College Operations Update in response to COVID-19 ... READ MORE  
close skinny banner

Expanding Scope of Practice: Pharmacist Prescribing for Minor Ailments

Feedback deadline is: May 22, 2020
Summary

The College has created posting guidelines to support open and constructive feedback that is directly related to the subject matter under consideration. Please read and follow these guidelines when submitting comments for this consultation.


The Minister of Health has asked the College to submit regulations that expand the scope of practice for pharmacists. The College recently submitted regulations to enable pharmacists to: 1) Administer the flu vaccine to children as young as two years old; 2) renew prescriptions in quantities of up to 12-month supply; and 3) administer certain substances by injection and/or inhalation for purposes that are in addition to patient education and demonstration on November 30, 2019 and are currently being reviewed by government. Communication will occur once these regulations are approved by government and therefore are able to be implemented.

The College was also asked to submit a regulation that would enable pharmacists to prescribe drugs for certain minor ailments by June 30, 2020 to improve access to care in the community and reduce the need for emergency or urgent care visits. As a result of this request, the College is seeking feedback on proposed amendments to the General Regulation 202/94 of the Pharmacy Act, Part VII.3 (Controlled Acts) that, if approved, would authorize pharmacists the expanded scope to prescribe medications for certain minor ailments.

Minor ailments are health conditions that can be reliably self-diagnosed by a patient who is familiar with their condition, and managed with self-care strategies and/or minimal treatment. Other criteria include:

  • Short-term conditions
  • Lab results aren’t usually required to make an assessment or prescribe the appropriate medication
  • Low risk of treatment masking underlying conditions
  • Medications and medical histories can reliably differentiate more serious conditions
  • Only minimal or short-term follow-up with the patient is required

The proposed draft amendments would enable pharmacists to prescribe medications in the American Hospital Formulary Service (AHFS) Pharmacologic-Therapeutic Classification system categories for the following 12 minor ailments:

Minor ailments and corresponding AHFS categories –

The draft regulations would enable pharmacists to prescribe medications within the AHFS categories for the corresponding minor ailment in the chart.

CONDITION AHFS CLASSIFICATION
1. Urinary tract infection (uncomplicated)
  • Anti-infective Agents: Antibacterials. Sulfonamides (8:12.20)
  • Anti-infective Agents: Urinary Anti-infectives (8:36
2. Dermatitis (atopic/eczema, allergic and contact skin rashes)
  • Skin and Mucous Membrane Agents: Anti-inflammatory Agents. Corticosteroids (84:06.08)
3. Insect bites (including tick bites) and urticaria (hives)
  • Skin and Mucous Membrane Agents: Anti-inflammatory Agents. Corticosteroids (84:06.08)
  • Antibiotic Tetracyclines (8:12:24)
4. Conjunctivitis (bacterial, allergic, viral)
  • Eye, Ear, Nose, and Throat Preparations: Anti-infectives. Antibacterials (52:04.04)
  • Eye, Ear, Nose, and Throat Preparations: Antiallergic Agents (52:02)
5. Allergic rhinitis (nasal symptoms from allergies)
  • Eye, Ear, Nose and Throat Preparations: Anti-inflammatory Agents. Corticosteroids (52:08.08)
  • Eye, Ear, Nose and Throat Preparations: Antiallergic Agents (52:02)
6. Candidal stomatitis (oral thrush)
  • Skin and Mucous Membrane Agents: Anti-infectives. Antifungals. Polyenes (84:04.08.28)
7. Herpes labialis (cold sores)
  • Anti-infective Agents: Antivirals. Nucleosides and Nucleotides (8:18.32)
  • Skin and Mucous Membrane Agents: Anti-infectives. Antivirals (84:04.06)
  • Skin and Mucous Membrane Agents: Anti-inflammatory Agents. Corticosteroids (84:06.08)
8. Hemorrhoids
  • Skin and Mucous Membrane Agents: Anti-inflammatory Agents. Corticosteroids (84:06.08)
  • Skin and Mucous Membrane Agents: Antipruritics and Local Anesthetics (84:08)
  • Skin and Mucous Membrane Agents: Miscellaneous Skin and Mucous Membrane Agents (84:36)
9. Gastroesophageal reflux disease (GERD)
  • Gastrointestinal Drugs: Antiulcer Agents and Acid Suppressants. Histamine H2-Antagonists (56:28.12)
10. Dysmenorrhea (menstrual cramps)
  • Central Nervous System Agents: Analgesics and Antipyretics. Nonsteroidal Anti-inflammatory Agents. Other Nonsteroidal Anti-inflammatory Agents (28:08.04.92)
11. Musculosketelal sprains and strains
  • Central Nervous System agents: Analgesics and Antipyretics. Nonsteroidal Anti-inflammatory Agents. COX-2 inhibitors (28:08.04.08)
  • Central Nervous System agents: Analgesics and Antipyretics. Nonsteroidal Anti-inflammatory Agents. Other Nonsteroidal Anti-inflammatory Agents (28:08.04.92)
12. Impetigo (bacterial skin infection common in children)
  • Skin and Mucous Membrane Agents: Anti-infectives. Antibacterials (84:04.04)
  • Skin and Mucous Membrane Agents: Anti-inflammatory Agents. Corticosteroids (84:06.08)

 

Before providing feedback, you are encouraged to review the proposed regulatory amendments to the General Regulation 202/94 of the Pharmacy Act in sections 35 and 38 and Schedule 4 which has been added. A clause by clause comparison of the draft regulations are available here.

When reviewing and commenting on the draft regulations, please consider:

  • the intent of these regulation changes to protect the public and support quality pharmacy care;
  • the expectations of the public in making sure the expanded scope for pharmacists is both accessible and safe;
  • the expectations of pharmacy professionals that the regulation changes appropriately enable them to apply their current knowledge, skill and ability to perform the expanded scope activities safely.
Submission

Background

Expanding scope of practice is intended to enable pharmacists – the health care professionals with the most extensive pharmacotherapy education – to take on a greater role in improving health outcomes by maximizing their knowledge and skills to initiate, manage and optimize drug therapy. In Canada, seven provinces have authorized pharmacists to prescribe for minor ailments, with Alberta being the first province to implement the expanded scope in 2007. Since 2012, Ontario pharmacists have had the authority to prescribe specific medication only for smoking cessation. Under the current Standards of Practice, pharmacists can prescribe based on their assessment of the patient, having collected and interpreted relevant patient information. The purpose of the assessment is not to diagnose, which pharmacists are not authorized to do, but to determine the most appropriate treatment option for the patient. Part of the assessment involves identifying when it would be appropriate to refer to another health care provider and to advise when to follow-up should symptoms not resolve.

In developing the regulatory changes needed to enable the new scope, the College considered the appropriate parameters that optimize the knowledge and skills of pharmacists in an integrated care model while also ensuring the delivery of safe, high quality patient care, improving access to care in the community and the ability to reduce unnecessary emergency department visits.

The proposed draft regulations were informed by feedback from registrants, the public, patient advisors, experts in pharmacy, medicine, public health, health systems research, and anti-microbial stewardship; as well as professional associations and other stakeholders. For more information about the College’s engagement and collaboration activities as it relates to expanding scope of practice, please visit our Expanding Scope of Practice webpage.

Please Note: The intent of this consultation page is to enable and encourage open and constructive feedback on matters that are directly relevant to the consultation topic, in accordance with our posting guidelines. Comments that are not directly related to the consultation topic or that are not in accordance with our posting guidelines will not be posted. Thank you.

Leave a Reply

Your email address will not be published. Required fields are marked *

Leave a Comment

Your email address will not be published. Required fields are marked *. Alternatively if you would like to reply via your email, use the link below.

Reply via email   

Read The Feedback
29 COMMENTS
  • pharmacist - POSTED March 25, 2020 REPLY   

    Good day, Although I think that it is a great step forward if this is approved, I still think it is not enough. Pharmacists have several years more training in pharmacology compared to doctors, thus, as you mentioned, pharmacists should not be diagnosing, but doctors should not be prescribing at all. A doctor is a specialist in diagnosis and a pharmacist is a specialist in treatment. I’m from South Africa where doctors have pharmacology for 6months compared to pharmacists with 4 years training in pharmacology. The number of prescriptions received from doctors with incorrect treatments plans are shocking, because they simply do not have the knowledge, they use standardized treatment plans from a book. So yes, pharmacists should be allowed to prescribe, ALL medicine. Doctors can recommend a prescription, but pharmacists should have the final say and be able to change anything on the prescription. Lastly, the reason why I am commenting from SA, I will be emigrating to Canada as soon as this pandemic is sorted. From an activist for the pharmacy profession.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : +27849912440
    Organization name : N/A
  • pharmacist - POSTED March 25, 2020 REPLY   

    I support the expansion of the scope of pharmacists to prescribe treatment for minor ailments. This would help improve the efficiency of care for Ontario patients, and it has been shown to be a successful strategy in seven other provinces already.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
  • pharmacist - POSTED March 25, 2020 REPLY   

    I absolutely support this expansion of pharmacist scope due to our accessibility to the public and our knowledge and understanding of these minor ailments. I hope to continue to support our patients in any way possible and look forward to moving forward with these regulations.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
  • pharmacist - POSTED March 25, 2020 REPLY   

    Dear OCP I am disappointed by the unnecessary caution taken in drafting this list. I find this list to be quite limited in scope, both in general as well as in comparison to other jurisdictions. I recommend you take this back to consider a significant expansion. As a starting point to the expansion, I would highly recommend adding that pharmacists can legally prescribe anything that is Schedule 2, 3 or unscheduled. We already recommend these products, so they are clearly within our scope. This will assist patients with drug coverage for medications they may not otherwise be able to afford. For example, many plans cover treatment for vaginal candidiasis but that is not on your list. This means a low income woman with drug coverage must take time away from work/family to make an unnecessary visit to the doctor for a prescription. This is a waste of her time/money as well as health care resources. Additionally, there was no consideration given to prescribing for contraception. (Was a gender lens applied in making this list? I note that the “missing” conditions predominantly affect women) Oral contraceptives and emergency contraception (including Plan B as well as Ella) must be considered as an essential preventative health service and access to BCP should not be contingent on Pap tests. I am relieved PPIs are not on this list as they are prone to misuse and complications. Notably absent is shingles. Treatment must occur in a short time period and pharmacists are ideally place to deliver. Also: Lyme disease is increasing in prevalence and there are standardized post-exposure protocols. again that must occur within a short window, that could easily be implemented in a pharmacy setting. These are simply the ones that come to the top of my mind. There are undoubtedly others. Other provinces have proven the utility of pharmacist-delivered prescribing while we have lagged far behind. Please do not squander this opportunity to improve health care delivery in Ontario.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
  • pharmacist - POSTED March 25, 2020 REPLY   

    My only concern is the timeline of June 2020. Assuming we are still in the middle of a pandemic, community pharmacists will still be trying to limit close contact with patients. Since every scope change comes with extra education and documentation requirements, I predict it will force us into closed rooms with patients to properly assess and document, get a signature of consent, etc without any kind of PPE available. Not to mention the extra workload it will add when many teams are already working with a skeleton crew due to either assistants staying home for their own safety or having to segment staff into siloed teams to limit the fallout should one team member contract Covid-19. I have no issue with minor ailment prescribing, in general. I even took a workshop course in preparation 2 years ago when talk really got going about it. My only issue is the timeline.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 2266220805
  • pharmacist - POSTED March 25, 2020 REPLY   

    I approve these new regulations but need more information on how to apply.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
  • pharmacist - POSTED March 25, 2020 REPLY   

    Whilst this a step in the right direction, the list provided is very limited. The Pharmacist should be able to do what the walk-in doctors do..they write a prescription for a patient for a patient and disappears ..leaving all the responsibilities to the Pharmacist to address all the issues eg. allergy, interactions etc. If we are to expand the scope of practice for the Pharmacists, we have to increase the listed conditions. Right now, in this pandemic situation, the Pharmacists are performing so much advisory role ..talking to the patients, constantly on the phone..and not getting paid one cent for these services. At this point of time Physicians on the telehealth are being rewarded by OHIP …Why these disparities..I care for the profession and I care for our patients..The Pharmacists are very capable of prescribing …with the expanded list

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 4167163196
    Organization name : AJAX PHARMACHOICE
  • pharmacist - POSTED March 25, 2020 REPLY   

    I don’t support any expansion in pharmacists’ scope of practice without mandatory reimbursement criteria. We extend and adapt prescriptions now without payment for the most part. We do thousands of flu shots for very little money after supplies costs and time are taken into account. This means we are spending time and accumulating liability without being paid for it. Until OCP mandates that pharmacists and pharmacies must charge for services, ALL pharmacists should oppose any expansion of scope including for minor ailments.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 4169602323
    Organization name : The Village Pharmacy
  • pharmacist - POSTED March 25, 2020 REPLY   

    Safety should be of great concern for both public and pharmacy members. As COVID 19 has cleary demonstrated there is a move for PHCP (doctors and nurse practitioners) to see and assess patients by virtual means. Thus I am recommending we “the profession of pharmacy” think about the current practice sites and have amendments that include safe practice sites that include virtual assessments of patients for current and future pandemics. Thus allowing the delivery of this needed service to our community and help free up ER time.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
  • pharmacist - POSTED March 25, 2020 REPLY   

    It is absolutely imperative that pharmacists provide these additional cognitive services with NO expectation of compensation. Minor ailment prescribing by pharmacists is an excellent way for provincial health ministries to contain spiralling costs. Take the above chart of eligible ailments, for example. If a physician saw 12 such patients with the listed conditions, he/she would bill the Ministry of health for $400 or more. A pharmacist would now be able to provide these services at no cost to the Ministry, saving tens if not hundreds of millions of dollars annually. These savings could be spent developing critical health infrastructure concepts like eHealth for every resident of Ontario. Minor ailment prescribing would greatly enhance professional satisfaction among pharmacists by removing them from the transactional drudgery of dispensing and counselling on prescriptions. As community pharmacies evolve into a model with A pharmacist could look forward to spending 30 minutes of each hour interviewing and meticulously documenting minor ailment encounters with patients.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Independent community pharmacist
  • pharmacist - POSTED March 25, 2020 REPLY   

    I agree with expanding Pharmacists role under 2 conditions; 1. All pharmacists to undergo mandatory certified educational program similar to cannabis education, this would ensure standardized practice. 2. Employers must do better to provide extra help for pharmacists. Dispensing staff need to be better educated instead of just qualified technicians, we must raise the standards so pharmacists do not feel rushed to perform like robots. No doubt there will be paperwork involved so it must be kept simple. We must put in place measures that ensure that patients receive the best care and not as how some pharmacies conduct poor Medschecks just to bill the government. Lets do this right!

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 6134911515
  • pharmacist - POSTED March 26, 2020 REPLY   

    I am in full support of prescribing for minor ailments. Many patients do not want to take time off work to see their doctor for something “minor”, we can be accessible. We should get compensated for it, just like the other provinces. Also, can we include sinusitis and pharyngitis to the minor ailments, and able to prescribe antibiotics for them? I see we can prescribe corticosteroids for them, if we can add antibiotics as well for those conditions that would be complete.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Riverbend Pharmacy
  • pharmacist - POSTED March 26, 2020 REPLY   

    I am very interested. I would also like to know if Pharmacists’s will get ohip billing rights or how we will be paid for our services

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 5194916778
    Organization name : London Road pharmasave
  • pharmacist - POSTED March 26, 2020 REPLY   

    Dermatitis/ insect bites could be accompanied by fungal or bacterial infection such as: chronic diaper rash with fungal infection or children insect bites that are scratched and started to develop a bacterial infection. Both cases would required an antibiotic/corticosteroid or antifungal/ corticosteroid topical combination.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Rexall
  • pharmacist - POSTED March 27, 2020 REPLY   

    For UTI’s I would be more comfortable if there was a process by which the patient could provide a urine sample that would be sent to a lab before the empiric antibiotic was given to the patient, so that drug therapy could be changed appropriately if the culture and sensitivities of the urine sample came back resistant for the antibiotic prescribed.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 6136561588
  • pharmacist - POSTED March 27, 2020 REPLY   

    It does concern me that lab work may not be checked when prescribing certain medications renally cleared and I think we should make it mandatory to check labs. It worries me that pharmacists will not have adequate and consistent training across the board before prescribing. Please make sure they have to have proper training for sure.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 5196961119
    Organization name : Grand River Hospital
  • pharmacist - POSTED March 29, 2020 REPLY   

    I am a Pharmacist. The list provided above is a good start. But as most of my pharmacist colleagues mentioned in their comments, it is still lacking lots of other topics. I find Ontario way behind other Provinces. Please look at the scope of practice in Alberta! What are the results, pros & cons of pharmacists prescribing? Can we learn from the experiences of other provinces & modify the practice based on their outcomes? Please move forward with the suggested scope. Ontario is in desperate need for legislating the help that we are already providing. I also suggest we start looking at the next set of minor ailments that we can add to the the list above. Several topics have been mentioned in the comments that can be added. Constipation is another example. Lots of schedule 3 medications are covered by ODB & just need a prescription to get it covered. I think I have clearly made my point. Hope to see this happening in the next few months.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
  • pharmacist - POSTED March 29, 2020 REPLY   

    I am against the proposed prescribing of minor ailments as it is a major conflict of interest to be both prescribing and dispensing for a patient. The only way I see this being resolved is if any prescriptions initiated by a pharmacist must be filled at a completely unrelated pharmacy, so that there is no financial conflict of interest and no pressure from owners to write unnecessary treatments.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
  • Other - POSTED March 30, 2020 REPLY   

    Minor ailments prescribing , good change to provide more care to patients and show how expert are pharmacists. Injection to children than 5 y may not be appropriate in pharmacy.

  • pharmacist - POSTED April 3, 2020 REPLY   

    I think it is not a bad idea but we need to qualify for it and do more CE to reach the level Possibly also limitation to less than what is mention is good. I would not suggested treating Impetigo or complicated UTI.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Myself
  • pharmacist - POSTED April 3, 2020 REPLY   

    OCP needs to have some involvement with the remuneration piece advocacy as it relates to pharmacist uptake and overall system benefits. Payment by government to pharmacy must be inclusive of all Ontarians and must be absent of any co-payment. Otherwise patients will gravitate back to primary care for minor ailment assessment in order to save themselves money. Otherwise pharmacist uptake will be piecemeal at best and will not effectively contribute to government system goals.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : MacTavish Pharmacy
  • pharmacist - POSTED April 3, 2020 REPLY   

    I feel that we need to get this done as we have lagged behind most of the other provinces by years. Once we have it in place we can adapt it, add more categories, etc. Education must be mandatory to provide these services. Right now it is more important than ever. I feel this should be made available right now.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 7052824124
  • pharmacist - POSTED April 5, 2020 REPLY   

    I am happy we are moving forward with this initiative however just like when the Fee Schedule came out years ago, pharmacies in general have not been charging for these services. Whenever I extend a prescription I tell my patients that there should be a $15 charge just so they at least know there is value in my work. Considering we do most of the functions on this list with many OTC products already I am fine with these changes but ONLY IF we are going to get paid by the government for easing the strain on the healthcare system and reduce wait times for family docs etc. It is ridiculous that the government pay for a MD visit to assess a bug bite and the prescription is HC 1%. The cost to the system is $50 versus paying the RpH a fraction of the amount. Moreover, please do not make the assessment and record keeping more arduous than it needs to be. That will help no one in the end. Finally, this COVID crisis should make pharmacists stand up and ensure our value is recognized and remunerated. Thanks

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 9054675745
  • member of the public - POSTED April 7, 2020 REPLY   

    I am in agreement that pharmacists have an expanded role in determining the best medication to be used for a condition or illness. They are highly trained professionals and know the uses and effect of drugs, more than many doctors.. If the customer always uses the same pharmacy to fill their prescriptions and the pharmacists are stable, then it may be OK to expand services. I fear that pharmacists that work as employees such as at Walmart or Cosco, rather than co-owners of a pharmacy, may not be working in a consistent fashion, ( greater staff turn over or shifts) and may not get to know their customers. Safeguards must be put in place for those circumstances.

    YOU ARE A : Member of the Public
    ON BEHALF OF : Myself
    Phone Number (optional) : 6137295998
  • member of the public - POSTED April 7, 2020 REPLY   

    I am supportive of the proposed changes. I feel that many patients have a closer relationship with their pharmacist than their Dr. as they are often easier to reach. It would also likely decrease emergency visits.

    YOU ARE A : Member of the Public
    ON BEHALF OF : Myself
  • pharmacist - POSTED April 7, 2020 REPLY   

    I am looking forward for this expanded scope of practice as this will enable me to help many patients faster and reduce the healthcare expense by reducing visit to clinic/hospital.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
  • member of the public - POSTED April 8, 2020 REPLY   

    I think this is overdue. Have always found my pharmacologist very helpful when asked for advice plus have to wait weeks for appointment with family doctor.

    YOU ARE A : Member of the Public
    ON BEHALF OF : Myself
  • member of the public - POSTED April 8, 2020 REPLY   

    I support the proposed change. However I always had a question on my mind since the first time the change was initiated. My understanding is that medical doctors have extensive insurance coverage for medical error in case it does happen. Do pharmacists have similar protections in case an error/accident happen? Are they covered?

    YOU ARE A : Member of the Public
    ON BEHALF OF : Myself
    Organization name : NHSS
  • pharmacist - POSTED April 9, 2020 REPLY   

    I agree totally with proposed amendments if only will be compensated by revenue. These extra services should be fully recognized and compensated by ODB and all private insurance. But if it will be an extra burden and responsibility for pharmacist with no compensation, then we don’t need it. We have proven during the evolving crisis of Covid 19 that we are fully responsible towards our communities and taking a huge risk from sick people and we are not yet compensated for anything

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 9058764466
    Organization name : Medicine shoppe