Feedback deadline was: October 26, 2019
The Minister of Health has asked the College to submit regulations to enable an expanded scope of practice for pharmacists to ensure that patients have streamlined care pathways that make connections easier in the health care system, and that there is access to minor and routine care in the community.
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 pharmacy professionals the expanded scope to:
- Administer the flu vaccine to children as young as two years old;
- Renew prescriptions in quantities of up to a 12-month supply;
- Administer certain substances by injection and/or inhalation for purposes that are in addition to patient education and demonstration.
In addition to these amendments, the Minister asked the College to work with the Ministry to enable pharmacists to perform certain point of care tests (POCT) to support their role in medication management and treatment of patients. Point of care testing will require the Ministry to make amendments to the Laboratory and Specimen Collection Centre Licensing Act regulations. It will also require the College to enable pharmacy professionals to perform the act of piercing the dermis to obtain blood for purposes beyond that of patient education and demonstration. These enabling changes have been included in the proposed regulatory amendments.
The Minister has asked for these regulatory changes to be submitted by November 30, 2019. Additionally, the Minister requested that the College submit amendments to the regulations by June 30, 2020 to enable pharmacists to prescribe for minor ailments.
Consultation on draft regulatory amendments related to prescribing for minor ailments will occur separately. Please consult the Expanded Scope Key Initiatives webpage for further updates and information.
Currently, pharmacists are authorized to administer by injection and/or inhalation for the purpose of education and demonstration, according to a list of substances as identified in Schedule I and Schedule II of General Regulation 202/94 of the Pharmacy Act. However, the College is working with the Ministry to consider shifting this approach to a new classification model based on drug categories referenced in the American Hospital Formulary Service (AFHS). Therefore the College is consulting on both the substance list and drug category classification approach, given the potential that either of these models may be accepted for the proposed amendments.
Before providing your feedback, you are encouraged to review the proposed regulatory amendments to the General Regulation 202/94 of the Pharmacy Act.
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 (including interns and students and pharmacy technicians where applicable) 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.
The expanded scope of practice will enable pharmacists – the health care professionals with the most extensive pharmacotherapy education – to utilize their knowledge and experience and take on a greater role to improve health outcomes for patients.
Over the past seven years, pharmacists have demonstrated their ability to safely and appropriately administer substances by injection and inhalation for the purpose of patient education and demonstration, and to extend patients’ prescription renewals for up to six months. The competencies required and practice standards expected for the safe expansion of these activities remain the same.
Pharmacists, interns and pharmacy students who have injection training are currently permitted to administer certain vaccines to eligible patients who are five years of age or older and have shown their ability to do so competently. Initial consultations with public health experts, physicians, pharmacists and experts in pediatric pain management suggest that pharmacists could benefit from education to equip them with techniques and strategies to manage administration of flu shots to this younger age group. If required, this would become a requirement under the Universal Influenza Immunization Program (UIIP) and would apply to all pharmacists registered to provide flu vaccinations.
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.
This response was submitted by The Neighbourhood Pharmacy Association of Canada. Read the full submission here.
This response was submitted by Ontario Branch of the Canadian Society of Hospital Pharmacists. Read the full submission here.
This response was submitted by The Ontario Nurses’ Association. Read the full submission here.
This response was submitted by The College of Nurses of Ontario. Read the full submission here.
This response was submitted by The Ontario Pharmacists Association. Read the full submission here.
I am against administering the flu vaccine to children under five years old due to lack of confidence in being able to maintain the usual workflow while providing these services. I am for renewing prescriptions in quantities of up to a 12-month supply (as needed for emergency cases), but would prefer to have access to labs and medical history in order to aid in prescribing for such an extended time. I would actually prefer if pharmacist’s prescribing scope would include diabetic supplies (e.g. lancets, needles, strips), and vaccines (e.g. prevnar, shingrix, travel) for high risk patients.
I disagree with lowering the flu vaccination age to 2. Looking at previous posts, I completely agree with the Pharmacist from Oct 23 who posted: “1. In a busy retail pharmacy setting, it is difficult to vaccinate everyone who wants a flu shots in a timely manner. Children between ages 5-10 usually take longer to give a flu shot due to injection fears, especially when there is no nasal spray flu vaccine. While waiting for parents to help calm down their children, the workload for pharmacists continue to grow as retail pharmacists are expected to check and prepare prescriptions, counsel on prescriptions, and answer OTC questions at the same time as giving flu shots. Allowing pharmacists to give flu shots to children age 2 and up will just add to the workload and stress that pharmacists experience. Retail pharmacy is currently not the most appropriate place for flu shots for young children. Most counselling rooms/waiting areas are small and not really equipped to handle an emergency. There will be greater concerns if we are to give flu shots to children starting at 2 years. At the same time, the retail pharmacy environment is also changing where there is less and less help for pharmacists year after year. It will not be safe to give flu shots to very young children in this type of retail environment. 2. If we are allowed to order or at least view/interpret bloodwork results, it could be ok for pharmacists to renew prescriptions up to a year. If we cannot access this information, then pharmacists should not be allowed to renew prescriptions for that long.”
1. Can we look towards administering high dose flu vaccine for seniors? If we can administer other types of vaccines that are IM, why not high dose? 2. For renewing prescriptions for 12 months – I think current length is fine. Renewals should only be done if a patient cannot see/access the physician in time and their care may be compromised. Someone correct me if I am wrong, but I cannot think of a situation where a patient would require 12 months of medication renewal from a pharmacist.
I see in the Globe and Mail that pharmacy fees are getting cut. Ontario strikes deal with pharmacists that will change payment scheme and save government $436-million https://t.co/D0MYHjA3m3?amp=1 How will pharmacists do more (safely and effectively) with less resources? Perhaps now is not the right time to be adding more to a pharmacist’s plate… who really seem to be acting and treated as retail employees, more so than qualified health care professionals. I am not sure why I would access care from a pharmacist who hides out at the back of a counter when I have so many options like seeing a doctor, nurse, walk in, etc. The pharmacists are not trained to diagnose and I would not take the chance. Why can’t all pharmacies have cheap fees like Costco?
I work full time in a retail pharmacy. In the retail sector, we are already working to our max capacity with the scope of practice that we have (ie. Giving flu shots to anyone 5 years of age and older, administering other vaccinations, completing medscheck, etc.) and I feel the addition of any other responsibilities would be to the detriment of our patients. Every time a new aspect is added to our scope of practice, we do not receive any additional support or time to allow us to incorporate it. In many retail pharmacies, the pharmacist is still largely responsible for many of the technical aspects of preparing a prescription despite the addition of registered pharmacy technicians. It would be wonderful if pharmacists were given the resources and support to embrace these suggested changes in our scope of practice. What it boils down to is this: the ministry and college want us to take on more responsibilities, the companies most retail pharmacists work for do not provide the necessary support for us to be able to safely do so, but yet we feel pressure from them to provide these services anyways. So unless the ministry is going to address the disconnect between the responsibilities a pharmacist has and the restrictive support staff allotted, I do not think it is in the best interest of our patients to further expand our scope of practice.
Reading these comments are mind blowing. I always wondered why my pharmacist seemed so stressed out when I would ask her questions. The public needs to question why the Ontario College of Pharmacists is choosing not to regulate the important stuff like staffing ratios in pharmacies, but are mandating pharmacists complete a course on marijuana. Scratching my head in disbelief…
I do not agree on administering the flu shot to as young as 2 years old,, away from the busy pharmacy issues, I see pharmacies and pharmacists are not equipped to manage any kind of risk that might occur for that age. Regarding extending prescription for 1 year, I think for the chronic meds it needs routine blood work follow up. 6 months can be a reasonable time.
I would have to say expanded scope sounds great in theory , but it does not translate well in practice when there is not enough support to provide the services. I am more than capable of providing these expanded services ;however I would not feel comfortable doing so knowing that it may put patient’s in harms way due to lack to support and staffing. Also, proposing expanded scope of practice without proper compensation is senseless. Pharmacists need to be paid for their time and the value they are able to provide through these services. Asking someone to take on a heavier workload and greater liability without proper compensation is preposterous.
I would like to add 1 more point. Pharmacists are well trained to undertake ALL the proposed expanded scope of practice proposals. However we need to ask our selves what is in our best interests. What may be in the best interests of pharmacy and MOH in general in not always best for us individually. For instance….injections are a technical job which anybody can do . So does it further our profession? I think most of us will say no. Extending for 1 year again does nothing for us except strain the already delicate relationship we have with doctors. Minor ailment prescribing is a good step. However until we have billing numbers, it does nothing for us. Chains will hijack it like med checks and place quotas . Also, how can we embrace these new proposals if our working standards are not improved? Already we are finding it difficult to incorporate med checks and vaccine administrations together with our usual dispensing responsibilities. We need to address staffing issues and reimbursement before we embrace these changes. Our wages are in free fall at present. Nb. Those who are proposing reg techs to inject are not really thinking it through. What happens when a reg tech is pulled away to inject? Are we expecting the pharmacist to count pills and prepare the compliance packs while the tech injects? We need to fix staffing and reimbursement before we embrace new roles. Otherwise we will be hung out to dry while nurses get more advanced with increased wages to reflect their new roles and abilities.
I truly believe that we should not take on vaccinations for children under 5yo. On the point of extending Rxs for up to 1 year I have to say that if that would be implemented the Pharmacist would be EXPECTED by the Company and by the Patient to do that while we have extremely limited means for proper patient assessment and there are not enough time allocated for the Assessment and paperwork. So it will all fall on the Pharmacist – the pressure of what’s expected from us on one side and the penalty for poor Assessment and insufficient paperwork due to lack of time. As to another initiative I think proper training from the Pharmacist upon release of the Rx and some key point reminders on refills is sufficient and should ensure an ability of the Pts to self administer their meds. We cannot help them with administration as a part of their daily routine.
I believe that Ontario Pharmacists are well trained and competent to take on more responsibility and assist patients with more than medication consulting and dispensing. However as this is a healthcare matter, defining parameters such as scope of these additional task, procedures and ample time allowance to provide such services must be studied, identified, implemented and communicated with the operators/owner of Pharmacies in order to minimize stress on the pharmacist daily hurdles. The regulators of this profession must understand the impact of additional services a pharmacist can provide on top of their already hectic and at most times chaotic working conditions, specially for the ones working at busy locations. Standards and regulations must be developed and implemented for owners to balance a pharmacists workload in order deliver effective patient care and delivery of supplemental services. I’m confident that with consideration of workload impact pharmacist will be able to and authorized to administer even more healthcare tasks with the appropriate training as needed and drastically improve Ontario’s healthcare service as long as their workload capacity is taken into consideration and regulated.
Please consider expanding the scope of pharmacists in Ontario to match other Canadian provinces. As per the Canadian Pharmacists Association Pharmacist Scope of Practice in Canada chart (https://www.pharmacists.ca/pharmacy-in-canada/scope-of-practice-canada/), most other provinces give injection authority (subcut or IM) to pharmacists for ANY drug or vaccine. This should be the same in Ontario. Similarly, most other Canadian provinces allow pharmacists to adapt/manage therapeutic substitutions (in addition to changing drug dose, formulation, regimen, etc…). This should also be the case in Ontario.
This response was submitted by the Ontario Medical Association.
Read the full submission here.
Thanks for sharing this. I agree with some of the concerns raised by the OMA. I am a pharmacist working at a Family Health Team. I have worked in hospital and community practice. The nature of my work is professionally rewarding. A major reason for this is effective collaboration working relationships and shared access to patient records. I don’t need to give vaccines or administer point of care tests to be effective. There is so much pharmacists have to offer WITHIN current scope….but the practice model for pharmacists need to change. This means unchaining pharmacists from corporate interests and regulatory changed to enable practice environments modernize. I personally would have a lot of trouble switching from my FHT job to a traditional community pharmacist position. The level of risk in that environment is way to high in my opinion. Once one get used to practicing high quality care, it is hard to work in an environment that compromises that.
It’s one thing to talk “expanded scope of practice” when the current standards of practice are not being met in many cases. I have had several experiences picking up new prescriptions for family members, where the extent of the “counselling” was “That will be $X dollars, do you have any questions for the pharmacist?” And this from several different locations of the self-acclaimed “best” drugstore chain in Canada. While I feel that there are many, many pharmacists who are capable of practicing to an expanded scope, as a whole we are not ready to move to this when we can’t even currently get 15 minutes to pee and eat a sandwich in a day. Mandate for safety to the public through adequate staffing levels first, THEN add scope. I personally would NEVER take a 2 year old to a community pharmacy for a flu shot and I think having young children who are inherently unpredictable, try to be slotted into a busy workday, is a recipe for disaster. Pharmacists will be stressed, parents will be stressed, kids will be upset and traumatized…not a great idea. Renewing prescriptions for up to a year? How can a pharmacist do this without being able to do appropriate drug therapy monitoring? You risk having a patient population that goes 2 years between doctor visits for a chronic condition. This proposal adds another level of liability that I would not be willing to assume without the proper monitoring tools available to mitigate the risks that come with it.
Always believe in the pharmacist capabilities to do more and more , helping the public more and more to have the service that they are looking for without waitinh 2 or 3 hours in the emergency departement to have a prescription for a chronic medications or a prescription for a minor condition . You can check the experience of Quebec when they gave the authority for the pharmacist to renew and prescribe for minor conditions , it’s is remarkable sucess overthere, with couple of situations that rises up in a 3 years period , I can say that this is a great sucess. I am proud of my Job and sure that my collagues have lots to give to help the public. But on the other hand, as we speak about most of private business owners , we can’t ask them to do more and more without searching for them a remburisement, this will be unfair as all of this acts consumes time to give better service. Thanks
YES I AGREE FOR PROPOSED AMENDMENTS AS PHARMACISTS ARE ABLE TO PERFORM THESE TASKS LONG TIME AGO . PHARMACISTS ARE VERY SKILLED PROFESSIONALS THAT NOBODY USES THEIR SKILLS. PLEASE ALLOW DISPENSING MEDICAL CANNABIS IN PHARMACIES TO CONTROL THE OVER USAGE OF OIL FOR ANY REASON EVEN IF IT IS NOT INDICATED
Recommend not lowering age limit for flu shots or extending renewals to 1 year. Current times allowed are plenty for a pt to f/u with their physician.
Pharmacists need more training and more time when dealing with such small children
I completely agree with above
yes providing all these services will be very challenging
Above comments are very valid points
I completely agree
1. re: pharmacists administering flu vaccine to children as young as 2 years old: – more training will be needed for pharmacists – it may help improve immunization rate of flu vaccine for ages 2-5 years old – more time may be needed to give a vaccine to children less than 5 years old – unfortunately, many large community pharmacies are so busy and not adequately staffed, which could lead to unsafe conditions since pharmacists are rushed so much – this is bound to cause errors in prescriptions or injection administration techniques – over the years, the pharmacist’s scope of practice has increased, so the pharmacist is doing more, and in most cases, still doing all the checking of prescriptions – even in extremely busy community pharmacies, registered technicians are not being used to ease the workload of the pharmacist and big corporations just keep cutting support staff or don’t add any additional staff during flu shot season – the quality of service and care is suffering 2. re: renewing prescriptions up to 1 year – I can’t think of a scenario where this would be needed in a community pharmacy setting – maybe if a pharmacist is working in a Dr’s office and has access to the patient’s lab work then it may be appropriate 3. re: point of care tests – if pharmacists are allowed to do these tests, then the technology of the devices needs to be regulated and the accuracy level of the devices needs to meet minimum standards – point of care testing by pharmacists is probably only valuable if the pharmacist can actually prescribe a medication based on the results eg. start the patient on metformin (if diagnosis of diabetes), a statin (if high cholesterol levels) or an antibiotic (if positive for strep) – again, providing all these services becomes very challenging in large community pharmacies that are not adequately staffed
I agree with a lot of the Pharmacist comments. 1. we should NOT be administering flu vaccinations to children as young as 2. we don’t have the time or resources. It does not improve us as a profession neither is it the safest option for the public. 2. we DO NOT need to renew prescriptions for up to one year. We just don’t have enough clinical information to do this, and I cannot think of any scenario were a pharmacist renewing a prescription for that long could be justified. 3. I can support an expanded scope to provide more injections- but the paperwork to be completed needs to be more user-friendly. Some pharmacists already do this under medical directives. I don’t think any of these proposals represent what we need most as frontline pharmacy professionals. Is anyone concerned about our wellbeing? our wages, breaks, support staffing, remuneration? Don’t even get me started on how the big corporations keep pushing pharmacists to do more- even when it is no longer safe or feasible. As I said earlier….these proposals do not address key issues
it is very challenging provide vaccines for children under 5 years old. So this is something I’m not with at the moment. Providing a year supply for the patient for chronic medications is something that is I am not with since the patient’s needs a follow-up in general with aphysician to evaluate stop appropriateness of the medication.
Agree with the above and I also do not give vaccines to children under 5 myself.
The issue re pharmacists giving flu shots to 2+ years will be a moot point down the road. With the Nova Scotia College of Pharmacists looking at having pharmacy technicians administer flu shots, this will inevitably trickle to other provinces. No pharmacy chain owner would pay a pharmacist to administer flu shots when they can have a less costly staff member do so. This is all economics. The issue was of renewing prescriptions for 12 months seems like a risk, when the College has no evidence to support how often and how safely pharmacists are renewing meds for 6 months. In terms of point-of-care testing, there are limited situations where this may be useful. As has previously been mentioned, some chains in other provinces has engaged in questionable use of these tools to draw in customers at the expense of evidence-based care. The College has a tough decision ahead of them, in my opinion. I will say that these scope expansions should not be chained to the bricks and mortar of a pharmacy. Pharmacists practicing in non-accredited practice sites eg primary care teams, or possibly integrated within Ontario Health Teams, should be able to offer all these services.
When a pharmacy is accredited, it is specified in the law and OCP accreditation requirements the following criteria must be met- https://www.ocpinfo.com/library/other/download/community-pharmacy-accreditation-assessment-criteria.pdf – The pharmacy floor area must be no less than 200 squared feet – The dispensary area must be no less than 100 squared feet. I don’t know why this rule exists and what the evidence is for is, or how this is suppose to protect the public, I raise this on the basis of a number being specified to set a standard. It is nonsensical to me that OCP is unwilling to commit to weighing in on minimum staffing for safety, and put that into law, The fact that they maintain the law that states you need a pharmacists with a license and pulse on site in order to operate a pharmacy has been majorly exploited by pharmacy owners, The College is well aware of this, They have stated that they are surprised the uptake and use of pharmacy technicians is low, How can you be surprised by this when you have not made this an accreditation standard? How many cases like Andrew Sheldrick’s will the College tolerate before taking staffing seriously? The AIMS data suggests a tip for designated managers- https://www.ocpinfo.com/wp-content/uploads/2019/09/AIMS-response-team-bulletin.pdf se opportunities with your team. “Do two pharmacy team members check patient name and address information as part of the dispensing process to ensure the prescription is entered against the correct patient?” Is OCP thus suggesting that a pharmacy must be staffed with two pharmacy members to enable this? If so, for goodness sake, put this into law! One of OCP’s Council Members, Dr Lisa Dolovich, is listed as an AIMS Response Member. Surely, this data needs review in the context of scope expansion and feasibility and safety in community practice.
There may be an association between the hiring of pharmacy technicians and the ability for pharmacists to offer full scope. This study here suggests https://www.ncbi.nlm.nih.gov/pubmed/29796133 “Pharmacy technicians were employed in 24% of the pharmacies in our sample. Technician employment rates were highest in Central Fill pharmacies and pharmacies serving long-term care facilities. In general, pharmacies employing 1 or fewer technician full-time equivalents (FTEs) had a slightly higher probability of providing MedsChecks and, of those that did provide Meds Checks Annuals, provided more of them. Pharmacies that hired 3 or more technician FTEs were markedly less likely to provide MedsChecks.”
In my opinion, the most important law that OCP needs to change to facilitate full scope and ensure high quality care is in the DPRA- https://www.ontario.ca/laws/statute/90h04#BK17 Specifically this section – Supervision of pharmacist 146 (1) Subject to subsection (1.0.1), no person shall operate a pharmacy unless, (a) it is under the supervision of a pharmacist who is physically present; and (b) it is managed by a pharmacist who is designated as the designated manager by the owner of the pharmacy. R.S.O. 1990, c. H.4, s. 146 (1); 2007, c. 10, Sched. L, s. 10 (1); 2009, c. 26, s. 8 (4). An amendment to include a point (c) as follows is suggested… (c) the designated pharmacy manager has ensured a minimum staffing ratio of 1:1:1 (pharmacist:RPT:assistant) in pharmacies with a daily prescription volume maximum of 200 prescriptions, and proportionately appropriate for higher volumes. This is a simple legal change well within OCP’s purview…. no more excuses please OCP. Your business is patient safety, which makes the business of pharmacy your business! (The corporate interests of OCP Council Members needs to be called out).
I support all expanded scope recommendations for pharmacists mentioned above, and those including minor ailments prescribing. I believe our knowledge and education is under utilized and not compensated fairly. That being said, I am excited to engage in the above recommendations as a step closer to further expand our scope.
I feel I don’t have the skill or the time in a pharmacy to administer injection for children under 2. This is a very delicate group .Not only do you need time but also a skill set to emotionally settle down young children. I feel it’s best to administer injections for this age group to be done in a setting where an appointment is needed and without the interruptions that occurs in a pharmacy, Almost all pharmacies are run on skeletal staff and this would place unneeded stress with all parties involved possibly resulting in negative outcomes,
I believe that as pharmacists, our duty is to provide the best patient care possible. However, these additional expansions in our practice do not necessarily meet this goal. Pharmacists should be forced to take on more responsibilities, in addition to the many responsibilities that we already have as pharmacists. I think that our role is to provide therapeutic care to our patients as medication experts. With these changes, our role as therapeutic experts is becoming less defined as we take on additional tasks that other healthcare providers should perform. Each professional as an expert in their field and collaboration of each expert is what makes healthcare as a whole. Pharmacists should not be taking up responsibilities of physicians, nurses, etc. Moreover, with the changing scope of practice, there has been no additional support or compensation or pay for pharmacists. Our wages are too low for all the sensitive work that we do. We are doing more tasks, handling more pressure, under a lot of stress, and taking on additional responsibilities beyond therapeutic care, but unfortunately we are not receiving any additional support from pharmacy corporates/companies nor from our College and Association. We are not receiving any additional compensation or payment for the all the extra tasks that we do, which is very unfair and unreasonable. We are treated very poorly as professionals, not being able to eat or take a quick break from a long 12 hour shift. Where is our health system heading towards? We have to put our own physical and mental health at risk because of all the pressure from these expansions and meeting certain corporate quotas that emerge from these expansions. Most importantly, our patients’ medication needs are be interrupted by the pharmacist doing other tasks (i.e. flu shots, A1C tests, other injections, medschecks, etc.). How many things could a human being do all at once? Pharmacists are humans. Please allow our profession to grow as pharmacy experts. We have studied and worked very hard to become pharmacists. We want our role and our tasks to represent us as pharmacists – not represent something else. Please let us focus on our patients’ therapeutic needs. Patients need us as their medication experts more than ever – this is one area of care that they can only get from a pharmacist. This is what we got trained to do. If we wanted to do other tasks unrelated to pharmacy, we would have selected another healthcare profession, possibly with a much higher compensation. Please respect our profession, our patients, our families and our future.
Good evening, I believe that as pharmacists, our duty is to provide the best patient care possible. However, this does not mean that pharmacists should be forced to take on more responsibilities, in addition to the many responsibilities that we have as pharmacists. I think that our role is to provide therapeutic care to our patients as medication experts. With the changes in our scope of practice, our role as therapeutic experts is becoming less defined as we take on additional tasks that other healthcare providers perform. I believe optimal patient care can be provided when we collaborate as healthcare professionals, with each professional as an expert in their field. Moreover, with the changing scope of practice, there has been no additional support or compensation or pay for pharmacists. We are now doing more tasks, handling more pressure, under a lot of stress, and taking on additional responsibilities beyond therapeutic care, but unfortunately we are not receiving any additional support from pharmacy corporates/companies nor from our College and Association. We are not receiving any additional compensation or payment for the all the extra tasks that we do, which is very unfair. We have to put our own physical and mental health at risk because of all these expansions and meeting certain corporate quotas that emerge from these expansions. Most importantly, our patients’ medication needs may be interrupted by pharmacist doing other tasks (i.e. flu shots, A1C tests, other injections, etc.). Please allow our profession to grow as pharmacy experts. We have studied and worked hard to become pharmacists. We want our role and our tasks to represent us as pharmacists – not represent something else. Please let us focus on our patients’ therapeutic needs. Patients need us as their medication experts more than ever – this is one area of care that they can only get from a pharmacist. This is what we got trained to do. If we wanted to do other tasks, we would have selected another healthcare profession. Please respect our profession and our patients. Thanks
Good evening, Considering the changing profession of pharmacists and meeting patient healthcare needs, pharmacists are in a good position to provide the best care to our patients. Given this advantage, I think the expanded scope of practice should have its limits as well. Not all pharmacies and pharmacists are equipped for these changes. We do not have enough support to carry out these changes. As pharmacists, we do put patient care first but that does not mean that we should be forced to take on more tasks every year with the same resources and same pay. We do not get compensated for all the changes made to expand our scope of practice, which is very unfair. We do injections, A1C tests, methadone, medication reviews, etc. without any additional compensation or human resource. We are doing more work than ever, handling greater pressure than ever, and taking on more and more responsibilities … with no change in our working condition or payment. We do not get much support from the corporates that we work so hard for, nor do we get support from our profession’s Association or College. With greater pressure on pharmacists, it is more difficult to meet every individual patient needs. I believe that as pharmacists, it is our duty to provide our patients with the best care possible. After all, as pharmacists, we are the therapeutic experts that help patients with management of their medications and wellbeing. However, now it seems like the role of a pharmacist is becoming less clear. It seems like we also have to take over some of the tasks that physicians and nurses do as part of their profession, which no longer makes our profession stand out as medication experts. With these changes and increasing work demand without any compensation, it would be a very difficult and unrealistic to achieve all of our patients’ healthcare goals. This is why there are different healthcare professions, with each profession focused and experienced in providing the best in their area of expertise. It is through collaboratively working together as healthcare professionals that we provide the best patient care possible. So first, we have to consider if it is realistic and fair for pharmacists to do additional tasks in their practice and if it would actually (not just theoretically) benefit patients; second, in order to implement any changes, how will pharmacists be compensated and supported to carry out additional responsibilities; and third, how will these changes impact the profession of pharmacy?
Not vaccinating under 5 year olds, not comfortable doing that. Not renewing prescriptions for 1 year until I can order lab values for example statins need lab values before renewing yearly rxs . Also diabetic meds we need to know A1c values. Do not run before we can crawl please, lets get things right first then expand.
I am in favour of the expanded scope of practice for pharmacy professionals and would like to know which substances (medications) will be included in the list that pharmacy professionals will be able administer by inhalation or injection. Patients will benefit from easier accessibility to medications in the list. Pharmacy professionals may require additional education/special training depending on which substances are in the approved list.
I agree for the flu shot starting from 2 years old and up and also to administer any kinds of injection as we are qualified for that . The part I don’t think make sense is to renew for more than 6 months as this the physician mandate to follow up . 6 months wpilde the maximum in my opinion. Also we should give more responsibility ordering test and prescribe minor elements as Quebec pharmacist doing long time ago . Thanks
I do not feel most pharmacies are conducive to giving vaccinations to children age 2 and over. I think children at that age you need to spend a lot of time with them and the parent and it is not feasible in today’s current practice setting.. In addition I think we need to have OHIP billing in place first compensating expanded services. Finally and not completely relevant but I think the college should make the $6.11 and $2. co-pays mandatory and law. Waiving or reducing them in anyway demeans the profession and makes it difficult to afford implementation of expanded care.
I don’t think community pharmacists should renew prescriptions beyond 90 days — they do not order labs or can review labs. For instance … refill on furosemide. Pharmacists are not watching serum creatinine or potassium. Or how about hydrochlorothiazide? Pharmacists are not commonly assessing blood pressure, let alone the associated labs — Na, K, creatinine, etc. What troubles me is that most pharmacists in general do not know their patients very well. I work as a renal pharmacist in an outpatient hemodialysis unit and commonly see patients receiving non-renally dose adjusted medications of potentially toxic medications like antibiotics (amoxicillin, ciprofloxacin, nitrofurantoin), antivirals (valcyclovir) and pain medications (gabapentin). I have seen, first hand, dialysis patients admitted due to toxicity. Reviewing ODB viewer, many of these patients have their prescriptions filled by their preferred pharmacy, not a walk-in clinic pharmacy who don’t know their patients very well.
Renew for up to 12 months supply ( In my opinion that the patient may need to see Dr. During this period for reassessment ( may need increase or decrease dose according to his/ her condition ) is better than renew for a year. Administration of flu shot for 2 yo is too young, need to do it at doctors office. It is ok to administer by injection and/or inhalation
I am not interested in further expansions to our scope of practice. The winter season is much too busy to even consider administering the flu vaccine to children as young as 2. I believe that the ability to inject should have been a voluntary designation and not forced upon us.
Giving an injection is a purely technical issue. Registered technicians need to be authorized to give flu shot and other injections under the supervision of the pharmacist. It is not in the best interest of patients pharmacists give injections and registered technicians check prescriptions. It is not in the best interest of patients pharmacists give injections and nurses prescribe but vise versa is in the best interest of patients. Thanks
On behalf of myself & many other pharmacist colleagues, I assure the ministry that we are more than capable & equipped to perform all the new duties outlined in the expanded scope. Please keep in mind that we are already performing these tasks on a smaller scale with no issues or gaps! Weather it be injections for younger children (flu shots) or patient assessments & extensions of medications, we are capable of using the same skills & knowledge on a larger scope! We have to move forward as individuals & certainly as a profession. A profession that never expands is doomed to be extinct one day because there will be other people that developed themselves to replace individuals in that profession! Something to consider when we expand our scope is our resources such as staffing, reimbursements for the services & our hours of operation. We cannot add more load to pharmacists without providing them with the funds to enable them to provide extra services. We also need to consider the extra staffing hours that will be needed for these services. Sad to say that our flu shot fee is very modest. Keep in mind that younger children will take more time to calm down or stay still for us to inject them. Assessments for a year supply would like need follow up after 6 months or so. To conclude, we can do it but we need the resources to keep the work load the same with maximum efficiency.
I believe these are great and this will allow for better patient care and physicians offices won’t be that crowded for a simple flu etc.
From this article that researched Ontario pharmacists giving flu shots- https://www.ncbi.nlm.nih.gov/pubmed/29140749 “Pharmacists reported that their expanded scope of practice was linked with higher workloads and quotas, often without a commensurate increase in available resources such as technician hours or pharmacist shift overlap. Some pharmacists also found quotas to be an infringement on their professional autonomy. They stated that other health care professionals do not have imposed quotas on the health care services that they provide. Previous studies have documented that time and space are barriers to providing immunization services10,13,14 Kummer GL, Foushee LL. Description of the characteristics of pharmacist-based immunization services in North Carolina: results of a pharmacist survey. J Am Pharm Assoc (2003). 2008;48(6):744–51. doi:10.1331/JAPhA.2008.07080. PMID:19019803 Valiquette JR, Bedard P. Community pharmacists’ knowledge, beliefs and attitudes towards immunization in Quebec. Canadian journal of public health = Revue canadienne de sante publique. 2015;106(3):e89−94. PMID:26125247 Edwards N, Gorman Corsten E, Kiberd M, Bowles S, Isenor J, Slayter K, McNeil S. Pharmacists as immunizers: a survey of community pharmacists’ willingness to administer adult immunizations. International journal of clinical pharmacy. 2015;37(2):292–5. doi:10.1007/s11096-015-0073-8. PMID:25687902 ; however, this is the first study to introduce the notion of quotas. This finding requires further investigation, particularly with respect to investigating workflow systems, including greater utilization of pharmacy technicians. Pharmacists are generally satisfied with the use of regulated pharmacy technicians.15,16 Schmitt MR, Desselle SP. Pharmacists’ Attitudes toward Technician Certification: A Qualitative Study. Journal of Pharmacy Technology. 2009/03/01 2009;25(2):79–88. doi:10.1177/875512250902500203. Watson T, Hughes C. Pharmacists and harm reduction: A review of current practices and attitudes. Canadian Pharmacists Journal: CPJ. 2012;145(3):124−7.e122. doi:10.3821/145.3.cpj124. Increasing the utilization of pharmacy technicians may free up pharmacists’ time and accommodate the changes in pharmacist activities. This may minimize the potential for an increase in errors in dispensing, which can impact patient safety.17 The findings regarding vaccination of children warrant additional discussion. Pharmacists cited that vaccinating children was a challenging experience and they felt uncomfortable, unprepared and ill equipped for dealing with them. Children took more time and required more effort from the pharmacists. Pharmacists reported utilizing restraint in partnership with parents in order to administer vaccinations in children. Restraining children contributes to children’s fear,27 Lacey CM, Finkelstein M, Thygeson MV. The impact of positioning on fear during immunizations: supine versus sitting up. J Pediatr Nurs. 2008;23(3):195–200. doi:10.1016/j.pedn.2007.09.007. PMID:18492548 [Crossref], [PubMed] , [Google Scholar] which can contribute to pharmacists’ anxiety as well. Pharmacists’ challenges in dealing with children are consistent with the experience of other health care providers. A survey of health care professionals, which included pharmacists in Canada, recently showed a trend toward more hesitancy to expand pharmacist scope of practice to include children, particularly among physicians.12 MacDougall D, Halperin BA, Isenor J, MacKinnon-Cameron D, Li L, McNeil SA, Langley JM, Halperin SA. Routine immunization of adults by pharmacists: Attitudes and beliefs of the Canadian public and health care providers. Human vaccines & immunotherapeutics. 2016;12(3):623–31. doi:10.1080/21645515.2015.1093714. [Taylor & Francis Online], [Web of Science ®] , [Google Scholar] Pharmacists may need additional support to assist them with the challenges of administering vaccinations in children and to allow for more positive experiences between pharmacists, children, and parents. Importantly, needle fears can develop as a result of a negative experience with a needle procedure.25
NO, we dont have TIME to be trying to secure a 2 to 4 year old down to do flu shot if they’re going to be fussy. We are so busy as it is. There is no reason for us to extend up to 1 YR supply. Pt should be seen Yearly by GP. Injections have too much paperwork. Even MD offices don’t document so much. If there is less paperwork, ok but if we have to fill out 5 pgs for 1 injection, way too time consuming.
From reading the large number of comments from us, The Pharmacists, it is very clear that there’s a bigger issue than expanding the scope of pharmacy at present time. Currently, there is not enough staff/support in pharmacies to run efficiently AND safely. It should not be a choice of delivering patient care safely OR efficiently. It can’t get any clearer that medication incidents or near misses are occurring due to a complete lack of governance with respect to workload and basic employee “rights”, like breaks. What needs to happen is some form of mandatory number of pharmacists per prescription count, or per services offered required of pharmacies. Would that not serve and protect the public well? Would that not reduce medication incidents and near-misses? Not only for safety, but more help in the pharmacy means we get to practice compassionate care. We would have time to collaborate with other HCPs and aim at reducing medication errors because we now have the time and help to properly investigate those near-misses. Other pharmacists have included great resources: https://www.ocpinfo.com/wp-content/uploads/2019/09/AIMS-data-snapshot-september-2019.pdf The College’s Mission statement is as follows: “Vision: A trusted, collaborative leader that protects the public and drives quality and safe pharmacy care and improved patient outcomes. Mission: The Ontario College of Pharmacists regulates pharmacy practice to serve the interests, health and well being of the public.” Not enough staff/support does not drive quality and safe pharmacy care, nor does it improve patient outcomes. It is certainly of the public interest, health and well being to have a pharmacist that gets a lunch break and not have to work back-to-back double 12s/16s. To me, enforcing minimum staffing levels is very much a part of what OCP should be doing in order to fulfill their mandate. It most definitely needs to happen before pushing the new required job duties upon already frustrated and tired pharmacists. I don’t agree with reducing the age of immunizations. I agree with POCT with the caveat that there must be at least two pharmacists working in order to safely and privately discuss the results. Otherwise, no.
1) in terms of injecting a two year old, I think it should not be part of our scope. I do not feel comfortable and do not feel we are equipped to vaccinate kids that young. Children are still building their immunity so should not be vaccinated unless at a dr office. The age of 5 is a good age 2) pharmacists should be able to provide medication for up to a year only if we are able to send patients for blood tests if they are required. For example, we should be able to send a patient for a1c if we want to extend the prescription for that long. If we do not have access to labs and the ability to send a patient for lab tests then it makes no sense. In order to follow up we must have access to this information so we are doing our due diligence
I am happy with the further expansion of the scope of practice. However, I think renewing prescriptions for up to 1 year may be too much. Unless we can order appropriate tests and monitor long-term outcomes, it is important to limit prescribing such that the patient follows up with their GP/NP at least once per year. My practice has been to use the renewal ability to renew scripts for 3-6 months, with the understanding from the patient that they visit their GP within that tone frame. Extending beyond that window may lead to more gaps in care, in my opinion.
Please don’t force and push pharmacist to inject flu to children as young as 2 years old or administer certain medication through inhalation or injection. Because pharmacists should keep themselves up to date regarding new medicines and clinical knowledge. Pharmacists are not nurses or medical practitioners to administer medications or injections. Putting these practices for pharmacists is going to hinder their main profession, ( they wont have time to counsel patients, medication reviews and…) and overall these unnecessary acts is going to adversely affect pharmacists quality of care for patents in terms of delivering and filling prescription and patient satisfaction.
Hello there, I am strongly in support of enhancing extended scope of practice for Pharmacist. Prescribing Minor Ailments privilege for pharmacist is great step.Even if OCP can give authority to Pharmacist to initiate medications or adjust dose according to patient’s condition that’s even better.As i have been practicing in alberta and BC,i have seen many instances where we know that what patient is suffering from and even we know what is the medication can make them rid of condition/symptoms ,but due to lack of extended scope of practice we cant help patient.Most of the times even for moderated conditions/symptoms patient does not prefer to see doctors because taking doctor’s appointment is very difficult most of the time!even even after getting doctor’s appointment sometimes it conflict with schedule with work/school so they have to wait few weeks extra.by that time condition might have either resolved or worsen.Even in emergency patients have to wait few hours!while they are already suffering from symptoms it is not wise idea to make them suffer or wait longer.instead if Pharmacists have authority same thing they can get it in few minutes.That even reduce Health care burden too ,which is beneficial for Provincial Government too. I have seen many patients they dont want to see doctor and looking for OTC medications even for infection too.For best patient care it is highly recommended to enhance extended scope of practice for pharmacist.If you have any questions please feel free to call me. Thanks Kevin
After 54 years as a pharmacist, I’m happy to see some changes that give pharmacists more responsibility in patient care. Unfortunately giving injections to individuals as young as 2 years of age is not one of them. Access to laboratory tests – yes! Redoing the Medcheck forms so they are more user friendly, definitely. Get pharmacists out of the dispensary altogether is the only way pharmacies will be able to supply these clinical services. Otherwise we’re doing the same old thing we’ve been doing for the last 100 years!
My main concern with approving up to a year supply (or even the current 6 months) is having access to important health information, such as kidney and liver function, A1C, etc. Will POCT be enough? We should be able to access patient’s medical profile before expanding prescriptions, as doing so without proper knowledge of patients’ health status could put them at harm.
As a practising pharmacist, I am against the idea of injections for less than 5 years Old.. these kids require more time usually when they are nervous as well as this drives pharmacist anxiety up because of crying/moving which may pose risk to kids health!.,this is the worst nightmare for pharmacists!.. pls note that pharmacists primary work is checking prescriptions ( clinical/therapeutics/appropriateness).. we aren’t nurses and not trained to handle kids !. Also scope of practice keeps expanding and you guys care about public interests!.. pharmacists are part of the public too!. All these services comes with a-lot of pressure from corporates to prescribe/inject while staffing/conditions not optimal..pressures on pharmacists to deliver more and more services pose risk to public ( hands down) if this isn’t accompanied by regulations to prevent corporates/pharmacy owners from doing so! ( imagine time needed to prescribe which means assessment, documentation and faxing doctors on top of current workload of checking prescriptions, injections , medications reviews, OTC questions , phone calls from patients). Finally, not all pharmacists are ready to prescribe, i think all pharmacists need to complete minor ailments course to get ready !. This is a personal point of view . Thanks, Mutasem (Taz) Marei
1) Ability to provide flu vaccine for those as young as 2 years old – I am against this proposal at this time. OCP states they are not involved in reimbursement. One can only assume the reimbursement will be $7.50/shot as is now. This is inappropriate funding in general and will be even more inappropriate for the ages 2-4 group. When pharmacists have a larger and well funded expanded scope then I will be in favour of this proposal. As of now, this service will be added work without added labour. A business will not be able to provide extra labour with such unreasonably low reimbursement and therefore its employees will be require to provide this service without additional labour help. For now I wold recommend instead that they allow pharmacists to administer Fluzone HD to seniors. If we are in fact looking for where pharmacists can help save healthcare dollars then Fluzone HD will be more beneficial than ability to administer to ages 2-4. Renew prescriptions in quantities of up to a 12-month supply – I am in favour of this proposal however we need to see access to lab values and potentially ability to order labs in order to effectively renew for 12 months for many medications. There will be little use in providing this ability without providing access to the information needed to provide this service Administer certain substances by injection and/or inhalation for purposes that are in addition to patient education and demonstration – I am strongly in favour of this proposal. Please keep in mind that unless you would like to create a 2 tier healthcare system there must be funding for this service. If this is not a funded proposal, they well to do will be able to pay and access services at their convenience in a pharmacy and those without the means will wait in physicians offices when they really should be working and earning for their families POCT – I am in favour of this proposal
I would love to see an expanded scope of practise as a pharmacy student myself. The health care system is over burdened and with pharmacists being the most accessible and trusted health care professionals, patients could benefit from us having an expanded scope. This will reduce the burden on ER, urgent care, and primary care health care.
1) renewal longet then 6 months is good for patient care. 2) Injection under 5: not very agree in current practicing model. It require lots of time from pharmacist which potentially increase error vecause of rush.
Could the pharmacist who wrote that 6 month extensions are good for pt care, please elaborate. Explain how it helps pt care? I fail to fathom the logic. It helps with allowing the pt get another supply without seeing the doctor for an evaluation and avoids the patient from having to wait to be seen. Please someone explain in detail how this helps patient care. Convenience ….yes. but care?
1.) Expanding flu administration to 2 year olds does nothing but harm the profession. Already pharmacists are finding it difficult to manage the work load during flu season due to staffing issues. If you have had 2 families suddenly turn up for flu shots on a monday morning, you know what a nightmare it can be. It is already challenging to administer to 5year olds so imagine the challenges we will face when we need to inject 2 year old kids. Pharmacists DON’T like to administer flu injections despite what pharmacist associations like to say. It brings nothing to our professional status. It is a technical job which can be performed by anyone who receives training. In fact patients often joke with me….after I have counselled them on a complex medication, they say “put on your nurse hat and give me my flu shot”. 2.) Extending rxs for 1 year is utter nonsense. This again does nothing for our profession. In fact it harms our already delicate relationship we have with physicians. They already look at us with distain and mock our so called med checks. I have several doctor friends who tell me that they usually throw away med checks as most of them are useless. I explained that it was not the pharmacist who were being unprofessional, but the companies they work for who force them to churn out med reviews to meet quotas. Why is it necessary to extend beyond 3 months in the 1st place. We are not clinicians and no amount of access to lab results will make us capable of “taking over” the care of a patient. That is exactly what we will be doing if we extend beyond 3 months. I have had patient come and ask me to renew his rx again after I extended it for 3 months. Why? Because he “forgot” to make an appt with his doctor…..but he had 3 months to make one. When I phoned the doctor, I was told that the doctor had not seen the patient for 2 years. Extensions are seen by patients as a tool to avoid the doctor. Extensions are useful to provide continuity of care, but it should NOT replace the doctor . And that is what 1 year extensions do. A commentator had also touched on liability. What happens when the doctors now file complaints? So to echo the comment above. Please don’t raise my fees to pay for the complaints investigations as you have been dually warned. 3.) Administration of substances like flu vaccines are a technical job which can be performed by anyone. Let’s not celebrate this new expanded scope of practice please. Recognize it for what it is…..convenience and a money saving ploy by MOH. However point of care services like INR are something we should be doing and getting paid for. Taking over INR care helps advance our image as health care professionals as we use our expert knowledge to determine dosages and interventions based on the patients diet and otc and rx use. We are the experts in drug interactions, so warfarin management is a no brainer. 4.) Minor ailments prescribing. In essence it’s a great move. Practically speaking, it’s a disaster in the making. Look how the valuable meds check program was hijacked by the corporate world in order to satisfy their shareholders and bottom line. Minor ailments will go the same way. Quotas will be introduced and unnecessary otc products will be “prescribed” to satisfy head office managers who have no medical knowledge and for the most part are diploma holders from some business course. There will be conflicts of interest. The pharmacist prescribing cannot also be involved in the sale of the drug. But how can you tell a patient that they have to go to another drug store to get the antifungal cream you have prescribed for their athletes foot! We are our own worst enemy I’m afraid. Expanded scope of practice needs to be properly evaluated by independent pharmacists and not MOH paper pushers and certainly NOT our pharmacist associations who unfortunately are not true representatives of our profession.
Here’s something significant for the OCP to consider. A practitioner was speaking to me recently and stated the following regarding “increasing the period of renewals up to a year”: “There is no reason to do this because you’re (pharmacist) supposed to figure out how much a patient might need until they can next get in to see me. That’s not a year, let alone six months. And in doing so, you’re compromising patient care negatively when you go for such a long period just to get $$$ with no doctor involvement.” (I made him aware that the name of the PHARMACIST has to go onto the extension as the prescriber, not his name, for liability; but he said it’s not about that). He then went on: “You’re going to p*** off a lot of doctors if you do that; your college better be ready for a deluge of complaints to be made to them from us because we’re not going to see our patient care compromised.” Now, putting the debate on this discussion aside: the reference to complaints is a real consideration because we know how a backlog can occur and just imagine if OMA, etc. rallied the forces to do this. A complaint about patient care can’t really be dismissed/not investigated as “frivolous/vexatious” and so, start booking those extended committee/panel reviews into the next couple of years! (BUT: please…do not raise my fees yet again because of increasing costs due to this, when you are warned in advance that this could result should you move forward with that aspect — extension beyond an already-adequate six month maximum — when there is no patient interest justification in doing so). Thanks.
The College needs to assess the potential impact of increasing scope of practice among pharmacists within the current work environment. Sometimes, when I go to a pharmacy I see the pharmacist working alone. He/she is answering calls, processing orders, filling prescriptions and counselling patients and cashing out non-pharmacy related purchases. Not to mention giving flu shots to anyone who walks in. Pharmacists have the skill set and knowledge for increased scope such as renewing prescriptions, assessing patients and prescribing common medications. The risk of errors however, is significantly high due to frequent distractions, lack of support and lack of privacy in the work environment. How do pharmacists even have time to step away from the counter to use their counselling rooms or get a break?
I feel like giving added responsibility to retail pharmacists without added compensation and raising the ODB fee for service will continue to add to the spiralling decreased quality of service that pharmacies are able to provide. I myself am happy with my own retail pharmacy because they don’t have time to even dig into how to bill my prescription properly to 2 plans because they are too busy off giving flu shots, trying to fill lots of numbers of scripts with little staff to make a profit. I know the pharmacists are good people and want to help and do all the things we should be doing but without adequate technician staffing and support from employers/government the profession is going nothing but down hill. Please consider this…the ODB fee was $6.11 when I graduated in 1996…it has not gone up in 23 years. how can pharmacists keep working and doing more responsibility without being compensated.
I think that administering the flu vaccine to children as young as two years old should be encouraged however it should be based on the pharmacist’s professional judgment as to whether they are able to safely inject a particular patient. There may be young patients who are not good candidates for immunization in a pharmacy setting. There may also be other patient populations that would also not be good candidates for immunization in a pharmacy practice setting. This discussion can occur with the patient, parent or guardian prior to immunization. What must also be considered is the fact that after assessment of the patient the actual technical function of injecting the patient could be completed by a pharmacy technician. Injection trained pharmacy technicians would permit the pharmacist the opportunity to assess for the injection and engage in other expanded scopes of practice. I fully agree with permitting pharmacists to renew prescriptions in quantities “of up to” to one year. Again the key point in this statement (up “of up to one year”). Not all patients would benefit from a full year of prescription renewal (again professional judgment). Administering certain substances by injection and/or inhalation for purposes that are in addition to patient education and demonstration would definitely require assessment by a pharmacist. As mentioned above the actual injection (& inhalation) of the substance could quite easily be delivered by a trained pharmacy technician. Performing point of care tests for certain chronic conditions could by equally shared by pharmacists and pharmacy technicians (of course after a thorough assessment by the pharmacist) I also feel that prescribing drugs for certain minor ailments is a step in the right direction. If the public was made aware of this expanded scope for pharmacists one would speculate that it would have a very positive effect on medication safety.
If understaffing of the pharmacy is an issue, how does redistributing tasks address that issue? It means other tasks the technician was doing before have to be done by someone else. Who is that person when there is no additional staffing to accommodate increasing work load? It leaves a situation where overworked and distracted staff are more error prone leaving the public at risk. Only by making pharmacy owners and directors more accountable for appropriate staffing levels and a working environment conducive to patient care will this issue be addressed.
I am against the expanded scope of practice. The government wants me to help with the patient care and spend some time to continue education and no extra wages or remuneration from the corporate where i work for the extra added responsibilities. If the college in collaboration with Government makes laws like the Physicians in the hospital get paid. The Pharmacist must be paid according to the Number of patients for which they provide the service, number of vaccinations given, number of rx extended and cost for education be paid by ministry for extra effort then it would make more sense for taking extra responsibility. Moreover, Cannabis program that government has launched and wants pharmacist to complete before next year is rubbish and neither government wants to pay for the educational fees nor the corporate wants us to pay for the educational fees but College of pharmacist wants us to complete before next year’s registration. If the college wants us to expand scope they should be regulating the pay for the Pharmacist through the UNION like Ontario CNO where the nurses get paid whether they work in GTA or they work in any part of Ontario they get paid equally and with standards based on their experience.
How about, while we are at it, we follow Nova Scotia’s lead in adding the technical aspect of injections to the scope of practice of Registered Pharmacy Technicians? “In what will be a Canadian first, the Nova Scotia College of Pharmacists (NSCP) is moving forward with new regulations that will allow technicians to administer drugs by injection, specifically flu and other vaccines, under the authority of a pharmacist.” Under existing legislation, amendments to the Pharmacy Act are not required, so a lengthy legislative process will not be necessary. The College has the authority to make this change through regulation.” http://www.canadianhealthcarenetwork.ca/pharmacists/technicians/technician-injection-authority-coming-to-nova-scotia-45408 In the United States, “under Idaho Rule 330.03, approved in March 2017, a pharmacist may “delegate the technical task of administering an immunization to a student pharmacist or a certified technician”—in addition to being certified as a technician, techs complete CPR training, and complete an accredited training program.” The training program is very similar to the instruction provided to pharmacists, focusing more on injection techniques and patient safety, while pharmacists cover clinical aspects of vaccine appropriateness and administration. https://www.pharmacytimes.com/contributor/karen-berger/2018/03/vaccines-administered-by-certified-pharmacy-technicians-in-idaho Training in the United States: https://pharmacy.wsu.edu/pharmacy-technician-immunization-training/ “Several studies demonstrate that untrained laypersons can safely administer intranasal or intradermal vaccines, and laypersons routinely administer medications through intramuscular or subcutaneous routes (e.g., patients with diabetes or rheumatic conditions). It stands to reason that a trained pharmacy technician could perform comparably on these techniques that laypersons have mastered.” https://pubs.lib.umn.edu/index.php/innovations/article/view/541 “Pharmacists play an important role in the national effort to achieve CDC’s Healthy People 2020 target goals to improve vaccination rates. (…) Pharmacies are the second most common location for patients to receive an influenza vaccination, after physicians’ offices, due in part to pharmacies’ extended hours of operation and convenient locations. A 2016 study by Gai showed that access to a pharmacy was significantly and positively associated with likelihood of receiving an influenza vaccination. Unfortunately, workflow challenges such as lack of time for immunizations may be contributing to less than ideal immunization rates. Pharmacy technicians can now play a major role in overcoming the time burden obstacle.” https://www.pharmacytoday.org/article/S1042-0991(18)30793-X/fulltext The talents and education of so many RPhTs are underutilized in current practice. We already do a lot to ease the time burden required for pharmacists to do their job of patient care. We can do more. Adding the injecting aspect of vaccinations to the scope of practice of RPhTs could make a significant difference in the services provided to patients in a timely manner. Many patients don’t want to wait to get their vaccination while the pharmacist is counselling, busy adapting or renewing prescriptions, or performing therapeutic checks on prescriptions for the que of waiters. With an RPhT ready to inject we can increase the efficiency and the amount of vaccinations performed at the most accessible point of care in the community, reducing the burden on the health care system in general. Thank you for your time and attention.
Unfortunately your proposal does not address the issue of understaffing pharmacies. Who is going to perform the duties a technician formerly did if they move on to other tasks? The real issue is ensuring pharmacy owners and directors are held accountable to ensure appropriate staffing and an environment conducive to patient care.
First of all, we need a system similar to Alberta’s Netcare which is highly secured and monitored. Under Necare, you can check lab test results, immunization history, hospital admission and discharge dates, a copy of discharged Rx, assessment notes, their diagnosis, Rx filled at other pharmacies etc. I used to work in Alberta and used to feel confident answering patient’s questions. I regret transferring my license in Ontario. I have to ask a lot of questions before recommending some OTC products which frustrates a lot of customers. On the other hand, in Alberta, I would just open Netcare and check their medications and lab tests. It saves time. It is also very safe and accurate. Until we have such system in place, Expanding Scope of Practice is a terrible idea. I mean why we are even considering this?
Administer the flu vaccine to children as young as two years old : I do not feel comfortable administering flu vaccine to toddlers. All other expanded scope of practices, I do agree. Thanks
It’s really hard to administer flu vaccines and run the pharmacy at the same time in the winter months. The 5 year olds cry, make tantrums and run out of the consultation room. It takes about 15 minutes for the mom to calm the kid down. Please don’t make us administer flu vaccines for the kids younger than 5. In a pharmacy where we do over 150 scripts with 1 technician, 5,000 OTC questions, question where is this and where is that……we can easily loose our concentration and easily make mistakes. Please make the owners share the responsibility for the mistakes the pharmacy team makes. It’s not only the pharmacist’s fault. No flu vaccines to under 5 please.
First of all Only dispensing activity with 250 to 300 scripts a day ( one pharmacist ,, no break ) In real world if pharmacist need to explain about medication to patient they need time . Ontario college of pharmacist should make a law like pharmacist to tech ratio in retail pharmacy like 1:2 ( one pharmacist , two assistant or tech ) *** if any chain would like to hire 3rd assistant , they need to hire a pharmacist too, so public get better clinical focus and more help with rx and otc and at that time if we introduce any new thing ( like minor ailment than it is good )
I strongly oppose changing the age for flu injections by pharmacist. Pharmacies are not set up for crying kids. It’s a big open space. How do you expect the pharmacy staff to carry on mandatory counseling , answer phone calls with other health care providers and collect necessary medical history information when there is a string of whaling kids in the pharmacy? Let’s face it- little kids will start crying even before the injection- out of fear/discomfort. Majority of pharmacies don’t have a second pharmacist to deal with it and to take the time to settle the child. And other patients will be affected greatly: there are people with anxiety and other mental health issues who can’t deal with excessive noise effectively and safely. And many seniors with various degrees of hearing loss. Having a crying child will make it harder for them to hear the pharmacist. Pediatricians are much better equipped to deal with that. They have trained nurses on staff to distract and smooth the little kids. They have toys and play stations. Pharmacies – don’t.
Expanded scope of practice …sounds amazing but what i personally see here is more technical duties and less clinical interventions. First of all let me begin with Injecting a flu shots for 2 years old and up….Injection training which pharmacists got is to inject needle on an orange or may be grapefruit and straight after that to another pharmacist partner who is ready to poke you. This is completely insufficient in injecting 2 years old child. May be after years of experience ,Pharmacists are well trained but again its all technical job. I recently heard that some provience in Canada got pharmacy technician to do injection expanded scope, which should be the case in ontario where a register tech can administer injection (technical work) and pharmacist can focus more on clinical work. Now let’s come to the another point of renewing medication up to a year..I am up for it but in real life practice scenario..physicians dont like when we do renewal as they would like to see patients for the follow up care. As in real life practice scenario Pharmacist has no access of clinical parameters..like lab works, BP readings or even Heart rate monitoring…how would we just renew medications without even proper clinically relevant information. Psych meds needs proper intervention specially when some one is not stable on medications due to various factors. Pharmacists should rather get minor ailments prescribing authorities which would help govt save tax payer’s money and allow patients an easy access of minor ailments care. Now the third part is POC tests..totally great..but the questions is who will reimburse for that test? e.g. Warfarin INR monitoring POC test strip would cost $10 per test. Will patient be paying for that or govt would reimburse for the service? Agian ..almost every pharmacist have mentions that they are under staffed and over worked . Pharmacists dont even get an official break time. I hope govt would read this and think twice before proceeding to next step.
I definitely want the following activities added in our scope as I felt powerless many many times in my practice. Administer certain substances by injection and/or inhalation for purposes that are in addition to patient education and demonstration & Prescribe drugs for certain minor ailments I work in downtown Toronto where people don’t have access to family/walk-in doctors. I have many clients who need their monthly psych meds injected. Poor patients have to keep going around and around just to find someone who can inject them the medication. I know the technique of it but can’t administer as it is not under my scope to do that. Most importantly patients suffer here as many times they can’t get their injection beyond the due date and get withdrawal symptoms and mental breakdown. You would think if they go to see the doctor they might get it done by the doctor, right? Nope few clinics I know where the receptionist is doing it under medical directives. So I leave it to the public and college to determine if it is better to have injection done by RPH who knows all about the drug being injected and has been trained in performing the injection or a receptionist who hasn’t been trained and doesn’t have any knowledge about the drug being injected. Prescribing for minor aliment: As mentioned above I work where there is no doctor who takes new patients or walk-ins. Lots of time my patient walk in with dental infection, ear, uti, skin problems. Etc. where I know 100% that this the medication they need but I can’t prescribe. After 2 hours of waiting in some clinic, my patient walks in with the Rx that I would have given or sometimes the inferior choice of medication by a doctor. And I feel so bad for the patient that they wasted so much time to just get that?? We need to include all the minor aliment where we can safely treat the patient. Obviously we don’t want to treat someone’s pheochromocytoma or pericarditis etc. or psych disorder etc. Also when I was working in a pharmacy with walk-in clinic. 80% of the time doc was used to come out ask my recommendation of the drug. When I talk to my friend pharmacists in Alberta they laugh at the situation as they can administer any Sch I drugs and prescribe anything except benzo/narcs. And I am feeling like this is the guy who was used to be in school with and has the same level of knowledge and license and just because he is Alberta he can do that I can’t? It’s not like he got special training for it. Still, he can do that but I can’t. I hope college will expand the scope as I know for sure pharmacists have so much to offer to the community and healthcare system. We can take away maybe a good portion of lots of overcrowded walk-in clinics and hospital emergency department’s patients as they might just be there for minor ailments.
I do not see the need for us to give injections to toddlers. Also, extending rx for 6 months, if for some reason we aren’t able to get in touch with their primary HCP, could allow us to get some of our snowbirds away; 12 months is excessive.
I think this absolutely correct. Pharmacists are experts in medications and vaccines. They can achieve that perfectly.
These changes are welcomed and most appropriate given the high level of capabilities within the profession. I would encourage further discussions to include a more comprehensive fee schedule for reimbursement for these services. MOH must recognize our value and provide a revenue stream that is in keeping with similar health care providers.
It is time for increased scope of practice within this profession, but a discussion needs to take place about safeguards for the public. 1) Pharmacists need to be able to order lab work to extend prescriptions. Full Stop. Without this vital information Pharmacists are walking blind and this will lead to public harm. The argument can be made re: Pharmacists ordering too many lab tests, but this is true for every profession. I argue that lab ordering authority will allow Pharmacists to access the OLIS system and prevent a number of duplicate requests for lab results. 2) Enhanced privacy in counseling rooms is a must. The glass wall with open ceiling room is simply not enough to have a private discussion. Regulations need to be improved to enhance patient’s privacy and health information. The enhanced scope of practice will not work in the majority of Pharmacy layouts and this does need to be considered going forward. 3) Documentation requirements need to be improved and enforced. Current Pharmacy software is great at providing records of dispensing, but poor at recording documentation that can be read by all Pharmacists working at the same location. This is a key factor to ensure first public safety, second public health. The profession needs to take time to put safe guards and regulation in place not just for this round of scope expansion but for future growth as well. We must examine and self reflect on our own professional environments and how this impacts patient health and safety.
i would like to comment on injection for 2 years and older and prescription renewal for up to 12 months strongly suggesting to implement these changes in Ontario, because now a days it is very difficult to get the rxs done by physician from fax on time and patient has a no time for waiting in line for physician to done the vaccine for kids and as well as adult , So these two changes i think will change and make it better our health system from all the ways thank you
I agree , to the proposed suggestions for expanding the scope of pharmacists , as it is already implemented in other provinces. Regards
Pharmacist should have a extended scope of practice. They are one of the most reliable healthcare professionals and are often the most accessible for the public in busy urban areas. The extended scope will be great for the public and also help the pharmacy profession grow. Thank You
I would welcome this change. It’s about we do what we were trained to do in school
Would welcome expansion. It would be a good idea to have mandatory courses e.g Cannabis so that all pharmacists learning is standardized and uniform across all pharmacies, thereby developing consistent level of service and education for patients. Pharmacy teams need to strengthen to allow pharmacists to spend quality time with patients and ensuing paperwork.
I am a member emeritus of OCP and retired Health Care and Drug Policy manager with the federal government. I am very supportive of the proposal to further expand the scope of practice for pharmacists as part of an overall strategy aimed at optimal deployment and effective management of health human resources in Canada’s health care system i.e. enabling health professionals to do what they are best suited and educated to do. It is disappointing that it has taken so long to permit pharmacists a more active front-line role in pharmacotherapy and patient care. Not enough has changed in this regard since I graduated 40 years ago. Nevertheless, changes in recent years and the proposed additional changes go a long way to better integrating pharmacy professionals into the primary health care system. While I am not convinced that administration of vaccines, etc. by pharmacists is the most appropriate use of their expertise and is better suited to nurse practitioners and/or other regulated health professionals, I support this move as a means to help enhance the visibility of pharmacists as primary health care professionals and not simply merchants of drug products. Providing pharmacists with greater authority to prescribe for minor ailments and to monitor/adjust previously prescribed pharmacotherapy as appropriate to optimize patient outcomes is the way to go! Pharmacists in Ontario should have at least the same authority as pharmacists in any other province in Canada. Any less implies that Ontario pharmacists are inferior to pharmacists in other provinces. Ontario needs to keep up with relevant regulatory amendments – or perhaps lead the pack!!
I don’t think it is wise to renew a Rx for 12 months, even if they have been stabilized for some years, as their MD will want to have them back in and would make that decision. Have you consulted with OMA about this? Clinical factors change and those on chronic medications should be reassessed at least once a year, minimum. Also, do not agree with flu vaccines under the age of 2. Limited evidence and retail pharmacies not equipped to deal with severe reaction and no transmittal of information to primary care provider so entered into person’s EMR. Administration of IV and inhalation medicines in the event of an OD or crisis situation only. This should be done routinely only at a clinic.
– minor ailments is a logical extension of our current services since we are essentially already providing this service without compensation, and without being able to provide the medication, where appropriate, we often know will be prescribed thereby precluding the final step of the care process that is initiated several times a day in the course of a days work as a pharmacist – extension prescriptions over 6 months is unnecessary, often clinically inappropriate and therefore unhelpful to patients In the long term and would likely rightfully stoke the ire of prescribers, the ISMP has cases where patient’s did not have BW follow up (I.e TSH levels) and died as a direct cause of this. We need access to blood work but in lieu of the ocp single handedly creating a harmonized e-health system, this proposal should be shelved. – Injecting antibiotics and others in this long list seems like a huge and impossible ask from pharmacists that I would not personally feel clinically competent to do thereby putting patients at risk, the dispersal of clinical activities need to keep in mind both safety and feasibility – POC testing makes sense however the OCP must consider current evidence when allowing one POC test over another – generally speaking expanded scope should be just that – a logical, feasible extension of the services we already provide that would both benefit the patient and be manageable for pharmacists as to deliver these services safely to said patients. We MUST be reimbursed for these services. If we are taking this burden off the health care system we need to be reimbursed sufficiently and accordingly, this will also help with the labour issue that is often brought up. Minor ailments, POC testing – these are extensions of the minor ailment counselling/OTC queries we get every day and the proposals can help us give better care to patients by completing the care process (rather than having to refer them to a physician for a simple rx). However, extending an rx beyond 6 months in lieu of a harmonized lab network we can access, injecting a frankly huge gamut of substances that we surely cannot be trained on each individual substance are more out of bounds – I believe this would be a huge burden on pharmacists and therefore a potential harm to patients.
I agree that a pharmacist can prescribe for minor ailments for an extra fee. I agree to extend prescription for patients up to one year but I don’t agree on giving injection to kids starting 2 yrs old. I am with the old regulation that states to give injection for 5 yrs old kids and up.
With greatest sympathy to my fellow pharmacists and respect to the rest of the public I shall start: Administering injections should not be done by a pharmacist in the first place, it’s a technical task that can be easily done after practicing injecting on an orange. No joke, this is what we did at the injection course (there was no screaming orange unfortunately) and then expected to inject 20-30 people a day the next day. And you can’t opt out. Pharmacy can be a brutal reality. I absolutely disagree with lowering the age to 2. I would actually raise it to 10 so that I can quickly deal with patients as my company expects me to: there’s your form, there’s your shot, next one! I will be quite upset if our college will implement something that will put our profit margin at risk. Sarcastically or not, it’s irrelevant, $ is what matters in pharmacy every day, several times a day (have you read your regional director emails recently?). How faster can we go downhill? Extending prescriptions for a year? Prescriptions for calcium and multivitamins yes. Anything else – no thanks. I am a moderately miserable pharmacist and I do not want to disturb the current balance (like not being able to fall asleep at night thinking about that guy on a year statin hyper-extended Rx, crossing fingers he didn’t go into some kind of liver failure since no lab work was ever done nor did I have access to.) Hope you enjoyed reading my post. Oh and one last thing, for some reason this saying came to my mind: The dogs bark, but the caravan moves on. CWOT
This is a great step towards a better healthcare for Canadians. I suggest also that OCP suggest a fee guideline for the public to receive this expanded service so pharmacist get their pay properly without any objection from the patient. I am also looking forward to see ocp is granting the pharmacist more opportunity to help the ontarians by allowing additional prescribing authority.
I agree with all the purposed changes
We as pharmacists, really seek to be more clinically engaged with our patients by providing extra health services, especially services that are not being fulfilled, due to an overburdened Gov/private heath system. But we also have to be realistic and to take a closer look at the current day to day dynamics at which pharmacists Operate. This will raise a big question ! How will the pharmacist be able to add additional duties at the time he/she even sometimes finds it difficult to drink a sip of water. !!! I think that the work dynamics of pharmacists should be first revised and adjusted in-order to take some of the unnecessary burdens off their shoulders, before adding any additional valuable duties and responsibilities we ourselves are thriving to fulfill in the near future . Pharmacists until now are deeply involved in technical dispensary duties, which causes an overburden, also the large and high dispensing volume must also be limited per pharmacist shift. We want to get away of the robotic kind of pharmacist who is really becoming like a machine in an ice cream factory. We don’t like to say that but that’s the bitter reality . Now how and who is going to support this shift in dynamics??. This could be achieved easily but there will be one thing missing in order for employers and owners to accept such a big shift and to start thinking to increase staff power inside the pharmacy and putting a limit for how many Rxs can one pharmacist complete per shift or per hour, etc. Such a big shift in dynamics will for sure come with increased expenses on companies and private pharmacies. That’s why this requires a big support from the Government and MOH to our sector in-order for the whole system to improve and bring up our missed potential as pharmacists .
Over years I have found our pharmacist more knowledgeable about drugs than our doctor
That why a have a doctor to discuss my health and medical needs not a phamacist or an assistant they will be the ones to give my shots and order my tests that why they spented all the years in school for. No i go to my doctor
I am excited to have the ability to renew prescriptions for patients for up to 1 year. However, I am unsure how I will be able to do this with no harm when I have no access to patient’s blood work. Many medications require blood work not okay for dose purposes but also to ensure no harm is being done to the patients. By pharmacists renewing medications for 1 year is that meaning patients are not having blood work as they have no family doctor? This could cause more problems for the healthcare system by patients having to visit ER departments due to side effects or not appropriate doses of medications. I feel as a pharmacist I would only be able to use this part of my expended scope if I not only have access to labs but can also order lab work so that I can ensure I am doing no harm and actually helping the patient. It would be a shame for us as a profession to have expanded scope that either is unused or not used appropriately that would then hinder further expanded scope if we are doing harm and not seen as a trusted health care professional.
Expanding the scope of practice for pharmacists is always a good thing and would help improve patient care as long as its done in collaboration with other Health Care Providers. Having gone through the proposed amendments, I get the feeling that the majority of the said expanded scope is more to do with managing workload or seeking a cheaper alternative for the Ministry. How can dropping the age for vaccination from 5 to 2 be seen as expanded scope? Ordering Labs on the other hand would be a good thing but can we just not ask access to the labs that would have been ordered by another HCP to enable us to offer comprehensive care. If such labs are missing then all we need is to collaborate and agree and way forward for the patient. I would not want to draw samples in the pharmacy but would rather get the authority to order labs but only where patient indicates that no such labs have been ordered before and after consulting with the primary HCP . Point of care tests that would lead to a quick referral would be a welcome scope however this should not substitute or override referrals. Extending the total renewal qty from 6 months to 1 yr will not benefit a patient if there is no adequate monitoring. I would not be surprised if the ministry is doing this as a cheaper alternative given the funding cut to other HCP. We may eventually be tricked to only one dispensing fee for the total 12 months refills. Most prescribers are already issuing 12 months refills for patients that are stable on chronic medications and by extending another 12 months would result in patients not seeing their doctor for 2 yrs. Nurses have been and continue to offer the services of injecting medication even at Dr’s offices and I don’t see the need for pharmacists to encroach on that domain. Most patients who require such services are either house bound or in hospital and have access to a nurse. products that require injecting from community are usually designed for self injection and as pharmacists we can continue to educate the patient to enable them to self inject. As I see it, we need to focus on services that will enhance patient care and not just offer a cheaper alternative for the ministry. We need to be consulted on the funding of such services.
If pharmacists are allowed to order tests how will they know their complete history. If ordering tests and referral needs to be made to a specialist then the patient has to go back to the family physician. Also lots of pharmacists English language is hard to understand. I disagree with ordering tests. Who will follow up with the results on these tests.
It is great to have the opportunity to do all these when our scope is expanded. I have been waiting for this moment for a long tome. Pharmacist have the knowledge or education to perform these services to our patients. It helps the patient a great deal and help us put our knowledge into use. Why waste knowledge. We went to school to help the public . We should be able to help as much as our knowledge takes us and we are ready for such responsibilities. Thank you again for making this possible.
In 2013, the Ministry of Health granted the OCP the power to inspect hospital pharmacies. At that time the Public Hospitals Act was amended. I am sure OCP was tickled pink to have more power to instil fear into pharmacists. Their understanding of hospital issues is poor. There are merely 2 hospital reps on OCP Council. The OCP Council should be ashamed that they have allowed differing scopes of practice for hospital vs community practice, as has already been mentioned in these comments. Can you imagine that if I see a patient on the floor with a COPD exacerbation and pneumonia, that I cannot order smoking cessation treatment…nope, I have to wait for the medical resident to prescribe (I am lucky if they know how to spell varenicline, let alone know the dosing)…..how demoralizing, not to mention inefficient and not in the patient’s best interest. OCP had an opportunity in 2013 when the MOH amended the PHA to raise this issue around harmonization of scope for hospital pharmacists (much like nurse practitioners have their scope respected in hospital)… they didn’t- it would seem like they cared more about themselves getting more power than pharmacists being empowered more to help patients. The strongest evidence looking at pharmacists preventing hospitalizations comes from the good work of hospital pharmacists. (While this is not the forum to discuss OCP’s partnership with HQO re quality indicators, they are misguided in their recommendation to have community pharmacists do Med Rec 14 days post discharge). I digress. I would like to remind the OCP that their name is the Ontario College of Pharmacists, not the Ontario College of Community Pharmacists. It’s well past time for OCP to reconcile intraprofessional scope divergence. How OCP gets away with not protecting the public boggles the mind. We should all be asking who regulates the regulator? I also want to comment about their mandatory education requirements. As a hospital pharmacist, I find it insults my autonomy as a self-directed lifelong learner to have to take a mandatory cannabis course….if they mandate all pharmacists have to do extra courses e.g. minor ailments, I will lose the last shred of confidence I have in OCP. I am never going to treat pink eye in my practice, so please don’t force me to take an OPA course (I am not a member) to learn about that. Do they not know that continuing education budgets are slashed? Why would I want to learn about pink eye when it is irrelevant in my patient population?
I wouldn’t hold your breath on OCP acting on scope issues for hospital pharmacists. Per their recently posted council meeting notes – https://www.ocpinfo.com/wp-content/uploads/2019/09/Sept_2019_Council_Meeting_Materials_Agenda.pdf?utm_content=bufferae31d&utm_medium=social&utm_source=twitter.com&utm_campaign=buffer “Hospital based Council members expressed concern that the current scope of practice is restricted in hospitals due to the Public Hospital Act (PHA), and the requirement that the CEOof each Hospital determine scope of practice for health professionals within each organization. It was explained that while the expansion of scope for pharmacists is enabled for all settings in Ontario through the proposed changes to the Pharmacy Act regulations, there may be other legislation, regulation or policy outside of the College’s jurisdiction that may restrict scope for individuals in some settings, for instance the Public Hospitals Act. It was suggested that the associations would be the best avenue to advocate with government for change in this respect.” I read this as OCP basically abdicating their obligation to protect the public to the advocacy associations… either that, or one could interpret it as OCP not wanting to do the hard work of protecting the public. (i.e. we protect the public, as long as we don’t find an excuse not to).
Well, you better get ready regarding courses. Take a look at the OCP Council Agenda from Sep 16-17 and you’ll see they’re now into the realm of “Indigenous Cultural Competency”: “Web Material: The College should create a cultural sensitivity page on the College’s website that would include resources and a training module on the inclusionary services that the College expects of registrants.” And while councils were required to eliminate prayer at the start of each meeting (self-reflection, etc.), now: “Land Acknowledgement: The College should begin Council meetings with a Land Acknowledgement (see Appendix 3). Doing so will remind Council members, College staff and registrants that we all have a role in the reconciliation process and to consider this role within our work.” This, even though it also states that “…this section focuses largely on actions from the federal government.” A dangerous road, considering the RHPA college objects to be done “to serve and protect the public interest.” There have been other historic atrocities committed against other cultural groups, yet they are not being given the same attention in this regard.
The expanded scope of practice for the pharmacist will help the to get more involve in the community care, Easy accessible the health care services and Most importantly reduce the burden for doctors heavy work load.
In terms of point of care testing, I would encourage OCP to look at this CADTH review- Point-of-Care Testing: Summary of Evidence January 2019 Update- https://www.cadth.ca/sites/default/files/pdf/PoC_summary-of-evidence-e-jan2019.pdf OCP may wish to consider that POC testing by pharmacists be limited to those who provide care in underserved rural areas (and define this explicitly in the regulations).
The suggested “limitation” here is a great comment. While it would be easy for the OCP to not want to “control” this, they already send notice of a new Narcotic Signer to Health Canada (OCS) when filed with OCP; why not also be able to establish “underserved rural areas” (similar to how the ODB dispensing fee is calibrated) and then notify the MOHLTC when a pharmacist (not pharmacy) practises in those areas, to permit compensation to the pharmacist? No other excuse in not wanting to do so could be justified, given what is already happening as described herewith in other situations.
Yes. I agree with the changes. The pharmacy professionals are trained doctors and have extensive knowledge that should be utilized .
I find it troubling that it can take up to 5 days for someone to comment on this website before it is posted. For example, I commented on Sept 6, but it didn’t appear on the site until Sept 11. This long lag-time seems to hinder efficient/effective discourse. I would like to encourage the OCP to re-look at their policy around “awaiting moderation” for comments to be posted vs posting in real-time and subsequently removing posts if they don’t meeting posting conditions. Finally, I would like the OCP to consider actually providing Council Members specific quotes/comments – and not dilute down the commentary with a summary. I am skeptical that Council members will take the time to review these comments, and worry that the summary presented to Council Members will not be as impactful. Thanks for considering.
I am appalled at the decision to consider lowering flu vaccinations to kids from 5 to 2 years of age. This is nothing more the Drug companies agenda to increase profits at the expense of our children! Where are the studies (non drug company funded) that show this is necessary?
There are some interesting points in the second phase of expanded scope of practice and some other not that interesting a. administering flu vaccine to children 2 to 5 yo , not really. I am not sure about this . This can be really hectic in a busy practice .b. administering other substances than vaccines may be convenient for the patient, prolia, vitamin B12 , methotrexate, some of the biologics or biosimilars etc. considering there would be some remuneration. c. POCT, which tests does this involve? This is really not clear to me . INR testing costs at least $8.00/ strip + time and this is if you get enough blood the first time. What about access to blood work first? It is overdue that pharmacists have access to blood work especially in the context of extending prescriptions Why would I extend levothyroxine for 1 year when I do not know what is their last TSH ? Why would I extend a statin for 1 year when I do not know where the lipid panel stands and their LFTs? Why would I extend medications for diabetes if I do not know when their last A1C was done , the result, and some information about their kidney function? This is not about diagnosing this is making sure this is the right drug, right dose for the right patient and really basic part of the pharmacist’s every day scope of practice. d. Prescribing for minor ailments, which one are we talking about ? Lets be more specific. Again , give the pharmacist the tools, resources. And finally MOHLTC needs to be more specific about remuneration. Finally lets have a word about Medscheck . It would be a huge step back to lose this program. I agree to some modifications such as the minimum number of medication required to provide the service . It could go up from 3 to 5 prescriptions for a chronic condition. or even 6 prescriptions. Medschecks allow to address DRPs such as non-adherence, duplication,side effects, the indication etc.It also allows pharmacist time to provide education to their patients on their medical condition and finally provide the patient or their caregiver with an up to date list of their medications that is communicated to their physician or nurse practitioner. As a diabetes educator I teach people with diabetes who have been prescribed insulin, insulin injection technique and follow an insulin start up check list ( titration, injection site rotation, hypoglycemia S&S, hypoglycemia treatment, driving, traveling with insulin etc..) Let’s try not to go back, let’s try to go forward.
Re- point-of-care tests… I was reading Minister Elliot’s letter to OCP. https://www.ocpinfo.com/wp-content/uploads/2019/08/ministers-letter-expanded-scope-of-practice.pdf And I find this statement interesting- “in recognition of the need for pharmacists to have access to information to assist with medication management and the treatment of patients, I have asked ministry staff to work with the College to authorize pharmacists to perform certain point of care tests for certain chronic conditions.” If the Minister wanted pharmacists to have access, they should be supporting funding for pharmacists (not pharmacies) to have access to Connecting Ontario/Clinical Connect or OLIS. Who would be short-sighted enough to think that a point of care test would be sufficient for pharmacists to assess drug therapy? For example, pharmacists should have access to creatinine values for elderly patients- you can’t do a point of care test for this. One could interpret the Minister’s statement as a lack of commitment from the MOH to support pharmacist access to lab testing/integrated records. This is unacceptable. OCP, please do not get distracted by the shiny ask from The MOH re point-of-care tests. This is a distraction, and potentially dangerous as it further fragments care delivered in pharmacies. Not to mention one could take a cynical view of the MOH downloading costs to pharmacies/patients for tests. My advice to OCP is to find the courage to say No to the Minister’s ask on POCT and truly advocate for the public interest by insisting the MOH enable pharmacist (not pharmacy) access to labs available via OLIS/Connecting Ontario). (As an analogy, please do not “fill the script” requested by the MOH re POCT, as it is not in the best interest of optimal medication management for Ontarians).
I encourage Council members to read the following, which is authored by one of their Council members, Dr Lisa Dolovich, et al. https://www.open-pharmacy-research.ca/wp-content/uploads/Future-of-Pharmacy-White-Paper-REVISED-for-posting-Jan-2019.pdf To quote this white paper, “There is a great need to ensure each patient can be served with optimal scope available at this time BEFORE seeking additional scope.“ Perhaps instead of acquiescing to the MOH’s ask re scope expansion (most of which are of dubious value to Ontarians), there are bigger fish to fry that the OCP needs to consider… (I am reminded of the Choosing Wisely campaign saying “More is not always better” – same can be said re scope expansion.)
Although I welcome expanded scopes of practice for pharmacists, I am concerned that mandating the vaccination of children as young as 2 would put this patient group at risk of harm. Pharmacies are not set up for caring for such a vulnerable group of patients and vaccinating them should remain at a physician’s office where the staff is experienced in dealing with any adverse events in patients that may not be able to verbally or clearly explain their symptoms. Also, in regards to extending prescriptions, pharmacists are currently doing this for continuity of care and until the patient is able to see their physician. But to extend a prescription for up to one year without having access to patient’s blood work data is utterly pointless and can put patients in harm’s way. If OCP mandate is patient safety then they must ensure pharmacists have access to medical records, like in other provinces, or force pharmacists to vaccinate a vulnerable population as pharmacists do not have the expertise or time for this service.
Some of the comments posted to date regarding the proposed “extension of prescriptions” are referring to 12 months as if it would be the option of a pharmacist to do so, regardless of how the original prescription was written. This should be clarified, because as the current legislation is worded, it is to be the LESSER of what was prescribed or 6 months. I have assumed that the proposal to extend the 6 to 12 will still be contingent on what was originally prescribed. We can’t be having the primary care giver issue for six months only to have us go and renew for 12; it makes no sense in the overall patient care model and will certainly serve to antagonize the primary care provider. Having said that, regardless of what term is authorized by statute, there should be no question to the pharmacist being able to receive compensation from the OHIP program. Simply put, if the patient went back to the original prescriber, that prescriber would be billing OHIP for the appointment (which is why many will not do verbal repeat authorizations as they have to show they assessed the patient in order to bill). That needs to change as part of this proposal. Clearly, if lab values are necessitated in order to exercise proper judgement in extending prescriptions, then there has to be a statutory change (as well), or standard of practice established (THROUGH CONSULTATION WITH MEMBERS) to identify WHAT tests will be requisite in order to meet that minimum standard of practice (best interests of patient, by having the proper data at hand in order to make the decision). Many have commented on this aspect, albeit in different ways. At least one comment referenced the need to have more than a glass partition providing privacy for counselling. This not only promotes more openness from the patient, but has been required going back to the 90s and yet is STILL not being enforced. Why would we think they will do so now? It’s long overdue; if the premises doesn’t have an acoustically and visual private area for certain types of interactions (including expanded scope injections, etc.) then they should not be allowed to be performed. End of discussion, come on! OCP can’t keep appearing to be acting in the patient best interests and then dropping the ball on ensuring compliance with the practice standards already put in place. Rather, it continues to look like it’s motivated by individual corporate interests via “elected” members of council who fail to disclose their true conflicts of interest.
While I welcome the opportunity for increased scope of practice, with the best interest of the patient in mind. There are a few important things to consider, which some of my colleagues have mentioned. 1. I don’t think we should administer vaccines to children 5 and under. It’s sometimes challenging enough with the older kids. 2. Keep prescription renewal at six months so patients can see their physician. Many patients don’t want to see their doctors because they know the pharmacist can renew their prescriptions. 3. Administering substances by injection and inhalation for patient education and demonstration is good for sometimes more clarity. 4. However, staffing is critical. I am not sure if many administrators are aware of how stressful it is to be pharmacist, cashier, telephone operator, entry tech, fill tech at the same time. Imagine walking to the counselling area with methadone in your hands and have someone say to you, pharmacist for lines 1, 2 and 3? It is brutal and that is what some of us go through every day. So there has to be a mandated minimum number of support staff per shift in consideration for patient safety or this will not be successful for many.
Given that a common theme in these comments relate to the need for OCP to have a more active role in ensuring staffing and workload conditions allow for safe completion of full scope activities, I thought I would do a bit of homework. Of interest, when a pharmacy applies for accreditation, believe it or not, there is no statement around the designated manager ensuring adequate staffing. https://www.ocpinfo.com/wp-content/uploads/2019/03/Application-for-Certificate-of-Accreditation-as-a-Pharmacy.pdf Though OCP has suggested that this is a manager’s responsibility, how does OCP ensure that pharmacy owners don’t exploit the minimum requirement for 1 pharmacist on duty? When a pharmacy inspector does a site visit, do they assess staffing levels? What are their guidelines for this? Again, I worry OCP remains too passive on this issue (and I question whether they can continue to do so and not appear neglectful of their obligation to protect the public). I would urge OCP Council members to truly listen to these comments- which consistently raise patient safety concerns, I also wish to share some resources (that I hope Council members read)- https://www.tandfonline.com/doi/abs/10.1080/13698575.2011.558624 https://pharmaceutical-journal.com/article/opinion/the-pharmacy-regulator-must-take-a-role-in-ensuring-minimum-staffing-levels-if-it-is-serious-about-patient-safety https://www.pharmacyregulation.org/sites/default/files/document/guidance_to_ensure_a_safe_and_effective_pharmacy_team_june_2018.pdf There is some irony in that pharmacists are often accused by academics to be apathetic and “stay in their lane” (studied extensively by Dr Zubin Austin) – insomuch as OCP seems to be using the same playbook (eg avoidance of proposing amendments to legislation unless asked to). I hope that OCP Council members vote with their conscience, as we are in dire need of leadership that put patients first. Too often, these consultations seem to be done as a formality and Council minutes suggest pre-determined decisions, or worse, rushed decisions that are largely influenced by the individual opinions of Council members (some of whom may have vested corporate interests and ambitions that inevitably weep through despite declarations of actual or perceived conflicts of interests).
So here’s the joke. We do have a statement in our Standards of Practiae in alberta that says the manager MUST have adequate staffing BUT we don’t have control over that. We don’t hire or set staff levels so what’s the point?!?!?
Yes, that’s an unenforceable statement that the OCP suggests as well. Horrifying really, as it puts patients at risk. Someone should do a study on Council Membership at OCP to determine what the corporate affiliations are, whether members are staff pharmacists or pharmacy owners, and look at the trends around decision-making. Perhaps then one can determine whose interests are really being served.
I don’t agree with corporate marketing us as doctors and making us as competent as a physician only to push the blame and liability on us. https://globalnews.ca/news/4979855/ontario-pharmacy-fraud-prescription-for-profit/ “Almost everyone overbills. Big chains (sdm, rexall, costco) to independents. Some just a little bit, sometimes by accident (that does happen), others a lot on purpose. Same with medicine and doctors offices. It can be tough for colleges of pharmacy (not schools, but the provincial pharmacy regulatory body) to go after big chains. They have power, influence, accountants, lawyers, and damage control protocols. Big chains actually make much more money through generic rebates (‘outlawed’ in ON, but allowed in most of the rest of Canada). As for overbilling, pharmacists in big chains have no incentive to overbill (it’s not really their money), but they get evaluated on store performance, so some pharmacy managers overbill just to keep corporate happy. Corporate usually suspects/knows, even encourages it off record, and turns a blind eye, until the pharmacist gets caught, then – “I had no idea! We’ll fire them immediately.” Thus the college will sometimes catch the pharmacist, but almost never the chain. Independents that are rampantly overblling are easier to successfully target (and publish, since college “convictions” are public, whereas investigations are private). Also, the article is right – in my time in pharmacy I’ve never seen the OPP get involved, nor the ministry. Just the OCP. And it’s incredibly easy to overbill and fake documents. You have to be extremely sloppy or lazy or brazen to get caught” ^copied from another discussion
Strongly against expanded scope of practice a non-owner, non-manager, staff pharmacist that is overworked and mistreated. Expanded scope of practice doesn’t help pharmacists – only owner bottom lines. My workload goes up, but my quality and wages and rights go down. I just want to provide good medication care and don’t want to be forced to spread myself thin with no breaks. How am I supposed to do more when I’m drowning in my existing tasks in a retail environment?
I support the proposed expanded scope of practice, CONTIGENT ON a supporting legal requirement to have a private room (not semi-private counter space with frosted glass divider) available, in every pharmacy, in order for pharmacists to provide these services. In addition, mandated support staff available to allow pharmacists time to provide these services to the public in a safe, professional and uninterrupted manner.
I think that extended a prescription for 12 months is too long. Pharmacists in the Community Pharmacy setting (Retail Setting) have no access to laboratory values, or diagnostic results for patients. They are unable to see current renal function testing, ambulatory blood pressure monitoring results in the chart, echocardiogram results, EKG results, specialist consult notes. These are just some of the information that could be required to see if it is safe to continue at treatment such as blood pressure medication, potassium supplements, diuretics, heart medications for heart failure, dementia medications, etc. It is also the information that is required to form good medication assessment and provide drug therapy recommendations-so this lack of information limits what can and should be done with regards to authorizing refill medications for long periods of time.
Please explain to me how increasing our scope is even possible at this point. No lunch breaks. Constant disruptions. Staffing cuts for over a decade. Patients already at serious risk of injury due to the staff cuts, interruptions, and pharmacist fatigue (surely there have already been many deaths but is anyone talking about it?). Employers’ money grabbing quotas. If you want me to provide such services, fine. But don’t expect me to do them while dispensing. And don’t expect me to do them over a countertop next to the till with a lineup of people listening. SHAME ON THE OCP AND OTHER PROVINCIAL COLLEGES FOR NOT LOOKING OUT FOR THEIR OWN-THE PHARMACISTS IN THE RETAIL TRENCHES WHO REALLY DON’T CARE ABOUT TOPICS SUCH AS THIS, WHEN MORE IMPORTANT ISSUES SUCH AS PROVIDING BASIC HUMAN RIGHTS TO PHARMACISTS IN THE WORKPLACE AND FOLLOWING LABOUR LAWS ARE BEING IGNORED BY YOU. I CAN ASSURE YOU IT IS BEING NOTICED BY ALL OF US. WE AREN’T HAPPY AT ALL.
There has to be consistency with what PharmD students are taught in school (@ UofT and Waterloo), tested in exams and clinical rotations and advanced pharmacy practice experiential (APPE) rotations and what is in legislation. I also believe OCP should not be providing blanket requirements on all RPhs in certain areas where it comes to education but not provide blanket requirements on all practice setting RPhs to have the ability to implement these changes for patient care (e.x. OCP should supersede Public Hospitals Act). Having said this: 1. I think pharmacists SHOULD be able to provide flu vaccines for patients 2 years of age and older as we are taught and trained on this in school (and for those RPhs that aren’t or haven’t, then they would require additional training, but not everyone). NB: I also think pharmacists should have access to give the elderly the higher dose flu vaccine as well – patients come to us at first point of contact with healthcare system so if we are being trusted to refer patients to their GP if higher dose is required, then we too, should be able to administer it ourselves… 2. I think pharmacists SHOULD be able to renew prescriptions for up to a 12 month supply for continuity of care and to assist patients without a primary care provider. Not only does this minimize unnecessary ER visits that are a significant financial and resource burden on the healthcare system, but it also encourages patient adherence to therapy, and completely within our scope. Having said this, what should logically come hand-in-hand with this new amendment is ordering and interpretation of lab values. Again, the fundamental epitome of pharmacotherapeutics as it related to hospital pharmacy practice as well as content in pharmacy school, it is monitoring of pharmacotherapy. For a prescriber and pharmacist to mutually decide upon and choose the correct indication and effective and convenient medication for a patient to start on for their condition is only one, arguably, small piece of the pie. What is equally if not more important is being able to monitor and maintain said treatment regimen, and doing so requires monitoring of its safety which, the majority of the time, is in the lab results that the patient nor pharmacist knows, with the latter being the drug expert. This should be common sense. By being able to order and monitor blood work with this amendment to extending for a 12 month supply, it allows other providers to see and monitor on ClinicalConnect the results, for continuity of care. I also believe, with each extension, pharmacists should also be able to bill the government as a GP would for a consult, especially if the patient is not a regular patient of the pharmacy, it is similar to seeing a walk-in clinic MD. So many times patients go to walk-in clinics for the prescriber to bill the government for an Rx renewal because the patient’s primary care provider is on holidays, the office is closed, and the pharmacist cannot continue extending. Therefore, we should bill as well for this service. 3. Pharmacists SHOULD be able to administer certain substances by injection/inhalation beyond patient education. If the government and OCP are to, first and foremost, provide patient care that is safe and effective, and also ensure it is financially viable for the government and cost effective, then why is it that patients can go and bill their GP simply to see a nurse to inject them their vitamin B12 and/or Depo-provera without even seeing their GP? Pharmacists should be able to do these acts beyond patient education and it should be billable to the government as a professional care service (e.x. like a POP), with the same price as a GP would. It still saves government money while ensuring equivocal patient care, and here’s why: it minimizes back log and therefore prevents unnecessary hospitalization due to non adherence by patients (e.x. skip their depo-provera shot, get pregnant unintentionally, partner is not expecting it, etc, etc as a domino effect), it ensures cold chain is maintained as the medication would logically and ideally be dispensed and administered on site at the pharmacy. With all of the above, it lends nicely to allow the initiation of diagnosing and prescribing for common ailments, with ample positive results on patient care and safety evidence in studies in other provinces with a more progressive and active government, and collaborative physician colleagues.
Thanks for asking our opinion I think prescribing not only for minor but also major diseases both could be added to the scope of practice as pharmacists are drug specialiists and know much more better than nurses. Regarding injection administration I am not agreed due to the nature of the job which needs to be done in a specific environment such as clinics. Also some pharmacists chose this profession only because of not having direct contact with patients. Thanks again
I do not believe these initiatives can be delivered safely in the current environment of most community pharmacies, where there is inadequate staffing level to allow pharmacists to perform thorough assessments needed to provide high quality of care. Patients will be harmed if the work environment is not conducive to patient care. If the college is serious about patient safety, they must ensure pharmacists practice in a safety centered practice environment. Rather than placing the onus on the individual pharmacist, they should address the systemic issues at play and mandate minimum staffing requirements.
1)flu vaccine to 2 year olds and up-may be more convenient to parents to make an appointment with primary care provider. Retail pharmacy chains long ago gave up on the idea of having customers make an appointment for flu vaccine. I have been working when 5 or more people just show up and expect a flu shot on the spot. If I am already busy with insufficient support staff (which is the norm), I will ask customers to wait 30 minutes or more. Might as well go to the MD’s office/public health clinic, etc. We are not trained to deal with preschoolers; they may require extra TLC and time. This extra time creates stress for the pharmacist who is madly trying to catch up as he/she falls farther and farther behind in other work. Ultimately this is a safety issue as a stressed, pharmacist who has zero control of his/her workload (and who gets no break and is often hungry, thirsty or needs to go to the washroom) is likely to make an error sometime in the shift. 2) 12 month renewal. Outrageous in most practice environments. We can’t order or view lab results which are critical for many meds. Completely unsafe for diabetes meds, most antihypertensives (ACE, ARBs, diuretics), DOACs to name a few. What do our physician colleagues have to say about this? I can’t imagine one (outside of the most remote areas) who would think virtually blind prescribing is a good idea. This will undermine whatever goodwill still exists between the professions. 3)administer substances by injection or inhalation. Which ones and in what circumstances? Tell us more. I personally feel competent to administer meds via these routes, but again, due to the practice reality of most retail pharmacists, unsafe (for reasons given in #1). 4) POCT-a wonderful idea to support clinical pharmacy in theory but again, completely out of touch with the workplace reality of most retail pharmacists. Creates unsafe workload. Let’s re-establish excellence in what we as pharmacists were trained to do. Our retail workplaces are, for the most part, not allowing us sufficient time to practice well as medication experts. It is making our workplaces and our practices less safe for patients by stacking on extra responsibilities while encroaching into the areas that have been well managed (for the most part) by other healthcare providers. No extra support staff was provided to us to do Medschecks properly. Profit and the shareholder will prevail and, for pharmacists, it will be exactly the same debacle for these initiatives as it has been for Medschecks and flu vaccine. Therefore, I reject the addition of these initiatives to pharmacist workload as unsafe.
Giving flu injection was difficult initially, when we started, but now we can give flu vaccine confidently, hopefully it will be same when we will get approval for more than 2 year old children I think first injection should be done by dr, if dr provided vaccination record means person at that age had that vaccine before without any problems, then it is a matter of proper injection technique, with proper training, we can also do it, if we can do flu vaccine, then for B12 inj or methotrexate and other inj, we should not have any problems Rx writing for 1 year should be allowed if we are allowed to write requisition for blood work also, if we have blood work results, blood pressure reading or HbA1c or tsh report then with proper training, we should be able to write Rx for 1 year, it will be big help for pt .
Pharmacists are valuable and knowledgable healthcare professionals. If they practice independently (their own office or in a hospital, but separate from selling medications), then I agree with an expanded scope of practice predicated upon the education. I have concerns if the pharmacist works for or runs the business that profits from the medication prescriptions. Patients might “like” pharmacists to prescribe medications for “minor” ailments, however, this is a significant conflict of interest for a community pharmacy. Healthcare professionals should not directly/indirectly benefit from recommending treatments and therapies. Patient satisfaction (antibiotic prescription for sore throat and upper respiratory illnesses), is negatively correlated with patient benefit. The Choosing Wisely campaign recommends against them and the patients are at risk of the side effects, and obtain little or no benefits. Renewal of prescriptions for a short time (one month, the most common timeframe currently), may be very beneficial for the patient. Longer renewals are for patient convenience but will interfere with the patient-physician relationship, and best patient care. I don’t support expanding renewals for a year.
I feel the expanded scope of practice can be very useful in reducing costs to healthcare , reducing wait times , and helping patients access knowledgable healthcare professionals. Many times I will send a patient to a walk in clinic and they come back with either exactly what I thought suitable or something similar, of course I would like to receive proper training for it and I would like to work in conjunction with their family physician .
My chief concern is the lowering of the age that pharmacists would give injections.The reality of the situation across the board in community pharmacy is that due to economic constraints there would be insufficient staffing for the extra time burden and responsibility to ensure absolute focusing on the task of dealing with young children and needles and OCP. would according to its own mandate of optimal safety for the public have to enforce new regulations ensuring staffing numbers and ratios (pharmacist/tec/rx numbers)..We know that the payment will be insufficient to help the staffing numbers so how is adding this extra responsibility and overburdening the pharmacists further going to help the public and its safety
I don’t recognise this profession anymore ….we are going beyond the boundaries of our profession ….are we doctors now …?or a hybrid between pharmacist and physician …?It’s a new breed concocted and we are going to end up by not doing anything right just more confusing …a nurse practitioner has more power to prescribe then a pharmacist ;it’s no longer a profession ..it’s just … bussiness….
I am a supporter of pharmacists and believe in expanded scope activities to leverage the expertise and accessibility of pharmacists. That being said, I think we need to be expanding in directions where we can have the most impact and not just expanding for the sake of expanding. I think pharmacists giving injections has certainly expanded access to vaccines in Ontario, but I’m not sure that reducing the age is necessary or efficient given the workflow issues cited by other commenters. My personal opinion is that extending many meds beyond 6 months is inappropriate when most pharmacists do not have the ability to order lab tests or at least review results. Patient monitoring and safety must come first. I really feel that the OCP should be pushing for the ordering of lab tests above any other expanded scope activity. This would give pharmacists access to data that would allow for more conscientious Rx renewals and adaptations. It seems a bit silly to me to focus on expanding scope to include injections or diagnosing minor ailments when we are handcuffed in our ability to do what we do best: identifying and resolving drug therapy problems. This should be the focus of practicing pharmacists, not watering down our expertise with activities that other HCPs are already specifically trained to do. There is a lot of value both for patient care and keeping healthcare costs down if pharmacists are equipped to perform medication management optimally. I truly believe this should be the focus of the OCP and the Ministry going forward.
I agree with these comments. Pharmacists seem to be scrabbling for a professional identity. That being said, I highly doubt the Ontario College of Pharmacists will turn down the opportunity to expand scope. After all, it gives them more to regulate. Could the OCP say to the MOH, none of the scope expansions proposed make sense or are in the best interest of the public – of course they can. But they will not. There’s a political angle to self-preservation it would seem.
I agree 100% with comments re mandated staffing for expanded scope. This may even simply include limited hours of pharmacy operation when sufficient staff are available. I also concur with the comments already made re mandatory education for continued practice. I have practiced for 30 years, providing health care to elderly patients, diabetic patients, patients with asthma and COPD, and as much as I appreciate offers for continued education, could not fathom completing all the “certified” this and that pharmacist programs. Besides the college mandated cannabis training, the company I work for has mandated training for methadone even though we may end up with less than any patients at each store. Can the college not launch minor ailment scope where it is best needed for patients . For example, how many of us have taken the time to help a patient get past a nasty receptionist so they can get a prescription to treat shingles before it is too late. The main issue for which I am DEEPLY concerned, is with the colleges ability to regulate conflict of interests of business and professional service as we move healthcare from the “business free” environment of the doctor office and clinic, to a paid for service environment in pharmacy. We all are familiar with med check billing going the way of the dodo; I think we need to carefully proceed with scope expansion ensuring that conflicting business interests are not imposed over our ability to provide care to patients. This goes without even mentioning the possible abuse of billing made by members we are all embarrassed to be associated with. I feel I have been a significant benefit to the level of care my patients receive from both myself and how I help them find the care they need. However, I also feel that my ability to juggle the interests of the government, college and business will likely be the reason for my retirement. Lastly, in regard to the specific task of flu shot immunization, I see no reason to go below the current 5yr old guideline. A busy store is not the place for a screaming 2-3 yr old to receive their first flu shot. I have helped families immunize their child screaming and thrashing in busy evening hours after school, and it is not a task to be taken lightly in between checking and counseling prescriptions and fielding phone consults. I feel pharmacy is doing more than it’s part in providing cost effective coverage for the 5-100 yr old demographic.
Strongly object to lowering the age of vaccine administration from 5 years to 2 years of age. Unlike a pediatrician’s clinic, a pharmacy is not setup properly to service this particular age group. This would create a safety hazard for the public, as well as the pharmacist.
The expanded scope of practice ammendments are both a win and a dump on to pharmacy. Administering the flu vaccine to children as young as two years old is not a win for pharmacy as we only get paid $7.50. This is not an accurate remuneration for the service provided. Trying to vaccinate even a 5-10 year old can be a tedious process depending on the child, so I’m less than thrilled to be vaccinating so young without appropriate pay. Also to renew a prescription in quantities of up to a 12-month supply is an easy way for patients to avoid seeing their physician or going for bloodwork. Depending on the patient, comorbid conditions, other medications, they most likely need to go for regular bloodwork & I unfortunately can not order or view the results at this point. In most situations today, I only extend the prescription for 1-3 months. I agree with administering certain substances by injection and/or inhalation for purposes that are in addition to patient education and demonstration – as long as their is remuneration involved. A problem with pharmacy is everyone expects services to be free. We need to change this and charge for services that we are not being paid for (ie. injections, travel consults). Prescribing for minor ailments is a great step to expanded scope! I’d look at other provinces & their corresponding regulations rather than building it from scratch here in Ontario.
I beleive that the suggested changes should have been here long time ago, and I also beleive that as pharmacists we have a generation of pharmacists who resist ANY clinical advancement or initiative and would love to stick to the old model of practice which is “lick and stick” labels and check interactions only ( AI is way better doing interactions check and if we keep doing what we are doing now soon our job will just vanish) and then we have pharmacists who are eager to advance their proffission and support the health care system more effectively. Regarding the hours and the staffing and as a business owner my self, I beleive that we should fight for proper coverage for the services by the GOV/insurance companies, if we get these services covered and a revenue is genarated, this will allow better staffing and more hours to be allocate to pharmacy. It is a simple calculation. It is a shame how lazy and scared of changes some pharmacists are, we are far behind in modern pharmacy practice and we have a great opportunity to support our communities and patients it’sabout time we finally move forward.
Pharmacists who want to do their job properly in an appropriate practice environment display the attributes a professional should. They care about their patients and the job that they do. Calling them scared or lazy displays a level of ignorance. It is time some pharmacy owners and directors cared more about patient care and safety than profits. It is also time the college held them to this standard.
I stand with the changes being made. With adequate training, we can reduce the burden of minor ailments that causes long wait times and extra workload for our physicians and hospitals. I am just slightly ashamed as a Pharmacist that our province is very slow at implementing these changes. We should be more upbeat similar to Alberta especially with the population and the resources we have. We should not be the last to implement such crucial changes that will benefit our healthcare system.
I am totally behind pharmacist expanded scope of practice. But as a pharmacist when I look at my colleagues in chain pharmacist they will be overwhelmed with added tasks which has an effect on patients safety with no regards on extra help ( pharmacy technician) or an increase in their salaries. We as pharmacist have been stepping up working through all the hard times but we are the only professionals who has had a decline in their income. In light of the new scope I highly suggest looking at retail chain pharmacist hours, number of assistants, and their salaries.
Overall, the idea of an expanded scope of practice for pharmacist is one that should have been implemented a while back. That said, I appreciate that we are now getting the opportunity to use our skills & knowledge to improve patient outcomes in a timely manner and help alleviate the burden that some of these patient visits (ie. for injections, Rx repeats, etc) might have on the health care system & primary care team (ie. family physicians). However, if we are truly thinking about implementing this expanded scope in such a way that patient safety is not compromised and pharmacist can truly deliver value to the system, then the college should put every effort behind mandating certain safeguards in the pharmacy including the # of staff that has to be on shift, the # of “meds checks” or other “professional services” that big chain pharmacies and even some independent will start requiring from their pharmacist, etc. It is not in the patient’s best interest to have a multi-tasking & pressured pharmacist perform these services. A pharmacist that is injecting a 2 year old patient, all the while knowing that there is a line of patients waiting for their prescriptions to be checked, and another line of patients waiting for consultation, is not in the right environment to be able to offer the best quality of care to all patients. As you know, many pharmacies are cutting back on hours for staff, there is hardly any pharmacist overlap – and this in one way or another affects the quality and safety of service that we can deliver. Secondly these quotas that big chain pharmacies impose on the staff drive a “quantity” over “quality” mentality. A 5 minute consultation is most often not enough for these patients to get something of value – particularly with these new services that we can offer from the expanded scope. I would suggest the college conduct some type of market research with patients to see what expanded scope services have they already received from a pharmacy to date, their satisfaction associated with the service and their recommendations for improvement. Would be happy to help with this if needed.
I totally agree that the staffing levels need to be looked at from a patient safety perspective when involved in a number of expanded scope of activities. Pharmacists cannot control traffic flow, and scenarios presented to us at any given point in time. The mindset is the convenience factor when it comes to pharmacy and pharmacy services. However the onus on the pharmacist to take on more activities in the pharmacy does create a potential for error, and with expectation of delivering services or prescriptions in a short time, patient safety is compromised. Look to the college to put guidelines or mandate the requirements of staffing based on services to protect the public.
But hang on here, reality check. The College has, via committee and individual council members, created an environment where they now ACCEPT that errors will occur in our practices (even though we know we were all trained, that as the final gatekeeper for the patient in the drug delivery system, we cannot make an error). With that type of “acceptance” and use of the (incorrect) “everybody makes mistakes” rhetoric, why would further errors due to staffing levels not be seen as a “college jurisdiction” concern? In the end, it results in patient best interest impact. I’d like to know how the new practice allowances and decreased time factors to ensure accurate, high-quality PATIENT care cited by so many colleagues will play into it when I can’t get the Canada Post parcel for someone who demands it stat. Maybe, a policy should be struck that makes it abundantly clear that any other “business” on premises of an accredited pharmacy that is not directly involved with patient health care cannot be operated with higher priority than immediate patient care needs for “pharmacy practice” to be effected as is expected under national standards of practice for pharmacists and technicians.
Unless the college puts policies in place that would ensure the employers are giving pharmacists the support staff, adequate working conditions (assistant help and breaks) and increase in salaries ,these additional tasks would just put even more burden on already exhausted pharmacists (>80% of pharmacists feel unhappy with their jobs!) and consequently put public on harm. If I wanted to be a glorified nurse I would have gone into nursing, I really don’t appreciate the addition of the injections for a pharmacist to do.
That’s a shame you feel that way. You should work with your employer to assist you in these changes. And if they don’t agree, find a new job where they do. If it’s chain retail, you’re working there for a reason… You are to blame yourself.
That seems like poorly thought out advice. Why should a pharmacy that does not operate with patient care and safety in mind be allowed to operate that way? Perhaps if the pharmacy owner cannot meet those standards, they should find another line of business like a fast food restaurant.
I like the idea of an expanded scope of practice, but regulations need to be strengthened to regulate the practice environment for this to occur. Pharmacy managers should be mandated to provide adequate staffing to ensure patient safety and care is not compromised, if these services are to be offered. At this point, this is surely not the case, as under staffed and over worked pharmacist are forced to meet “quotas” to bring in profit for the owners/shareholders. Under staffing increases the risk of error and harm to the patient. The current environment has not evolved to keep pace with the increased professional responsibilities and work load.
Pharmacist are very capable health care professional and knowledgeable to carry these tasks and more my suggestion not to add too many restrictions , notifying the primary care of available and off course screening the patient , I think is enough as we saw the success with immunizations and the expanded scope that we have now ( extending and initiating rx). And also in Alberta and other provinces that adopted it already
In order to allow renewing prescriptions for a 12-month supply to work in practicality, it must be tied to reimbursement. Currently, pharmacists are permitted to renew prescriptions for up to 6-months. If you were to look at the data of how often that is actually being done, I would be surprised if you found any pharmacists renewing for >1 month supply. There is no incentive for the pharmacist to take on the risk of renewing a patient’s prescription for such a long duration. Unfortunately, they are consequently referred to their prescriber which is an inconvenience to the patient as well as a cost burden to our healthcare system. By ensuring that this piece of the expanded scope proposal is implemented efficiently, access to medications is enhanced and cost-savings are realized by avoiding an extra trip to the patient’s respective prescriber.
I am so glad you mentioned looking at data. Indeed, data should inform policy. To quote a recent publication titled “Lessons learned from 3 attempts to use data sources to evaluate pharmacist prescribing in Ontario” – the authors state, “Three unsuccessful attempts were made to describe the uptake of pharmacist prescribing by authorizing renewals and adaptations in Ontario community pharmacies. The current available data sources did not allow for an accurate depiction of this expanded role for pharmacists. Renewals were documented much more frequently than adaptations, limiting any description of adaptations. It became evident that pharmacists may not be recording themselves in dispensing software as prescribers. Recommendations for enhancements to the process of documenting prescribing and data structures within existing software are made. Most important, policy makers and advocacy organizations must develop evaluation plans and incorporate mechanisms for data collection before new pharmacy services are implemented.” https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6610502/ I hope OCP can heed the advice suggested in this article.
Very important points are made here, thanks. For one, in order to extend prescriptions, pharmacists can only do so to THE LESSER OF what was originally prescribed, or six months (at present). “What was originally prescribed, including refills,” does not mean add all the refills together into one quantity and dispense it. BUT WHATEVER IS DONE, THE PHARMACIST’S NAME MUST APPEAR AS THE PRESCRIBER and literature reports are showing this is not being done. Why not? You should be aware of these requirements before undertaking them. (Maybe, we need further courses from the OCP when such is authorized, as this is directly related to practice for everyone whereas cannabis for medical use is not). An earlier comment references practitioner limitations to 6 months re ODB, and you know what? How can this not be adequate in extending prescriptions? If a patient has already gone 6 months since seeing the primary care practitioner, by renewing it for another 6 months (under what “patient best interests” argument?) it can become a year until the patient is seen by the original prescriber. Now, to go to 12 months (ONLY if it was originally prescribed for that period, which is rarely done these days as prescribers want to see their patients every 6 months, in part due to their own best practices expectations), we could be allowing a patient to go TWO YEARS without such re-visit. That just is not good practice, nor in the patient’s best interests. AH, YES, there is that phrase the OCP likes to use regularly — so now it’s time to step up and apply it here. Keep it at six months max; there is no justifiable, patient-best-interests rationale to increase this, because a patient can get in to see the primary care provider sometime over a 6 month period. Any real “argument” to extend beyond this can only be attributed to $$$$ motivation ahead of patient care.
All these points are in place and practice in Alberta since 10 years ago or so. Means we are very late in Ontario applying the obvious. When I moved from Alberta to ON 10 years ago I felt restrained. In Alberta we order lab tests, we inject everything, we adapt to a different therapeutic class and we prescribe in emergencies…Let’s get into the 21st century folks. Pharmacists are way more capable of what we are doing right now.
Agree, however our salaries need to be increased to reflect the increase in the workload/liability/responsibility (instead they are steadily declining). As well employers need to provide adequate work conditions to embrace these changes, instead of cutting amount of assistant hours and focusing only on profits and quotas with the total disregard for patient safety or care
I fully support expanding the scope of practice of Ontario pharmacists. This would allow a more seamless, effective and efficient provision of pharmaceutical care and medication therapy management for Ontarians, and bring us more in line with what many other provinces are already doing.
I believe the scope of practice should be expanded only when the college is involved ensuring that patient safety is truly the main concern. For example, no injections in retail when only 1 pharmacist is working without additional support. Let’s allow pharmacist to expand their scope but only in a professional setting before there is an incident and possible harm to the patient because the pharmacist was multi-tasking (ie. giving flu shots or injections in between filling prescriptions and working a cash register). Thank you
As a health care professional, we are responsible towards our patients and with these expanded scopes of practice, we will provide better and more accurate service for our valued patients. I am very happy that we will begin to provide these services soon. It is hard for our patients to be followed up by their doctors on a regular basis. Sometimes they miss their appointments. Sometimes they forget to see their doctors. On the other hand , doctors are very busy and they might miss calling the patients for follow ups. By having these expanded services, we as pharmacists can help patients receive health care services faster and easier.
I totally agree to the Pharmacist Expanded Scope of practice for a better patient care.
Its great idea and recommended to have extended scope of practice for Pharmacist.Which can be very beneficial to reduce healthcare burden as well as to increase patient compliance and conveniency. Its very good step and i would strongly recommed for it. Thanks Kevin
1- I don’t foresee a situation where a pharmacist will need to extend a prescription for a full year, in particular without possessing the ability to properly monitor for effectiveness and safety by ordering certain tests i.e. blood work. 2- The term minor ailments can be offensive to patients, who may not think of their condition as “minor” and which may be causing them a great deal of suffering. It is also belittling to pharmacists because it implies that they only have the ability to deal with minor issues. This term should maybe be replaced with “ambulatory conditions”. Words matter and the devil is in the details. 3-A more appropriate scope of practice may be allowing a therapeutic substitution as this can be helpful in this era of shortages and back orders. It is evident that this will require thorough patient assessment and communication amongst all professionals in the circle of care.
I think this looks great. Keep it smart and evidence-based. Keep it practical. For flu shots 2-5 years I wouldn’t mind some tips / a refresher on how to inject in this age but I’m more than willing to do this. OHIP should pay a bit more for 2-5 years – more time consuming vs adults. I know some pharmacies now “don’t do kids” b/c it is time consuming. We want to prevent that from happening. Point of care – I mean it’s duplication of services. Give us access to labs (recent A1C), much better than giving the patient another prick, ($15-20/test) and getting their A1C, again. Medscheck- make the cut off way higher than 3 meds. Make it 8-12 meds. Only the complex people who really need it get it. Not the 52 year old stock broker who is on 2 BP meds and a statin. Also, Anytime there is a DTP (drug therapy problem) caught and faxed to the doctor, this is where the big value to the system is, and this is what should be paid for. How to do this I don’t know exactly. Increase Pharm opinion to $20 and get rid of a lots of Medschecks is a start. Minor Ailments – love it. Don’t re-invent the wheel every other province does it just copy the best one. Don’t waste public dollars too much. Minor Ailments- A good primer on Diagnosis (sensitivity/specificity/likihood ratios, ect) should be considered since RPhs will truly be using these skills.
Unless the pharmacist themselves are reimbursed for their services and supported and protected against corporations and pharmacy owners than these should NOT be implemented
Many comments have rightfully been aimed at the “business” and personal pharmacist impact aspects of expanded scope proposals. It has always been a dilemma for pharmacists to enhance their professional role while working within the constraints of the current practice/business (renumeration) model. This too must change. Pharmacy professionals must find a better way to concurrently lobby for the required health care system changes – actually a challenge for all health care professionals these days! Simply saying “no” to changes which enhance our professional role is simply shooting ourselves in the foot! Find the right way to make needed change happen. Lobby harder with OPA, CPhA to effectively represent our profession and with both the federal and provincial governments for changes to better support pharmacists in making the best use of their expertise. It is not easy but it can be done!!!
Allowing pharmacist to prescribe minor ailments will be a great step towards engaging pharmacy profession into healthcare. A pharmacist will be able to use the clinical knowledge to its most extent. Moreover it will be beneficial to patient not getting enough care from walk-in clinics and emerge.
That’s a very good approach to include above expansion of scope for us in Ontario. I recently moved here from Saskatchewan where we already had this scope of practice. As per my experience, patients were appreciative towards prescribing minor ailments and getting injections in the pharmacy, and prescribing interim supply to satisfy their urgent need rather than going to doctors office. It would not just save their time but also doctors workload. Doctors can focus on more complicated things rather than small issues like refills, cold sores and other minor conditions. Apart from this, there is no purpose of medscheck in Ontario as it is just business in the pharmacy rather then having actual care. We can not see patients blood test results so there is nothing to check in minor ailments. In Saskatchewan and Alberta, we could actually check their lab results and that was the reason why it was “actual” med review there. Patients were so happy and satisfied after knowing their results as doctors don’t show them. All in all, i would rather spend money on minor ailments, interim supply and injections than on med reviews and naloxone kit. Naloxone kit is schedule 3 in alberta and Saskatchewan. I still don’t understand why government here paying money for that thing. So my request would be please stop medscheck program and spend our money in fruitful things which is actually helpful to patients.
Actually, Naloxone and its salts when used for opioid emergency is national schedule II and so is available OTC through discussion with a pharmacist in determining appropriateness of sale in the individual circumstances.
I completely agree with this comment. What is even more baffling is that hospital pharmacist in Ontario for years are given access to patient data and can order blood work. There is fairly robust data that demonstrate patient and economic benefit. The framework is there, pharmacist education is there. Giving access is mostly a bureaucratic issue. The only other barrier to these expanded scope is the elephant in the room: mandatory assistant hours AND to reimburse pharmacies appropriately. We can force a company or corporation to follow these minimums but if it stops becoming financially feasible, and entire industry with collapse.
1. In a busy retail pharmacy setting, it is difficult to vaccinate everyone who wants a flu shots in a timely manner. Children between ages 5-10 usually take longer to give a flu shot due to injection fears, especially when there is no nasal spray flu vaccine. While waiting for parents to help calm down their children, the workload for pharmacists continue to grow as retail pharmacists are expected to check and prepare prescriptions, counsel on prescriptions, and answer OTC questions at the same time as giving flu shots. Allowing pharmacists to give flu shots to children age 2 and up will just add to the workload and stress that pharmacists experience. Retail pharmacy is currently not the most appropriate place for flu shots for young children. Most counselling rooms/waiting areas are small and not really equipped to handle an emergency. There will be greater concerns if we are to give flu shots to children starting at 2 years. At the same time, the retail pharmacy environment is also changing where there is less and less help for pharmacists year after year. It will not be safe to give flu shots to very young children in this type of retail environment. 2. If we are allowed to order or at least view/interpret bloodwork results, it could be ok for pharmacists to renew prescriptions up to a year. If we cannot access this information, then pharmacists should not be allowed to renew prescriptions for that long.
I believe that collège have to regulate or control the help (tech or assistant)that the pharmacist should have during his shift . Nowadays , many pharmacies are processing a lot of daily prescriptions but they keep cutting hours for the tech so they keep their profit . So it is pure business.For sure , pharmacist won’t be able to give suitable patient care or enough time for each patient to address all his concerns . So I believe before adding more responsibility to the pharmacist or expending the scope , we should assure the availability of enough help or staff , so care can be delivered in his best picture . For example , they can relate the number of RX to the staff working during this shift . 100rx = at least 1 pharmacist + 1 tech
As a community pharmacist, my main objection lies with the proposal to lower the minimum age for influenza vaccines from 5 to 2 years. Working in a busy pharmacy I just cannot imagine having to deal with such young patients. Most parents already come with their children for vaccinations believing that the non medical office like setting will make it easier on their reluctant kids to receive ” a needle.” I just cannot even imagine the added stress when dealing with such young patients. Most pharmacies are inadequately equipped and staffed to properly perform current duties pertaining to vaccine administration. If OCP is serious in its mandate in protecting the public then they should perhaps legislate minimum staff that is required to be on hand to adequately support the pharmacist performing these additional duties. As to point of care testing, I personally have not come across a great need in the community for this. Similarly, with the ability to extend prescriptions for up to a year. At some point in time, these patients should be seen by their primary care health care professional to have appropriate blood work done. Again, from my personal experience this has never been an issue.
I want to follow-up on your statement: “If OCP is serious in its mandate in protecting the public then they should perhaps legislate minimum staff that is required to be on hand to adequately support the pharmacist performing these additional duties.” I completely agree with this – however, OCP will never do this. They historically claim they are not getting involved in the business of pharmacy. Yes, their business is patient safety, and if workload / employee workplace conditions affect patient safety – they should/must weigh in. They choose to not do so. In fact, their indifference to this issue can be noted in their Apr 2018 letter to the MOH when commenting around pharmacists being exempt from the ESA – https://www.ocpinfo.com/library/consultations/download/LtrMinistryLabourESAFollowUpApril2018: “It should further be noted that the College does not have a role to play in the business structures in pharmacies, except that which is governed under applicable legislation (e.g. the Drug and Pharmacies Regulation Act, 1990), the Code of Ethics, standards of practice and College policies. Other than general information regarding where pharmacists work, the College does not collect information on, nor have any regulatory role related to, hours of work, remuneration or other business or employment-related conditions or benefits. As stated in our original submission, the College recommends that the Ministry consider the feedback of other organizations focused on the business models of pharmacy that could help provide guidance to avoid any unintended consequences – such as reduced access to quality and timely pharmacy services – associated with removal of, or modification to, any of the current exemptions under the ESA applicable to pharmacists.” What a dance!
As the Ontario government will only pay for up to 6 months on ODB, I feel that a full year of authozation allowed by a pharmacist is beyond what a doctor might find agreeable without his prior consent. We have to have doctors on our side and not appear to be taking away his or her authority on drug extensions. We only need 6 months maximum if a patient is going out of country and the doctor is not available.
While I think most of the proposed amendments could benefit a lot of patients, I worry about staffing levels and workload as others have mentioned. I worked retail for many years and 2 years ago moved into a hospital setting and I think it’s an issue on both sides. When workload is too high and the pressure to work faster increases, more errors are bound to happen. I have no doubt that the many amazing pharmacists we have in Ontario would utilize this enhanced scope of practice to the betterment of patient care, IF there was enough staff and therefore time to do so. Unfortunately for many I just dont think that’s the case currently.
I support expanded scope of practice for pharmacists, but regulations need to be strengthened to regulate the practice environment so that it is safe and confidential for patients. It should be mandated that pharmacists use a private counseling room to provide professional services. Patient confidentiality and care is compromised when these services are provided in areas not conducive to care. So called semi-private counseling booths allow other people to walk up and listen to what are supposed to be private conversations. Also, interruptions can increase the risk of accident or injury for procedures that require concentration such as injections. Additionally, pharmacy owners, directors, and managers should be mandated to provide adequate resources such as staffing and private counseling rooms to ensure patient safety and care is not compromised. Understaffing pharmacies increases the risk of error and harm to the patient. As scope has expanded, the work environment has not evolved to keep pace with the increased professional responsibilities and work load. Without these measures, expanded scope could be taking place in an environment that places the patient at risk and compromises care.
I totally agree with your comments.
We don’t have the staffing for what we are doing Presently. Much as this would be appreciated years down the road ….. this is not the time. The public will be put in harms way if so much more need to be done with inadequate time or staff. It may be good for business money wise but for the working pharmacist ( majority of us ) it is more stress and putting the public at risk….
Expanded scope of practice is an successful initiative that has always proven to be beneficial to patients in almost all cases. Most of the key points listed have been practiced in other provinces and have been greatly successful.
This is it? We should also talk about remuneration while we’re having this discussion. Free vaccine injections is already demeaning enough. I would think that we’re at the point where pharmacist-prescribed medications would be the norm.
I became a pharmacist because I didn’t want to be a doctor or a nurse. Seems like we are going to be expected to be all that and more. How exactly are we going to be paid for all the extra services that we are going to be providing? Who is footing this bill? OHIP, private insurance plans, patients or independent pharmacy owners? Do we get an OHIP billing number? What about conflict of interest?
100% agree with all you said. I didn’t go to Med school and I am not trained to diagnose. Full stop
I totally agree with my colleagues that we don’t have the tools to make those things happens. We don’t have Access to blood work to assess if medications such as diabetic pills or cholesterol pills work enough or need an adjustment. We don’t have the time to do pharmacist job and doctor job together. Are these changes going to save money for the health care system? Are doctors going to receive a cut on their pay because we as pharmacist are doing their work ?
I totally agree. How will we be compensated for all of this? Or will it be the corporations we work for that will be compensated (like flu shots) and we will just be expected to fit this into our already overloaded schedule. Regulations must be in place for pharmacist compensation as well as safe work practices, such as proper staffing and pharmacist overlap.
As pharmacists gain the ability to renew prescriptions for longer durations and continue to enact the ability to adapt prescriptions, I feel it also becomes important to not just perform POC tests but order labs. Results such as electrolytes, creatinine, eGFR can help the pharmacist decide safety and parameters for continued prescribing or need for referral back to primary care provider. Furthermore, tests such as TSH and FT4 are also important if patients are on thyroid replacement long term and should be assessed annually. Testing INR and PTT for patients on anticoagulation would be deemed appropriate not just for POC but continued monitoring. Also, taking into consideration the growing demographic of diabetic patients requiring medication renewal and prescription adjustment, the ability to order an A1c and random glucose levels may be merited. The use of CBC to determine efficacy of iron replacement and vitamin B12 levels can help reduce use of ineffective therapies or unnecessary therapies. I also propose that pharmacists have the ability to order drug levels such as lithium, divalproex and phenytoin (as well as albumin) if renewal of a prescription is required as these medications do have safety parameters built in to the drug level ranges that can help with decision making if a prescriber cannot be reaches for further consult. Furthermore liver panel tests may be necessary if there is concern that a drug may be causing liver injury, however if this is suspected, a referral to hospital would be required.
This is an interesting point. OCP/the regs will need to be very clear about whether performing a point-of-care test is essentially ordering a lab test. For example, lets take INR monitoring as an example. Should a pharmacist be allowed to do a point-of-care test for an INR, but not be allowed to order an INR through a standard requisition where a patient can take it to the lab. It may actually be better if the INR testing is done via the lab, as then those results are available for multiple providers on OLIS. Also, OCP needs to be clear on where the POCT can be done- and perhaps offer flexibility. If a point-of-care INR test was needed- in theory, that can be done by the pharmacist at a pharmacy; by a pharmacist on a home visit for an elderly patient at the patient’s residence; or by the pharmacist in a primary care team practice. I really hope that OCP doesn’t “chain” these new scopes to a community pharmacy. Aren’t we “chained” enough as it is as pharmacists by corporate agendas?
I had the exact same thought when reading about the proposed prescription extensions. We will need to be able to order lab testing to ensure safety/efficacy for several medications. However, we also should have access to lab testing. We really need a provincial system that gives pharmacists access to lab requisitions!
Totally agree with colleague the need to full access to lab reports. Great ideas in increasing ease of testing or ordering tests… but let’s start with what is in place already. Some pharmacists through strong relationships do have access to labs but it should be mandated across the board to best serve our customers.
As a passionate and engaged pharmacist, I wanted to provide 3 pieces of feedback re: https://www.ocpinfo.com/wp-content/uploads/2019/08/August22_2019_Council_Materials_For_Website.pdf 1. Harmonization of pharmacist scope across sectors It is really important that OCP ensure that the legislation allows that pharmacists in all sectors of care – community, primary care team, hospital, LTC – have harmony in scope of practice. This is a real problem for hospital pharmacists, and pharmacists working in hospital-affiliated clinics (e.g. me), where full scope is not possible. (still can’t prescribe drugs for smoking cessation independently – though part of the Pharmacy Act, seems to be superseded by the Public Hospitals Act). I am quite troubled about the potential for establishing a tiered scope of practice for pharmacists across sectors. I don’t see how this is in the public’s best interest, and as a front-line pharmacist, it appears to me that OCP hasn’t had any meaningful efforts to bridge this gap over the years. How does one fulfil their stated mandate to protect the public, if at vulnerable transitions of care, pharmacists aren’t fully empowered to act in the interest of patient safety? I truly don’t understand OCP’s inertia on this issue. 2. Re point-of-care testing. OCP has not specified which point-of-care tests would be within scope in the Council materials I reviewed. There’s a range of available point-of-care tests, with different purposes (e.g. screening of disease; diagnosing a medical condition; medication monitoring, etc.) Some examples of point-of-care tests include a. Group A Strep tests for sore throat (buccal swab with rapid antigen detection) b. Pharmacogenetic test kits c. A1C tests d. INR tests e. And a whole host of others including lipids, influenza, H pylori etc. https://www.pharmacists.ca/cpha-ca/assets/File/news-events/Point-of-care%20screening%20programs%20in%20community%20pharmacy%20practice_Papastergiou_DN_Final.pdf OCP may need to consider 1. Not all of these tests are reputable (eg. False positives/negatives). You must be aware that the Nova Scotia College of Pharmacists spoke out about inappropriateness of POC strep testing – https://www.cbc.ca/news/health/do-not-rule-out-strep-throat-in-pharmacy-tests-nova-scotia-1.4930840 2. Some of these tests potentially put the pharmacist in the position of making a diagnosis (which is a controlled act) 3. Some of these tests may be unnecessary 4. Some of these tests may be duplicate (with no way of pharmacists knowing). I remember having a patient at our clinic that had an A1C done at a lab, then also got a point of care A1C test 2 days later at a community pharmacy- quite inappropriate. 5. Some of the pharmacy chains have corporate relationships with the makers of the POCT that may put pharmacists in a position of conflict of interest (e.g. pharmacogenetics tests) 6. In some other provinces I’ve seen pharmacists advertise on Facebook that patients can get a strep test and if they pay $15 they can get store “reward points” – seems a bit troubling. OCP needs to take a stand on possible business practices that incentivize point of care tests, especially as it is not clear or likely the Ministry will reimburse pharmacists for these tests. My feeling is that OCP needs to specify which point of care tests pharmacists should be allowed to do and to ensure that it doesn’t fall into the realm of the controlled act of “diagnosis.” 3. Education While I am still dumfounded that OCP Council imposed mandatory cannabis education, I hope that mandatory education for new scope is not imposed, and pharmacists can self-determine need based on their practice. If the discussion around “more training and education” comes up at Council, I hope that people who have a conflict of interest with respect to education (e.g. the faculties) recuse themselves from this as they may stand to profit from mandatory education. (I was disappointed to see that the faculties didn’t do so when the mandatory cannabis education discussion came up at Council). Thanks for considering.
I cannot agree enough with this person’s comments. I strongly urge to review them and take them into consideration when making any decisions about scope of practice.
Whilst, this may be a good step forward, it definitely needs a lot more thought. It is already hard enough administering injections to 5 or 6 year olds, you spend more than 5-10 minutes in the counselling room fighting to get them to sit still and at the same time a bunch of other patients are sitting outside waiting and wondering why their rx, their flu shot, their counsel or their questions are taking too long to attend to. This coupled with the busy winter season at the pharmacy and the understaffing that is too frequent of an occurrence now at retail pharmacies will definitely put patients at risk. How do you expect to increase the workload and services provided without tackling the issues of staffing? The corporations will never increase the hours or overlap time with the increase in services. Working in a pharmacy that does 350 rxs a day with no overlap (and having everything finished by the end of the shift), this increased scope is not feasible. Not to mention, how do you expect us to renew rxs in up to a year supply when we don’t have access to blood work to assess efficacy of the medication? The ministry definitely needs to think this through more thoroughly before throwing it out there. It’s enough we don’t even get any breaks (food or washroom) breaks during a pharmacy shift as is.
I agree with the comment on understaffing. The Institute for Safe Medication Practices (ISMP) has identified reduced staffing levels, increasing workload, and distractions as key factors that contribute to errors. The link below from an ISMP bulletin details some aspects of these issues: https://www.ismp.org/sites/default/files/attachments/2018-02/ISMP_AROC_whole_document.pdf By not addressing these systemic issues, the College is failing in its mandate to protect the public.
In some states, the ratio between pharmacists and regulated pharmacy technicians (RPT) is regulated- https://en.m.wikipedia.org/wiki/Pharmacist-to-pharmacy_technician_ratio I would like to quote this study authored by Dr Zubin Austin and his colleagues- “While it is difficult to accurately define an “appropriate staffing ratio,” most participants in the study suggested that a ratio of 1:1:1 (pharmacist:RPT:assistant) with a daily prescription volume of 150 to 200 seemed reasonable..” https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5958432/ The OCP needs to use their regulatory authority to look at staffing as it relates to ability to practice to full scope in the patient’s best interest.
I see OCP recently released this report – https://www.ocpinfo.com/wp-content/uploads/2019/09/AIMS-data-snapshot-september-2019.pdf Some of the data here has to be a call to action for OCP to address staffing and working conditions… one would think. Is the environment really ready for “full scope” that can be done safely?
I ageee that the harmonization of OCP is absolutely necessary.
I agree with the harmonization of OCP
(1) I very much agree with this pharmacist’s comments regarding a “tiered scope”. Pharmacists working in hospitals are currently limited by the Public Hospitals Act. This forces pharmacists to rely on “medical directives”, “policies” or other approaches to fulfill acts that are well within our expanded scope, but not yet acknowledged by the Public Hospitals Act. The need for these additional policies/directives limits the widespread implementation of these practices, particularly within small hospitals and underserviced areas. By advocating for the Public Hospitals Act to be amended, rather than relying on local policies, a more standardized approach will be adopted across Ontario. There is even further confusion with regards to pharmacists working in Family Health Teams and other collaborative care settings that are not affiliated with a hospital. These pharmacists are left with little guidance as to what falls within their “scope of practice”. It is imperative that OCP acknowledge that many pharmacists do not work in a traditional community pharmacy role – and advocate for these practitioners as well. (2) I am concerned that the ability to perform POCT is being presented prior to offering pharmacists access to laboratory data (ex: via OLIS). As outlined by the above comments, this can result in duplication of efforts (and potentially a difference in management strategies). Many lab values need to be interpreted in the context of trends and other relevant information. Although I do feel that providing pharmacists with access to lab values will improve medication management, I am concerned that allowing for POCT in isolation does not achieve this goal. (3) In my opinion, flu shots are a purely technical task. There is very little clinical decision making that goes into the administration of a flu shot. The “decision making” that does occur could easily be standardized with a checklist. We have made significant efforts to move away from our technical role of dispensing, and in my opinion administration of flu shots is simply another technical task that detracts from our ability to provide superior patient care. I would suggest that OCP consider looking into allowing RPhTs to administer flu shots. (4) I am concerned about extending the authorized refills to a maximum of 12 months. There are very few chronic conditions that do not require additional monitoring within that year timeframe. For example, if a pharmacist orders a POCT HbA1c and refills the patient’s metformin, who is assessing for neuropathy? Who is monitoring the patient’s renal function? Is the pharmacist taking the time to perform a proper BP assessment as part of the encounter? Until the pharmacy-model changes significantly (ie enabling pharmacists the opportunity to conduct 30 min private appointments), this patient is likely missing out on additional care. Most physicians use their prescribing as a means to ensure that the patient returns to the clinic for follow-up. I understand the value in short-term refills to allow for continuity of care, and I do believe that pharmacists have the knowledge to provide exceptional medication management, however in the vast majority of cases the current workflow is not conducive to this model.
Being understaffed all the time, with lots of distractions especially in busy Pharmacies there is no room left for taking another unnecessary responsibility of giving injection to 2 year-old as it needs way more attention, focus than adults. Pharmacists are being burnt-out and instead of putting extra pressure , we could put policies in place making sure they get enough support and get enough help, then we could expand scope of practice. Thanks everyone