The Ontario College of Pharmacists believes, just as other regulators and health system organizations do, that solutions to the opioid crisis and the misuse of narcotics in our community necessitate multi-jurisdictional collaboration. As such, the College has engaged health system stakeholders to ensure that opioid issues are addressed in an interprofessional manner, given that the delivery of care is multifaceted and involves many healthcare providers.
For example, the College has and will continue to work with partners through the Provincial Opioid Emergency Task Force, the Centre for Addiction and Mental Health’s opioid-related committees, the National Association of Pharmacy Regulatory Authorities (NAPRA), the Prescription Monitoring Leadership Roundtable and Health Quality Ontario’s Opioid Partnered Supports Table.
As well, last fall the College announced it’s Opioid Strategy, which highlights specific priorities and areas of focus for the profession of pharmacy to contribute to system-wide efforts aimed at curbing the impact of this crisis on our communities. As a specific focus of the Strategy, the College has further reinforced to pharmacy professionals our expectations related to the management of controlled substances and their responsibilities related to the standards of practice, provincial and federal laws, regulations, and our Code of Ethics.
Furthermore, the College has cooperative relationships with Health Canada’s Office of Controlled Substances and the Ministry of Health and Long-Term Care to support our respective regulatory roles related to the oversight of narcotic management in community pharmacies. The relationship with law enforcement agencies is equally important as we work with them on investigation-related matters and collaborate in communicating the role of pharmacy professionals in loss prevention strategies.
The role of assessments in promoting quality pharmacy care
The College’s pharmacy assessments are an important component of our quality assurance program.
During a community pharmacy assessment, a College practice advisor reviews the pharmacy’s operations. The assessment is designed to confirm that the pharmacy is adhering to operational standards, with practice advisors reviewing a pharmacy’s records to determine that it has the proper processes and procedures in place to operate safely. The College’s pharmacy assessments are also part of a cooperative approach with other regulatory agencies that together are focused on maximizing quality and safe pharmacy care while minimizing risk to the public.
In response to the opioid crisis, College practice advisors now place a greater focus on reviewing narcotic reconciliation processes with pharmacy managers to ensure that they fully understand their professional and legal responsibilities and obligations related to the management of narcotics under their control. And starting next year, practice advisors will be conducting more detailed reviews and analyses of a set number of narcotic prescriptions to complement the audits already performed by other agencies.
This greater focus will involve reviewing a random sample of narcotic prescriptions to confirm that pharmacies can demonstrate their full compliance with operational standards for each of the prescriptions reviewed. It also includes reviewing evidence that each of these prescriptions can be accounted for and that all other standards of practice expected of the profession have been satisfied.
This additional emphasis will better identify potential gaps in processes or procedures, help strengthen coaching opportunities for pharmacies to ensure that they are in compliance with standards and expectations, and contribute to our ability to identify potential red flags that would warrant further follow up and action by the College.
The College’s pharmacy assessments are not designed to audit or perform a reconciliation of a pharmacy’s narcotic inventory. The responsibility to inspect and confirm a pharmacy’s compliance with federal Narcotic Control Regulations (NCR) rests with Health Canada. Through a cooperative relationship with Health Canada, the College may receive information uncovered through an inspection that can lead to the initiation of, or support an existing, investigation.
Unlawful conduct by any pharmacy professional is not acceptable
As health professionals, pharmacists and pharmacy technicians are held to a high standard and accordingly are considered stewards of the public trust. They play an important role in a patient’s care and his/her quality of life and have, and will continue to, contribute to our health system in positive ways.
The deliberate misuse of narcotics by pharmacy professionals is considered an abuse of professional privilege and a breach of the public trust. This type of conduct compromises the reputation of the vast majority of pharmacists and pharmacy technicians who provide quality, safe and ethical care to their communities and cannot be tolerated. Allegations of professional misconduct are taken very seriously and the College will investigate all such allegations and will act accordingly to protect the public, up to and including revocation of a professional’s license.
Those who engage in unlawful conduct often put great effort into concealing their behaviour. That’s why the College relies on information reported to us from law enforcement, other regulatory agencies such as Health Canada, the Ministry of Health and Long-Term Care, health professionals and members of the public so that we can become aware of, and subsequently act on, any unusual or concerning behaviour.
That’s also why reporting concerns to the College is so important; anyone can file a report or initiate a complaint at any time. Every report and complaint is thoroughly and impartially investigated.