Feedback for Proposed Revisions to By-law No 3 — Fees & Public Register

1.
Pharmacist  ·  Sept. 24, 2015

The hospital fees seem to be extremely high. Bearing in mind that hospitals are publicly funded institutions and have strict budgetary restrictions, I think these fees should be re-thought

Pharmacist  ·  Nov. 9, 2015

I am not sure how the proposed fees were arrived. But when MOH proposed to have OCP oversight on hospital pharmacies, this policy shift outcome is what hospitals are seeing. All hospital have budgets; it is time that their operating budgets be re-balance accordingly. If this proposed hospital fee adds to the pharmacy budget, it should be view positively. Any department with bigger budgets usually have bigger political voice. It is certainly time that Rx should ascend to higher levels of influence at Hospitals !!!!

2.
Pharmacist  ·  Sept. 24, 2015

I would like to see a decreased fee option for pharmacists who are on maternity/paternity leave and are not actively practicing, but do not wish to resign for the time they are on leave.

3.
Pharmacist  ·  Sept. 24, 2015

I do not agree.

why you want to increase the cost of anything while you know what is the job situation for pharmacists ,government cuts, RPI groups slaving pharmacist for job. what does realy OCP doing for pharmacist? please think about helping rather than finding a way to charge them.

4.
Pharmacist  ·  Sept. 24, 2015

I am questioning "any language" While I go out of my way to explain the little bit of some languages I know I think that English and French are official and to ignore this is problematic. Most new immigrants pride them selves on learning the official languages. I have missed out on employment solely because I didn't know the language of the people in the area

5.
Pharmacist  ·  Sept. 24, 2015

Fees increases seem pretty steep ! I agree some comments received. Yes, nowadays with government cutting us AGAIN ! Why not help us rather than increase this and that , so many increases !

6.
Pharmacist  ·  Sept. 24, 2015

I see why they would charge a fee , and I don’t pretend to know all the costs involved, but why would a hospital pharmacy which makes no profit have to pay 5 times the amount that a retail pharmacy would pay? I assume this fee would apply to each site and would have to come out of an already strained pharmacy budget.

7.
Pharmacy Technician  ·  Sept. 24, 2015

A decrease in the yearly registration fee would be nice to see. Has there been any thought to reimbursement for the technicians who already paid the SPT cost and the higher exam price?

Pharmacy Technician  ·  Oct. 6, 2015

I agree with some sort of reimbursement for the technicians who already paid the SPT cost and the higher exam price. I believe a lot of techs who already paid full price for SPT did & still do NOT make enough money to make these prices relative. Once finishing after paying the 410, another 1000 dollars needs to be paid to complete license. It is very hard especially for single people who have a lower income and live on their own. It is nice to see these prices are actually being thought about but this should have been done a long time ago. This price tag prevents people from becoming regulated because they can not afford the courses. I believe that there will be some growth now in registering techs because of the fees lowered.

Pharmacy Technician  ·  Nov. 5, 2015

I always wanted to ask if there would be any reimbursement for these fees. Especially those that are currently going through the registration process. Also to add to the high prices of these fees, students who have just graduated from an accredited college are then required to pay these high registration fees while trying to get into the field all while employers are hesitant to higher these new grads because they are not yet registered.

8.
Pharmacist  ·  Sept. 24, 2015

The blister pack and compliance systems helped lots of people to organize their medications which had a huge impact on their quality of life , less hospital admissions and fees , but cutting our fees a large category of these people wont get their medications as required which will reflect on high hospital admissions and more fees paid buy the government for the hospitals . instead its better to control the the controlled and narcotic prescriptions , do more awareness to the physicians to do drug testing to ODB people which are addicting on these or selling them in the streets
and the government is paying for it , how many of these people they do not deserve these drugs , its better to control this than cutting the pharmacists fees Do not agree with the changes

9.
Pharmacist  ·  Sept. 24, 2015

Really do not see a need to increase any fee especially since we have lost revenue over past years from Ontario Drug Benefit . Cost going up to run business and revenues going down reply not good

10.
Pharmacist  ·  Sept. 24, 2015

As a part time pharmacist, I find the pharmacist fees prohibitive. I was hoping they would be reduced, like some of the other fees

11.
Applicant  ·  Sept. 24, 2015

As an aspiring future member of OCP, it's disappointing to see how the financial structure of pharmacy in Ontario seems to devalue pharmacists. Recent government cuts have already limited resources province-wide and incentives to provide quality healthcare is becoming more and more limited. The reality of being a community pharmacist in Ontario right now is working longer hours with less financial incentive. MedsChecks and Professional Opinion take time to complete and do not provide the financial support necessary to run a successful community pharmacy. Yes, patient care will always be our number one priority but by further increasing annual fees, along with non-opposition for government cuts, the profession of pharmacy is being put through a crises with no clear voice of advocacy.

12.
Pharmacist  ·  Sept. 24, 2015

In regard to the Public register, there needs to be considerably more clarity on the conditions the Registrar can disclose information on members. Transparency works both for the public and for the members. There needs to be a clear and consistent framework on the process.

13.
Pharmacist  ·  Sept. 25, 2015

What was the rationale for the size of the fees for hospitals? As for the amendments to the register, all looks good provided only information affecting/related to practice need publishing

14.
Pharmacist  ·  Sept. 25, 2015

Agree with most of the changes. The fees for new applicants are still high considering what they have already paid to get to this stage. Studentship and internship fees are still a concern but this is a good start.

15.
Pharmacy Technician  ·  Sept. 26, 2015

I am not sure if initial registration fee increase from $130 make sense, especially many of the applicants tend to be students. I feel that OCP needs to provide more rationale for the proposed fee changes for members to provide constructive feedback.

16.
Pharmacist  ·  Sept. 27, 2015

I agree but I'd like to see a lower fee for Pharmacists who are not practising (on Part B )

17.
Pharmacist  ·  Sept. 27, 2015

There is no need to reduce applicant registration and exam fees. When the cost is reduced, the perceived value is also reduced. Those in the profession are already paying enough (and paid in the past) without having to subsidize new applicants. The reduction in new applicant fees will ultimately be borne by current registrants.

18.
Pharmacist  ·  Sept. 27, 2015

No health care college and including pharmacists should be able to charge high fees under the umbrella of protecting the public. This province is one of the most expensive ones in terms of collecting fees and should align itself with other provinces and even with States. If OCP is intending to have supervision on hospital pharmacies, which that entails extra work and hiring more employees, should not rely on raising funds from its members but to ask for funding from government because although "protecting the public" is its mission, but it is the government's as well. At the time a profession becomes a major target for funding cut backs which is politically motivated, our candidates in the college should not be hesitant to ask for financial assistance.

Pharmacist  ·  Nov. 9, 2015

This is a very good suggestions that the government should give OCP grant funding to inspect the hospital pharmacies. The government subsidize Ontario Education systems; so why not OCP in this new oversight of Hospital Pharmacies ??!! If government funding is available, then the hospital fees can be assessed and make this a budget neutral event for OCP.

19.
Pharmacist  ·  Sept. 28, 2015

Pharmacists and technicians demonstrate their language proficiency at time of registration in either English or French. Aside from declaring fluency in English/French, no other declarations are required on the public register. The public register should not be a vehicle for advertising services (language or otherwise). I would therefore suggest that language declarations not be included in the public register.

Pharmacist  ·  Nov. 17, 2015

Excellent point!

20.
Pharmacist  ·  Sept. 28, 2015

The hospital fees, especially for annual renewal, seem very high. Hospital pharmacy budgets are already tight, with some sites cutting pharmacist hours due to the cost. I think high accreditation fees will not help the situation.

21.
Pharmacist  ·  Sept. 28, 2015

I would encourage the College to consider decreasing the Membership Annual Renewal Fees.

In the past five years or so, pharmacists salaries have decreased. This is due to many things.

First of all, there are more pharmacist on the market. With two schools of pharmacy, we have many new pharmacists graduating every year. When supply exceeds demand on the market, then pharmacist wages go down.

Secondly, Drug Reform has decreased reimbursement for pharmacy. Although cognitive services such as Pharmaceutical Opinion, Meds Check, Prescribing for Smoking Cessation are a new source of revenue, it is not enough to offset the losses from Drug Reform.

Thirdly, although technicians are becoming Registered, their salary in retail pharmacy has not increased dramatically. The case may be different in hospital pharmacy.

22.
Pharmacist  ·  Sept. 28, 2015

It's obvious that the college is to protect the public from pharmacist but what did the college do to protect the pharmacist when they got abused from public?????? Obviously nothing . The college is not even protecting the whole profession from government cuts!! Still dealing with pharmacists with concepts of very old days that pharmacies is doing very good profits so they should pay more and more . Pharmacist are struggling nowadays to have a shift , they can stay most of the week at home jobless . I see that no increase of fees should be done at all . If inspection costs more then inspectors should experience low salaries exactly like community pharmacist do. A newly licensed pharmacist now is paid a rate of 25$ /hour (before taxes) in GTA. Some pharmacies are cutting from their services and opening hours because they cannot afford to pay all costs after government cuts. what quality of patient care are you protecting? By increasing the fees you are actually protecting government and neglecting public care.

23.
Pharmacist  ·  Sept. 28, 2015

I am a well paid full time community chain pharmacist. I have no issue with increased fees AS LONG AS the extra money will benefit community pharmacy or my patients. I am all for strict rules and regulation to keep pharmacy a nice clean cut profession in Ontario.

24.
Pharmacist  ·  Sept. 29, 2015

While I am not aware of the costs associated with Hospital Pharmacies, accreditation fees seem excessive compared to community pharmacies

25.
Pharmacist  ·  Sept. 30, 2015

Pharmacy fee increase should not be there, reason pharmacy profit is getting hurt significantly. I will recommend college that should decrease that fee.

26.
Pharmacist  ·  Sept. 30, 2015

there should be both pharmacists and accreditation fees reduction because owners business bottom line hurting and pharmacists wages and hours are cut back, even now.

27.
Pharmacist  ·  Sept. 30, 2015

Hospital fees are out of line for taxpayer funded facilities. OCP should recoup costs not "profit" from change. Non practicing pharmacists fees are excessive for services provided.

28.
Pharmacist  ·  Oct. 8, 2015

The cut in cost of becoming a registered pharmacist is good, if the cost of registration filling can be left at 130.00 that will be the best considering that on renewal you start paying a higher fee and wages are low. Please rethink the fee for hospitals- way too high.

29.
Pharmacy Technician  ·  Oct. 9, 2015

The fee for hospitals seems exorbitant. While most community pharmacies are relatively similar in size, hospital pharmacies vary greatly. A large hospital in the GTA might have 50 or more pharmacy employees, while a small town may have 3 or 4. Just because they are government funded, does not mean they are rolling in money - $5000 is a significant additional cost.

30.
Pharmacy Technician  ·  Oct. 12, 2015

Application fee, issuance fee and annual renewal fee are not fair at all for Hospital Pharmacies. Hospitals are not for profite onganisations and they are publicly funded. I have seen budget cut to run hospitals in last few years especially in rural areas. And I don't get how OCP came up with this hugh amount. Does it cost this much money to inspect a small hospital pharmacy which even doesn't have 20 beds or not even a full time staff? And annual membership fee for pharmacy technician is too high. Pharmacy technicians in community pharmacy do not make enough money to pay $452 annually. I think OCP should help pharmacy technicians by reducing their annual membership fee.

31.
Lennox and Addington County General Hospital  ·  Oct. 19, 2015

I think the hospital accreditation fees should be relatively lower for smaller and rural hospitals, in recognition of our smaller size and budget. It might be worthwhile comparing Lab accreditation and Hospital accreditation fee structures.

32.
Pharmacy Technician  ·  Oct. 22, 2015

Pharmacy Technician fees are way out of line. You are charging 2/3 of amount that a pharmacist pays. The average pharmacy technician does not make 2/3 of what a pharmacist makes. Other health professionals at hospital where I work are shocked at the annual fees required!!!

Pharmacy Technician  ·  Nov. 19, 2015

The fees do seem high especially for students, and even for those working at Retail pharmacies as they are not paid enough compared to their hospital counterparts

33.
Pharmacist  ·  Oct. 22, 2015

Not agree with the concept of increasing fee, already pharmacist profession is suffering, no job opportunities and low pay scale. please do some thing for pharmacist who are not getting full time job and working through some agencies like RPI taking their own advantages and paying very less to relief pharmacists.

34.
Pharmacist  ·  Oct. 22, 2015

To publicly announce an inspection on any pharmacy even if it's just a routine inspection reduce the trust in that pharmacy . The public don't need to know and will not benefit from knowing of a routine inspection or re inspection of a pharmacy because some re inspections are due to just some technical requirement that does not affect patients safty but will cause reduction in patients trust for there pharmacies. In the event that the pharmacy or a pharmacist had done something wrong to affect public safty , that should be published not just a reinspections due to not having the latest version of some reference books

35.
Pharmacist  ·  Oct. 23, 2015

Please re-think an increase in the pharmacist annual registration fees. The current fee is already very difficult for individuals who are not sponsored by the organization they work with especially if the position is part-time/relief.

36.
Pharmacist  ·  Oct. 23, 2015

New hospital fees are outrageous. We are a not for profit organization and all feeling great pressure to reduce total operating costs. The fee for application and yearly renewal consider the inspection may not be every year is unreasonable. We should be charged the same as community practice sites

Application fee of $3,000 Issuance fee of $3,000 Annual renewal fee of $5,000

Pharmacist  ·  Nov. 9, 2015

Community pharmacy and hospital pharmacy have differing workflow and therefore different inspection criteria. Maybe the fee should reflect labor hours require to inspect each facilities; ie like lawyer billable hours ? A formula should be proposed with reason's how it was derived, before setting up a fee structure. More transparency needed on how OCP arrived at the hospital fee structures.

37.
Pharmacist  ·  Oct. 30, 2015

Hospital fees are excessive ... When we were inspected there were 4 x different inspections (one for each site), with 4 x different reports even though we are one hospital. As I understand it, and perhaps someone can correct me, the application and issuance fee (total of $6K) and the annual fee ($5K) is for each "site" and not the "hospital"? (ie. so I am looking at a $24K fee for the first time license (each site) and $20K for the annual fee after this first year). If I need to find $20K each year, then I am into budget reductions elsewhere. We do not generate revenue as an inpatient pharmacy to offset this added/new expense. Thinking that you need to reconsider this fee structure or strategy, or get the Ministry to pay for these hospital fees. Do we know why the fee was set so high?

38.
The Scarborough Hospital  ·  Oct. 30, 2015

The proposed fee for Accreditation of the hospital is excessively large in comparison to those charged for community pharmacies. There are significant changes occurring with the funding to Ontario hospitals with a move to Quality Based Funding, HBAM and a smaller portion of the Global Funding envelop. Hospital pharmacies do not generate revenue and at our particular hospital we are facing 3.5% and 4% budget reductions in the next 2 years.

39.
Pharmacist  ·  Nov. 2, 2015

Hello. It is hard to be fair in a process like this because of varying sizes and management models. Both of these hospitals are operated under the same director. Ninety- five percent of the Policies and Procedures that were asked for f our inspection were the same for each site. Could you modify visits to cut out duplication when 2 sites are under one corporation or one director. These cost savings would then be passed on to the hospitals. I am sure there are many small sites working with partners this way to save money.

40.
Pharmacist  ·  Nov. 2, 2015

I am emailing to provide input into the proposed hospital pharmacy fees put forth by The Ontario College of Pharmacists.

Recognizing that inspection and regulation were mandated by the Ontario government I realize that extra staff and resources had to be hired by OCP to develop the program, then carry out the inspections. There is cost involved in this and someone has to pay for it. However, once the process has been developed and initial inspections completed the job shifts to maintaining and refining the process and I would expect travel would be reduced substantially.

Having worked in both retail and hospital pharmacy I have been involved in both type of inspections. Both took approximately a day unless the hospital had more than one site. Currently belonging to a 2 site rural hospital our first day of inspection took about 7 hours and the second only 4 hours since policies and procedures are duplicated at both sites as we are the “same” hospital. I found the inspection very useful and was very appreciative of the direction and guidance I received.

As I stated earlier I recognize that the program must be funded. However, the math does not add up. A new retail pharmacy undergoing inspection for the first time would pay a fee of approximately 1100 dollars . The invoice that I will receive for our hospital will be $22,000 for a similar service ( 11,000 per site). Subsequent years the retail pharmacy pays 900 dollars per year verses a hospital at 5000 dollars per year (or in our case 10,000 dollars). A non profit organization pays 5 times what a for profit organization pays.

As you are aware, hospitals are restrained by their budgets and many of us are short staffed. The 22,000 dollar fee for registration does not appear to be aligned with the payment structure for a profit organization. There will also be a burden on the hospital budget as this is a new fee. My recommendation would be that the fee be aligned with the fee for profit organizations . This would allow hospitals to maintain our staff and service levels. An additional 22,000 dollars would have an impact on my budget and may lead to reduced staffing levels. This would have a direct impact on patient care.

I urge you to reconsider your fee structure for hospitals especially those with more than one site and would appreciate your feedback on my recommendation.

41.
Pharmacist  ·  Nov. 4, 2015

Recently the College asked for feedback on the proposed amendments to its By-law No. 3, specifically related to fees and changes to information that the College will post on the public register. I would like to provide comment on the application and annual renewal fees for hospital pharmacies.

The proposed fees for hospital pharmacies are an application fee of $3000, issuance fee of $3000, and annual renewal fee of $5000. For comparison’s sake, annual renewal fees for community pharmacies are proposed to increase from $860 to $940.

The disparity between community and hospital fees are concerning. Hospitals, by their nature of being publically funded institutions, are non-profit organizations. Their operating costs are covered primarily by the tax payers of the province of Ontario. They do not generate a profit. And given the current reality of health care funding, they are being asked to reduce costs and improve efficiencies at all opportunities. The proposed fees, which have never been accounted for by a hospital pharmacy, are detrimental to their significantly limited and chronically shrinking budgets.

Our corporation of four hospitals is expected to reduce total operating costs by $11.5 million in the next fiscal year. Over the previous three years, our funding has been cut by $25 million. Our corporation has four hospitals, three of which operate pharmacies on site, though all four sites were visited by College accreditors. This will result in a cost of $18,000 – $24,000 to initially register with the College, followed by $15,000 – $20,000 annually thereafter. Again, for comparison’s sake, to register one non-profit hospital pharmacy is over five times the cost of registering one for-profit community pharmacy.

According to the list of pharmacies in Ontario on the College’s public register, there are approximately 225 hospital pharmacies in the province. This represents a cost of $1.35 million in application and issuances fees that would be paid by taxpayers in the first year, and $1.125 million in renewal fees annually thereafter. This is prior to applicable HST.

I urge that the College reassess this fee structure prior to implementation and ask that hospital pharmacies pay the same fees as for-profit community pharmacies. Hospitals in Ontario, as well as health care in general, are under significant financial strain due to rising costs and an aging population. These significantly higher fees will add to the economic hardship of non-profit hospital pharmacies, and may result in reduced services, reduced staff, and/or reduced patient safety. It is a well-known fact that the current health care model is financially unsustainable – please do not further contribute to this issue.

42.
Pharmacist  ·  Nov. 4, 2015

Recently the College asked for feedback on the proposed amendments to its By-law No. 3, specifically related to fees and changes to information that the College will post on the public register. I would like to provide comment on the application and annual renewal fees for hospital pharmacies.

The proposed fees for hospital pharmacies are an application fee of $3000, issuance fee of $3000, and annual renewal fee of $5000. For comparison’s sake, annual renewal fees for community pharmacies are proposed to increase from $860 to $940.

The disparity between community and hospital fees are concerning. Hospitals, by their nature of being publically funded institutions, are non-profit organizations. Their operating costs are covered primarily by the tax payers of the province of Ontario. They do not generate a profit. And given the current reality of health care funding, they are being asked to reduce costs and improve efficiencies at all opportunities. The proposed fees, which have never been accounted for by a hospital pharmacy, are detrimental to their significantly limited and chronically shrinking budgets.

Our corporation of four hospitals is expected to reduce total operating costs by $11.5 million in the next fiscal year. Over the previous three years, our funding has been cut by $25 million. Our corporation has four hospitals, three of which operate pharmacies on site, though all four sites were visited by College accreditors. This will result in a cost of $18,000 – $24,000 to initially register with the College, followed by $15,000 – $20,000 annually thereafter. Again, for comparison’s sake, to register one non-profit hospital pharmacy is over five times the cost of registering one for-profit community pharmacy.

According to the list of pharmacies in Ontario on the College’s public register, there are approximately 225 hospital pharmacies in the province. This represents a cost of $1.35 million in application and issuances fees that would be paid by taxpayers in the first year, and $1.125 million in renewal fees annually thereafter. This is prior to applicable HST.

I urge that the College reassess this fee structure prior to implementation and ask that hospital pharmacies pay the same fees as for-profit community pharmacies. Hospitals in Ontario, as well as health care in general, are under significant financial strain due to rising costs and an aging population. These significantly higher fees will add to the economic hardship of non-profit hospital pharmacies, and may result in reduced services, reduced staff, and/or reduced patient safety. It is a well-known fact that the current health care model is financially unsustainable – please do not further contribute to this issue.

43.
Pharmacist  ·  Nov. 4, 2015

Recently the College asked for feedback on the proposed amendments to its By-law No. 3, specifically related to fees and changes to information that the College will post on the public register. I would like to provide comment on the application and annual renewal fees for hospital pharmacies.

The proposed fees for hospital pharmacies are an application fee of $3000, issuance fee of $3000, and annual renewal fee of $5000. For comparison’s sake, annual renewal fees for community pharmacies are proposed to increase from $860 to $940.

The disparity between community and hospital fees are concerning. Hospitals, by their nature of being publically funded institutions, are non-profit organizations. Their operating costs are covered primarily by the tax payers of the province of Ontario. They do not generate a profit. And given the current reality of health care funding, they are being asked to reduce costs and improve efficiencies at all opportunities. The proposed fees, which have never been accounted for by a hospital pharmacy, are detrimental to their significantly limited and chronically shrinking budgets.

Our corporation of four hospitals is expected to reduce total operating costs by $11.5 million in the next fiscal year. Over the previous three years, our funding has been cut by $25 million. Our corporation has four hospitals, three of which operate pharmacies on site, though all four sites were visited by College accreditors. This will result in a cost of $18,000 – $24,000 to initially register with the College, followed by $15,000 – $20,000 annually thereafter. Again, for comparison’s sake, to register one non-profit hospital pharmacy is over five times the cost of registering one for-profit community pharmacy.

According to the list of pharmacies in Ontario on the College’s public register, there are approximately 225 hospital pharmacies in the province. This represents a cost of $1.35 million in application and issuances fees that would be paid by taxpayers in the first year, and $1.125 million in renewal fees annually thereafter. This is prior to applicable HST.

I urge that the College reassess this fee structure prior to implementation and ask that hospital pharmacies pay the same fees as for-profit community pharmacies. Hospitals in Ontario, as well as health care in general, are under significant financial strain due to rising costs and an aging population. These significantly higher fees will add to the economic hardship of non-profit hospital pharmacies, and may result in reduced services, reduced staff, and/or reduced patient safety. It is a well-known fact that the current health care model is financially unsustainable – please do not further contribute to this issue.

44.
Pharmacist  ·  Nov. 4, 2015

Recently the College asked for feedback on the proposed amendments to its By-law No. 3, specifically related to fees and changes to information that the College will post on the public register. I would like to provide comment on the application and annual renewal fees for hospital pharmacies.

The proposed fees for hospital pharmacies are an application fee of $3000, issuance fee of $3000, and annual renewal fee of $5000. For comparison’s sake, annual renewal fees for community pharmacies are proposed to increase from $860 to $940.

The disparity between community and hospital fees are concerning. Hospitals, by their nature of being publicly funded institutions, are non-profit organizations. Their operating costs are covered primarily by the tax payers of the province of Ontario. They do not generate a profit. And given the current reality of health care funding, they are being asked to reduce costs and improve efficiencies at all opportunities. The proposed fees, which have never been accounted for by a hospital pharmacy, are detrimental to their significantly limited and chronically shrinking budgets.

Our corporation of four hospitals is expected to reduce total operating costs by $11.5 million in the next fiscal year. Over the previous three years, our funding has been cut by $25 million. Our corporation has four hospitals, three of which operate pharmacies on site, though all four sites were visited by College accreditors. This will result in a cost of $18,000 – $24,000 to initially register with the College, followed by $15,000 – $20,000 annually thereafter. Again, for comparison’s sake, to register one non-profit hospital pharmacy is over five times the cost of registering one for-profit community pharmacy.

According to the list of pharmacies in Ontario on the College’s public register, there are approximately 225 hospital pharmacies in the province. This represents a cost of $1.35 million in application and issuance fees that would be paid by taxpayers in the first year, and $1.125 million in renewal fees annually thereafter. This is prior to applicable HST.

I urge that the College reassess this fee structure prior to implementation and ask that hospital pharmacies pay the same fees as for-profit community pharmacies. Hospitals in Ontario, as well as health care in general, are under significant financial strain due to rising costs and an aging population. These significantly higher fees will add to the economic hardship of non-profit hospital pharmacies, and may result in reduced services, reduced staff, and/or reduced patient safety. It is a well-known fact that the current health care model is financially unsustainable – please do not further contribute to this issue.

45.
Pharmacist  ·  Nov. 4, 2015

Recently the College asked for feedback on the proposed amendments to its By-law No. 3, specifically related to fees and changes to information that the College will post on the public register. I would like to provide comment on the application and annual renewal fees for hospital pharmacies.

The proposed fees for hospital pharmacies are an application fee of $3000, issuance fee of $3000, and annual renewal fee of $5000. For comparison’s sake, annual renewal fees for community pharmacies are proposed to increase from $860 to $940.

The disparity between community and hospital fees are concerning. Hospitals, by their nature of being publicly funded institutions, are non-profit organizations. Their operating costs are covered primarily by the tax payers of the province of Ontario. They do not generate a profit. And given the current reality of health care funding, they are being asked to reduce costs and improve efficiencies at all opportunities. The proposed fees, which have never been accounted for by a hospital pharmacy, are detrimental to their significantly limited and chronically shrinking budgets.

Our corporation of four hospitals is expected to reduce total operating costs by $11.5 million in the next fiscal year. Over the previous three years, our funding has been cut by $25 million. Our corporation has four hospitals, three of which operate pharmacies on site, though all four sites were visited by College accreditors. This will result in a cost of $18,000 – $24,000 to initially register with the College, followed by $15,000 – $20,000 annually thereafter. Again, for comparison’s sake, to register one non-profit hospital pharmacy is over five times the cost of registering one for-profit community pharmacy.

According to the list of pharmacies in Ontario on the College’s public register, there are approximately 225 hospital pharmacies in the province. This represents a cost of $1.35 million in application and issuance fees that would be paid by taxpayers in the first year, and $1.125 million in renewal fees annually thereafter. This is prior to applicable HST.

I urge that the College reassess this fee structure prior to implementation and ask that hospital pharmacies pay the same fees as for-profit community pharmacies. Hospitals in Ontario, as well as health care in general, are under significant financial strain due to rising costs and an aging population. These significantly higher fees will add to the economic hardship of non-profit hospital pharmacies, and may result in reduced services, reduced staff, and/or reduced patient safety. It is a well-known fact that the current health care model is financially unsustainable – please do not further contribute to this issue.

46.
Pharmacist  ·  Nov. 4, 2015

Recently the College asked for feedback on the proposed amendments to its By-law No. 3, specifically related to fees and changes to information that the College will post on the public register. I would like to provide comment on the application and annual renewal fees for hospital pharmacies.

The proposed fees for hospital pharmacies are an application fee of $3000, issuance fee of $3000, and annual renewal fee of $5000. For comparison’s sake, annual renewal fees for community pharmacies are proposed to increase from $860 to $940.

The disparity between community and hospital fees are concerning. Hospitals, by their nature of being publicly funded institutions, are non-profit organizations. Their operating costs are covered primarily by the tax payers of the province of Ontario. They do not generate a profit. And given the current reality of health care funding, they are being asked to reduce costs and improve efficiencies at all opportunities. The proposed fees, which have never been accounted for by a hospital pharmacy, are detrimental to their significantly limited and chronically shrinking budgets.

Our corporation of four hospitals is expected to reduce total operating costs by $11.5 million in the next fiscal year. Over the previous three years, our funding has been cut by $25 million. Our corporation has four hospitals, three of which operate pharmacies on site, though all four sites were visited by College accreditors. This will result in a cost of $18,000 – $24,000 to initially register with the College, followed by $15,000 – $20,000 annually thereafter. Again, for comparison’s sake, to register one non-profit hospital pharmacy is over five times the cost of registering one for-profit community pharmacy.

According to the list of pharmacies in Ontario on the College’s public register, there are approximately 225 hospital pharmacies in the province. This represents a cost of $1.35 million in application and issuance fees that would be paid by taxpayers in the first year, and $1.125 million in renewal fees annually thereafter. This is prior to applicable HST.

I urge that the College reassess this fee structure prior to implementation and ask that hospital pharmacies pay the same fees as for-profit community pharmacies. Hospitals in Ontario, as well as health care in general, are under significant financial strain due to rising costs and an aging population. These significantly higher fees will add to the economic hardship of non-profit hospital pharmacies, and may result in reduced services, reduced staff, and/or reduced patient safety. It is a well-known fact that the current health care model is financially unsustainable – please do not further contribute to this issue.

47.
Pharmacist  ·  Nov. 5, 2015

Recently the College asked for feedback on the proposed amendments to its By-law No. 3, specifically related to fees and changes to information that the College will post on the public register. I would like to provide comment on the application and annual renewal fees for hospital pharmacies.

The proposed fees for hospital pharmacies are an application fee of $3000, issuance fee of $3000, and annual renewal fee of $5000. For comparison’s sake, annual renewal fees for community pharmacies are proposed to increase from $860 to $940.

The disparity between community and hospital fees are concerning. Hospitals, by their nature of being publicly funded institutions, are non-profit organizations. Their operating costs are covered primarily by the tax payers of the province of Ontario. They do not generate a profit. And given the current reality of health care funding, they are being asked to reduce costs and improve efficiencies at all opportunities. The proposed fees, which have never been accounted for by a hospital pharmacy, are detrimental to their significantly limited and chronically shrinking budgets.

Our corporation of four hospitals is expected to reduce total operating costs by $11.5 million in the next fiscal year. Over the previous three years, our funding has been cut by $25 million. Our corporation has four hospitals, three of which operate pharmacies on site, though all four sites were visited by College accreditors. This will result in a cost of $18,000 – $24,000 to initially register with the College, followed by $15,000 – $20,000 annually thereafter. Again, for comparison’s sake, to register one non-profit hospital pharmacy is over five times the cost of registering one for-profit community pharmacy.

According to the list of pharmacies in Ontario on the College’s public register, there are approximately 225 hospital pharmacies in the province. This represents a cost of $1.35 million in application and issuance fees that would be paid by taxpayers in the first year, and $1.125 million in renewal fees annually thereafter. This is prior to applicable HST.

I urge that the College reassess this fee structure prior to implementation and ask that hospital pharmacies pay the same fees as for-profit community pharmacies. Hospitals in Ontario, as well as health care in general, are under significant financial strain due to rising costs and an aging population. These significantly higher fees will add to the economic hardship of non-profit hospital pharmacies, and may result in reduced services, reduced staff, and/or reduced patient safety. It is a well-known fact that the current health care model is financially unsustainable – please do not further contribute to this issue.

48.
Pharmacist  ·  Nov. 5, 2015

Recently the College asked for feedback on the proposed amendments to its By-law No. 3, specifically related to fees and changes to information that the College will post on the public register. I would like to provide comment on the application and annual renewal fees for hospital pharmacies.

The proposed fees for hospital pharmacies are an application fee of $3000, issuance fee of $3000, and annual renewal fee of $5000. For comparison’s sake, annual renewal fees for community pharmacies are proposed to increase from $860 to $940.

The disparity between community and hospital fees are concerning. Hospitals, by their nature of being publicly funded institutions, are non-profit organizations. Their operating costs are covered primarily by the tax payers of the province of Ontario. They do not generate a profit. And given the current reality of health care funding, they are being asked to reduce costs and improve efficiencies at all opportunities. The proposed fees, which have never been accounted for by a hospital pharmacy, are detrimental to their significantly limited and chronically shrinking budgets.

Our corporation of four hospitals is expected to reduce total operating costs by $11.5 million in the next fiscal year. Over the previous three years, our funding has been cut by $25 million. Our corporation has four hospitals, three of which operate pharmacies on site, though all four sites were visited by College accreditors. This will result in a cost of $18,000 – $24,000 to initially register with the College, followed by $15,000 – $20,000 annually thereafter. Again, for comparison’s sake, to register one non-profit hospital pharmacy is over five times the cost of registering one for-profit community pharmacy.

According to the list of pharmacies in Ontario on the College’s public register, there are approximately 225 hospital pharmacies in the province. This represents a cost of $1.35 million in application and issuance fees that would be paid by taxpayers in the first year, and $1.125 million in renewal fees annually thereafter. This is prior to applicable HST.

I urge that the College reassess this fee structure prior to implementation and ask that hospital pharmacies pay the same fees as for-profit community pharmacies. Hospitals in Ontario, as well as health care in general, are under significant financial strain due to rising costs and an aging population. These significantly higher fees will add to the economic hardship of non-profit hospital pharmacies, and may result in reduced services, reduced staff, and/or reduced patient safety. It is a well-known fact that the current health care model is financially unsustainable – please do not further contribute to this issue.

49.
Pharmacist  ·  Nov. 5, 2015

Recently the College asked for feedback on the proposed amendments to its By-law No. 3, specifically related to fees and changes to information that the College will post on the public register. I would like to provide comment on the application and annual renewal fees for hospital pharmacies.

The proposed fees for hospital pharmacies are an application fee of $3000, issuance fee of $3000, and annual renewal fee of $5000. For comparison’s sake, annual renewal fees for community pharmacies are proposed to increase from $860 to $940.

The disparity between community and hospital fees are concerning. Hospitals, by their nature of being publicly funded institutions, are non-profit organizations. Their operating costs are covered primarily by the tax payers of the province of Ontario. They do not generate a profit. And given the current reality of health care funding, they are being asked to reduce costs and improve efficiencies at all opportunities. The proposed fees, which have never been accounted for by a hospital pharmacy, are detrimental to their significantly limited and chronically shrinking budgets.

Our corporation of four hospitals is expected to reduce total operating costs by $11.5 million in the next fiscal year. Over the previous three years, our funding has been cut by $25 million. Our corporation has four hospitals, three of which operate pharmacies on site, though all four sites were visited by College accreditors. This will result in a cost of $18,000 – $24,000 to initially register with the College, followed by $15,000 – $20,000 annually thereafter. Again, for comparison’s sake, to register one non-profit hospital pharmacy is over five times the cost of registering one for-profit community pharmacy.

According to the list of pharmacies in Ontario on the College’s public register, there are approximately 225 hospital pharmacies in the province. This represents a cost of $1.35 million in application and issuance fees that would be paid by taxpayers in the first year, and $1.125 million in renewal fees annually thereafter. This is prior to applicable HST.

I urge that the College reassess this fee structure prior to implementation and ask that hospital pharmacies pay the same fees as for-profit community pharmacies. Hospitals in Ontario, as well as health care in general, are under significant financial strain due to rising costs and an aging population. These significantly higher fees will add to the economic hardship of non-profit hospital pharmacies, and may result in reduced services, reduced staff, and/or reduced patient safety. It is a well-known fact that the current health care model is financially unsustainable – please do not further contribute to this issue.

50.
Pharmacist  ·  Nov. 5, 2015

Thank you for the opportunity to provide feedback on the proposed application and annual renewal fees for hospital pharmacies. My comments are as follows:

  1. It is not clear to me what will be the total cost for the hospital to have the pharmacy accredited. I am assuming that the application fee of $3,000 is a one-time cost. On an annual basis would the hospital be required to pay both the issuance and annual renewal fees, or is the issuance fee a one-time cost with the application fee?

  2. At GRH, there are three pharmacy areas. At the KW campus, there is the inpatient pharmacy and the Cancer Centre pharmacy. At the Freeport campus, there is a small inpatient pharmacy which is a satellite of the main inpatient pharmacy at the KW campus. Will the proposed fees cover all three areas at the two sites, or will each area be required to pay the fees separately? Please clarify as there is a significant budgetary impact between $11,000 and $33,000.

  3. Our hospital has had to cut $5.8 million from its budget this fiscal year and pharmacy services is required to cut an additional $150,000 from the pharmacy budget for 16/17. Every additional expenditure, such as these proposed fees, is very difficult to accommodate and there will be no choice but to decrease staffing to meet our budget since our supplies budget is very lean and we have had our discretionary funding frozen.

51.
Pharmacist  ·  Nov. 5, 2015

All fee should be lower to reflect the current state of profession.

52.
Pharmacist  ·  Nov. 6, 2015

Recently the College asked for feedback on the proposed amendments to its By-law No. 3, specifically related to fees and changes to information that the College will post on the public register. I would like to provide comment on the application and annual renewal fees for hospital pharmacies.

The proposed fees for hospital pharmacies are an application fee of $3000, issuance fee of $3000, and annual renewal fee of $5000. For comparison’s sake, annual renewal fees for community pharmacies are proposed to increase from $860 to $940.

The disparity between community and hospital fees are concerning. Hospitals, by their nature of being publicly funded institutions, are non-profit organizations. Their operating costs are covered primarily by the tax payers of the province of Ontario. They do not generate a profit. And given the current reality of health care funding, they are being asked to reduce costs and improve efficiencies at all opportunities. The proposed fees, which have never been accounted for by a hospital pharmacy, are detrimental to their significantly limited and chronically shrinking budgets.

Our corporation of four hospitals is expected to reduce total operating costs by $11.5 million in the next fiscal year. Over the previous three years, our funding has been cut by $25 million. Our corporation has four hospitals, three of which operate pharmacies on site, though all four sites were visited by College accreditors. This will result in a cost of $18,000 – $24,000 to initially register with the College, followed by $15,000 – $20,000 annually thereafter. Again, for comparison’s sake, to register one non-profit hospital pharmacy is over five times the cost of registering one for-profit community pharmacy.

According to the list of pharmacies in Ontario on the College’s public register, there are approximately 225 hospital pharmacies in the province. This represents a cost of $1.35 million in application and issuance fees that would be paid by taxpayers in the first year, and $1.125 million in renewal fees annually thereafter. This is prior to applicable HST.

I urge that the College reassess this fee structure prior to implementation and ask that hospital pharmacies pay the same fees as for-profit community pharmacies. Hospitals in Ontario, as well as health care in general, are under significant financial strain due to rising costs and an aging population. These significantly higher fees will add to the economic hardship of non-profit hospital pharmacies, and may result in reduced services, reduced staff, and/or reduced patient safety. It is a well-known fact that the current health care model is financially unsustainable – please do not further contribute to this issue.

53.
Pharmacy Technician  ·  Nov. 6, 2015

I thank you for providing us with an opportunity to share some of our insight and comments on the proposed fees for Hospital Inspection.

Since the inspection process and the regulation of Hospital Pharmacies was mandated by the Ontario government I understand that additional resources had to be developed to support this initiative. In my experience in both hospital and retail I have also been involved with both types of inspections. Currently in our organization there are 2 sites, each with pharmacies, one serves as the main Pharmacy and the other as a satellite, both were visited by the Accreditors. Overall the inspection process was 7 hours at the main site and 3 hours at the satellite, with policies and procedures duplicated at both pharmacies. Overall our inspection process was positive, and the reviews and recommendations were appreciated.

Since this initial inspection was based on defining baseline levels, subsequent inspections will focus on quality and adherence to standards. As hospitals are non-profit and publically funded any operational increase will draw on a perpetual shrinking budget. The difference in the proposed fee structure between retail vs hospital is five times more for the non-profit organizations. Hospitals are already plagued with rising costs, significant budget cuts, and a reduction in staff which directly impacts patient care. Imposing these fees will result in a further reduction of staff and possibly the elimination of some of the satellite sites and a loss of pharmacy presence altogether.

My recommendation would be to align the fee structure already in place for retail with that of hospital and to reconsider those organizations with more than one site. I urge you to reconsider the fee structure for hospitals and ask that the OCP would not contribute to the economic hardship that hospitals and hospital pharmacies are facing.

54.
Pharmacist  ·  Nov. 7, 2015

I don`t agree on posting proceedings or reprimands on pharmacists this will let the public burn him/her up and we loose their trust. the profession is in the lowest wages and pay of any time why would you charge anyone more. I am against posting any languages or ethnical info about any pharmacy or pharmacist..it will be like a free promotion for someone some where from the college..so no no and no. I think pharmacists now are in their slavery era so help them rather than finding ways to charge them or making public their professional mistakes. i know as a fact many pharmacists who are just quitting and opening thier own pizza shops!

55.
Pharmacist  ·  Nov. 7, 2015

The hospital fees appear excessive. Where will these fees go? If it is simply to fund the process of the hospital site visits (paying salaries for inspectors, administrative work, etc) then this is a misuse of funds.

Pharmacist  ·  Nov. 9, 2015

It should be a budget neutral event. The aggregate cost of OCP expenses for inspection should balance out the cumulative fee amount collected from hospital proposed fees. It would be nice to know how the College arrived at the proposed hospital fees !! Is it evidence based or has any comparison been made from other jurisdiction whether with in North America or other countires ?

56.
Pharmacist  ·  Nov. 7, 2015

The flat rate for hospitals is out of proportion. While the pharmacies big and small pay the same rate it is considerably less and affordable by most businesses. Large organizations may be able to afford this fee, however for small hospitals the fees will be a hardship and are totally out of line with the overall budgets for these sites.

57.
Pharmacist  ·  Nov. 8, 2015

Structured Practical Training fees should not be eliminated; reduced from $410 to $300 is acceptable. The cost of the program must balance the revenue generated. Otherwise, it is subsidize by other programs or area of expenses at the College. Jurisprudence exam sitting fee should remain the same. This is to deter students from writing exams before they are ready. Registration filing fee should increase from $130 to $250.

Hospital fees should be tiered according to size (no. Of beds). Numbers to be discussed amongst OCP committee members. If ODB can tiered dispensing fee to smaller rural pharmacies, why OCP cannot come up with a workable formula to do what I have suggested? Using the argument of how it currently charges fees for community pharmacies as a guideline is unsatisfactory explaination. Community pharmacies are private enterprises. Hospital pharmacies are Public enterprises. Therefore fee structure need to be thoroughly discussed, all avenues explored, before submitting to committee for approval.

58.
Pharmacist  ·  Nov. 8, 2015

Doubling of numerous community pharmacy fee's (other than the $80) is too steep. OCP should also be transparent in taking steps to reduce costs/expenses and or work more efficiently with the revenue they are already provided.

59.
Pharmacy Technician  ·  Nov. 10, 2015

Recently the College asked for feedback on the proposed amendments to its By-law No. 3, specifically related to fees and changes to information that the College will post on the public register. I would like to provide comment on the application and annual renewal fees for hospital pharmacies.

The proposed fees for hospital pharmacies are an application fee of $3000, issuance fee of $3000, and annual renewal fee of $5000. For comparison’s sake, annual renewal fees for community pharmacies are proposed to increase from $860 to $940.

The disparity between community and hospital fees are concerning. Hospitals, by their nature of being publicly funded institutions, are non-profit organizations. Their operating costs are covered primarily by the tax payers of the province of Ontario. They do not generate a profit. And given the current reality of health care funding, they are being asked to reduce costs and improve efficiencies at all opportunities. The proposed fees, which have never been accounted for by a hospital pharmacy, are detrimental to their significantly limited and chronically shrinking budgets.

Our corporation of four hospitals is expected to reduce total operating costs by $11.5 million in the next fiscal year. Over the previous three years, our funding has been cut by $25 million. Our corporation has four hospitals, three of which operate pharmacies on site, though all four sites were visited by College accreditors. This will result in a cost of $18,000 – $24,000 to initially register with the College, followed by $15,000 – $20,000 annually thereafter. Again, for comparison’s sake, to register one non-profit hospital pharmacy is over five times the cost of registering one for-profit community pharmacy.

According to the list of pharmacies in Ontario on the College’s public register, there are approximately 225 hospital pharmacies in the province. This represents a cost of $1.35 million in application and issuance fees that would be paid by taxpayers in the first year, and $1.125 million in renewal fees annually thereafter. This is prior to applicable HST.

I urge that the College reassess this fee structure prior to implementation and ask that hospital pharmacies pay the same fees as for-profit community pharmacies. Hospitals in Ontario, as well as health care in general, are under significant financial strain due to rising costs and an aging population. These significantly higher fees will add to the economic hardship of non-profit hospital pharmacies, and may result in reduced services, reduced staff, and/or reduced patient safety. It is a well-known fact that the current health care model is financially unsustainable – please do not further contribute to this issue.

60.
Pharmacy Technician  ·  Nov. 10, 2015

Recently the College asked for feedback on the proposed amendments to its By-law No. 3, specifically related to fees and changes to information that the College will post on the public register. I would like to provide comment on the application and annual renewal fees for hospital pharmacies.

The proposed fees for hospital pharmacies are an application fee of $3000, issuance fee of $3000, and annual renewal fee of $5000. For comparison’s sake, annual renewal fees for community pharmacies are proposed to increase from $860 to $940.

The disparity between community and hospital fees is concerning. Hospitals, by their nature of being publically funded institutions, are non-profit organizations. Their operating costs are covered primarily by the tax payers of the province of Ontario. They do not generate a profit. And given the current reality of health care funding, they are being asked to reduce costs and improve efficiencies at all opportunities. The proposed fees, which have never been accounted for by a hospital pharmacy, are detrimental to their significantly limited and chronically shrinking budgets.

Our corporation of four hospitals is expected to reduce total operating costs by $11.5 million in the next fiscal year. Over the previous three years, our funding has been cut by $25 million. Our corporation has four hospitals, three of which operate pharmacies on site, though all four sites were visited by College accreditors. This will result in a cost of $18,000 – $24,000 to initially register with the College, followed by $15,000 – $20,000 annually thereafter. Again, for comparison’s sake, to register one non-profit hospital pharmacy is over five times the cost of registering one for-profit community pharmacy.

According to the list of pharmacies in Ontario on the College’s public register, there are approximately 225 hospital pharmacies in the province. This represents a cost of $1.35 million in application and issuances fees that would be paid by taxpayers in the first year, and $1.125 million in renewal fees annually thereafter. This is prior to applicable HST.

I urge that the College reassess this fee structure prior to implementation and ask that hospital pharmacies pay the same fees as for-profit community pharmacies. Hospitals in Ontario, as well as health care in general, are under significant financial strain due to rising costs and an aging population. These significantly higher fees will add to the economic hardship of non-profit hospital pharmacies, and may result in reduced services, reduced staff, and/or reduced patient safety. It is a well-known fact that the current health care model is financially unsustainable – please do not further contribute to this issue.

61.
Pharmacist  ·  Nov. 11, 2015

I have a Michigan state license as well as an ontario license to practise as a pharmacist, the Michigan fees are 75% less than what OCP currently charges pharmacists. In light of economic difficulties facing the profession in Ontario it shows that the powers that be running OCP are out of touch. It would be interesting to know how much WE pay the pharmacists that work for the college. I Say NO emphatically to any rate hikes, there are no grounds for it. To also want to charge hospitals $5000 is absurd, these are non for profit organizations. The college has contributed immensely to the problems facing pharmacists in this day and age and this idea of a rate increase buttresses my point.

62.
Pharmacist  ·  Nov. 12, 2015

Recently the College asked for feedback on the proposed amendments to its By-law No. 3, specifically related to fees and changes to information that the College will post on the public register. These significantly higher fees will add to the economic hardship of non-profit hospital pharmacies, and may result in reduced services, reduced staff, and/or reduced patient safety. It is a well-known fact that the current health care model is financially unsustainable – please do not further contribute to this issue.

The proposed fees for hospital pharmacies are an application fee of $3000, issuance fee of $3000, and annual renewal fee of $5000. For comparison’s sake, annual renewal fees for community pharmacies are proposed to increase from $860 to $940.

The disparity between community and hospital fees are concerning. Hospitals, by their nature of being publically funded institutions, are non-profit organizations. Their operating costs are covered primarily by the tax payers of the province of Ontario. They do not generate a profit. And given the current reality of health care funding, they are being asked to reduce costs and improve efficiencies at all opportunities. The proposed fees, which have never been accounted for by a hospital pharmacy, are detrimental to their significantly limited and chronically shrinking budgets.

Our corporation of four hospitals is expected to reduce total operating costs by $11.5 million in the next fiscal year. Over the previous three years, our funding has been cut by $25 million. Our corporation has four hospitals, three of which operate pharmacies on site, though all four sites were visited by College accreditors. This will result in a cost of $18,000 – $24,000 to initially register with the College, followed by $15,000 – $20,000 annually thereafter. Again, for comparison’s sake, to register one non-profit hospital pharmacy is over five times the cost of registering one for-profit community pharmacy.

According to the list of pharmacies in Ontario on the College’s public register, there are approximately 225 hospital pharmacies in the province. This represents a cost of $1.35 million in application and issuance fees that would be paid by taxpayers in the first year, and $1.125 million in renewal fees annually thereafter. This is prior to applicable HST.

I urge that the College reassess this fee structure prior to implementation and ask that hospital pharmacies pay the same fees as for-profit community pharmacies. Hospitals in Ontario, as well as health care in general, are under significant financial strain due to rising costs and an aging population.

63.
St. Joseph's Health Centre Guelph  ·  Nov. 17, 2015

Thank you for the opportunity to provide feedback. I am writing on behalf of my organization and would like to highlight the following concerns: 1. The fees appear to be fixed with no consideration of number of beds, size of hospital, size of department, or number of pharmacy staff. 2. Given the current fiscal climate of restraint and operational cuts this proposed fee is very concerning as there is no budget allocation to cover these new costs, and our only recourse will be to take from direct patient care. 3. This will potentially require our organization to put key safety initiatives such as eMAR on hold as licensing fees may usurp these funds.

64.
Pharmacist  ·  Nov. 17, 2015

So community pharmacies which are businesses and make profits of tens of thousands or even hundreds of thousands of dollars a year only have to pay a renewal fee of $940, but hospital pharmacies which are pubically funded and do not generate any revenue have to pay $5000 per year?

65.
Pharmacist  ·  Nov. 18, 2015

Recently the College asked for feedback on the proposed amendments to its By-law No. 3, specifically related to fees and changes to information that the College will post on the public register. I would like to provide comment on the application and annual renewal fees for hospital pharmacies.

The proposed fees for hospital pharmacies are an application fee of $3000, issuance fee of $3000, and annual renewal fee of $5000. For comparison’s sake, annual renewal fees for community pharmacies are proposed to increase from $860 to $940.

The disparity between community and hospital fees are concerning. Hospitals, by their nature of being publicly funded institutions, are non-profit organizations. Their operating costs are covered primarily by the tax payers of the province of Ontario. They do not generate a profit. And given the current reality of health care funding, they are being asked to reduce costs and improve efficiencies at all opportunities. The proposed fees, which have never been accounted for by a hospital pharmacy, are detrimental to their significantly limited and chronically shrinking budgets.

Our corporation of four hospitals is expected to reduce total operating costs by $11.5 million in the next fiscal year. Over the previous three years, our funding has been cut by $25 million. Our corporation has four hospitals, three of which operate pharmacies on site, though all four sites were visited by College accreditors. This will result in a cost of $18,000 – $24,000 to initially register with the College, followed by $15,000 – $20,000 annually thereafter. Again, for comparison’s sake, to register one non-profit hospital pharmacy is over five times the cost of registering one for-profit community pharmacy.

According to the list of pharmacies in Ontario on the College’s public register, there are approximately 225 hospital pharmacies in the province. This represents a cost of $1.35 million in application and issuance fees that would be paid by taxpayers in the first year, and $1.125 million in renewal fees annually thereafter. This is prior to applicable HST.

I urge that the College reassess this fee structure prior to implementation and ask that hospital pharmacies pay the same fees as for-profit community pharmacies. Hospitals in Ontario, as well as health care in general, are under significant financial strain due to rising costs and an aging population. These significantly higher fees will add to the economic hardship of non-profit hospital pharmacies, and may result in reduced services, reduced staff, and/or reduced patient safety. It is a well-known fact that the current health care model is financially unsustainable – please do not further contribute to this issue.

66.
Pharmacist  ·  Nov. 19, 2015

Recently the College asked for feedback on the proposed amendments to its By-law No. 3, specifically related to fees and changes to information that the College will post on the public register. I would like to provide comment on the application and annual renewal fees for hospital pharmacies.

The proposed fees for hospital pharmacies are an application fee of $3000, issuance fee of $3000, and annual renewal fee of $5000. For comparison’s sake, annual renewal fees for community pharmacies are proposed to increase from $860 to $940.

The disparity between community and hospital fees are concerning. Hospitals, by their nature of being publicly funded institutions, are non-profit organizations. Their operating costs are covered primarily by the tax payers of the province of Ontario. They do not generate a profit. And given the current reality of health care funding, they are being asked to reduce costs and improve efficiencies at all opportunities. The proposed fees, which have never been accounted for by a hospital pharmacy, are detrimental to their significantly limited and chronically shrinking budgets.

Our corporation of four hospitals is expected to reduce total operating costs by $11.5 million in the next fiscal year. Over the previous three years, our funding has been cut by $25 million. Our corporation has four hospitals, three of which operate pharmacies on site, though all four sites were visited by College accreditors. This will result in a cost of $18,000 – $24,000 to initially register with the College, followed by $15,000 – $20,000 annually thereafter. Again, for comparison’s sake, to register one non-profit hospital pharmacy is over five times the cost of registering one for-profit community pharmacy.

According to the list of pharmacies in Ontario on the College’s public register, there are approximately 225 hospital pharmacies in the province. This represents a cost of $1.35 million in application and issuance fees that would be paid by taxpayers in the first year, and $1.125 million in renewal fees annually thereafter. This is prior to applicable HST.

I urge that the College reassess this fee structure prior to implementation and ask that hospital pharmacies pay the same fees as for-profit community pharmacies. Hospitals in Ontario, as well as health care in general, are under significant financial strain due to rising costs and an aging population. These significantly higher fees will add to the economic hardship of non-profit hospital pharmacies, and may result in reduced services, reduced staff, and/or reduced patient safety. It is a well-known fact that the current health care model is financially unsustainable – please do not further contribute to this issue.

67.
St. Joseph's Health Centre Guelph  ·  Nov. 19, 2015

Subject: Proposed Revision to By-law Number 3

Dear Ontario College of Pharmacists (OCP),

I am writing on behalf of St. Joseph’s Health Centre Guelph. This letter is to offer our feedback on the proposed revisions to By-law Number 3.

The proposed flat fee structure does not take into account the size of the organization, clinical complexity, operational budget, services offered, or number of staff.

Our pharmacy services 59 Complex Continuing Care beds and 27 Rehabilitation beds. Our current staffing is comprised of fewer than 4 FTEs which includes 1 FTE of purchased Pharmacist time.

The complexity of the services we offer cannot be compared to larger academic teaching hospitals or even to community general hospitals. We would expect that an inspection of larger more complex facilities would also require more inspectors and a more lengthy inspection process. Smaller, less complex hospitals should be charged a much lower fee.

The proposed fee will divert funds from patient care and patient safety.

In an environment where hospital funding is being held at zero or reduced, the new fee is not affordable and would necessitate the diversion of resources from patient care to pay for this new regulatory overhead. Further the new fee may impair the ability of organizations such as ours to implement new safety measures that require new investments.

The proposed fee is exorbitant when compared to the fees charged to community pharmacies.

The proposed fees for hospitals include a $3,000 application fee, plus $3,000 issuance fee, plus an annual renewal fee of $5,000 which are exorbitant when compared to the community pharmacy fees with an application fee currently of $250 (proposed $500) and annual renewal fees currently of $860 (proposed $940).

68.
Pharmacy Technician  ·  Nov. 20, 2015

The proposed changes are reasonable but what about the Registered Technicians that are in the process of their SPT. Will the changes affect them?

69.
Pharmacist  ·  Nov. 20, 2015

-I believe that it is professionally more relevant to specify extra certification (e.g. Certified Geriatric Pharmacist) for public knowledge than to list languages (which can be posted at pharmacy level and will probably vary according to staff at work. PLEASE start to add extra educational descriptions to pharmacist information. -I have worked in both hospital and retail pharmacies. Is OCP creating some kind of a schism? There is a lot of variety in pharmacy workplaces. Could we consider that a pharmacy is a pharmacy is a pharmacy? It is unfair and unrealistic to expect, for example, a small hospital pharmacy to pay higher OCP fees than a facility such as the one run by ESI/Eclipse insurance. Fee structures need review and justification to members. Also, has OCP asked for financial assistance of any kind from government sources? For example, I consider that it is unfair that the Ministry of Health subsidizes physicians malpractice insurance, but does not give a similar offer to pharmacists. -Fees for Pharmacy Technicians should be in proportion to their wages as compared with Pharmacist fees. Because we are in a difficult financial climate, fees should all be reviewed, including fees for new members starting to work. OCP can always change fees later, if we achieve a more prosperous future.

70.
Pharmacist  ·  Nov. 20, 2015

I wish to applaud the document that you created (Table Summary) in order to make it easier to compare the proposed changes to what is currently in place. My comments below reference the sections of the By-law as they occur in that Table:

10.3.2: (grammatical)...Just preceding the proposed changes, the word "by" appears to be absent from directly in front of "...any two of the Registrar,..." (etc.).

11.4.27: The proposal to allow any language(s) the Member wishes to form part of the Register information has been addressed by other respondents, and I would agree that it is inappropriate to allow self-declared lising of this information on the public Register -- UNLESS the College is going to assess that this is accurate information, to the extent that there can be adequate provision of services to/with patients in that language.

At present, the OCP website is very clear in its position regarding the two official languages of this country: English, & French. (http://www.ocpinfo.com/registration/training-exams/language-proficiency/)

Members have the right to be "interacted with" in either of these official languages. Will this not mandate that the OCP staff (inspectors) be able to inspect the member in that language? Or, during a practice review, will staff be qualified to "listen in on" and assess the level of care being provided if a language other than English or French is used? This is very dangerous territory and should likely be left OUT OF the statutory and By-law requirements/permissives. If a member wishes to notify their patients they can speak another language, that's another matter. But don't get into "permitting" it in the By-law if you're not going to be able to assess the veracity of that "officially-listed" (per it being in the Register) self-declaration.

11.8.2: Changing the retention period for information to the public at large regarding a member's history, etc. from 6 years to 3 is a change that results in far too short an interval. If a review is made of recidivism by members, one will see that often the interval for repeat offenders is beyond 3 years. In some cases, the probation period alone for "repeat inspections" etc. resulting from Discipline may extend to 3 years.

The six-year period for this vital information is still quite reasonable and should remain; even the CRA requires financial records, etc. be retained for at least six years from the end of the year in question. I would suggest a serious re-visit to this proposal prior to making this change, taking into consideration some of the concerns mentioned above.

Thank you.

71.
MICs Group of Health Services  ·  Nov. 20, 2015

The proposed position of fees for accreditation of hospital pharmacies seems excessively high, especially for small hospitals. I am writing on behalf of a group of 3 small hospitals. Our hospitals share one pharmacy department to minimize cost. I would advocate for prorating fees based on size and complexity of services offered. The presence of a pharmacy in the hospital should also be taken into consideration. Two of our hospitals do not have physical pharmacies, but yet will be expected to pay the same fee as large teaching hospitals. The proposed fee alone represents over 7% of the annual pharmacy budget for two of our hospitals, which as you can imagine, puts additional pressure on our resources. Thank you for your consideration in this matter.

72.
Grey Bruce Health Services  ·  Nov. 20, 2015

Thank you for the opportunity to provide feedback on the proposed revisions to the Ontario College of Pharmacists (OCP) By-Law No. 3. The OCP has done a great deal of work in the last two years to create a framework for, and a baseline assessment of Pharmacy Practice in the Hospital Pharmacy setting. As a multi-site hospital corporation, our greatest concern is the financial impact of the proposed fee structure. With six individual sites, our total initial Assessment and Issuance fee will be $36,000, and the annual renewal fee an additional $30,000. This is a very significant added expense for a hospital with no budgetary support. The fee itself seems excessive on first review. To have hospital fees placed at over five times that of a Community Pharmacy fee is simply unfair and unacceptable. Given the current framework for hospital funding, the cost will be paid from either Pharmacy departmental budgets, or from other budgets currently supporting direct patient care. It would be a very unfortunate irony if this initiative - designed to ensure quality and patient safety, in fact becomes a factor in reducing a hospital’s ability to provide the best possible patient care. Many small hospitals, ours included, have regionalized services and support structures, including Pharmacy management and distribution systems, in an effort to maximize efficiencies and use resources responsibly. To separate these individual hospitals on a ‘per site’ basis as proposed will result in a disproportionate increase in fees applicable to our amalgamated entity. This also seems contrary to effective management of limited resources. We submit a few possible alternatives to the proposed fee structure that could address some of these difficult decisions: 1. a reduction in the fees for each hospital site to something much closer to our Community Pharmacy counterparts 2. consideration for reduced fees or a single common fee for amalgamated hospital corporations 3. a tiered system based on number of beds, number of services (according to those defined in the OCP hospital assessment document) or a combination of both 4. a fee per hospital (as defined by the Ministry of Health and Long-Term Care) rather than per site (as defined by OCP accreditation number) 5. a fee based proportionally on number of beds, number of visits for ambulatory centers, total hospital budget, or Pharmacy operational budget.
6. consideration to have the total provincial fees paid directly from the MoHLTC to the OCP.

73.
Providence Care  ·  Nov. 20, 2015

Recently the College asked for feedback on the proposed amendments to its By-law No. 3, specifically related to fees and changes to information that the College will post on the public register. I would like to provide comment on the application and annual renewal fees for hospital pharmacies.

The proposed fees for hospital pharmacies are an application fee of $3000, issuance fee of $3000, and annual renewal fee of $5000. For comparison’s sake, annual renewal fees for community pharmacies are proposed to increase from $860 to $940.

The disparity between community and hospital fees are concerning. Hospitals, by their nature of being publicly funded institutions, are non-profit organizations. Their operating costs are covered primarily by the tax payers of the province of Ontario. They do not generate a profit. And given the current reality of health care funding, they are being asked to reduce costs and improve efficiencies at all opportunities. The proposed fees, which have never been accounted for by a hospital pharmacy, are detrimental to their significantly limited and chronically shrinking budgets.

Our corporation has two hospitals and a long term care home. Funding to our two hospitals has been cut by $4.2 million in the past three years. Based on the funding formula, we expect to see funding cuts into the future as well. Both hospital sites were visited by College accreditors. This will result in a cost of $12,000 to initially register with the College, followed by $10,000 annually thereafter. Again, for comparison's sake, to register one non-profit hospital pharmacy is over five times the cost of registering one for-profit community pharmacy. I would be interested to hear the rationale behind the disparity in the proposed fee structure between community pharmacies and hospital pharmacies.

According to the list of pharmacies in Ontario on the College’s public register, there are approximately 225 hospital pharmacies in the province. This represents a cost of $1.35 million in application and issuance fees that would be paid by taxpayers in the first year, and $1.125 million in renewal fees annually thereafter. This is prior to applicable HST.

I urge that the College reassess this fee structure prior to implementation and ask that hospital pharmacies pay the same fees as for-profit community pharmacies. Hospitals in Ontario, as well as health care in general, are under significant financial strain due to rising costs and an aging population. These significantly higher fees will add to the economic hardship of non-profit hospital pharmacies, and may result in reduced services, reduced staff, and/or reduced patient safety. It is a well-known fact that the current health care model is financially unsustainable – please do not further contribute to this issue.

74.
Ontario Branch of the Canadian Society of Hospital Pharmacists (CSHP-OB)  ·  Nov. 23, 2015

The Ontario Branch of the Canadian Society of Hospital Pharmacists (CSHP-OB) thanks you for the opportunity to provide feedback on the proposed revisions to the Ontario College of Pharmacists (OCP) By-Law No. 3 respecting fee changes, in particular, the implementation of fees for application and issuance of Certificates of Accreditation, and annual renewals of this Certificate. The OCP has done a great deal of work in the last two years to create a framework for, and a baseline assessment of Pharmacy Practice in the Hospital Pharmacy setting. CSHP-OB certainly welcomes and endorses the OCP’s role in this important patient safety and quality initiative. By drawing together best-practice as well as legislated standards into a single organized, justifiable and implementable format is no small endeavor. As a stakeholder in the process as well as a collection of members who have participated in the initial assessment process, we continue to support the ongoing activities of the OCP. The amount of the proposed total fees for the province of Ontario seems justifiable on a cost-per-value basis.
The fees and structure presented in the proposed bylaw, however, do raise numerous concerns amongst our membership. We welcome the opportunity to provide feedback on those issues. The feedback heard most often, is that the fee itself seems excessive when placed next to fees for our colleagues practicing in a Community setting ($940), or a Drug Preparation Premises ($2500). A fee that is over five times greater than the Community annual renewal has captured the attention of most respondents.
This leads to another concern raised: Some members and leaders that responded to CSHP-OB are gravely concerned that these fees will be taken from Pharmacy Departmental or Program operating budgets. Hospitals have little flexibility in absorbing new costs – these monies may well be taken from direct patient care initiatives, or alternately at the expense of other departmental supports or activities that support direct patient care. It would be unfortunate to see the cost of OCP’s activities, aimed at increasing patient safety and quality, actually reduce a hospital’s ability to support the same goal. Smaller, amalgamated hospitals of various configurations and sizes have also raised the concern that efforts to regionalize common services, including programs and activities to standardize medication therapy management, procurement and quality assurance systems will now be compromised due to the approach of this proposed fee structures. In particular, the “per site” strategy suggested will be overwhelming for small hospitals that have used regionalization to gain the ability to provide services above what might be possible if they functioned independently.
As an organization, CSHP-OB is also concerned for the patients at hospitals, particularly smaller institutions that have limited contact with modern, team-centric pharmacy services. These institutions, focusing on how to provide the best possible care for their patients may not be as aware of the benefits to some of the ‘aspirational’ standards in the OCP assessment document. It would be unfortunate, but we believe possible, for these hospitals to ‘opt out’ of having a pharmacy department within their hospital. In the short term this could benefit the institution financially, but I cannot believe that would be the intent or goal of the OCP to have the entire pharmacy services outsourced in an effort to avoid the annual fee. To reiterate, CSHP recognizes the value for the proposed total fees requested by the OCP. To make this financial impact less to hospitals, we submit a few possible alternatives to the proposed fee structure:

  1. a flat fee across Ontario Pharmacy in its entirety (same fee for retail and hospital)

  2. consideration for reduced fees or a single common fee for amalgamated hospital corporations

  3. a tiered system based on number of beds, number of services (according to those defined in the OCP hospital assessment document) or a combination of both

  4. a fee per hospital (as defined by the Ministry of Health and Long-Term Care) rather than per site (as defined by OCP accreditation number)

  5. a reworking of current bylaw section 14.1 that considers multi-pharmacy fee structures

  6. a fee based proportionally on number of beds, number of visits for ambulatory centers, total hospital budget, or Pharmacy operational budget.

  7. consideration to have the total provincial fees paid directly from the MoHLTC to the OCP.

  8. advocacy to the MoHLTC to increase base budgets and earmark the increase for Pharmacy fees

One particular model discussed at length at the CSHP-OB was the concept of a ‘risk/activity formula’. Working on the assumption that a high-risk, high-volume hospital will utilize more of OCP’s dedicated but limited resources, and presumably is in a hospital with a larger base budget, we would consider a cost formula structured in the general format of:

  1. Base fee (example – congruent with community pharmacy of $940)

  2. additional fees:

a. Per-activity fee – using the OCP assessment document, identifying higher risk practice areas – Radiopharmaceuticals; Aseptic Hazardous Drugs preparation; Methadone/Suboxone; high-level automation and charging a $500 “per activity” fee – full suite of this example would be an additional $2000 per year. This may also support Thiessen’s recommendation #8 to annually inspect pharmacies, focusing on risk stratification

b. Per-volume fee. Set a defined “Per Bed”, “Per visit” or combination fee to charge higher costs to those hospitals with a greater need to avail themselves of OCP assessment staff. This could be set to place a “usual” mid-to-large community hospital close to $1500

c. Per-site fee. Add $500 per pharmacy department in an amalgamated entity.
These numbers are for illustration purposes only, and would need to be considered by OCP. CSHP-OB recognizes the value to hospitals that OCP oversight and assessment brings, and wishes to balance that against a hospital’s ability to re-organize revenue and according to the OCP staff workload they would potentially generate.

Again, thank you for the opportunity to present these considerations. CSHP-OB executive is available for discussion of any of these points.

75.
Ontario Pharmacists Association  ·  Nov. 23, 2015

The Ontario Pharmacists Association (OPA or the “Association”) welcomes the opportunity from the Ontario College of Pharmacists (OCP or the “College”) to comment on the proposed revisions to By-Law No. 3.

Read the rest of OPA's submission here.

76.
North East LHIN Integrated Alignment Committee  ·  Nov. 23, 2015

Thank you for the opportunity to provide feedback regarding your proposed revisions to By-Law Number 3. On behalf of 25 hospitals (see list below) in the North East Local Health Integration Network (LHIN), we collectively...

Read the rest of North East LHIN Integrated Alignment Committee's submission here.

77.
Ontario Hospital Association  ·  Nov. 23, 2015

The Ontario Hospital Association (OHA), on behalf of its members, appreciates the opportunity to provide comments to the Ontario College of Pharmacists’ (College) on its proposed revisions to By‐Law No 3 – Fees and Public Register. The proposed By‐Law amendments include the proposed fee model for application, issuance, and renewal of certification along with public register in response to the Drugs and Pharmacies Regulation Act (DPRA), which will enable the oversight of hospital pharmacies by the College.

Ontario hospitals are deeply committed to providing high‐quality patient care and ensuring compliance with legislation, standards, and accepted safeguards. Further to the Ministry of Health and Long‐Term Care’s (Ministry) commitment to support implementation of the recommendations of the Review of Oncology: Under‐dosing Incident Report, the OHA is committed to working collaboratively with the College, the Ministry, and other health system stakeholders to establish an appropriate role for the College in the oversight of hospital pharmacies.

Reflecting on input from our member hospitals’ Directors/Managers of Pharmacy and Leadership Councils, the OHA has significant concerns related to the proposed fees and respectfully submits that the proposed framework is not a viable fee structure. With this in mind, we have outlined a number of recommendations and would be pleased to discuss these further with you.

1. Proposed College Fee Structure

The draft College By‐Law proposes an initial application fee of $3,000 and issuance fee of $3,000 per site for hospitals; and, additionally, an annual renewal fee of $5,000 per site, to support a cost‐recovery model and cover the $1.1 million in expenses the College’s current model would incur annually.

Ontario hospitals are experiencing significant and sustained budget constraints with a wide range of cost pressures and competing priorities. This is the fifth year where hospitals have not received any inflationary increase to meet growing financial pressures. Despite these challenges, hospitals have remained committed to improving patient care. Today, hospitals are at a critical juncture where they must make difficult resourcing decisions around continuing programs and services for patients. Hospital oversight strategies, such as that proposed by the College for pharmacies, must be designed to be respectful of this challenge and share stewardship for the financial capacity of the province’s hospitals.

Ontario hospitals are remarkably diverse in their size and structures. Some small, rural and northern hospitals have fewer than 20 beds. Others are multi‐site corporations with differing pharmacy requirements and services across different sites. Across all hospitals, the fees proposed by the bylaws represent yet another cost pressure and will only add to the financial pressures elsewhere in the hospital.

The OHA respectfully requests that the College consider the following options:

Recalibrate the Scale of the Oversight and Licensing Program

Hospitals are regularly faced with difficult program design decisions. We respectfully request that the College reconsider aspects of the design of its hospital oversight program (e.g., budget, staffing, travel) in order to sustain achievement of core objective through resources that the province and hospitals can afford. It is our understanding that the initial thrust of work to complete baseline assessments in all hospitals in one year, while commendable, would not be a true reflection of future work requirements. The OHA supports a more viable fee structure that allows hospitals to focus resources toward the implementation of standards and future safety practices, rather than paying administrative fees.

Seek Ministry Funding and Nominal Hospital Application/Renewal Fee

With the Ministry committed to supporting the new role for the College and the licensing of all Ontario hospital pharmacies, the OHA supports the creation of a dedicated budget that would be provided to the College to support the infrastructure and ongoing inspection/licensing requirements associated with this work. This separate budget would ensure that the costs would not require offset hospital fees, as it would in the current proposal. With this preferred fee structure, hospitals would pay a nominal initial application fee and then an annual renewal fee. For instance, in British Columbia, the OHA understands that this fee is $1,331 per hospital site.

Amalgamate College Infrastructure and Fee Schedule for Hospitals and Community

The current fee structures associated with hospital pharmacy oversight is many times greater than the fees charged to community pharmacies. Not‐for‐profit hospitals do not have capability to raise additional revenue to offset additional fees. Closer alignment of the hospital and community programs would better leverage the expertise and economies of scale currently being achieved in the community sector and divide the total budget among all pharmacies.

Delivery Through a Regional Peer‐Surveyor Model

Based on member feedback, one additional consideration toward the model that may support the College with decreasing its annual budget requirements is a regional peer‐surveyor model, similar to Accreditation Canada. Pharmacy leads from Ontario hospitals would support review, inspection and ongoing peer mentoring of peer and local hospitals; and in addition, the review and update of standards related to the practice. With consideration to this model, the staffing and travel requirements for the College may not need to be as extensive.

Utilize Differentiated Licensing and Fee Structures

While a number of hospitals in Ontario are comprised of one site, there are many situations where a hospital corporation has numerous sites. In the case of community and small hospitals, many of these sites have pharmacies, but many do not participate in high‐risk pharmacy activities (e.g., chemotherapy drug preparation). As such, we would also recommend consideration to differentiating hospital pharmacies licenses and fee structures.

2. Communicating the College Inspection Results through a Public Register

The OHA is supportive of a public register that would outline details similar to the current public register (e.g., accreditation number, corporation name, address, status of accreditation). It is important to consider the best way to capture hospital site‐specific information within the fields that relate to the broader hospital corporation. Additionally, the inspection criteria and the standards that hospitals are being assessed against should be posted; however, individual hospital summary reports would not.

The OHA recommends the College specify how they will address situations where a hospital may receive a “pass with conditions” or a potential “fail” as it would be critical for the hospital to address the areas of concern, liaise with the College for an update to the inspection report, and continue to provide pharmacy services to meet patient care needs at the hospital. It is our understanding that an inspection report would be effective immediately, and, as such, we request further clarity on the process and next steps that would be considered.

3. Additional Operational and Implementation Considerations

The OHA wishes to raise a number of other operational and implementation issues related to the inspection and accreditation of hospital pharmacies:

  • While the OHA support appropriate oversight of hospital practices we must draw attention to situations where duplication of efforts contributes to inefficient use of valuable time and resources. There is significant overlap with the emerging work of the College and that of Accreditation Canada’s standards, which include a specific set targeted at medication management. In moving forward with the accreditation of hospital pharmacies by the College, it would be helpful to clarify the scope of accreditation and how the overlap of accreditation between the two organizations will occur. For instance, to prevent duplication of assessment on the same criteria, having Accreditation Canada defer to the College’s inspection results, where accreditation was recently assessed and completed. 

  • In consideration of the baseline assessments that have been completed, there are a number of resource requirements needed for hospitals in order to meet the standards outlined in the inspection templates to support accreditation. A number of hospitals are faced with challenges related to implementing these standards – for example, concern has been raised with the cost of the estimate for implementing USP 795 and 797 standards, which the OHA understands could range from anywhere from $100,000 to more than $1 million per hospital site. Further, several members indicated that the renovations required to fully implement these standards may be physically impossible given the current size and structure of their facilities. 

  • Acknowledgement of the number of different quality initiatives currently underway in the province and the need for a service‐based prioritization and provincial‐level plan to address the areas with a realistic outlook regarding the standards, timelines and outcomes we wish to achieve.

Conclusion

We are committed to working with the College, the Ministry and our member hospitals to establish an appropriate role for the College that balances oversight with fiscal realities hospitals are facing, and also support the prioritization of work such that legislation/regulation and standards are successfully and consistently implemented across the sector.

The OHA would like to thank you once again, for the opportunity to provide feedback on the draft proposed By‐Law. We would be please to meet and speak further on the recommendations outlining our suggested alternative models above at any time.

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