Feedback for Proposed Changes to the Pharmacy Act (Registration and Quality Assurance)

Pharmacist  ·  Oct. 12, 2017

As a former Registrar I am usually reluctant to comment on College proposals; however, I feel the need to share my concerns/thoughts respecting the proposals relating to the QA program. My primary concern is that the College is using the same staff person during a visit to the same pharmacy- to perform both a compliance-based inspection under the DPRA and then a QA assessment under the Pharmacy Act. Notwithstanding the creation of ‘firewalls’ to separate the two functions, I believe that using the same College Practice Advisors, to perform inspections relating to operational standards (per the DPRA) followed by contemporaneous QA assessments (per the Pharmacy Act) which are educational, remedial and non-punitive- create perceptions that are misleading to members, and may raise questions of appropriateness. The Health Professions Procedural Code (S.83) is clear that information gathered under Quality Assurance is confidential, not to be shared with any other committee or program area of the College; in my view, using inspectors to conduct quality assurance assessments may create problems for the College, and the practice should be reconsidered. I also believe that the proposed regulation needs to include more details regarding what the new components actually are/will be. As example, a required component of any QA program is a Peer Review process. Since College staff are not peers, I think provisions need to be made in the proposal to include such member/peer interactions, as part of the details. I agree that too much detail may preclude flexibility, but would suggest that enough particulars respecting the program and its components need to be included to ensure the components and integrity of the QA program are maintained and continued going forward, in compliance with the statutory requirements

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