Feedback for Proposed Changes to the DPRA regulations

Pharmacist  ·  May 10, 2015

Regarding the DPRA, I would like to comment as follows:

1) For part 2, drug schedules, the DPRA should read that a pharmacist or pharmacy student/intern working under the direct supervision of a pharmacist shall be available for consultation and shall supervise the sale of Schedule 3 products. This ensures that the health professional with proper training in therapeutics is overseeing the sale of these products in line with the patient's best interest.

2) Regarding O. Reg 58/11, there should be an outright ban on drug price advertising for Schedule 1 products. Also, there should be an outright ban on advertising involving price for professional services related to Schedule 1 and 2 products. This will help to ensure continuity of care and reduce the potential for errors occurring with frequent transfers. For professional services such as vaccinations, frequent transfers driven by promotions makes it more difficult to track patients who require a series of time sensitive injections and ensure proper compliance. Interruptions in this schedule could impact upon the effectiveness of the vaccine.

3) For Part VI, acts of proprietary misconduct, 32. The following are acts of proprietary misconduct for the purpose of section 140 of the Act: 18. Entering into any agreement that restricts a person’s choice of a pharmacy or pharmacist without the consent of that person.

The word consent should read express written consent and add language to this clause that includes entering into agreements that limit and/or deny a patient’s medication coverage, without consent, so that it would also be considered as an act of proprietary misconduct.

Patients should be able to seek out the care that best meets their individual needs without having their choice encumbered by insurance plans that unnecessarily restrict their coverage. Part of the therapeutic relationship involves the trust that is built up between a patient and their individual pharmacist. Some patients have been forced to go to pharmacies outside of their community to ensure full insurance coverage even though some patients have limited mobility and means to travel.

4) I fully agree with the following: • Acts of Proprietary Misconduct [Newly proposed section 34]:

34: It is a conflict of interest for a responsible person to do, or to cause or permit another person to do, directly or indirectly, any of the following: (e) Enters into any agreement or arrangement that adversely influences or appears to adversely influence the exercise of professional expertise or judgment or the ability of a member working in the pharmacy to engage in the practice of the profession in an ethical manner or in accordance with the standards of practice of the profession

5) I support the maintenance of the existing language of O. Reg. 58/11 as it pertains to the availability of pharmacy references. This will ensure consistent minimum standards are set regarding references so that pharmacists are able to provide optimal care.

6) Remote dispensing should only be authorized in locations where reasonable and documented efforts have failed to obtain the services of a physically present pharmacist. In line with best practice, a physically present pharmacist can offer a suite of services unmatched by the machines. The physical assessment of patients is facilitated by the physical presence of a pharmacist and vital services such as vaccinations require the physical presence of a pharmacist. A physically present pharmacist can detect the smell of alcohol on the breath of patients or their unsteady gait which may be a sign of intoxication and intervene to prevent potentially dangerous interactions with benzodiazepines or alcohol to name a few. Remote dispensing should not be used in a way to displace physically present pharmacist services which would be contrary to the public interest.

7) Regarding the DPRA, pre-54 charters should not be allowed to be passed on so that there is movement towards full accountability for all owners. Currently there is one class of owners, pharmacists, who have the education and accountability necessary for the College to regulate the profession in the best interest of the public. Non-pharmacist owners have no license to practice and so are immune from suspension of this license. Non-pharmacist owners also do not have the education necessary to know which products have an acceptable risk benefit profile when deciding which products to carry. As an example, many retail pharmacies continued to sell Kava kava long after reports of liver toxicity surfaced. A pharmacist owner who continued to sell these products could be held to a higher standard than a non-pharmacist owner by the College given their training and education.

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