Feedback deadline was: November 22, 2024
Summary
The College is seeking input from registrants, members of the public and system partners about proposed By-Law updates during a 60-day open consultation which closes on November 22nd at 4pm. The proposed updates address changes in regulations, application of gender-neutral language, changes or additions to administrative fees, and updates to the public register, as well some minor housekeeping revisions that do not change the intent of the By-Law or introduce new provisions.
Summary of Proposed Changes
The key changes proposed include:
Harmonizing the By-Law with General Regulation (O.Reg 256/24) under the Pharmacy Act, 1991
- To align with General Regulation O.Reg 256/24, which comes into effect on October 1, 2024, By-Law changes are required to update terminology and classes of registration.
- The introduction of a two-part register (Part A and Part B) for pharmacy technicians also requires the addition of associated registration fees.
Gender-Neutral Language
- To demonstrate our commitment to equity, diversity and inclusion, and to help ensure our communications are clear and focused on content, By-Law changes propose removing superfluous gendered language.
Fee Changes
Several administrative fee changes are proposed including:
- Requiring payment of outstanding cost orders or fees as a condition of registration renewal. This change is expected to improve collection rates on outstanding accounts, particularly when registrants seek to continue to practice.
- Introducing cost recovery for registrant cancellation of routine practice or operational assessments with less than six weeks’ notice. This fee is based on the costs associated with last-minute cancellations and informed by advice from the Office of the Fairness Commissioner. It would apply to a second or further instance of late cancellations without reasonable cause.
- Introducing a cost recovery for additional assessments or inspections resulting from non-compliance with policies or standards. This fee would help cover the costs of the extra assessments or inspections and may act as a deterrent to non-compliance with policies or standards.
- Increasing fees for the Jurisprudence, Ethics and Professionalism exam. Since the pandemic, the cost of administering the exam has tripled, and this fee—which is consistent with the low end of what other regulators charge–will help recover those costs.
- Introducing a registration and annual renewal fee for Part B pharmacy technicians. Pharmacists in Part B are already subject to registration and renewal fees that are 50% of the fees required for pharmacists listed in Part A. For consistency, this new fee would introduce a registration and renewal fee for Part B pharmacy technicians that is 50% of those required for Part A pharmacy technicians.
- Introducing a fee for registrants who are required to complete an assessment when transferring from Part B to Part A of the register. This fee would recover a portion of the costs associated with a PACE assessment and required administrative procedures.
Quality Improvement
- Removal of the reference to a pharmacy’s narcotic signer from the public register. The inclusion of this information is unique to Ontario, is not required due to federal authority, and results in unnecessary administration.
- Adding temporary pharmacy closures of four days to three months to the public register. The public and other system partners rely on the public register as a source of real-time information about the status of operation of a pharmacy, and requiring pharmacies to notify the College about prolonged closures would help ensure that appropriate actions to assume responsibility for managing and securing drugs and/or patient records are taken.
Housekeeping
- A number of other minor housekeeping changes are being proposed that relate to numbering, section titles, deletion of outdated references or updating of terminology that do not change the intent of the By-Law or introduce new provisions.
Supporting Documents
To provide further details, we’ve put together a summary chart of proposed changes along with their rationale.
You may also refer to proposed By-Law No. 7 with tracked changes, or a clean copy of proposed By-Law No. 7.
A copy of the briefing note from the September 16 Board meeting is also available.
How You Can Participate
Pharmacy professionals, system partners, and members of the public are invited to provide feedback on the proposed By-Law changes by November 22, 2024, at 4pm. Your input will help inform any potential changes to the By-Law that are presented to the Board for approval in December 2024.
The feedback we receive is published in accordance with our Posting Guidelines.
Jump To:
This response was submitted by OPA. Read the full submission here.
I don’t believe a pharmacist signing on behalf of the patient will improve workflows. Let’s be realistic- assistants are the core of Pickup station. You can’t expect to call the pharmacist over every time this needs to be signed. Getting the Id and/or signature is enough. Secondly, gender neutral language is inappropriate for a medical environment. I will refuse to do this as I need gender in order to make sure therapies are safe and effective for my patients. If a patient has a specific pronoun they tell me to refer them by, that is fine, but this is completely unnecessary to implement. OCP should be focusing their efforts elsewhere.
I do not agree with adding more costs to pharmacy technicians. The fee’s we pay are already far greater than others in similar professions and our wages are lower by comparison.
Harmonizing the By-Law with General Regulation (O.Reg 256/24) under the Pharmacy Act, 1991 – Agree with changes Gender-Neutral Language – If this refers to OCP’s communication with its members then yes. – If this refers to pharmacy as a profession communicating with the public then no as gender can play a large role in how healthcare is safely administered to patients (ie. meds with potential negative effects on female reproductive system, etc.) Fee Changes -Yes: payment of outstanding fees. Jurisprudence (only if OCP demonstrated that they have made effort to explore lowering cost to administer the exams in good faith). – No: additional assessments due to non-compliance (may encourage assessors to issue more non-compliance results to increase revenue) -No: cancellation of routine and operation assessments. “Reasonable cause” not clearly defined and could unfairly punish those that had legitimate reason but reason not accepted by OCP as “reasonable”. Quality Improvement – Yes: removing narcotic signer note on public register. – Yes: notifying the public of closure of pharmacy for 4 days to 3 months. Housekeeping – Yes
I am agree with changes and not agree to increase the fee.
The November 19th comment about signing for narcotics — not sure where this is coming from. From what I read in the proposal, the move is to just delete identifying “signing authority” on the OCP website, etc. This has nothing to do with the requirements of the NSAA and requirements at pick up of a prescription; some confusion appears to be present here. Since the CDSA regulations define who can order narcotics, and the wording has morphed over the years to not require the pharmacist who ORDERS the narcotics to be the same as the one who RECEIVES the order in the pharmacy, then any licensed pharmacist is authorized to order narcotics (unless restrictions appear on their licence from past administrative actions). Again, this is regulatory and has nothing to do with additional information that the OCP has previously put on the public register, after having required that under the By-Laws (a provincial decision). The ordering, receipt, records, etc. for controlled substances is a FEDERAL matter. The turning over of the prescription medication is provincial under the NSAA in terms of signatures, identification, etc. that are set out as mandatory in that piece of legislation.
Suggested changes: 4.17.2 – (a), (b), and (c): fails to be, or is not available, without cause …. 5.2.1 – If two-thirds … communications facilities as permit all persons.. – ‘permit’ should be plural; the subject of the clause is ‘facilities’ not ‘means’ 13.1.2: (c) is repeatedly unavailable to participate … 15.12.21: The date of re-opening after a temporary closure should also be noted. 18.5.2: (b) after the above assessment, is found … – comma after ‘assessment’ 18.5.5: … fee for any cancellation or missed second or further practice assessment … – replace ‘missing of a’ with ‘missed’ 19.6.1: … pay a cancellation fee/missed appointment fee for any cancellation or missed second or further pharmacy operations’ assessment … – replace ‘missing of a’ with ‘missed’ – possessive (use of apostrophe) for ‘operations’ assessment’ Consider consistency in use of ‘with respect to’, ‘in respect of’,
Good comments made about the concern over the “need” for gender-neutral language when it comes to a medical/health profession. One person has pointed out the significance of the medical field requiring this in order to assess idiosyncracies that may be relevant to treatment. Good point.
Only have one part I wish to provide feedback on: I believe that the party should still sign for narcotic pick-up – I would amend it to a signature, self or agent ( specify agent ), date – specifically remove ID – this is where the true delay in processing through a Rx at the counter. When there is a dispute regarding collection of a narc or control and or a balance of this meds – the signature provides a great deal of authentication that indeed it was collected etc
ONMMS is a good system in place. It’s a good idea to remove one more layer of ID requirement at the pick up.
I don’t believe that having an agenda item on including gender-neutral language is what the OCP should be focusing on right now their efforts on right now. The OCP is regulating pharmacists, an already gender neutral term! And as a member of the LGTBQ community, I find the change in language totally unnecessary – it has nothing to do with the college’s primary functions and as I said before, is not a priority given all the issues and challenges pharmacy professionals are experiencing at this time. On another note, I try think that removing the narcotics signer is a good idea, any pharmacists should be able to sign for them – a good way to reduce administrative burden on staff.
I greatly support the proposed changes in regulations, application of gender-neutral language, changes or additions to administrative fees and updates to public register. All these things will help getting bigger steps in the progression of our pharmacy profession with better shinning future .
I don’t support gender neutral language. Because we need to know the gender for many things. Without gender how to know pregnant or breastfeeding. Are we asking this to everyone? How to calculate kidney function, dose for some treatments based on gender. This is not acceptable in medical field.
Good day, 1. If they remove the requirement altogether it’s easier for us to verify the pharmacist (one less step to verify and no going back and forth with the pharmacy because they are adding someone to our sheet that doesn’t have that authority as per OCP). 2. If there is still the requirement for signing authority, but they don’t show it on their site anymore, then we would need to know how we are supposed to know it (i.e. is the authority just given by the pharmacy themselves and therefore we just need their letter showing who they approve to sign, or is the authority still given by OCP, in which case we would have no way to verify it). Thank you.
As a pharmacist, I propose that the Accreditation Committee be empowered to oversee Drug Preparation Premises (DPP) licensing and inspections, with the ability to appoint a specialized DPP subcommittee as needed. Importantly, this DPP subcommittee would report directly to the Accreditation Committee, ensuring that all decisions and actions are aligned with the standards and priorities set by the Accreditation Committee, without requiring oversight from the board. Key Points: Accreditation Committee as the Central Oversight Body: The Accreditation Committee should have the authority to manage all aspects of DPP licensing and inspections. This ensures that the same standards of excellence and safety applied to pharmacies are extended to DPPs. Authority to Appoint a DPP Committee: The Accreditation Committee will have the ability to appoint a DPP-specific subcommittee, if necessary, to address the specialized nature of drug preparation oversight. This subcommittee would operate under the direct authority of the Accreditation Committee and not the board, streamlining accountability and decision-making. Direct Reporting Structure: The DPP subcommittee, if appointed, would report directly to the Accreditation Committee rather than the board. This ensures that the Accreditation Committee retains full control over DPP-related decisions, maintaining consistency in oversight and avoiding unnecessary layers of bureaucracy. The Accreditation Committee would be responsible for guiding the subcommittee, approving their actions, and ensuring alignment with the overall regulatory framework. Flexibility and Specialization: This structure allows the Accreditation Committee to maintain flexibility—if DPP operations require specialized expertise, the subcommittee can be appointed. However, the committee is not permanent and would only be used when necessary, making the regulatory structure more efficient. Consistency in Standards: By ensuring that the DPP subcommittee reports directly to the Accreditation Committee, we maintain consistency in standards across both pharmacies and DPPs. This allows for coherent decision-making processes and ensures that all aspects of drug preparation meet the same high regulatory sta Thank you
I do not support gender neutral language (this is a medical field! Gender matters and so does grammer)