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

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.

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