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Proposed Changes to the Pharmacy Act (Registration and Quality Assurance)

Feedback deadline was: November 20, 2017
Summary

This consultation is now closed.

The College is currently seeking feedback on proposed amendments to the Pharmacy Act Regulations that, if approved, would update the College’s approach to registration and quality assurance. The regulations, if enacted, will allow for a more efficient registration process and an enhanced approach to quality assurance in the interest of patient health outcomes and safety.

The proposed amendments will assure greater transparency to the public, streamline the registration process, and improve accountability by:

  • Implementing an Intern Pharmacist and Intern Pharmacy Technician class of registration;
  • Incorporating pharmacy technicians into the quality assurance regulations;
  • Eliminating unnecessary steps in registration; and
  • Shifting from an hourly reporting of practice to a self-declaration of competency in conjunction with practice assessments.

In accordance with the Regulated Health Professions Act, the proposed changes are being circulated for 60 days to members and stakeholders for comment. A consultation report, including a summary of feedback, will be presented to Council for consideration in December 2017.

Before providing your feedback, you are encouraged to review the following:

Proposed Pharmacy Act Regulation

Pharmacy Act: General Regulation Revision Framework

Comparison: Current Regulation to Proposed Changes (blackline version)


Background

The provisions of the Regulated Health Professions Act [s. 29(1)] provide the authority for students who are not registered with a College to practice to the scope of the profession under supervision, while enrolled in an education program. In preparation to these proposed regulations, the Drug and Pharmacies Regulation Act (DPRA) was updated to align with the intended approach:

The DPRA [s. 149 (1)] (once proclaimed) will read (sections c and d updated):

Dispensing of drugs

….no person shall compound, dispense or sell any drug in a pharmacy other than,

a) a pharmacist;

b) an intern acting under the supervision of a pharmacist who is physically present;,

c) a student who is in the course of fulfilling the educational requirements to become a member of the College, acting under the supervision of a pharmacist who is physically present; or

d) a pharmacy technician or an intern technician acting under the supervision of a pharmacist who is physically present.


Common Questions

Why are these amendments important?

The amendments will implement a new class of intern registration for pharmacy technicians, incorporate pharmacy technicians into the quality assurance regulations, and eliminate unnecessary steps in the registration process. Member reporting will shift from an hourly reporting of practice, to a self-declaration of competency in conjunction with practice assessments.

These changes will permit all registered members to practice while in training under supervision. In addition, a yearly self-declaration of competence is a more relevant self-assessment approach than simply counting and reporting practice hours.

How do the proposed changes to registration protect the public?

The College’s registration practices are fair, transparent, objective and impartial. Applications are processed in a timely manner, and without unnecessary delay. Decisions about the suitability of an applicant to become a member of the College are made in the interest of public safety, and based on the applicant’s knowledge, skill and judgement and ability to practice according to the standards of the profession.

Why was the class of ‘registered pharmacy student’ removed?

Registration as a student has become an unnecessary registration requirement due to changes in the education programs over time. As with other health professions, the Regulated Health Professions Act has provisions to permit students to practice while in an education program, and recent changes to the Drug and Pharmacies Regulation Act allow these provisions to apply to pharmacy students as well.

As a student, will I be able to engage in the full scope of pharmacy practice if I am not registered with the College?

The provisions of the Regulated Health Professions Act [s. 29(1)] are sufficient to permit students to practice while training, and the amendments to the Drug and Pharmacies Regulation Act allow both students and interns to practice within the full scope of pharmacy, while under supervision. Changes to the registration process based on the amended regulations will be communicated well in advance of implementation.

What is the two-part register?

Part A of the register is for members who provide patient care, while Part B is for members who do not provide patient care but wish to maintain registration with the College.

Will Pharmacy Technicians have a two-part register?

Yes, for consistency, the register is expanded to incorporate pharmacy technicians who will be able to register in either Part A or Part B. Those parts will be further defined for technicians as the proposed regulations are implemented. Changes will be communicated well in advance of implementation.

Have language proficiency and conduct requirements changed?

The regulations have been streamlined to emphasize outcomes in these areas. Policies and guidelines will be developed to communicate specific requirements and how members will be expected to meet them.

Language proficiency is an important element in providing excellent care to patients, and a member must be able to demonstrate language proficiency that allows them to practice to the standards established by the profession, both at entry to practice and throughout their practice career.

Similarly, it is in the public interest to require applicants to demonstrate they will practice with honesty and integrity. The provisions within the regulations that address findings of guilt, current proceedings, and offences and conduct have not been changed, but consolidated to remove redundancies. A declaration of good character will continue to be required upon the annual renewal of a certificate of registration.

What changes have been made to the Quality Assurance provisions?

The components of the Quality Assurance Program within the regulations are already stated at a high level, reflecting the requirements of the Regulated Health Professions Act; therefore, few changes are required in the proposed regulations to remove specificity, reflect outcomes, and support a new program design.

Why were practice hour and time frame requirements removed and replaced with a requirement to demonstrate competence through a practice assessment?

The assessment of a member in the work place is a better measure of competency than simply requiring a member to note a number of practice hours. This approach is in line with the College’s focus on providing members with practice advice and support to improve practice.


 

Read The Feedback
41 COMMENTS
  • Other - POSTED September 28, 2017

    The 2 part designation for technicians is long overdue. However I do feel that the number of practice hours should be incorporated with the practice assessment.

  • Other - POSTED September 28, 2017

    Having just recently completed the SPT myself with little benefit from it, I agree with the amendments to the act. For someone who has years of experience in pharmacy already, forcing a pharmacy technician candidate to complete a certain numbers of weeks/hours as part of their training can be more a hindrance than a help. I also believe that the 12 week SPT training is too short for someone who only has college education and very little working experience in pharmacy. There is no minimum amount of hours one must complete before feeling competent. By eliminating the hourly reporting of practice, It puts the onus on the individual to truly self reflect on their knowledge and whether they feel they can safely practice. I do have concern that this may allow more candidates to get licensed sooner than they should and lack the experience to work to their full scope safely. The SPT program for technicians needs a complete overhaul. Allow the preceptor and preceptee to assess their progress more freely and come to a consensus on how long the training should be. Allow the preceptor to notify the college when they feel the candidate is fully competent to be licensed. The preceptee should not only be judged on their knowledge, but also their attitude. Completing all of the assignments provided in the SPT correctly does not mean the individual should be allowed to practice if they have poor relations with the clientele or their colleagues. Having the correct attitude towards patient care is more important than knowing everything, and I personally do not want to be cared for by people who are only in the field for the money.

  • Other - POSTED September 29, 2017

    These are fantastic ideas and properly reflect the different roles in the pharmacy. Next it would be nice to have the OCP acronym encompass technicians as well: Ontario College of PharmacY. It’s a good idea to have students and interns ‘practising’ what they will be practising so that they have realistic exposure well before having full licensure. Part B technicians is a smart move. Lastly, a practice assessment is a much more accurate reflection of how a technician is keeping current in their profession compared to assuming that practise hours corrolate with practise quality. Excellent.

  • Other - POSTED October 5, 2017

    re. the PT intern position, would that allow the independent technical double-check to be under direct supervision ? Might be difficult to directly supervise that task without a full "triple-check" by the preceptor, as is currently done.

  • Other - POSTED October 5, 2017

    All proposed changes are excellent. I especially approve of the recognition of students (Intern/Intern Technician) as they move forward in the profession, allowing them to practice within their scope of practice under the direct supervision of a pharmacist. Those of us who work in other pharmacy related fields are looking forward to Part B registration. Great Job!

  • Other - POSTED October 5, 2017

    I think this would be great! It would let everyone work in their scope. As of right now as a register tech, I don’t get to use my whole scope on a daily basis.

  • Other - POSTED October 5, 2017

    In daily routine for community Pharmacy workflow, control and narcotics receiving, ordering and verbal prescriptions authority should be extended to Pharmacy Techs. It helps immensely to handle the workflow professionally where pharmacists are the sole authorized designation in Pharmacy who are adhered to century old practice to delegate this tasks, whereas Pharmacy techs have full abilities to perform this tasks excellently. It will free up time for pharmacists to focus their clinical work more attentively, and will give better platform for techs to provide their practice if scope.

  • Other - POSTED October 5, 2017

    Fully agree with the 2 part Technicians. I fall into both categories in 2 separate roles though. Definitely need the Part B in the role I hold in Information Technology where I help support 15 hospitals’ pharmacy departments from the back end side of things in regard to their computer software, drug formularies, rules, and many other tools/applications. The Intern designation is also good for those not quite registered but in process of doing so. There are limitations we need to set on their positions within hospital pharmacy to maintain to proper privileges and preferences given to their positions.

  • Other - POSTED October 5, 2017

    Language proficiency requirements need to be improved. I have been part of OSCE’s & OSPE’s where I cannot understand what the candidate is saying. This puts the public at risk if they are unable to understand the pharmacist or tech. It is one thing to pass a written language proficiency test, but it is quite another to be able to make yourself understood and understand what a patient is asking.

  • Other - POSTED October 5, 2017

    It would be beneficial to see Pharmacy Technicians practice as interns seeing as the scope of practice for both Pharmacists and Pharmacy Technicians are expanding. I believe this will also result in a closer working relationship and compelete trust between both the Pharmacist, Pharmacy Technician and other colleagues and will better serve the public. This will also better prepare Pharmacy Technicians that are taking their pebc exam because they’ll have had a chance to experience what their scope of practice is from experience rather than what’s been taught from a text book. It has been my experience from the whole registration process as a technician that it hasn’t felt very ‘hands on’. I would have appreciated having the ability to practice as a technician throughout the registration process to better allow me to challenge the exam and become comfortable with the scope of practice to better serve the public. It will allow Technicians to feel more comfortable asking questions and receive the proper training on how to handle consultations, product training (glucometers, blood pressure machines, inhalers, etc) meds checks and gathering information for best possible medication histories. Another issue is that many out of school will work in only hospital or community practice settings and I feel that PEBC and OCP needs to implement some kind of cross training program between the two categories so that anyone who is taking the exam can have the proper knowledge of both practice settings. With the fees that are being paid to challenge the exam there needs to be more resources made available to applicants. The cost of the pebc exam is just outrageous. Thank you for your time I’m very excited to see how these changes will become implemented and what it means for Pharmacy Technicians and the impact it will have.

  • Other - POSTED October 6, 2017

    Looking forward to changes, as every change is for the better. The assessment of a professional is at its best while on the "job" , hence the intern position is for sure a welcome concept. The Part A and B if on par with the idea of "patient care" is something to be looked at very carefully, as has been noted pharmacy technicians tend to get too focussed and miss the frequent updates in the pharmacy. Hence number of practice hours should be incorporated with the practice assessment.

  • Other - POSTED October 6, 2017

    In Part III does section 10. (2) include all pharmacists now practicing, or only those seeking registration or re-registration? (Unclear).

  • Other - POSTED October 10, 2017

    I agree on improving language competency for both pharmacists and pharmacy technicians. I don’t agree on changing the registration from the number of hours to self-reporting competency. We have too many assessments already- way more than any other profession. We have a learning portfolio, practice visits from the College, and the exam. It is disruptive to the practice and personal life and it is demeaning to the professionals. If an individual practices a certain number of hours and there are no complaints logged against him or her- it should be sufficient for re-registering.

  • Other - POSTED October 10, 2017

    Thank you for continuing to make positive changes in the name of patient safety. This is clearly a much needed update.

  • Other - POSTED October 10, 2017

    I fully agree with the proposed changes. I would add to self declaration and workplace assessment a quarterly, well designed, mandotry CME with focus on minor ailments, continuous quality assurance for medication safety, patient interviewing, travel and adult vaccines, expanded scope of practice, smoking cessation, diabetes prevention, opioid guidelines and deprescribing, etc. We want to take the profession into new highs to meet challenges the system encounters by the current and future demographics.

  • Other - POSTED October 10, 2017

    These changes are necessary as we work to expand the role of the Pharmacist to better meet the needs of the public and support our health care system. Providing a structured method to regulate the skillset of our partners in the dispensary as well is important to support these changes. Ideally as we move forward we need to work towards a dispensary workflow process that only incorporates regulated Pharmacy Technicians and Pharmacists. Non regulated dispensary personnel need to be phased out of the dispensary over the short term.

  • Other - POSTED October 10, 2017

    looks like an open door … for a " nurse practitioner" ……to "directly prescribe"

  • Other - POSTED October 10, 2017

    I agree with most of the proposed amendments to the Act .I think it is necessary in the face of current changes to pharmacy practice and the emphasis on patient focused care.To fully implement the expanded scope of practice expectations , there is need to free up more time for the pharmacist I agree that the student registration is no longer relevant .Also Language competency for technicians , interns and newly registered pharmacists is a good idea . Will the proposed assessments for registered Interns and Technicians mean they will be able to do more than they do now ?will they be mandated to get Liability Insurance?

  • Other - POSTED October 10, 2017

    I think it is a good idea to change the process from hourly to self declaration.

  • Other - POSTED October 11, 2017

    "practice hour and time frame requirements removed and replaced with a requirement to demonstrate competence through a practice assessment" I’m not clear on what the above means, in practical terms? Is it a yearly declaration of competence? Does it mean pharmacists and technicians have to complete yearly practice assessments? I found the wording vague. The other changes proposed seem reasonable to me, and are in line with changes in pharmacy education in Ontario.

  • Other - POSTED October 11, 2017

    I agree with simplifying the registration process and elimination of unnecessary steps. I hope other requirements are also simplified while maintaining quality and maintaining the professional respect to both pharmacists and technicians.

  • Other - POSTED October 16, 2017

    As a former Registrar I am usually reluctant to comment on College proposals; however, I feel the need to share my concerns/thoughts respecting the proposals relating to the QA program. My primary concern is that the College is using the same staff person during a visit to the same pharmacy- to perform both a compliance-based inspection under the DPRA and then a QA assessment under the Pharmacy Act. Notwithstanding the creation of ‘˜firewalls’ to separate the two functions, I believe that using the same College Practice Advisors, to perform inspections relating to operational standards (per the DPRA) followed by contemporaneous QA assessments (per the Pharmacy Act) which are educational, remedial and non-punitive- create perceptions that are misleading to members, and may raise questions of appropriateness. The Health Professions Procedural Code (S.83) is clear that information gathered under Quality Assurance is confidential, not to be shared with any other committee or program area of the College; in my view, using inspectors to conduct quality assurance assessments may create problems for the College, and the practice should be reconsidered. I also believe that the proposed regulation needs to include more details regarding what the new components actually are/will be. As example, a required component of any QA program is a Peer Review process. Since College staff are not peers, I think provisions need to be made in the proposal to include such member/peer interactions, as part of the details. I agree that too much detail may preclude flexibility, but would suggest that enough particulars respecting the program and its components need to be included to ensure the components and integrity of the QA program are maintained and continued going forward, in compliance with the statutory requirements

  • Other - POSTED October 13, 2017

    I do not have any objections to the proposed changes.

  • Other - POSTED October 13, 2017

    For international pharmacy graduates……. 1. While it is imperative to ensure that language proficiency is up to standard for each member in order to effect proper communication in the workplace, it is an unnecessary step for pharmacists whose FIRST language is English to have to sit a Test of English exam in order to complete the registration process. Consideration should definitely be given for this step to be eliminated or modified. Instead, monitoring could be done by preceptors at the initiation of the PACE program. If any "triggers" (defined by NAPRA) are detected then recommendation could be made for that individual to do such testing or to complete a recommended course to sharpen use of the English language (depending on the level of incompetency detected). 2. Modify the requirement for the Bridging Program so that it is mandatory after 3 failed attempts at the Qualifying Exams (instead of after the first attempt). Failing at the first attempt is not a strong enough indicator that an individual needs this kind of intervention. For an individual who would like to re-sit the exam right away, the bridging program, while having its advantages, reduces such individual’s focus on some core areas that this exam covers and lengthens the time period for a pharmacist to complete registration and be fully functional.

  • Other - POSTED October 16, 2017

    i agree with the proposals

  • Other - POSTED October 16, 2017

    Looking forward to proposed changes.I strongly fill that two part registration allows pharmacy technicians to perform their duties in fuller capacity.

  • Other - POSTED October 16, 2017

    I have a number of questions regarding this– will pharmacy assistants who have been working at the pharmacy for over 15 years also have to be registered as technicians? A lot of them are very proficient due to experience and that would be a hardship for them . Secondly —– PACE is great for those students who have already had practice in community pharmacy. I strongly feel that 3 weeks working in a pharmacy prior to registration is just not enough experience to working as a pharmacist in Ontario. At least 6 months experience in working in community pharmacy is important prior to PACE.

  • Other - POSTED October 17, 2017

    I agree on the proposed changes for both Pharmacists & Technicians.

  • Other - POSTED October 20, 2017

    I have no objections to the proposed changes

  • Other - POSTED October 23, 2017

    I am in favour of these changes. It’s very difficult for pharmacy technician applicants who do not hold a certificate of registration to practice and to be hired as an "intern level" of their profession and is long over due. I like the idea of keeping practice hours in place instead of an assessment and that the pharmacy technician would have the option to choose part A or part B.

  • Other - POSTED October 23, 2017

    I like to make registeration process simple and remove unnecessary steps . Improving Language competency is very important to any professional working with customers . I like to stick to hours of working rather than self reporting .

  • Other - POSTED October 30, 2017

    I like to make registeration process simple and remove unneccary steps . Improving language competency is very important I like to stick to hours of working than self reporting .

  • Other - POSTED October 30, 2017

    I appreciate the college’s attempt to provide a better patient care to public along with protecting their safety by CQA and CQI programs. But some points are not very clear to me. How the CQA would determine the actual prectice hours of a pharmacist ? One pharmacist may have a clean record of no occurrence of incident while working for 40 hours a week, and one pharmacist may have the same clean reacord by not working at all or by working less than the present requirement of practice hours . I encourage the college to implement a well developed CQA which should respect the pharmacists, protect the profession of pharmacy as well as safe guard the public health by safe handling of medications.

  • Other - POSTED November 1, 2017

    I think the new changes are relevant to the current scope of practice. I still feel that the bridging program has multiple deficiencies in helping International practitioners transition into the Canadian practice. This is especially true when I compare and contrast between the PharmD for pharmacists and the IPG program.

  • Other - POSTED November 3, 2017

    The proposed changes to the Pharmacy Act regarding Registration and Quality Assurance would be good but would every Pharmacist in the Province be assessed ? I had noticed with the old Quality Assurance program not all Pharmacists in the Province were assessed.I hope the new changes would be fair to everyone.

  • Other - POSTED November 6, 2017

    I would fully support the proposed changes to the Pharmacy Act.

  • Other - POSTED November 10, 2017

    I agree with the proposed changes. I am wondering how it will work for individuals who have not had a practice review in their work. There could be many reasons why someone was not there when the college does their review of the work place. How is the college planning to handle this? How often does this have to happen?

  • Other - POSTED November 13, 2017

    I’d like to know more about the practice assessment element. Will this assessment be modified for different practice settings? For example, will technical questions be matched to the pharmacist’s clinical area of practice? My practice site and day to day activities are different from a community pharmacy practice and while I agree that we all use similar skills, it would not make sense to me to assess my competency with the same clinical questions.

  • Other - POSTED November 15, 2017

    I agree with most of the proposed changes, but would recommend that the simple term "intern" be amended to be "intern pharmacist" for clarity.