Feedback deadline is: 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.
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