Feedback deadline was: October 29, 2018
Summary
This consultation is now closed.
The Ontario College of Pharmacists (OCP) is currently seeking feedback on a draft Opioid Policy. The College is inviting all pharmacy professionals, stakeholders, members of the public and others to comment. Following the consultation, the final draft Opioid Policy will be brought forward for approval by Council in December 2018.
The College recognizes that no single initiative will “fix” Ontario’s opioid-related issues and is committed to implementing a comprehensive opioid strategy that will align with federal and provincial opioid-related goals. To ensure that a sustainable and effective approach is taken to addressing opioid-related issues, the College has developed a multi-pronged Opioid Strategy to simultaneously address relevant areas of practice. One of the initiatives of this Strategy is the development of an Opioid Policy. This policy has been developed to outline OCP’s expectations for pharmacy professionals regarding opioids. An External Working Group comprised of representatives from key stakeholder groups, pharmacy professionals from various geographic areas and practice settings and persons with lived experience assisted in the development of this policy.
The development of the Opioid Policy was guided by the following principles:
- The policy should be in alignment with federal and provincial strategies,
- The policy should be in alignment with Health Quality Ontario Quality Standards,
- The policy should provide direction regarding the appropriate processes, policies and procedures that pharmacists should have in place, and the considerations that pharmacy professionals should incorporate into their workflow processes to ensure best patient outcomes,
- The policy is not intended to be clinical in nature, duplicate information contained in clinical practice guidelines, or direct specific details for the development of processes, policies and procedures,
- The policy will include further direction regarding the standard of practice and operation applicable to any opioid therapy, regardless of the indication, and highlight the requirements for Opioid Agonist Treatment and
- The policy will not duplicate information contained in other College guidelines or policies, or other resource documents (e.g. CAMH pharmacist’s guide to methadone and buprenorphine for opioid use disorder, clinical guidelines on opioid prescribing, health quality standards)
Questions to Guide Your Feedback
- The purpose of the Opioid Policy is to promote safe and appropriate opioid use through education and training, sharing of evidence-based best practice and outlining expectations. Does the document achieve this objective?
- Does the Opioid Policy align with the principles listed above?
Frequently Asked Questions
Frequently Asked Questions about the Opioid Strategy can be found here.
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Feedback from Doug Hunter, Chairperson, Education Committee, Families for Addiction Recovery: 1. Information Resources for Those With Substance Use Disorders: The pharmacist in some cases may be the first one to notice an addiction issue in a customer. If each pharmacist kept a list of local resources (eg Rapid Access Clinic, Smart Recovery, NA etc.) that could be reviewed with any customer to assist in their addiction recovery, outcomes could be improved. The pharmacist has the potential to play a key role in a customer’s recovery. 2. Broad Provision of Naloxone Kits Across Ontario: Our organization is in the process of doing a survey of all pharmacy chains in Canada to understand their policy with respect to the stocking of Naloxone kits and signage that announces this within their stores. We will send you this when it is complete. If a pharmacy stocks and dispenses opioids of any kind, they should also have to stock Naloxone kits. We are still finding stores that are not stocking Naloxone kits and this makes it challenging especially in remote communities where there isn’t other choices to get the Naloxone kits. There are actually a couple of cases in the US where pharmacists have revived people from overdoses in the pharmacy parking lot using Naloxone. The more that Naloxone kits are available across the country, the more lives could be saved. If OCP in fact cannot mandate this, it should be highly recommended. 3. Opioid Agonist Treatments: As with the provision of Naloxone, FAR believes that if a pharmacy stocks opioids of any kind, they should also stock OAT substances such as Suboxone. OAT treatments are working successfully to prevent potentially fatal relapses and assist those in addiction recovery. The more that Suboxone is available across the country, the more lives could be saved. If OCP in fact cannot mandate this, it should be highly recommended. Thanks for the opportunity to provide feedback. We would be happy to further discuss any aspect of our feedback with you. Regards Doug Hunter
On behalf of the Board of Directors and members of the Ontario Pharmacists Association (‘˜OPA’, the ‘˜Association’), we welcome the opportunity to comment on the draft opioid policy of the Ontario College of Pharmacists (‘˜OCP’, the ‘˜College’). The Association is supportive of College’s overarching Opioid Strategy, on which the draft policy is based, and agrees with its focus on advancing opioid- related education, harm reduction initiatives, strategies to prevent opioid use disorder, and the promotion of quality assurance specific to opioid security and dispensing. [Read the full submission](/library/consultations/download/OPA-feedback.pdf)
The Neighbourhood Pharmacy Association of Canada (Neighbourhood Pharmacies) appreciates the opportunity to provide this Submission Brief regarding the Ontario College of Pharmacists’ Draft Opioid Policy. The impacts of the Opioid Crisis have been well documented, with over 1,000 opioid related deaths in Ontario in 2017. Many strategies have been initiated in Ontario to attempt to address the ongoing Opioid Crisis, and to better serve patients suffering from acute and chronic pain and prescribed opioids. We are pleased to see that the College’s proposed policy framework is aligned with several other strategies ‘" both provincially and federally. [Read the full submission](/library/consultations/download/neighbourhood-feedback.pdf)
Dear colleagues at the Ontario College of Pharmacists: The Canadian Society of Hospital Pharmacists (CSHP) is a national voluntary organization of pharmacists committed to patient care through the advancement of safe, effective medication use in hospitals and other collaborative healthcare settings. Thank you for providing CSHP OB the opportunity for providing feedback on the Opioid Policy. Members of CSHP Ontario Branch (CSHP OB) have reviewed the Draft Opioid Policy, the following feedback was received and collated for your review and consideration: [Read the full submission](/library/consultations/download/CSHP-feedback.pdf)
I have very pleased to find that this document addresses both sides of opiate use – its wonderful benefits for many patients as well as the possible terrible outcomes for some patients and when it is abused. Many documents from other sources are focusing on the crisis only. This document clearly states the pharmacist role in opioid use.
1. Under Principles – `Pharmacy professionals should employ the same respectful, patient-centred, professional approaches and attitudes towards opioid dependent patients as they would toward any other patient’ I would suggest change opioid dependent patients to: patients who are on chronic opioid therapy, opioid agonist therapy or those with opioid use disorder. Opioid dependent patients is not defined and seems to have a negative connotation to it. 2. Under Assessment also include symptoms of opioid use disorder or diversion as a bullet (risk is listed but not identification) 3. Communication with Prescribers- change `Patients with possible substance abuse disorder and diversion to `Patients with possible opioid abuse disorder OR diversion (instead of and making both must be present to communicate to the prescriber and that it is regarding opioids not all substances as currently described)
I don’t find it useful in any way or shape, lack new rules and as always new authorities for pharmacists to use and help them deprescribe/taper opioids, or correct aga overprescribing from irresponsible MDs, to protect the public. Distribution of naloxone kit is a passive tactic and far from enough to face the crisis, be proactive snd correct the cause, RCA as OCP always recommend for error prevention.
I find the opioid policy very vague and does not address the common scenarios that community pharmacists often struggle with. They need support how to deal with patients with abberrant behaviour, motivational counseling for patients going through opioid tapering. Pharmacists also need to be educated on how to best taper opioid prescription and support prescribers. There are many questions that need to be asked… how slow, how often, how much to release based on patient’s individual characteristics. Ideally, pharmacists in the community should have direct connection with mental health services and build a stronger rapport with physicians to collaborate on managing withdrawal symptoms and pain management.
Opioid misuse is no longer an acceptable term, and I would suggest the following: Introduction …opioid use or aberrant use. …growing numbers of opioid morbidities and death. Education and Training …special considerations are necessary for opioid therapy Assessment …past medication history, lifestyle factors, – rather than ) –identify benefit from opioid tapering or rotation ….communicate with prescriber regarding opioid tapering, rotation or alternative…. page 5 near top …aberrant opioid use….. —tapering or rotating opioids for pain in title and body of the paragraph Record keeping add This includes providing patients with a written receipt to document they have received their OAT medication when doses are administered at different facilities.
The opioid policy but we have to stress the pharmacist to keep an eye for ONMS warning and call the other colleagues to check the dose and the amount of opioid and comparing it with the maximum dose of opioid.
lot of medications are misused by patients or by physicians who accept always early refill even though there is a strict interval or double doctoring without noticing NMS . more strict opioid rules must be applied and more education programs for physician and pharmacists to be applied although naloxone kit should be mandatory on any prescription having any high risk medication