This action was brought by the district attorneys after discovering that Walgreens had employed someone as a pharmacist who was not licensed by the Board of Pharmacy. The individual, Kim Thien Le, worked at multiple pharmacy locations throughout California's bay area for approximately ten years. Allegations against Walgreens claim that Ms. Le performed at least one required step in the pharmacist process as it related to more than 745,000 prescriptions. Approximately 100,000 of these prescriptions were written for controlled substances. The complaint further alleges that Ms. Le was not properly vetted when Walgreens promoted her to positions that required a license and that the company failed to ensure that their internal systems were robust enough to prevent a situation such as this.

As a result of the civil judgement outcome, Walgreens was instructed to:

• implement a verification program, posting proof of licensure;
• conduct annual audits;
• submit an annual compliance report; and
• pay approximately $7.5 million in penalties, costs and remedial payments

Ms. Le's employment ended in 2017 and she has since been criminally charged with false personation and related felonies by the California Attorney General's Office.

Companies operating in industries that involve positions for which licensure is required are encouraged to review not only their processes and policies for vetting employees and applicants but also the internal systems being utilized to support the vetting of an individual's licensure status. Furthermore, employers in these spaces beholden to these requirements should allocate the resources necessary to review the procedures and internal workflows in place that monitor the currency and expiration of their employees' licenses.