Feedback deadline was: November 20, 2017
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:
Comparison: Current Regulation to Proposed Changes (blackline version)
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.
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.