Feedback for Proposed Changes to the Pharmacy Act (Administration of Vaccines by Pharmacists)Pharmacist · April 19, 2016
To begin, in past consultations, the minutes of Council have reported upon the numbers of responses received. As such, many of them appearing here appear to be very very similar; perhaps repeat posters, perhaps "flooding" to try and increase the numbers on one concept so it gets favoured consideration by the College? One hopes not.
The response from a public member (#118) is far too specific in terms used, references, etc. to be an "average" member of the public. It sounds more "administrative" or "outside professional". But further comments are warranted:
1) While many favour this "advance" in practice, given the vaccines being considered and the acumen of the average community pharmacy, do we really think that these vaccines will be "in demand" on a regular basis from such pharmacies? That cuts two ways: first, not being as busy as some might suggest it could be; and second, how does a pharmacy that only gets the occasional request for certain of the 13 vaccines keep them in stock so they don't expire before being needed?
2) Will "convenience" be realistic to the patient? That is: if a prescription is presented for one of the vaccines and it's not in stock, or has expired, there will still be a wait and re-visit by the patient when it arrives in the pharmacy. This needs consideration.
3) Given the "live vaccine" aspect that others have commented on, it is imperative that rather than "grant approval to the pharmacist" to administer, the OCP needs to first make sure the PREMISES has a designated area that meets its specifications -- not the general dispensary area where multiple patients sit beside each other as they wait for their shots (first-hand experience as a patient at a prominent pharmacy chain administering the flu vaccine). If the premises is not set up to provide this designated area, the pharmacy should not be allowed to participate (same manner as being properly outfitted to do non-sterile/sterile compounding). It is no good to assume the premises will meet requirements, then find out it does not and "pull" the ability to administer vaccines. It must be kept professional, and the designated area will go a long way to achieving that goal.
4) It must be mandated that any administration of vaccine be reported to the primary care physician after (to cover situations where the patient is not a regular patient, as well as in regular patients), so that the healthcare file is comprehensive. This will prevent duplication of vaccinations (possibly hazardous) when patients aren't really aware in attending the pharmacy what they may/may not have had in the past. (We base a huge degree of confidence in assuming we shall have a complete record from the patient at time of attendance -- far from realistic). Since doctors bill OHIP and that creates a central record under the Health Card for that patient, pharmacists don't have that benefit. Either it must be incorporated into the process, or duplication could occur when a secondary authority to the physician is allowed to administer vaccines (i.e., no central record access for pharmacists).
5) Extra workload on the pharmacist: hard to tell at this point how many of these new vaccines (if approved) will be required to be administered at the pharmacy, and how often, in order to state that it will create a huge further strain on pharmacists already stretched to the limit, or not. The impact of this action on practice should be monitored and assessed by the OPA, in liaison with the OCP. Since the OCP has a mandate of, in part, protecting the patient interest, certainly increasing the risk of errors in an already maximized pharmacy by increasing workload ought to be an OCP concern.
6) The specific 13 vaccines put forward in "16-HLTC005" (regulatory change to O.Reg 202/94) raises a question as to whether it is that specific that only those listed will be approved (i.e., Hepatitis A alone, item 3; Hepatitis B alone, item 4), or if combinations of the listed vaccines will be permitted (i.e., Twinrix). To avoid confusion, HepA+HepB mixture should be listed as an individual entity, if it is expected that Twinrix is to be approved for administration. (This is a realistic consideration given that individual drug plans are very specific in terms of what vaccines may be covered on a patient's plan).
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