Expanding Scope of Practice

Feedback deadline is: October 26, 2019
Summary

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:

  1. Administer the flu vaccine to children as young as two years old;
  2. Renew prescriptions in quantities of up to a 12-month supply;
  3. 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.

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.
Background

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.

Leave a Reply

Your email address will not be published.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

Leave a Comment

Your email address will not be published.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

Reply via email   

Read The Feedback
80 COMMENTS
  • pharmacist - POSTED August 26, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Mount Sinai Academic Family Health Team
    • pharmacist - POSTED August 28, 2019 REPLY   
      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.
    • pharmacist - POSTED September 5, 2019 REPLY   
      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.
      • pharmacist - POSTED September 8, 2019
        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.
      • pharmacist - POSTED September 11, 2019
        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.
  • pharmacist - POSTED August 26, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 12262680849
    Organization name : Family Health Team
    • pharmacist - POSTED August 27, 2019 REPLY   
      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?
    • pharmacist - POSTED August 27, 2019 REPLY   
      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!
      • pharmacist - POSTED August 29, 2019
        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.
  • pharmacist - POSTED August 27, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 4165778211
    Organization name : none
    • pharmacist - POSTED August 31, 2019 REPLY   
      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?
      • pharmacist - POSTED September 7, 2019
        100% agree with all you said. I didn’t go to Med school and I am not trained to diagnose. Full stop
      • pharmacist - POSTED September 11, 2019
        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 ?
  • pharmacist technician - POSTED August 27, 2019 REPLY   

    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.

    YOU ARE A :
    ON BEHALF OF : Myself
    Phone Number (optional) : 6479233569
    Organization name : Rexall
  • pharmacist - POSTED August 27, 2019 REPLY   

    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….

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 7057376500
    Organization name : Sdm
  • pharmacist - POSTED August 27, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 416-917-0361
    Organization name : None
  • applicant - POSTED August 27, 2019 REPLY   

    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.

    YOU ARE A : Applicant
    ON BEHALF OF : Myself
    Organization name : Self
    • pharmacy technician - POSTED September 1, 2019 REPLY   
      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.
  • pharmacist - POSTED August 27, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Loblaw
    • pharmacist - POSTED August 28, 2019 REPLY   
      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!
  • pharmacist - POSTED August 27, 2019 REPLY   

    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

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Community pharmacy
  • pharmacist - POSTED August 27, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Rexall
    • pharmacist - POSTED August 31, 2019 REPLY   
      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.
  • applicant - POSTED August 27, 2019 REPLY   

    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.

    YOU ARE A : Applicant
    ON BEHALF OF : Myself
    Phone Number (optional) : 7059707152
    Organization name : Myself
  • pharmacist - POSTED August 27, 2019 REPLY   

    Unless the pharmacist themselves are reimbursed for their services and supported and protected against corporations and pharmacy owners than these should NOT be implemented

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Independent
  • pharmacist - POSTED August 27, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 2899835489
    Organization name : n/a
  • pharmacist - POSTED August 27, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : None
  • pharmacist - POSTED August 27, 2019 REPLY   

    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

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : N/A
  • pharmacist - POSTED August 27, 2019 REPLY   

    I totally agree to the Pharmacist Expanded Scope of practice for a better patient care.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Soljay Pharmaceuticals
  • pharmacist - POSTED August 27, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Loblaws company
  • pharmacist - POSTED August 28, 2019 REPLY   

    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

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 902-403-4081
    Organization name : Indigenous Services Canada
  • pharmacist - POSTED August 28, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : North York Family Health Team
  • pharmacist - POSTED August 28, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Costco
    • pharmacist - POSTED August 29, 2019 REPLY   
      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
  • applicant - POSTED August 28, 2019 REPLY   

    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.

    YOU ARE A : Applicant
    ON BEHALF OF : Myself
    Organization name : None
    • pharmacist - POSTED August 28, 2019 REPLY   
      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.
    • pharmacist - POSTED August 31, 2019 REPLY   
      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.
  • pharmacist - POSTED August 28, 2019 REPLY   

    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

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Main st Centre Pharmacy
  • pharmacist - POSTED August 28, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 7054984808
    Organization name : Janzen's Pharmacy
  • pharmacist - POSTED August 28, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : N/a
    • pharmacist - POSTED August 29, 2019 REPLY   
      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.
      • pharmacist - POSTED August 30, 2019
        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.
  • pharmacist - POSTED August 28, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Neilson Pharmacy
    • pharmacist - POSTED August 29, 2019 REPLY   
      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.
      • pharmacist - POSTED August 31, 2019
        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.
  • pharmacist - POSTED August 29, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Pharmacist
  • pharmacist - POSTED August 29, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 6478627728
    Organization name : One Eva Pharmacy Inc.
  • pharmacist - POSTED August 29, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Pharmasave
  • pharmacist - POSTED August 29, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : NA
  • pharmacist - POSTED August 29, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Self
  • pharmacist - POSTED August 29, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Elliot Lake Family Health Team
    • pharmacist - POSTED August 29, 2019 REPLY   
      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.
  • pharmacist - POSTED August 29, 2019 REPLY   

    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….

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 6479685545
    Organization name : Cornwall Community Hospital
  • pharmacist - POSTED August 29, 2019 REPLY   

    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

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : myself
  • pharmacist - POSTED August 29, 2019 REPLY   

    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 .

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 9055512523
    Organization name : pharmasave 9717
  • other - POSTED August 30, 2019 REPLY   

    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.

    YOU ARE A : Other
    ON BEHALF OF : Myself
    Phone Number (optional) : Welsford
    Organization name : hhs
  • pharmacist - POSTED September 1, 2019 REPLY   

    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 .

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Loblaw pharmacy
  • pharmacist - POSTED September 1, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : I speak on behalf of myself. If you want to know which organization I work for, it's public information on your site
  • applicant - POSTED September 1, 2019 REPLY   

    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.

    YOU ARE A : Applicant
    ON BEHALF OF : Myself
    Organization name : Applicant
  • pharmacist - POSTED September 2, 2019 REPLY   

    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

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 6476077728
    Organization name : Myself
  • pharmacist - POSTED September 2, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : High St Guardian Pharmacy
  • pharmacist - POSTED September 3, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : myself
  • pharmacist - POSTED September 3, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 18074686321275
    Organization name : Sunset Country Family Health Team
  • pharmacist - POSTED September 3, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : St Joseph's Healthcare
  • pharmacist - POSTED September 3, 2019 REPLY   

    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?

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Pharmacist
  • pharmacist - POSTED September 3, 2019 REPLY   

    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

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Anonymous
  • pharmacist - POSTED September 3, 2019 REPLY   

    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://pharmsquality.com/gphc-asks-pharmacy-bodies-to-show-how-theyre-tackling-staffing-issues/ https://www.tandfonline.com/doi/abs/10.1080/13698575.2011.558624 https://www.pharmaceutical-journal.com/opinion/comment/the-pharmacy-regulator-must-take-a-role-in-ensuring-minimum-staffing-levels-if-it-is-serious-about-patient-safety/20205482.article?firstPass=false 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).

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Mount Sinai Academic Family Health Team
    • pharmacist - POSTED September 7, 2019 REPLY   
      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?!?!?
      • pharmacist - POSTED September 11, 2019
        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.
  • pharmacist - POSTED September 6, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Pharmacist
  • pharmacist - POSTED September 6, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : none
  • pharmacist - POSTED September 6, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : nka
  • pharmacist - POSTED September 6, 2019 REPLY   

    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.)

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Mount Sinai Academic Family Health Team
  • pharmacist - POSTED September 6, 2019 REPLY   

    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).

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Mount Sinai Academic Family Health Team
  • pharmacist - POSTED September 8, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Medical Arts Pharmacy
  • member of the public - POSTED September 11, 2019 REPLY   

    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?

    YOU ARE A : Member of the Public
    ON BEHALF OF : Myself
    Organization name : The Right to Choose
  • pharmacist - POSTED September 11, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Mount Sinai Academic Family Health Team
  • member of the public - POSTED September 11, 2019 REPLY   

    Yes. I agree with the changes. The pharmacy professionals are trained doctors and have extensive knowledge that should be utilized .

    YOU ARE A : Member of the Public
    ON BEHALF OF : Myself
    Organization name : None
  • pharmacist - POSTED September 11, 2019 REPLY   

    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).

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Organization name : Mount Sinai
  • pharmacist - POSTED September 13, 2019 REPLY   

    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.

    YOU ARE A : Pharmacist
    ON BEHALF OF : Myself
    Phone Number (optional) : 6473508553
    Organization name : Weston care Pharmacy

Leave a Reply

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

Leave a Comment

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

Reply via email