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