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

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.

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