- Controlled Drugs and Substances Act (CDSA)
- Food and Drug Regulations, G.03.002
- Narcotics Safety and Awareness Act (NSAA)
Definitions
Controlled Substance: A substance listed in the schedules to the Controlled Drugs and Substances Act (CDSA), including narcotics, controlled drugs, benzodiazepines and other targeted substances.
Monitored drug: Controlled substances, any opioids that are not controlled substances, and any drug product designated by the Minister of Health as per the Narcotics Safety and Awareness Act.
Background
Controlled substances are regulated by federal legislation under the authority of Health Canada’s Controlled Substances Directorate and the Drug Strategy and Controlled Substances Programme. The Office of Controlled Substances (OCS) works with other federal departments (such as the Canada Border Services Agency), provincial and territorial agencies (such licensing authorities for medicine and pharmacy) and law enforcement for the purposes of protecting public health and safety by minimizing the diversion of controlled substances for illegal use.[1]
Provincially, Ontario’s Narcotics Strategy promotes the proper use, prescribing and dispensing of monitored drugs to help reduce the misuse, addiction, unlawful activities and deaths related to these medications. The Narcotic Safety and Awareness Act (NSAA) permits the monitoring, analyzing and reporting of information related to the prescribing and dispensing of monitored drugs via the Narcotic Monitoring System (NMS).
The NMS alerts pharmacies of potential issues such as as patients who obtain prescriptions for a monitored drug from more than one prescriber or from more than one pharmacy. NMS also alerts pharmacies when a prescriber has notified the Ministry about a previously identified forged prescription for a monitored drug and/or stolen prescription pad. Ideally, proper use of the system also helps reduce unlawful activities involving controlled substances, such as double-doctoring[2] and forgery[3].
Suspected forgeries
When there is suspicion that a prescription may be fraudulent, the pharmacy should attempt to retain the prescription. If its authenticity cannot be confirmed before the “patient” requests to have their prescription back, if possible, create some documentation on the prescription itself. For example, complete missing patient information (e.g. demographics, allergy status, drug plan, etc.) or add the pharmacy’s contact information (handwritten or using an ink stamp). This action itself could thwart an attempted forgery, or if the individual takes the prescription elsewhere, the other pharmacy will be alerted to the suspicion of its validity.
Once a forgery is identified or confirmed
- Use a delaying tactic to stall for time. This generally frustrates perpetrators who are usually in a hurry and do not want to come back. Even if they do not seem rushed, waiting a long time or having to return later may make them abandon their attempt, thinking that the forgery has been detected.
- Notify the police.
- Use the emergency number 9-1-1 if the suspect is still in the pharmacy and advise the operator that the suspect is at the pharmacy and that there is a forgery in progress.
- If the suspect has left, report the offence to your regional non-emergency police number. Advise the police if the suspect is expected to return to pick up the prescription so they can arrange to be present. Some police service websites will accept fraud reports via online reporting.
- Do not attempt to physically restrain the suspect. This jeopardizes your safety, and possibly the safety of your staff, patients, and customers.
- Make note of the suspect’s description and, in the event the suspect leaves, note their direction of travel and, if in a vehicle, try to obtain the license plate number, make, model and color.
- Preserve the evidence.
- Whenever possible, retain the prescription, or, if that is not possible, make a copy of it.
- Minimize handling the forged prescription to preserve fingerprints left by the suspect by placing it in a plastic ”Ziploc®” type bag.(If the prescription is wet, do not place in plastic; if possible, place in a paper bag instead.)
- If the suspect demands the return of the prescription, comply with this request in the interest of safety.
- Contact other pharmacies in the area to inform them of the situation.
Reporting requirements
- Report a prescription forgery for a monitored drug to the Ontario Drug Benefit program by emailing the following information to drugprogramsdelivery@ontario.ca:
- The prescriber details including prescriber name, address, phone/fax number;
- The name(s) of the drug(s) mentioned; and
- Attach a copy of the prescription and any additional forged prescription pages you may have.
- Report a prescription forgery for a controlled substance as a theft to Health Canada’s Office of Controlled Substances within 10 days of its discovery only if it has been dispensed, either partially or fully: Reporting Loss or Theft.
Additional References
- NAPRA Model Standards of Practice for Canadian Pharmacists
- Health Canada: Guidance Document: Reporting Loss or Theft of Controlled Substances and Precursors (CS-GD-005)
- Health Canada: Abuse and Diversion of Controlled Substances: A Guide for Health Professionals
- Health Canada: Loss or Theft
- Narcotic Monitoring System: Monitored Drug List, Questions and Answers, List of approved forms of identification and Section 15 of the Ontario Drug Programs reference manual
- Executive Officer Notice: Forgery Notification Alerts in the Health Network System (HNS), including the Narcotics Monitoring System (NMS) and Frequently Asked Questions
- Information and Privacy Commissioner Fact Sheet – Disclosure of Personal Information to Law Enforcement
CONTACT INFORMATION
Health Profession Regulators of Ontario
www.regulatedhealthprofessions.on.ca/professionscolleges.html
Office of Controlled Substances
Health Canada National Compliance Section
Tel: 613-954-1541
hc.ocs.reporting-rapporter.bsc.sc@canada.ca
Ontario Public Drug Programs
ODB Pharmacy Help Desk Tel: 1-800-668-6641
drugprogramsdelivery@ontario.ca
Published: July 2013
Version #: 5.10
College Contact: Pharmacy Practice