Prescriber Registration Status Changes

(formerly Physician Prescribing Status)

FACT SHEET

Published: September 2012
Revised: April 2014; November 2020

Legislative References:

College Contact: Pharmacy Practice

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 member of a College so authorized by a specific health profession Act (Schedule I of the RHPA) in accordance with requirements established by its regulations.

Health Professions with Prescribing Authority

  • Physicians; College of Physicians and Surgeons of Ontario (CPSO)
  • Chiropodists/Podiatrists; College of Chiropodists of Ontario (COCOO)
  • 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)
  • Dentists; Royal College of Dental Surgeons of Ontario (RCDSO)
  • Dental Hygienists; College of Dental Hygienists of Ontario (CDHO)

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

Registration Status

A Certificate of Registration is issued after an applicant has met the registration requirements set out in the health profession Act and College 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 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 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.
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 relationship with the patient, clinical knowledge or expertise with respect 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 centre 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 medications.
  • 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 they are no longer a 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 (renewals) 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 as described with respect to new prescriptions in first bullet above. This term is not 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, pharmacy professionals 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).
Additional Considerations

Examples of points to consider might include, and are not limited to:

  • What was the intent of the prescriber?
  • Is the patient at a greater risk of harm if they receive or if they do not receive the medication?
  • Have any concerns been identified that cannot be appropriately addressed without the prescriber’s involvement?

Based on this assessment, the pharmacist 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.

Additional References:

  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