Survey Introduction:
The AACP Experiential Task Force for Draft Standards 2016 has been charged with seeking
input from the AACP Experiential Education (EE) Section members on the new Draft Standards
2016 with respect to areas affecting EE. The charge specifically reads:
"Draft a response of feedback for the Board's appointment committee using the following
guideline:
a. Clearly state specific issues or concerns about the Standard in question and offer possible
solutions. Please be specific and constructive in your feedback.
b. Where applicable, clearly state positive comments and why the change in a given Standard is
desirable."
We have sent this survey to the Dean of every School/College of Pharmacy to streamline our
responses and collect ONE response from each School/College. We ask that this survey be
completed by the most appropriate individual (e.g. Director of EE, etc.) but that all stakeholders
in your institution contribute to the statements given by this representative.
The survey will focus on those areas that are most applicable to EE (Pre-APPE Curriculum,
APPE Curriculum, Preceptors, Practice Facilities, Appendix 2, Appendix 3, Appendix 4, and the
Guidance Document). It will also provide a "catch all" opportunity to provide feedback on ALL
Standards as they relate to EE. Please complete the following survey by FRIDAY, JULY 11th at
5:00PM. We appreciate your time and consideration of this important matter.
Standard 12: Pre-Advanced Pharmacy Practice Experience (Pre-APPE)
Curriculum
 46 COMMENTS FOR THIS SECTION
 NO COMMENT OR RECOMMENDATIONS FOR ANY CHANGE - 14 responses
SUPPORT:



This standard provides clarity to IPPE hours, core activities, and simulation experiences
(5 responses)
“In general, the change to address the pre-APPE curriculum is a positive change as this
seems to provide general advice, not specific implications” (2 responses)
300 hours is appropriate and there is a good balance between community and
institutional hours. (2 responses)
SUGGESTED CHANGES:



Clarification of terminology (16 responses):
o “Exemplary pharmacy practice” (12.4)
o “Threaded throughout” (12.5): Does this mean that IPPEs cannot be done in
summer blocks?
o Other terms from standard 12.4: “contemporary”, “professional ethics and
expected behaviors”, “direct patient care”
o Other terms from standard 12.5: What constitutes an institutional site?
Ambulatory care is linked with community in other standards, so are they linked
in this standard? Does “balanced” mean 75 hours each in community and
institutional health-system?
Concerns about hours requirements (9 responses):
o There have not been data communicated to support 300 hours of IPPE time, and
this requirement places a heavy burden on pharmacy schools and practice sites.
o “Reflection is not listed as part of the 300 hour requirement. What percentage of
the 300 hours can be allocated toward reflection?”
o RECOMMENDATION: “Flexibility with the specific hours requirement would be
helpful. It would be helpful it schools could focus on specific learning objectives
and outcomes rather than number of hours.” (Other respondents also said this is
preferred over particular settings)
o RECOMMENDATION: Increase the amount of simulation allowed to 80 hours
o RECOMMENDATION: Allow an ambulatory care IPPE to count towards a portion
of the 150 hours reserved for community/institutional settings.
o RECOMMENDATION: Allow schools to use sites outside of the U.S. (such as in
Canada) for IPPE hours, holding the school accountable for the same vetting and
evaluation process used for U.S. sites.
Concerns about simulation activities (7 responses):
o The new standards for simulation indicate that “didactic instruction associated
with the implementation of simulated practice experiences must not be counted
toward any portion of the 300 clock hour IPPE requirement.”
o
o
o
o
There was concern about whether all simulation experiences must be those that
are difficult to achieve in actual practice and how tightly schools should regulate
these experiences.
RECOMMENDATION: Allow for training for point of care testing to count for
IPPE hours.
RECOMMENDATION: Allow for simulation to be part of laboratory coursework
and still count as IPPE hours.
RECOMMENDATION: Allow schools to use simulation for institutional IPPE
requirements since there is little consistency for this setting.
Guidance for Standard 12: Pre-Advanced Pharmacy Practice Experience
(Pre-APPE) Curriculum
 42 COMMENTS FOR THIS SECTION
 NO COMMENT OR RECOMMENDATIONS FOR ANY CHANGE - 13 responses
SUPPORT:



“I appreciate the greater clarification on simulation” (3 responses)
The guidance document is concise and helpful. (1 response)
“The use of the term ‘Early IPPE’ was good to see. We have been using that term for
several years to identify the initial experiential education in our program.” (1 response)
SUGGESTED CHANGES:


Concerns about IPPE Exemptions (16 responses):
o The majority of concerns about IPPE exemptions related to the fact that a
student may be paid for employment (and therefore may be exempt from an
IPPE) yet may not be paid for a practice experience.
o Another concern about this exemption is because there are different objectives
for an IPPE compared with paid employment. IPPEs are designed to reflect what
is learned in the classroom. A student may still have a new experience in a
practice site where they have previous experience.
o Several respondents were unclear whether this guidance indicates that a student
is exempt from an actual practice experience or simulation. And, if the student is
exempt, whether they would still be required to obtain 300 IPPE hours.
o RECOMMENDATION: Clarify how the exemption process fits in with required
IPPE hours.
o RECOMMENDATION: One respondent suggested instead that schools “work
with preceptors to be able to assess students’ level of knowledge and work to
enhance their knowledge in a given area.”
Concerns about simulation (4 responses):
o There is confusion whether simulation can be part of a didactic course. There
were opinions voiced on both sides of this issue. One opinion was that “the
outcome achieved, not the structure of the curriculum, should dictate what meets
o
the requirement of the standard”. Another opinion is that this is considered
“double-dipping.”
Interprofessional simulation “is unrealistic and impractical to schedule”.
Standard 13: Advanced Pharmacy Practice Experience (APPE) Curriculum
 52 COMMENTS FOR THIS SECTION
 NO COMMENT OR RECOMMENDATIONS FOR ANY CHANGE - 19 responses
Standard 13: Advanced Pharmacy Practice Experience (APPE) Curriculum
A continuum of required and elective APPE must be of the scope, intensity, and
duration required to support the achievement of the Educational Outcomes
articulated in Standards 1-4 and within Appendix 3 to prepare practice-ready
graduates. APPE must integrate, apply, reinforce, and advance the knowledge,
skills, attitudes, abilities, and behaviors developed in the Pre-APPE curriculum
and in co-curricular activities.
SUPPORT:

A clear focus on the curriculum in this Standard is a positive move from the
current standard.

There is support for the new categories for APPE rotations, with the thought that
it more closely resembles pharmacy practice. Some of this, however, assumes
that Am Care will not be required in the new standards (merging with
community), which may not be the intention of the document.

Patient care is the priority, and this is clearly spelled out. Diversity in patient
exposure is also seen as positive (but may also require better defining)

There is appreciation for the integration of interprofessional training into the
standard (although a need for it to be further defined)
SUGGESTED CHANGES:

Concern about definitions and wording within the standard
o Minimize “buzz words” and use consistent language (ie continuity of care,
transitional care services). (“innovative”, “in depth”, how will these be
assessed by a site team?) (4 responses)
o Defining diversity leaves too much out, and implies all must be met (8
responses)
o “Diverse geographic locations” – there is some confusion as to what this
means; is it rural vs urban? International? ( 11 responses)
RECOMMENDATION: There needs to be some clarification on both diversity and
diverse geographic locations, to help people understand what “minimums” must
be met within a program.
o “Hospital/Health systems”- Is this institutional, or does health system
extend into AmCare settings (6 responses)
 13.1 seems to conflict with 13.6, with “inpatient/health-system” vs
“hospital/health systems”
 Standard 12 refers to “community and institutional”; another
terminology discrepancy
RECOMMENDATION- Clear efforts should be made throughout the Standards for
uniform terminology, particularly in defining a hospital or health system
o (13.3) Concern about the interprofessional team- not defined (20
responses)
 Some interpret this to mandate “rounds” in hospitals
 Does this mandate interprofessional students interacting, or one
student and other practitioners? (4 responses)
 What does “in depth” mean here? (4 responses)
 What does “majority” of experiences mean?
RECOMMENDATION: Some clarification as to what “interprofessional” is defined
as, and perhaps examples of how this could be met, would help to alleviate these
concerns. Is it expected for IPE to be part of every required rotation? This is
interpreted as true by many. Examples of what pharmacy students should be
expected to do as part of IPE would also be helpful, when possible

Concern about increasing geographic restrictions to extend to electives (8
responses)
o Some people are in favor of removing this restriction, or including Canada

Concern about specific patient care model cited in 13.1 (JCPP model)
o Thoughts that this model may not remain in date or be accessible to
everyone, or applicable to all settings (3 responses)
o If this is to be cited, the reference needs to be available (6 responses)
RECOMMENDATION: If the JCPP model remains in the Standards, a link to this
should be provided for easy access.

(13.6) Concern about stated 400 hour requirement for APPE groups, and of
the grouping of APPEs themselves (24 responses)
o 4 week rotations or monthly APPEs will fall short of this requirement
RECOMMENDATION: There needs to be an accommodation for programs with 4
week APPEs, (ie reduce to 8 weeks or 320 hours) or a global decision that 4 week
APPEs will not be allowed; otherwise this will require programs to mandate 3
APPEs to reach 1000 hours. There is concern that there is not logistical support
for programs to expand to 3 required APPEs.
o Question about grouping community and Am Care APPE- does this mean
5 weeks minimum of each, or can one replace the other? (13 responses)
Note: Some see excluding one for the other as a positive, while others
are very concerned about excluding one in a pharmacist’s education
RECOMMENDATION: Some clarity is needed in section 13.6 regarding the
grouping of Am Care and Community, and if one can replace/the other, or if the
time should be split even between the two settings. Same would go for
hospital/health systems. Clearly defined required rotations and number of
required hours should be outlined, as this will likely be the most scrutinized part
of the standard for Experiential.

Concern about specified “timing” for APPEs (13.4) (8 responses)
o Can students engage with didactic/ capstone courses after APPEs have
started?
o Electives are often offered during APPEs, why do they need to be
completed prior? (3 responses)
o Some programs start APPEs in P3 spring and allow electives during
APPEs
RECOMMENDATION: It appears that many programs have some type of didactic
work going concurrently with APPEs. It may be useful to build in some latitude to
allow electives or other type of coursework to go on during APPEs, instead of
specifying these must be completed prior to the APPE year.
Guidance for Standard 13: Advanced Pharmacy Practice Experience
(APPE) Curriculum
 43 COMMENTS FOR THIS SECTION
 NO COMMENT OR RECOMMENDATIONS FOR ANY CHANGE - 17 responses
Note: Most of these comments reiterated concerns above, and were included
above instead of repeating those concerns here in the guidance section.
SUPPORT:

The new version more clearly describes the patient care emphasis of APPEs,
and should help with preceptor development

There is more guidance on the balance between three key areas: Am
care/community, hospital/health systems, electives
SUGGESTED CHANGES:

Part-time rotations
o There’s concern about allowing part-time rotations along with full-time
ones, and the logistics of tracking them (2 responses)
Standard 21: Preceptors
 44 COMMENTS FOR THIS SECTION
 NO COMMENT OR RECOMMENDATIONS FOR ANY CHANGE - 9 responses
The college or school must have a sufficient number of preceptors (practice faculty or external
practitioners) to effectively deliver and evaluate students in the experiential component of the
curriculum. Preceptors must have professional credentials and expertise commensurate with
their responsibilities to the professional program.
Support:
Several comments indicating appreciation, mostly for making “Preceptors” its own Standard.
(6)
Suggested Changes:
There should be a consideration of other health care providers such as nurses and
physicians, physician assistants as preceptors especially for the IPPEs. (1)
21.1. Preceptor criteria – The college or school must make available and apply quality criteria
for preceptor recruitment, orientation, performance, and evaluation. Experiential education
preceptors must be qualified licensed pharmacists unless a compelling case can be made for
alternative practice credentials.
Support:
Comments indicating appreciation for the flexibility and lack of restriction regarding who can
be a preceptor. (2)
Suggested Changes:
Several comments indicating concern regarding the phrase “Experiential education preceptors
must be qualified licensed pharmacists unless a compelling case can be made for alternative
practice credentials.” The interpretation of “compelling case” may preclude the used of nonpharmacist preceptors. Placements outside on hospital and community pharmacies, in
understaffed public health clinics and other ambulatory sites, in certain IPPE activities, in rural
areas, and in critical interprofessional education opportunities might commonly have and
require non-pharmacists preceptors. Several individuals pointed out that this Standard may
impair our ability to provide interprofessional, rural, or ambulatory care experiences. In these
and other experiences (research), non-pharmacist preceptors (physician and mid-level
practitioners, scientists, etc.), should be, if not encouraged, then at least allowed by ACPE.
(14)
Recommendation: Modify the statement as follows: “Experiential education preceptors for
ACPE required experiences must be qualified licensed pharmacists. Preceptors for elective
rotations may be appropriately qualified non-pharmacists specific for the practice setting.”
21.2. Student to preceptor ratio – Student to precepting pharmacist ratios must allow for the
individualized mentoring and targeted professional development of learners.
Support:
None
Suggested Changes:
Comments suggesting the ratio is vague and perhaps difficult to capture from experiential
management systems (2)
21.3. Preceptor education and development – Preceptors must be oriented to the program’s
mission, the specific learning expectations for the experience outlined in the syllabus, and
effective performance evaluation techniques before accepting students. The college or school
must foster the professional development of its preceptors commensurate with their educational
responsibilities in the program.
Support:
No comments
Suggested Changes:
Comments suggesting that there is not enough clarity regarding “foster” and that this Standard
may be best directed toward new preceptors. (5)
Recommendation: Modify the statement as follows: “New preceptors must be oriented to the
program’s mission, the specific learning expectations for the experience outlined in the
syllabus, and effective performance evaluation techniques before accepting students. The
college or school must promote the professional development of its preceptors commensurate
with their educational responsibilities in the program.”
21.4. Preceptor engagement – The college or school must solicit the active involvement of
preceptors in the continuous quality improvement of the educational program, especially the
experiential component.
Support:
No comments
Suggested Changes:
Comment suggesting that the active involvement of preceptors is challenging to measure. (1)
21.5. Experiential education administrator – The experiential education component of the
curriculum must be administered by a pharmacy professional with knowledge and experience in
experiential learning. This administrator must be supported by an appropriate number of
qualified professional, administrative, and clerical staff.
Support:
No comments
Suggested Changes:
Comments suggesting that there is not enough clarity regarding “appropriate number of
qualified professional, administrative, and clerical staff.” (6)
Comment regarding the phrase “the experiential education component of the curriculum must
be administered by a pharmacy professional. We believe this limits the opportunity to engage
others who possess valuable skills and insights who are non-pharmacists. For example,
individuals with expertise in educational models (M.Ed. or D.Ed) may bring excellent
management and innovation to experiential education programs beyond what a practicing
pharmacist may have. We agree that pharmacists should be involved in EE programs, likely
as the EE director but also possibly as an associate director or as a supervisor to the EE
director, such as a dean-level position.
Recommendation: That ACPE not limit the experiential education director to only being a
pharmacist, but rather recommend that at least one pharmacist with practice experience be
included somewhere in the leadership structure of the experiential education program.
Guidance for Standard 21: Preceptors
 40 COMMENTS FOR THIS SECTION
 NO COMMENT OR RECOMMENDATIONS FOR ANY CHANGE - 15 responses
21a. Student-to-preceptor ratios – In addition to the issues stated within the Standard 21,
student:preceptor ratios for the practice experience components of the curriculum should be
adequate to provide individualized instruction, guidance, and evaluative supervision, and to
comply with state statutes and regulations. In most situations, this ratio for IPPE and APPE
should not exceed 3:1 and 2:1, respectively. (21.2)
Support:
Several comments indicating appreciation for the flexibility regarding ratios, and indicating
general agreement with them. (5)
Suggested Changes:
Several commenters are concerned about listing specific ratios. For example, some schools
have rotations that use a “layered learner” approach to experiential teaching. This model
expands the number of learners under a preceptor, but optimizes teaching time by having
higher-level learners teach the lower-level learners. This model is of course quite successfully
used in the medical education model. (8)
Recommendation: The guidance recommendation should be changed to suggest an optimal
ratio could be 2:1 for traditionally precepted APPEs, but that individual sites/preceptors can
alter the ratio if they are optimized to effectively precept learners.
21b. Aptitude for teaching – Preceptors should demonstrate a desire and an aptitude for
teaching that includes the important roles necessary for teaching clinical problem solving
(instructing, modeling, coaching, and facilitating). (21.1 & 21.3)
Support:
None
Suggested Changes:
Comments indicating concern regarding the phrase “Aptitude for testing.” This term seems to
have not obvious measure, other that the preceptor does teach. It also may be better to look
for a desire to facilitate learning (student centered) rather than teaching (preceptor centered).
(3)
21c. Additional attributes of preceptors – In addition to the requirements stated within the
standard, preceptors should be positive role models for students and who demonstrate the
following behaviors, qualities, and values (as applicable to their area of practice):
Support:
None
Suggested Changes:
Comments regarding the difficulty in assessing several of these behaviors, qualities or values
(e.g., “demonstrate creative thinking that fosters an innovative, entrepreneurial approach to
problem solving”), and that this guidance is unnecessarily prescriptive. Additionally most of the
items listed are the attributes of positive practice role models; while important, they are
insufficient. This list should provide more examples of attributes of good preceptors and their
precepting abilities. Having an “aptitude for learning” is important, but having the ability to
facilitate learning is much more important. The ability to provide timely and understandable
feedback is another critical preceptor attribute that should be assessed and developed. (4)
Recommendation: Modify the list to include: “have the ability to facilitate learning” and “have
the ability to provide timely and understandable feedback.”
21d. Preceptor appointments – Practitioner preceptors may be volunteers or paid program
contributors, depending on local customs. Appropriate academic titles (e.g., Adjunct Associate
Professor, Clinical Professor) should be considered for preceptors. Educational support (e.g.,
access to library resources and software used in the student education and evaluation process,
provision of continuing professional education programs and materials) should be provided to
preceptors to facilitate clinical skill development and the ability to mentor and evaluate students.
Development of formal mechanisms through which preceptors may officially affiliate with the
college or school is encouraged. (21.1)
Support:
None
Suggested Changes:
The guidance refers to preceptors officially affiliating with the school. Historically, sites have
affiliated with schools while preceptors have applied and been appointed. The inference of
preceptors affiliating becomes a much more complicated, labor-intensive process. (1)
Recommendation: Clarify the intent of preceptors affiliating to distinguish the difference from
being accepted or appointed.
Standard 23: Practice Facilities
 41 COMMENTS FOR THIS SECTION
 NO COMMENT OR RECOMMENDATIONS FOR ANY CHANGE - 26 responses
SUPPORT:






OK with this one as is.
Very appropriate.
In support of/currently following all items listed there.
We do these things already.
Clear and concise.
Appreciate the emphasis on diversity. Appreciate the inclusion of contemporary services.
Appreciate inclusion of non-patient care sites.
SUGGESTED CHANGES:
23.2: Written agreements ……4 comments
o
o
o
Current standard states agreements must be in place for sites that are “routinely used”.
Concern about need to establish an agreement with a site only used once. – 2
comments
Some agencies (FDA, CDC, AACP, Board of Pharmacy) will not sign agreements.
Concern re: “in accordance with state and federal laws”. Schools have little leverage and
often are required to use the training site’s agreement
23.3: Sites must be evaluated “regularly”…..6 comments
o
o
Seeking definition of regularly – 4 comments
Are student evaluations and feedback adequate evaluation? Or can they be
included in this assessment? – 2 comments
23.3: Sites must be evaluated regularly and “new goals” established…..4 comments
o
o
o
Reword second half of sentence to delete the word “new”. Difficulty with implication that
the College would work with sites to create new goals when needed. What happens to
the previous goals? Are they discarded?
Are these goals set jointly by the preceptor and School? Is what is meant that when
there is an identified improvement needed at the site to support student learning, it is
monitored for such improvement? Suggested wording: Site must be evaluated regularly
and realistic improvements needed to support student learning outcomes should be
communicated and followed.
Section is not clear as to establishing new goals. Is this suggesting a formal plan for
each site? There is no guidance to this part of the standard.
Guidance for Standard 23: Facilities
 38 COMMENTS FOR THIS SECTION
 NO COMMENT OR RECOMMENDATIONS FOR ANY CHANGE - 24 responses
SUPPORT:
o
o
o
Overall, I am fine with this standard and have no other comments.
In support of/currently following all items listed there.
23.b clarifies non-patient care sites which is helpful; 23.c clear and concise.
SUGGESTED CHANGES:
23a: Additional selection criteria….7 comments
o
o
o
o
o
Some of the items in this list cannot be known when the site is first identified and
consequently cannot be selection criteria. The might better be described as “Additional
selection and/or monitoring criteria”.
Bullet 1: “a patient population that exhibits diversity. Example of diversity may include
but are not limited to ethnic and/or socioeconomic, cultural, medical conditions, gender,
and age”. Otherwise, a pediatric or geriatric facility night not fit the criteria for diversity in
age.
Bullet 10: (e.g., not stocking cigarettes and other tobacco products)…4 comments
Concern that many community pharmacy sites stock these products and the pharmacy
has no say over the matter. Do these sites need to be excluded?
Replace “a strong commitment to health promotion….” With “demonstrated” concern.
Need a set of criteria for practice sites with which to develop appropriate site evaluation
forms/checklists.
These selection criteria are focused on patient care, useful for core required rotations,
but not so for non-patient care electives.
23c: Official agreements…..2 comments
o
o
Modify wording to require affiliation agreements for sites used on an ongoing basis.
Not all affiliation agreements address health services, malpractice, criminal background
checks, etc. Last line of 23c is unnecessary.
Other:
o
o
Clarify or give examples of “quality improvements made to improve student learning
outcomes as a result of assessment”. Not addressed in guidance.
No guidance provided on 23.3 Evaluation of Standard 23. Need clarification on
establishing goals for sites.
Appendix 2: Required Domains or Pre-Advanced Pharmacy Practice
Experiences Within the Doctor of Pharmacy Curriculum
 35 COMMENTS FOR THIS SECTION
 NO COMMENT OR RECOMMENDATIONS FOR ANY CHANGE - 15 responses
SUPPORT:



Pre-APPE core domains are clear, appropriate, comprehensive and/or helpful in the
development of students as competent health care providers (8 responses)
Inclusion of the insurance/drug coverage domain is appreciated (2 responses)
This appendix “clearly gives the needed flexibility to meet the Standards. The
performance competencies can be integrated into the appropriate syllabi to ensure
successful completion of the Standards and ensure common training across the schools
of pharmacy.”
SUGGESTED CHANGES:



Concern over achievement of ALL domains prior to the APPE year:
o “I’m not sure that all of these activities can be achieved at the typical IPPE site.
Some seem more appropriate for APPEs.”
o “To make room in these three years to cover these competencies, it seems that
any basic sciences, like biochemistry and pathology, will by necessity need to be
moved to pre-pharmacy.”
o “These experiences seem to be unreasonable and excessive to be achieved in
the time allocated to IPPEs in the Standards. Concur that between lab-based
experiences, simulation and IPPEs, these are reasonable expectations but not
IPPEs alone.”
o “As long as many of these things are allowed in the curriculum, these would be
acceptable. For example, pharmacokinetics laboratories expose students to
accurate medication calculation. If so, then these criteria are acceptable.”
o Concern has been voiced from preceptors about students having enough time to
be comfortable (not proficient!) in dispensing activities - this cannot be completely
covered in IPPEs, and should be outcome measures within the whole curriculum
- and assessed (and addressed, if needed on a 1:1 basis) in the APPE
curriculum.”
Concern over exactly when or how the pre-APPE domain is met.
RECOMMENDATION: “to indicate under each domain if it is expected to occur in the
didactic curriculum, simulation, or in IPPEs…..It would be helpful if it were outlined that
specific domains must occur in IPPEs.”
Domain 1 (Patient Safety – Accurately Dispense Medication):
o “Accurately Dispense Medications (order fulfillment) is an important domain.
However, encompassing it under ‘Patient Safety’ does a disservice to patient
safety as we teach our students and how it is evolving in thought process at
practice sites, particularly in health systems. We instructs students they have a
responsibility for the entire medication-use-process. They may not necessarily
be hands on with each step but their scope of responsibility needs to incorporate
thought for the whole process. This extends to thinking of ‘Patient Safety’ for the
entire medication-use process, not just dispensing.” RECOMMENDATION:
“Perhaps Patient Safety should have its own domain to address the overall
medication-use-process and the various elements of establishing a safe system
(hard stops, technology, human factors, etc.).”
o With respect to compounding parenteral products, “I’m a strong supporter of
students developing the skills to prepare sterile parenteral products. However,




an increasing number of facilities are no longer allowing students in their clean
rooms and/or to prepare parenterals. Hospitals frequently cite their internal
policies on training and the need for fingertip or media testing which is both costly
and can’t be completed in a timely manner. RECOMMENDATION: “Schools
may be left with no choice except simulation and the Standards need to address
this emerging trend.”
Student knowledge of “patient education level”:
o “How does a student demonstrate knowledge of patient educational level and
unique cultural and socioeconomic situations of patients that is included in the
required ability statement?
o “Patient educational level is not necessarily the best marker for patient
understanding.”
RECOMMENDATION: “Consider health literacy instead or unique patient factors
influencing patient outcomes”; “It may be better to state that the students are able to
assess patient understanding and apply this understanding when collecting, interpreting,
and evaluation the information collected.”
Domain 5 (Mathematics): “Value is a difficult thing to assess.”
No RECOMMENDATION given.
Domain 6 (Ethical, Professional, and Legal Behavior): Is the terminology “in all
health-care activities” and “all practice activities’” necessary”? RECOMMENDATION:
remove these terms as professional behaviors should really be in force 24/7.
Domain 11 (Insurance/Prescription Drug Coverage): there is “too much detail” and
“’affordable’ is a relative term”. RECOMMENDATION: Replace with the “assist”
statement in the example. OR place this under Domain 1 because “as written, it gives
too much importance to this element”.
RECOMMENDATION: Include management topics such as “management of
information, drug inventories, and people” in the pre-APPE domains.
Appendix 3: Required Elements of the Experiential Curriculum
 52 COMMENTS FOR THIS SECTION
 NO COMMENT OR RECOMMENDATIONS FOR ANY CHANGE - 5 responses
SUPPORT:





Appendix 3 is helpful because it pulls various components of the standards together in a
single area
This is a good list and provides a good structure for developing outcome management
for APPE.
This appendix “clearly gives the needed flexibility to meet the Standards. The
performance competencies can be integrated into the appropriate syllabi to ensure
successful completion of the Standards and ensure common training across the schools
of pharmacy.”
I like the push towards simplicity and the even experiences between
community/ambulatory and hospital/health systems. I support the focuses for both
groups
This Appendix is useful in that it pulls things mentioned throughout the various standards
into an easy to use section. It is probably most useful for those faculty members and
administrators who are not involved directly with Experiential Education, to help them
understand the various required elements. This version adds in more interprofessional
requirements, which is probably a good thing.
SUGGESTED CHANGES:

Concern over different operational strategies used to deliver APPE (Hours
Mandate):
o “The use of 400 hours in each of the required and elective settings fits well with
programs that have 5-week rotation schedules. It does not fit as well for 4-week
programs and can be problematic with 6-week programs. Would ACPE prefer 5week rotation schedules? Alternatively, ACPE could choose to require a certain
number of exposures in each settings (e.g. two in community, one in ambulatory
care, two in hospital/health systems, one elective, etc.)”
o “Concerns about the specific minimum time requirements for total
community/ambulatory care rotations carry over from Standard 13. Agree with
total of 800 required APPE hours, but not evenly split between
community/ambulatory care and hospital/health system. We note description of
the major rotation categories (community/am care & hospital/health system) and
have concern that it would be possible for a student to have an APPE year that
omits an entire practice type in lieu of substituting the other within those
categories. We believe it would be a disservice to students if they were not
required to experience pharmacy practice in all of these environments, so the
possibility of exclusion should not exist. We recommend the standard be restated
to say that within each category, some percent of the 10-weeks should be spent
in each of the sub-category areas (community and am care; hospital and clinical
inpatient) than to have an APPE year that omits an entire practice type.”
o “Hours mandate distribution between community/ambulatory care and
hospitals/health systems: Not sure the terms used to describe the practice
settings reflect the intent of the standard. I think the intent is to have a minimum
of 400 hours in community/ambulatory care vs. institutional settings (acute care
hospitals, LTC etc. where the patient resides in a bed and has a “chart” specific
for that stay). By using the term “hospitals/health systems” the scope of rotations
meeting this definition to include ambulatory care clinics, home infusion care, and
even community and specialty pharmacies that are increasing part of health
systems but not what I think is intended for institutional rotations. In the ideal
world we should be able to say community pharmacy and ambulatory care
experiences achieve the same learning outcomes. Would suggest that at least
200 hours of the community/amb care experience must involve direct patient
care which could include MTM in community pharmacy or patient drug therapy
management in a pharmacist run clinic or physician practice.”
o “Table 1. The description of “Hospital/Health System” hour should be clarified to
include the acute care rotations as it is unclear.”
o “At least 400 hours in community/ambulatory and care and 400 hours in
hospital/health system is not enough detail. In the broadest interpretation this
could mean 400 hours in community and 400 hours in and in-patient centralized
pharmacy with no hours in ambulatory care clinic or in an advanced practice
setting in the hospital, (i.e. ICU, E.D., cardiology service, etc.). Also, by grouping
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ambulatory care with community pharmacy implies that ambulatory rotations are
in the community setting when in fact most of our ambulatory pharmacist and
their IPPE/APPE rotations are in a health-system. Possible Solution: Going back
to the old wording and keep, community, ambulatory, hospital and acute
care/inpatient as the four requirements.”
o Reduce minimum community/ambulatory and hospital/health system APPE hours
to 320.
Concern over Managing Medication dispensing, distribution, administration and
systems management.
o “Under "Medication dispensing, distribution, administration and systems
management" - Don't believe that "managing the use of investigational drug
products" should be a required element. Believe that many schools would have
trouble meeting this requirement...”
o “While we understand the importance of creating a business plan, this activity
takes longer than the usual rotation length. We have our students complete this
task in a course during the 3rd year of the curriculum. RECOMMENDATION: It
would be helpful to have examples of how this is implemented in APPE block
rotations.”
o Under the "Medication dispensing, distribution, administration and systems
management" section, there are several activities that our preceptors have
indicated a given student during a given rotation block may not have the
opportunity to experience (examples include: participating in purchasing
activities; creating a business plan to support patient care services, including
determining the need, feasibility, resources, and sources of funding; managing
the use of investigational drug products). RECOMMENDATION: The word
"MUST" here could make achieving some of these "required elements" for all
students quite challenging if, during the course of a usual rotation month, such
opportunities for student exposure were deemed as unavailable by a preceptor.
Concern over Institutional IPPE/APPE hours requirements
o “The more recent developments of consolations within the health systems is an
area of concern for a number of reasons but relating to experiential education
this could potentially translate to private healthcare systems, concerned about
controlling costs and resources, may take less of our students on IPPEs or
APPEs. This is all directly related to the ACA "Obamacare" and the decrease in
Medicare reimbursements.” RECOMMENDATION: “Draft Standards 2016
represent our future standards of the professional pharmacy degree programs
we need to consider this issue as a potential reality that we will all need to deal
with in the very near future. I would like to see the ACPE Draft Standards 2016
reflect more flexibility especially in the area of IPPE & APPE Institutional
rotations. Allow for other creative means to achieve the exact same outcomes yet
not require the burden of achieving specific hour’s requirements at an institutional
setting. An example would be to allow more integration of acceptable simulation
type activities that will create a consistent learning environment which mimics
what an institutional pharmacist does in the central pharmacy.”
Concern over Service Learning Definition. RECOMMENDATION:
o “Service learning has so much more value beyond learning to practice pharmacy,
including interpersonal skills, communication, empathy, sympathy, time
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management, as well as a sense of professional obligation to the community at
large. Students are capable of providing education and training to the lay public
in addition to patients related to pharmacy activities through service learning that
provide valuable learning experiences. While some criteria to ensure that
“service learning” activities as IPPE are more than just community service hours
is appropriate; however, as written the criteria in the 2016 Draft Standards seem
overly restrictive.”
o “We like the revised expectations for APPE. We disagree with the statement that
for Service Learning to count as IPPE it must meet the 4 criteria outlined in the
Appendix. Service learning provides a very meaningful early platform, regardless
of site, for students to develop patient communication skills, recognition of health
needs of disparate populations, and basic concepts of empathy and
professionalism.”
o There is still the need to clearly define service learning. Different programs
interpret service learning that counts as IPPE.
o Introductory Pharmacy Practice Experience (page 41) Service Learning within
IPPE Since Service Learning must meet identified community needs and be
implemented in full partnership with the population being served, as described in
this part of the Appendix 3, it is recommended to substitute the term patients for
served community or population being served while describing the activities.
o Service Learning as an IPPE: If service learning occurs as part of co-curricular
activities (not as part of a course) but all the learning elements including
reflective learning take place: can these co-curricular activities be counted as
IPPE hours.
Concern over direct patient care experiences with a diverse patient population:
o “Page 39, Paragraph 4 - I am concerned about the additional documentation and
tracking involved in documenting specific disease states and diverse patient
populations. How will this be implemented? Will each student be required to
document a specified number of encounters with African American patients,
Caucasian patients, Catholic patients, Hindu patients, lesbian patients, straight
patients etc. etc.”
o There are a lot of competencies, and not a lot of reliable, validated assessments.
“For ACPE required experiences involving direct patient care, the major disease
states/conditions that all students are expected to encounter must be specified.”
This is a lot of “bean counting”, and I am not sure that it will be helpful overall.
Concern over mid-point documentation:
o Suggest eliminating requirement for documentation of midpoint performance
during a rotation. In some programs a midpoint may be considered optional or is
done can be done informally without completing a specific evaluation form.
o "At a minimum, performance competence must be documented midway through
the experience and at its completion." RECOMMENDATION: We would suggest
a final summative evaluation be documented, with a midterm evaluation provided
either verbally or in writing. Not required for both because of the added workload
for preceptors!
o Midway evaluations: certainly appropriate for APPE rotations. Not always
feasible for IPPE rotations that are of short duration.
Appendix 4: Required Documentation for Standards and Key Elements
2016
 39 COMMENTS FOR THIS SECTION
 NO COMMENT OR RECOMMENDATIONS FOR ANY CHANGE - 19 responses
SUPPORT:
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Section seems particularly helpful (2)
SUGGESTED CHANGES:
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It would be helpful to reduce the amount of redundancy when the same documents
are requested in multiple sections.
In the sub-sections regarding Standards 1, 10, & 12, Better clarification on whether
the PCOA is actually required. (6)
In the sub-section regarding Standard 4, how does a college assess professionalism,
self-awareness and creative thinking? An example of a tool would be helpful. (2)
In the sub-section for Standard 11, are explicit documents regarding IPE required
just for rotations focused on IPE? Or, will all sites that are IPE by nature require
additional agreements/documentation? Clarification is needed, and/or consider
adding “if applicable”. (5)
In the sub-section regarding Standard 12, what credentials are needed for the faculty
in the Pre-APPE curriculum?
In the sub-section regarding Standard 12, clarification is needed regarding the
components of the manuals. For example, how are they different from syllabi.
In the sub-section for Standard 13, what is acceptable as assessments for APPE
educational outcomes? Should PCOA be administered again? Are NAPLEX passing
rates okay?
In the sub-section related to Standard 21, clarification is needed regarding what
types of communication examples are needed? Is this referring to e-mails? Syllabi?
Broadcast messages? Etc…?
In the sub-section regarding Standard 21, it is felt that obtaining a CV from ALL
preceptors is unrealistic/impossible. Consider a college defined preceptor
application. (4)
In the sub-section regarding Standard 23, many schools have a large number of
affiliated sites (some >300). Will all of these actually be reviewed at site visits? We
recommend that a review of randomly selected affiliation agreements be reviewed at
site visits. (3)
In the sub-section regarding Standard 23, the use of the capacity ratio
(http://www.ajpe.org/doi/pdf/10.5688/ajpe7510198) should be considered rather than
the capacity charts.
In the sub-section regarding Standard 23, consider removing the comment about
student:preceptor ratio, since this is typically covered by policy (at the school,
institution and/or state board of pharmacy level).
ALL Other Standards Applicable to EE:
 34 COMMENTS FOR THIS SECTION
 NO COMMENT OR RECOMMENDATIONS FOR ANY CHANGE - 15 responses
SUGGESTED CHANGES AND QUESTIONS
STANDARD 4: Personal and Professional Development
4.3 Innovation and Entrepreneurship
“Innovation and entrepreneurship – The graduate must be able to engage in innovative
activities by using creative thinking to envision better ways of accomplishing professional
goals.” This one will be difficult to do for all students. Should we only screen for student
candidates who can be innovative? Some people just aren’t innovative but that doesn’t make
them poor pharmacists. I have an issue with this.
STANDARD 10: Curricular Design, Delivery, and Oversight
10.8 Feedback
Not sure what the focus is of the first sentence. Meaning, how does the curricular structure
affect allowance for timely formative feedback?
10.12 Course Syllabi
The third bullet is too specific to include in a syllabus.
Faculty approved syllabi is not appropriate as faculty as a group do not approve the content of
a course syllabus. Possibly, in this instance, the term faculty means one individual?
10.13 Experiential Quality Assurance
Does #3 mean to standardize the student performance assessment or to maintain consistency
of student performance assessment?
It would be nice to have more guidance as to what should be included in experiential quality
assurance.
Recommend additional language to clarify that APPE programs should standardized key
components of the entire APPE experience across geographic regions or multiple campuses in
addition to across all sites offering the same experiential course.
10.14 Remuneration/Employment
While this is the norm to not allow this, there are always times where exceptions have to be
made. We can't determine if this wording is meant to recognize that this may happen after all
options are exhausted or meant to be even more restrictive?
Currently employed - Need clarification on how to enforce and how this is applied to locations
that have multiple rotations (e.g. large hospital) or multiple sites, (e.g.: chain pharmacy)
“Nor may they be placed in the specific practice area within a pharmacy practice site where they
are currently employed: ”Support this as worded: as long as they can be placed in other areas
of the employer organization (example doing a management rotation in a chain where they work
in a pharmacy or for a student working in a hospital to be able to do an ICU rotation if they are
not routinely in that ICU (ex. a satellite pharmacy) when they work as in intern.
We are affiliated with several large institutions that offer a multitude of various experiences. I
don't feel a general statement regarding employment at a practice site prohibits that particular
student from completing experiential education activities at that site. The VA, for example, has
outpatient / inpatient / research opportunities / etc. and to prevent a student from exploring other
experience at that hospital that they don't get to participate with as part of their "employment"
does not make sense. This more or less penalizes (or limits?) our students for pursuing
pharmacy employment while in school.
Students can't be placed within a pharmacy practice site where they are currently employed.
This statement puts an unnecessary amount of restrictions on programs. Most programs
subscribe to this, however exceptions are made. Asking the site to apply for a waiver in footnote
3 is going to put an unnecessary burden on the ACPE staff. Possible solution: Please allow
sites to police this on their own, soften the wording to state that schools should "avoid placing
students where they are currently employed whenever possible". __ I am glad to see 10h states
colleges can assist students during IPPE and not violate receipt of payment.
It states students may not be placed in the specific practice area within a pharmacy practice site
where they are currently employed. If this is interpreted as a student who is employed as a tech
at Hospital A cannot do any APPEs at that hospital, this could be a hardship for programs in
smaller communities that may not have many sites. If the student is supervised by a faculty at
that site or in an area where they don’t typically work, this should be allowed as there would be
no conflict.
STANDARD 11: Interprofessional Education
11.3 Interprofessional Team Practice
How will students participate with prescribers in the didactic setting? Or does this refer to
different disciplines having didactic coursework together? This sentence seems too directive.
Suggest the standard to be just the first sentence.
Should/must IPE instruction include all three of the following or is IPE in the experiential setting
sufficient to meet the standard? 1. Classroom, 2. Laboratory 3. Practice Settings.
MISC:
Having opportunities for students to participate in didactic education with student prescribers
and other health care professions students is extremely difficulty considering the complexity of
each school's curriculum. Being able to schedule times for students from different disciplines is
almost impossible. Schools on non-health science campuses without a medical school are at an
extreme disadvantage when it comes to this standard. I agree that IPE is important but making
this happen is nearly impossible. We have been trying over the last 2 years to implement IPE
with our nursing school but without complete curricular revisions from both sides, it has not been
accomplished yet. Schools with multiple campuses add even more complexity to the picture of
IPE. Unfortunately, I don't have any good answers to this dilemma.
Interprofessional Education is obviously important, but it may be more difficult to achieve this
standard in certain states/regions in comparison to those that are more progressive.
Many rotations would be considered interprofessional just by nature of their existence, is the
expectation that we pull out these experiences into a separate IPE designation? Or does this
Standard address those experiences that may be linked and created specifically as part of an
IPE Curriculum?
There are significant requirements for IPE in the new standards. However, IPE is not required
for other health professionals. While these activities may be good, requiring other health
disciplines to be involved in our didactic courses goes beyond our control. Although we are
actively pursuing this, ACPE must keep in mind that we are having to convince medical, dental,
nursing, social work, etc. to be involved in IPE while this is NOT a requirement for their
accreditation. I wonder how pharmacy would respond if their accreditation mandated that we do
something different in our curriculum to accomodate them.
STANDARD 14: Co-Curriculum
If these elements are clearly outside the curriculum, then how are the students and college held
accountable for them? If they are required, then wouldn't that mean they are curricular?
If student organizations set-up innovative service learning events on their own, and then receive
approval for participating in these events, does this count both as IPPE service learning and cocurriculum or would that be considered "double dipping" to meet accreditation standards?
STANDARD 26: Assessment Elements for Section II: Structure and Process
26.7 Interprofessional Team Readiness
We had a difficult time with assessing "preparedness" of students both prior to and the
conclusion of the APPE. We thought maybe incorporating the term “practice-ready” into the
standard would be more appropriate.
Request alternate language to clarify whether the intention is to have a separate assessment of
interprofessional team readiness following the completion of all APPE rotations or if a
compilation and review of assessments gathered at the conclusion of each APPE rotation will
suffice for the standard requirement.
NO guidance is provided on how to assess the preparedness of all students to function
effectively on an interprofessional team both prior to and at the conclusion of APPE. This will be
very difficult, particularly at the end of APPE.
26.9 APPE Readiness
Using the terms MTM and population-based care seems too specific to be here in this broad
outcome. We interpret this outcome as outlining the 3 main pillars: knowledge, skill and
attitude.
Competency assessment prior to APPE should be adequately demonstrated by successfully
passing all didactic and experiential courses prior to APPE. Why is another assessment
required?
The APPE readiness and how that will be determined might be a concern for programs.
MISC:
1. Do we need to seriously consider re-initiating <<or advocating for>> an applied, “live”
component to our NABPLEX exam? With the movement towards more patient-based
APPE experiences, is it time to now reflect in our ultimate exam at licensing?
2. What are the things that we are unable to teach/cover in the curriculum, including skills
labs and experiential training? How do we translate this to our preceptors so they can fill
the voids? (or work to define what can be covered in the curriculum, to help define where
student are at going out into practice and into residency training)
3. What are some areas that should be requirements of expanded experiences, which are
covered in the didactic curriculum and need to be integrated (or practiced) during
rotations? Examples: calculations – require in the applied setting, number of solo
presentations, group presentations, patient-based presentations, education sessions for
the community (whether professional-based or patient-based)
4. Please do NOT make OSCEs a "required" standard of practice!