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

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).

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