Prescriber Registration Status Changes

(formerly Physician Prescribing Status)

FACT SHEET

Legislative References:

Introduction

Under federal regulations, a prescription must be issued by a practitioner who is authorized or entitled by provincial/territorial law to prescribe and who is practicing the profession in that province or territory.

In Ontario, prescribing a drug is a controlled act under the Regulated Health Professions Act (RHPA), which may only be performed by a registered member of a College so authorized by a specific health profession Act (Schedule 1 of the RHPA) in accordance with requirements established by its regulations.

Health Professions with Prescribing Authority

  • Chiropodists/Podiatrists; College of Chiropodists of Ontario (COCOO)
  • Dentists; Royal College of Dental Surgeons of Ontario (RCDSO)
  • Dental Hygienists; College of Dental Hygienists of Ontario (CDHO)
  • Midwives; College of Midwives of Ontario (CMO)
  • Naturopaths; College of Naturopaths of Ontario (CONO)
  • Nurses; College of Nurses of Ontario (CNO)
  • Optometrists; College of Optometrists of Ontario (COO)
  • Pharmacists; Ontario College of Pharmacists (OCP)
  • Physicians; College of Physicians and Surgeons of Ontario (CPSO)

Registrants should consult the health professional’s regulatory College website and/or the legislation governing their health discipline for details on prescribing authority including the extent of which drugs are within scope.

Registration Status

A Certificate of Registration is issued by a College to an applicant who has met the registration requirements set out in the respective health profession Act and by-laws. A prescriber’s current registration status can be verified by consulting the public register maintained by the College issuing the certificate of registration.

The RHPA Health Professions Procedural Code, s 23 sets out specific information that must be included on the public register and each health profession’s College Council (board of directors) establishes by-laws determining additional content provided about its members. Therefore, the information publicly available on the register and the terminology used varies by College.

A prescriber’s registration status will be active or inactive:

  • Active: The member currently holds a valid certificate of registration (license).
    • Restricted: A member may have an active certificate of registration with restrictions (terms, conditions and limitations or TCLs) imposed by a committee or voluntarily by the registered member (i.e. as an undertaking).
    • A member who retires or closes their practice may decide to retain active registration for a certain time period afterward to facilitate the transition of patient care.
  • Inactive: The member does not currently hold a valid certificate of registration (license).
    • Reasons for inactive registration may include deceased, expired, inactive, non-practising, resigned, retired, revoked, or suspended.
    • A member whose certificate of registration has been suspended or revoked may be reinstated in the future in accordance with the RHPA.
Assessing Prescription and Refill Validity after a Change in Registration Status

The decision to dispense a prescription or prescription refill after a prescriber’s registration status has changed and the patient is no longer under their care should be made on a case-by-case basis.

  • Professional judgment is specific to each pharmacist and may be based on a combination of factors, such as their familiarity with the patient’s health history, clinical knowledge or expertise with respect to the treatment/condition, practical experience, reflection, and learning from one’s peers.
  • The Code of Ethics places the well-being of the patient at the center of the decision-making process. Pharmacists have an obligation to act in the best interest of the patient and take steps to maintain continuity of care for prescribed therapies.
  • The Standards of Practice require the pharmacist to assess the prescription and gather the information necessary to make an informed decision based on the individual patient’s specific needs.

In all cases, the patient should still be directed to find a new or interim prescriber or primary care provider as soon as possible.

Assessing Prescriptions

Prescriptions are considered valid when issued by a prescriber while actively registered with their College.

Assessing Refills

In most cases, prescription refills are considered invalid after a prescriber’s registration status has changed and, as such, they are no longer a registered member of their College. In these situations, the pharmacist may decide to honour the refill request based on their assessment of the patient and the circumstances at hand in the best interest of the patient.

  • Refills (repeats) are considered invalid once a prescriber ceases to be a registered member of their College, and the prescriber-patient relationship no longer exists.
  • Part-fills may be considered valid when the original prescription was issued by a prescriber while actively registered with their College. ”Part-fill” is not a term defined in legislation, but is used to describe dispensing a quantity which is less than the total amount of drug specified by the prescriber[1]
    • Consideration should be given to how the prescription was originally issued by the prescriber and the reason for dispensing as a part-fill.
  • When a prescriber has or had TCLs on their certification of registration, pharmacists should carefully review, and take into account, the details of any prescribing restrictions (e.g., specific drug schedules) and the dates of the restriction(s).

Based on these assessments, the pharmacist is responsible for determining how to address the situation, and may decide to:

  • refuse to fill and/or;
  • refer the patient to another prescriber or primary care provider (if available) for a new prescription or;
  • renew the prescription under their own authority or;
  • exercise professional judgement to determine another course of action

Regardless of the course of action chosen, the pharmacist is accountable for their decision and should effectively communicate their rationale to the patient. Documentation on the patient record should be completed in a timely manner and easily accessible for other pharmacy team members for continuity of care, and any necessary monitoring or follow-up by the pharmacist.

Health Canada Notices of Restriction (NOR)
  • A notice of restriction may be issued by Health Canada to pharmacies, not to sell or provide controlled substances to, or to fill prescriptions/orders for controlled substances from, the practitioner named in a notice of prohibition or restriction.
  • These restrictions correspond to those on the public register for the prescriber’s regulatory College.
  • Access Health Canada’s website for more information and the list of health care practitioners and pharmacists named in a notice of restriction.
Additional References:

Published: September 2012
Version: 2.1

College Contact: Pharmacy Practice

Revision History
Version Date Action
1 September 2012
  • Published as “Physician Prescribing Status”
1.1 April 2014
  • CPSO contact information updated
2.0 November 2020
  • Changed title to “Prescriber Registration Status Changes”
  • Reformatted
2.1 September 2021
  • Incorporated Health Canada Notice of Restriction
  • Link to Patient Assessment Tool
  1. https://www.canada.ca/en/health-canada/services/health-concerns/controlled-substances-precursor-chemicals/policy-regulations/policy-documents/prescription_management_pharmacists_controlled_substances.html

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