Feedback for Proposed Changes to the Pharmacy Act (Administration of Vaccines by Pharmacists)

Pharmacist  ·  April 1, 2016

I am firmly in favour of pharmacists being able to provide greater access to immunizations, however these regulations fall short of truly increasing access as most of the vaccines listed in table 3 are Schedule 1 products and require a prescription, and therefore the prescribing and the administration of these products are separate acts. The way the regulations read currently, pharmacists will only be able to administer these vaccines if the patient presents with a prescription for the schedule 1 product and that without a prescription written by an authorized prescriber, pharmacists will not be able to initiate immunization for the patient. Influenza vaccine is a schedule 2 product, so being able to merely administer the vaccine did not present a legal issue, however with schedule 1 products, the patient will still need to visit a prescriber). With the current wording of the regulations, the only vaccinations that can be administered in pharmacy without a prescription would be Haemophilus influenzae type B, pediatric Hepatitis B, and pneumococcal (conjugate and polysaccharide). Moreover, pharmacies will not be able to become yellow fever designated sites and order vaccine as pharmacists will not be able to be the site's designated health care provider without the authorization to prescribe the vaccine - they would need to have a collaborative relationship with a prescriber as the pharmacist cannot be the designated HCP even with a medical directive. This means that very few pharmacies would ever be able to actually purchase or administer yellow fever vaccine. I see these as huge drawbacks to the changed regulations as it "sounds" like patients will have better access to vaccines, but they truly will not. It is often the patient assessment & prescribing of the vaccine that is the barrier to access, rather than the administration itself.

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