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

Novartis  ·  May 30, 2016

Please find below the submission from Novartis with regards to this request for feedback to the proposed legislation. I think we have picked up an important nuance that needs to be included in this review and amendment.

Currently, pharmacists may administer the influenza vaccine within the context of Ontario’s Universal Influenza Immunization Program (UIIP). These proposed amendments to the Pharmacy Act Regulation support the Ministry of Health and Long-Term Care’s promise to provide Ontario’s patients with an improved healthcare experience. The proposed changes would allow for the administration of additional vaccinations for 13 diseases that are preventable by vaccines. The Ontario College of Pharmacy and Ontario Pharmacists Association have asked for feedback on proposed amendments to the Pharmacy Act Regulations that, if approved, would authorize pharmacists to administer vaccines beyond influenza vaccine.

Novartis is pleased to provide feedback to the proposed amendments to the Pharmacy Act Regulations. Providing safe, effective and accessible vaccines to the public is a central theme to achieving a high standard of health care in Ontario. Currently there are many vaccines that have been approved by Health Canada that are not funded by the government, that individuals may choose from to protect themselves. The addition of vaccines in the 13 disease areas into the scope of pharmacist practice is an important step towards allowing greater access to the public of those vaccines that remain approved but unfunded.

Influenza has long been recognized as one of the most challenging vaccine programs to delivery effectively and an important first step was achieved by involving Pharmacists in the UIIP program. It is important to note that the UIIP program is restricted to only those vaccines that are funded by the Ontario government and for those individuals that are deemed eligible. Currently it is not within the Pharmacists scope of practice to provide an influenza vaccine that is approved but unfunded, while physicians can. Similar to the 13 new disease areas, many influenza vaccines are approved but remain unfunded.

Novartis would like to provide the feedback that the amendment to the Pharmacy Act be expanded to include all vaccines that protect against Influenza (not just those covered by the UIIP). This would then ensure that Ontarians would have access to all vaccines in the 14 disease state areas that are both funded and unfunded.

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