Feedback deadline was: May 24, 2021
Summary
Virtual care in pharmacies is an emerging area of practice that is being facilitated by advancement in technology. As an emerging practice area, and in line with the College’s Policy Review Process, a new Virtual Care policy has been drafted that outlines the practice expectations for registrants providing care to patients using virtual approaches. A comprehensive review of pharmacy regulatory authorities across Canada and of health professional regulators in Ontario, alongside a review of privacy legislation and guidance from external organizations, has informed the development of this new policy.
The Ontario College of Pharmacists (OCP) is currently seeking feedback on the draft Virtual Care policy. The College is inviting all pharmacy professionals, pharmacy stakeholders, and members of the public to comment. Following the consultation, the final draft Virtual Care policy will be brought forward for approval by the Board in June 2021.
The Virtual Care policy reflects the profession’s commitment to patient care and recognizes that virtual care in pharmacy practice pertains to interactions outside of common and accepted practice models that use telephone-based communication.
Providing care to patients virtually requires that healthcare professionals consider certain factors such as maintaining a patient’s right to privacy, the appropriateness of using a virtual approach to care, and ensuring the same quality as in-person care is provided. The policy outlines these expectations and rests on the principle that the benefit of providing care virtually must outweigh any risks to the patient.
See the draft Virtual Care Policy
Questions to Guide your Feedback
- The purpose of drafting this policy is to provide pharmacy professionals with direction on the College’s practice expectations when providing virtual care. Does the draft policy achieve this purpose?
- Is the draft policy clear? For pharmacy professionals, is it comprehensive enough to support your practice? In what ways might the clarity and/or comprehensiveness of this policy be improved?
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The current draft of the virtual care policy is comprehensive and overall is a good start on the approach to implementing an official policy regards to providing virtual care for pharmacists in Ontario. As a licensed pharmacist who had been conducting Annual, Diabetic, and At-home Medschecks (all in the homes of our Pharmacy’s patients) full-time prior to the covid-19 pandemic for several years I believe the following amendments can assist in improving the policy for both the College and its Members: 1) Currently as of March 2020 the requirements for Ontario Medschecks are: “…only continue to be provided where medically necessary for the patient’s understanding of their medications AND to resolve urgent medication management issues (e.g significant change to their medications after hospital discharge) -As the situation in Ontario improves with regards to the pandemic and the year progresses; my proposal is this policy should be amended to ” Continue to be provided where medically necessary for the patient’s understanding of their medications AND/OR to resolve urgent medication management issues (e.g significant change to their medications after hospital discharge) This will allow the resumption of Medschecks to be conducted virtually now for all patients who are eligible for one and have not received a Medscheck in almost 2 years where it is clinically and practically appropriate for the patient. 2) Clarify signature requirements for specific services: The current virtual care policy draft states that “Documentation requirements remain the same whether pharmacy services are provided to a patient in-person or through a virtual visit”. For the Ontario Medscheck program which requires many pages of paperwork to be signed during the appointment, how and when are we expected to obtain the patient’s signatures (IE: can we e-mail them to be signed after the meeting or does a 3rd-party software need to be used to ensure signatures are obtained during the meeting)? Thanks for your time and I look forward to reading the finalized policy.
Virtual Care Policy 1. Re: Current Definition `Virtual Care: a professional interaction between a registrant and a patient that occurs remotely using an enabling technology, such as videoconferencing, text messaging, web-based and mobile applications, that facilitate registrant-patient interaction. In pharmacy, virtual care pertains to clinical activities beyond the regular interactions that occur with patients using a telephone.’ Concern with current definition Virtual Care Definition should include telephone in addition to videoconferencing, text messaging, web-based mobile applications, as this is also an enabling technology for professional interaction between a registrant and a patient that cannot occur in-person (e.g. remote pharmacist services, homebound patients, patients in communities without a community pharmacy). Suggested amendments to Virtual Care Definition: Virtual Care Revised Definition: A professional interaction between a registrant and a patient that occurs remotely using technology such as videoconferencing, text-messaging, telephone, web-based and mobile applications to enable and facilitate registrant-patient interaction that may not occur in-person. In pharmacy, virtual care does not pertain to regular professional interactions that occur with patients using a telephone as a convenience when in-person communication is possible. 2. Re: Informed Consent Current statement: `Registrants must document that they have received consent to deliver virtual care and the mechanism used to provide virtual care in the patient’s record. ‘ Concern with the statement above: Virtual Care may be provided in hospital or in the community. Does the patient record refer to the pharmacy software system, the hospital electronic health record or primary care provider health records? Clarification is required. 3. Re: Maintain Privacy and Confidentiality Current statement: `Registrants must provide virtual care in a private environment that ensures patient information is not overheard or seen by others. Communicating this to patients, as well as confirming that they are also in a private environment, is advised.’ Concern with the above statement: Virtual Care can be provided in the hospital setting where patients may not be in private rooms. Also, partners/caregivers are often involved/present when providing virtual care to patients during virtual visits. Suggest amend wording to: When possible, registrants must provide virtual care in a private environment that ensures patient information is not overheard or seen by others not involved in the patient’s care. Communicating this to patients, as well as confirming that they are also in a private environment (if possible), is advised.
How would we facilitate virtual care if the patient does not have access to the right technology? My understanding is that without facilitating the technological support it would limit to a certain group of people and visualization will not be in broader aspect.
Hi, For the section, “Maintain Privacy and Confidentiality” how would video applications such as Facetime or Whatsapp Video call be classified? A lot of the older demographic has a hard time starting a Zoom or MS Teams video call, whereas FaceTime is much more intuitive. Would the current policy support FaceTime use ? (or any similar video messaging/call app)
policy achieved the purpose
I disagree with the virtual care policy because it would eliminate the open door relationship between the patient and the pharmacist. The only people who would benefit from the virtual care are the big corporation.
The ability to provide c consultation in a variety of methods is necessary and a step forward for the profession. Younger patients will demand a different style of consultation that is aligned with their use of technology and this policy brings us closer to being to meet these coming expectations.
As a pharmacist I am finding no problem in implementing this policy but it should be more clear in terms of explaining what services included, how long a consent is valid and if it’s a verbal consent then what will be the other acceptable measures to verify patient authentication. Also there are other details mentioned in above comment. In this pandemic situation virtual care providing is sometimes unavoidable such as patient doesn’t want to wait they need hospital discharge follow up, my counselling room is already occupied due to vaccination or any other reason and pharmacy counter is not providing enough confidentiality even having separators due to glass shields, masks and face shields the communication is very difficult so of course if patient consent, virtual care is really nice solution.
Virtual care can not replace the conventional way to provide health care services to patients. However, due to the pandemic, the virtual care here will be beneficial to both the patients and pharmacy staff.
I disagree strongly with the concept of virtual care in pharmacy. It’s not needed as pharmacists are highly accessible and it will open a door for eliminating more jobs and breaking the bond that pharmacists gave with their patients.
“draft virtual care policy” – I believe that the policy does achieve expected purpose. I also think that is it clear & comprehensive. I have nothing to add for improvement. Thank you.
The draft is clear . I personally believe that in person care is much more effective than virtual care . Perhaps it’s a safer way during the pandemic time . But over all , phones are more private than virtual care . Most patients who can not come to the store are elderly who will not find it easy to cope with the technology. I believe the phone conversation is second to in person service
With respect to Draft Virtual Care Policy, I think we can practice this in limited cases where the person can not be physically available e.g. bed ridden. It is also hard to provide medication reviews by virtual care in comparison when providing our consultation in person.
The Virtual Care policy seems to focus on informed patient consent, privacy and confidentiality as safe environment. However it is not clear as to whether on not pharmacists will need to register to become a Registrant or is this the responsibility of the pharmacy owners? What type of services will be applicable or allowed virtually? Will pharmacist have access to patient profiles, test results or electronic health records, if the patient is not a client of the pharmacy in question? Who will pay for this service? Is this only to facilitate patients during the pandemic or is this a new reality for pharmacies and pharmacists? Will this include e-mails and telephone services and how will this be incorporated in the pharmacy workflow? What type of patients will be eligible? The policy need to be more clear and comprehensive, regarding training for pharmacy staff; quality of care expectations and issues regarding continuity of care.
I believe virtual care is no better than providing consultation in person. Virtual care might be ok in limited cases when patient is not able to come to pharmacy at all , mostly bed ridden. Virtual care should just be restricted and only if absolutely needed to provide only counselling advice and not to provide medication reviews. Providing medication review is an in depth time demanding process and it makes all sense to provide only in person that creates confident environment for both patient and pharmacist.
how is this proposed regulation different than providing patient care over the phone?. in my opinion the only difference is the visual.,which does not require new regulation.
Re: Section, “assess appropriateness of virtual care delivery”. For those pharmacists whose practice involves supporting a specialist’s clinic, the authority to determine if a patient should have virtual vs in person visit is not given to the pharmacist, it is determined by the specialist leading the clinic and the patient. The language in the current version states the pharmacist must assess the appropriateness but does not have the authority to do anything about it in that practice setting.
This is a very reasonable policy. I foresee no problems regarding its implementation
I don’t believe that virtual care is in the best interest of the patients. It removes the relationship part out of care and opens the doors for system abuse. Pharmacist is the most accessible health care professional and in rare cases when a patient is home bound we can provide care over the phone. In majority of cases it’s the elderly who are unable to come in person and they won’t benefit from technology heavy virtual care. I also think that it’s detrimental to the profession itself- it will allow big corporations to cut more jobs and create more mail-in orders from big processing centers that again take the relationships out of the equation,
Hello, I like the idea of virtual care .. With eveything going virtual now .. I think it’s more convenient for everyone to do it in pharmacies .. It will save more time and lessen the chances of transmitting infectious diseases but has to be done with a way to keep patient’s confidentiality !