submitted via the Michigan Legislative Council Website to the JCAR Committee. If you received a copy of this email and you did not send this email, please contact the Committee by replying to this email.