March 19, 2020: Important update regarding the novel coronavirus (Covid-19) pandemic
Health Canada has issued pharmacists a temporary Controlled Drugs and Substances Act (CDSA) subsection 56(1) class exemption to permit pharmacists to transfer prescriptions of controlled substances by sending the prescription to another pharmacy within the province for the purpose of having it filled and dispensed to the patient at that pharmacy.
Pharmacists acting under the authority of this exemption must:
- Only transfer the prescription for a patient under their professional treatment;
- Only transfer the prescription for the purpose of renewing an existing prescription;
- In addition to the requirements outlined in this Fact Sheet, keep records of:
- a copy of the prescription written by the practitioner or the record made in accordance with the practitioner’s verbal prescription;
- the name and business address of both the transferring pharmacist and the pharmacist receiving the prescription transfer;
- if applicable, the specified interval between refills.
While this exemption is in effect:
- pharmacists may transfer prescriptions of narcotics and controlled drugs to another pharmacist in Ontario and if they have already been transferred, may be transferred to another pharmacist
- prescriptions for a benzodiazepine or other targeted substance that have already been transferred, may be transferred to another pharmacist
Pharmacists should refer to the Subsection 56(1) class exemption for patients, practitioners and pharmacists prescribing and providing controlled substances in Canada during the Coronavirus Pandemic and related Frequently Asked Questions for further information.
Published: August 2013
Revised: August 2016, March 2020
- Drug and Pharmacies Regulation Act , s 157
- Ontario Regulation 264/16, s 5
- Public Hospitals Act, R.R.O. 1990, Reg. 965, s 22.1
- Food and Drug Regulations, s. C.01.041.1 – C.01.041.4
- Narcotic Control Regulations, s. 31, 32
- Benzodiazepines and Other Targeted Substances Regulations, s.54
College Contact: Pharmacy Practice
Prescription transfers are subject to federal and provincial regulations. In December 2013, changes to the federal Food and Drugs Regulations gave pharmacy technicians the authority to transfer prescriptions.
1. Transfers occur between “pharmacies” with registrants responsible for the transfer.
2. A prescription shall be transferred from a pharmacy upon the request of the patient or a person acting on behalf of the patient. (O. Reg. 264/16, s. 5)
- Where refills exist, a pharmacy must transfer a prescription when requested
- A person acting on behalf of the patient includes a registrant acting on behalf of the patient
- The consent to transfer is implied and there is no need for a pharmacy to contact the patient to verify the transfer when the request comes from a registrant acting on behalf of a patient. Delaying a transfer for this reason interferes with continuity of care.
3. The Public Hospitals Act Regulation 965 addresses transfers and prescriptions/orders in a hospital.
4. A prescription may be transferred either under the signature of a registrant who is practising at the pharmacy transferring the prescription or verbally by a registrant who is practising at the pharmacy making the transfer.
5. A prescription can be transferred either by signature or verbally to,
- If the pharmacy is in Ontario, a registrant who is practising at the pharmacy where the prescription will be transferred.
- If the pharmacy is outside of Ontario, a person who is authorized to practise pharmacy at the pharmacy where the prescription will be transferred.
Requirements for the Information that the Transferring Pharmacy Must Provide:
1. Name and address of the patient for whom the drug was prescribed
2. Name and strength (if applicable) of the drug prescribed
3. Directions for use as prescribed
4. Name and address of the prescriber
5. Identity of the manufacturer of the drug product most recently dispensed
6. Identification number of the prescription, i.e. prescription number
7. Total quantity of the drug remaining to be dispensed
8. Date the drug was first dispensed under the prescription and the date of the last refill
a. The date issued by the prescriber is not required except for benzodiazepines and other targeted substances (Benzodiazepines and Other Targeted Substances Regulations)
9. Quantity most recently dispensed, if different from the quantity prescribed
10. Name of the registrant who is responsible for the transfer of the prescription
Records Required by the Transferring Pharmacy
- Date of the transfer
- Identity of the pharmacy to which the prescription was transferred
- Name of the registrant responsible for the transfer
- If the prescription is transferred verbally, the name of the registrant who received the transfer.
Requirements for the Receiving Pharmacy
- The person receiving the transfer must ensure the transfer was made from a pharmacy licenced in a province or territory of Canada, i.e. can only receive a transfer from an accredited Canadian pharmacy.
- The required information provided by the transferring pharmacy has been recorded.
- For verbal transfers, the record is signed by a registrant.
All the above requirements for both pharmacies are required in order to transfer the authority to dispense the prescription in the receiving pharmacy.
Limitations to the Transfer of Prescriptions
Under the regulations, conditions exist where a transfer is not permitted:
1. Prescriptions cannot be transferred if the total quantity of the drug authorized has been dispensed, i.e. no refills remain or no quantity left to transfer.
a. A copy (1) of the prescription can be provided to the other pharmacy who can then contact the physician for a new authorization or the registrant may use their expanded scope to authorize the prescription provided they have enough information
b. A copy is not an authorization to fill
3. Narcotic and Controlled Drugs cannot be transferred (2)
4. Benzodiazepine and targeted substances can only be transferred once (3). Once transferred they can no longer be transferred any further.
Misconceptions and Best Practices
1. Where a patient brings in a prescription for multiple drugs on a single sheet, registrants are under the misconception that they can photocopy the prescription, fill one or two items and give the prescription with the remaining drugs ordered, back to the patient to fill elsewhere.
This is not an acceptable practice. A photo-copy does not provide a true authorization to fill the prescription as it is only a copy.
2. Some pharmacies may charge for a transfer; withholding a transfer unless the patient pays a required fee first is not in the patient’s best interest. If a pharmacy wishes to charge for a transfer, this charge is between the pharmacy and patient. Pharmacies may invoice the patient but in no way should this prevent the transfer. Registrants charging for professional services should review the policy regarding Fees for Professional Pharmacy Services.
Transfers should be done in a timely manner. If circumstances arise that result in a delay, as a professional courtesy, the registrant should inform the pharmacy awaiting the transfer.
- Drug and Pharmacies Regulation Act, s.157
- Narcotic Control Regulations, s. 31, 32
- Benzodiazepines and Other Targeted Substances Regulations, s. 54