Members of the Ontario College of Pharmacists are required to opt into Part A or Part B of the Register.

Part A refers to practitioners who are engaging in Direct Patient Care, and maintaining the minimum practice requirements as set forth in the regulations to the Pharmacy Act, 1991 (Section 45).

Part B of the Register refers to practitioners who are not engaging in Direct Patient Care. Members in Part B are not subject to random selection and participation in the Quality Assurance Practice Review, nor are they required to maintain the minimum practice requirement (600 hours of practice within Canada every three years).

As a member of the Ontario College of Pharmacists, your membership fees remain the same, whether you are in Part A or Part B of the College Register. Part A and Part B, members are required to maintain a record of Continuing Education (Learning Portfolio), and are expected to maintain the ethical and practice standards of the profession set by College Council.

Membership Requirements in Part A of the Register

In the regulation, "Part A" means the "direct patient care" part of the register. Council was unanimous in its decision that election into Part A of the register be incumbent on a pharmacist providing care directly to patients. Therefore, if you interact directly with patients or their agents in the course of practising the profession in Canada, you must be in Part A of the register. Council further defined "practising the profession" according to the scope of practice for pharmacy in Ontario, as set out in the Pharmacy Act, 1991.

This means that only pharmacists in Part A of the register will be able to provide pharmacy services directly to patients or their agents, provide information related to drug use in the course of providing direct patient care, and be the designated manager of an accredited pharmacy.
Effective January 2000, pharmacists choosing Part A of the register must have provided direct patient care in the course of practising pharmacy for a minimum of 600 hours (within Canada) over the past three years.

The employment criteria below meets the definition of Direct Patient Care, and qualifies the minimum practice requirement:

• Counsel or dialogue with patients or their agents about medications including non-prescription medications and health care aids
• Provide information related to drug use, in the course of practicing the profession, directly to patients or their agents
• Perform either or both cognitive and/or technical functions of compounding or dispensing
• Supervise the compounding or dispensing function, as above
• Directly supervise the part of a non-accredited pharmacy where drugs are kept
• Review any prescription order for individual patients, or perform a patient profile or clinical review for an individual patient
• Develop drug therapy protocols or policies directly related to drug therapy practices specific to the institutional setting in which you practise.

Pharmacists in Part A of the register are also required, upon random selection beginning in March 1997, to undergo a Peer Review. This review is based on the National Model competencies adopted by Council in May 1997, and updated in 2007.

Membership Requirements in Part B of the Register

Pharmacists choosing "Part B" of the register are declaring that they will not be providing direct patient care.
This means that a pharmacist in Part B of the Register may not:

• Work in a pharmacy as a pharmacist
• Fill in as a pharmacist on an occasional basis
• Provide information related to drug use to patients, agents or health care providers in the course of providing direct patient care as a pharmacist, or
• Be the designated manager of an accredited pharmacy

Although a pharmacist electing to Part B cannot be the designated manager of an accredited pharmacy, he or she can, as a registered pharmacist in Ontario, be an owner of a pharmacy, or a director of a corporation owning a pharmacy in Ontario. Pharmacists in Part B may also be the manager, director or supervisor of a pharmacy department in a hospital or health care facility, and could therefore supervise pharmacists and technicians in an institutional setting but may not provide direct patient care.

Those pharmacists who provide information related to drug use in their usual workday, but who do not provide direct patient care while practising the profession, would be expected to elect into Part B of the register. Examples could include, but not be limited to, pharmacists currently working in: administration (including College staff), academia, government, the pharmaceutical industry, drug information services, and consulting firms. However, such pharmacists wishing to remain in Part "A" of the register could do so provided that they fulfil the practice requirement of 600 hours of direct patient care while practising the profession, over a three-year period as set out in this regulation.

If you wish to discuss whether your current employment duties satisfy the minimum practice requirement, please contact the Continuing Competency Programs in writing, providing details regarding your employment duties.

Changing your Membership Status on the Register

Movement from Part A to Part B
A member may move from Part A to Part B of the Register at any time simply by notifying the College (to the attention of the Client Services Department) in writing, of his or her intent to do so. The change in election would take place immediately, and a new wallet card reflecting the change in election to Part B would be sent to the member by mail.

If the member is currently participating in Phase I or Phase II of the Quality Assurance Practice Review, the member is also required to provide written notice to the Continuing Competency Programs, indicating the intent to move to Part B of the Register. Peer Review candidates who opt into Part B of the Register, are exempted from participating in the Peer Review, until such time as the member wishes to move back to Part A of the Register.

Movement from Part B to Part A
A member may move from Part B to Part A of the Register by notifying the College, in writing, of his or her intent to do so and by successfully undergoing the College's peer review. Peer reviews are currently held 4 times yearly. Every attempt is made to ensure that a member wishing to undergo a peer review for the purposes of transferring from Part B to Part A is promptly scheduled into the next available administration.

Members who have not notified the College otherwise, but who seek to change their election from Part B to Part A on the annual pharmacist fee form, will be contacted by staff to confirm that a change in election is indeed being requested, and to schedule the member into the next mutually convenient Peer Review.

Current policy allows a member in Part B to work in a pharmacy under the direct supervision of a pharmacist in Part A, for the purposes of preparing for the peer review, for a period of time not to exceed two consecutive six-month periods without the approval of the Quality Assurance Committee. In order to do this, pharmacists in Part B must notify the College in writing of their intention, citing the name of the pharmacist under whom they will be working, the name and address of the practice site, and the anticipated start and finish dates.

A member will be transferred from Part B to Part A of the Register provided they successfully complete Phase II of the Practice Review (the Peer Review) and satisfy the educational and practice requirements that may be specified by the Quality Assurance Committee. Members are considered to have successfully completed the Peer Review if they met or exceeded the set standard in the following areas of assessment: clinical knowledge, gathering information, patient management and follow-up, and communication skills.

The Quality Assurance Committee will not transfer a member from Part B to Part A unless it is satisfied that he or she has met or exceeded the standards in both the areas of clinical knowledge and communication skills.

For more information: “Moving From Part B to Part A of the Register”

Powers of the Quality Assurance Committee to Transfer from Part A to Part B

The Quality Assurance Committee has the discretion to transfer a member from Part A to Part B of the Register by the authority granted under Section 47(3) of the College's Quality Assurance regulation, which reads:

If a pharmacist listed in Part A fails to undergo a required practice review, the Committee may transfer the pharmacist to Part B after giving him or her a reasonable opportunity to make written submissions.

This section would apply to any member who fails to participate in either Phase I or Phase II of the QA practice review process after being randomly selected to do so. The QA Committee would only act under the authority of this section in instances where repeated communications from the College to a member have gone unanswered. Section 47(3) gives the Quality Assurance Committee the power to transfer a member from Part A to Part B in such instances after giving him or her reasonable opportunity to make written submissions to the QA Committee. Members must be given 14 days in which to make written representation or to request an appearance before the QA Committee in order to make an oral submission to the QA Committee citing reasons why they should not be transferred into Part B.

Members Who Resign and Are Reinstated

If a member resigns after having been selected for either Phase I or Phase II of the QA practice review process; their obligation to participate in the process will cease with their resignation. However, should that member be reinstated according to current College policy, he or she shall resume his or her position in the QA process and shall be expected to continue as a full participant.