The College produces FAQs to support pharmacists and pharmacy technicians in certain aspects of practice. FAQ sets are chosen based on questions that we receive most frequently.
Disclaimer: Note that these answers were current at date of publication (as noted in each answer) and are meant as guidance for pharmacy professionals. The College cannot tell a registrant what course of action to take, provide legal advice or opinions, or make any decisions for a registrant.
CANNABIS: DISPENSING, COMPOUNDING AND PROVIDING PATIENT CARE
Pharmacists are considered to be medication experts and are often the most accessible healthcare providers for patients. Ontarians who consume or are considering consuming cannabis should expect their pharmacist to have the knowledge to help them make the best decisions about their care and to be able to effectively respond to their cannabis-related inquiries.
In addition to the opportunity to provide advice on cannabis use, there is also an opportunity to educate the public on harm prevention strategies to reduce possible risks associated with cannabis consumption and to identify and assist patients who are at risk of cannabis use disorder. Also, as a patient could acquire recreational cannabis without the intervention of a health professional and intend to consume it for medical purposes, pharmacists are in an ideal position to support patients in such circumstances.
Pharmacists are expected to gather relevant information through dialogue with the patient to assess the appropriateness of a prescribed medication and to identify potential drug interactions. This may include asking about allergies, medical conditions, and lifestyle factors, such as the patient’s diet, alcohol, exercise, tobacco, and cannabis consumption.
As medication experts, pharmacists are in a unique position to support patients who consume cannabis, collaborating with other health care professionals as needed, to promote patient safety while striving to meet their health goals and desired treatment outcomes.
No. Under the federal Cannabis Act, the Access to Cannabis for Medical Purposes Regulations prohibit pharmacies (or any retail outlet) from dispensing cannabis for medical purposes.
A pharmacist cannot alter or repackage cannabis, or be responsible to obtain, possess, or distribute cannabis on behalf of a patient.
The holder of a federal license for sale for Cannabis for Medical Purposes must deliver directly to the patient, by mail and in the licensed processor’s original packaging, pursuant to an order from a health care practitioner.
Cannabis for recreational or non-medical purposes can only be distributed or sold through the online Ontario Cannabis Store or through privately run retail stores that have received a license from the Alcohol and Gaming Commission of Ontario.
Community pharmacists are not exempt from the methodologies of distribution of cannabis outlined in the legislation. For additional information, please contact Health Canada’s Cannabis Legalization and Regulation Branch (CLRB) at cannabis@canada.ca.
No. Under the federal Cannabis Act, activities with cannabis are prohibited unless authorized by the Cannabis Regulations. It is prohibited to obtain, or offer to obtain cannabis by any method or process, including altering its chemical or physical properties. Any compounding activity involving cannabis would require enabling regulations or an exemption from the application of the Act by the Minister under subsection 140(1).
For additional information, please contact Health Canada’s Cannabis Legalization and Regulation Branch (CLRB) at cannabis@canada.ca.
CONTROLLED SUBSTANCES, BUPRENORPHINE, METHADONE
Published in the Pharmacy Connection Winter 2018 edition.
There may be more than one way to dispense a prescription to ensure the patient receives the correct drug, dose and total quantity, such as in the situation you describe. The College cannot provide a specific answer on the action the pharmacist should take; it is the registrant’s responsibility to assess the prescription and decide the best course of action based on all the information at their disposal.
In situations where a specific dose or strength indicated on a prescription does not exist, is unavailable, or is not the most appropriate option for the patient, the pharmacist, in exercising their professional judgment, may choose to use available dosage forms to make up the prescribed strength/dose. Alternatively, the pharmacist may choose to contact the prescriber for clarification — either in writing or verbally — when presented with a prescription that is ambiguous or the intent of the prescriber is not clear.
Depending on the specific scenario, it may be important to ascertain if there was a clinical reason for prescribing a particular strength or dosage form. If there are different options, what does the patient prefer? Or, if the drug does not exist in a given strength, is it possible an error was made in the name of the drug or the dose?
When deciding whether or not it is appropriate to split the tablets prior to dispensing, pharmacy professionals should apply their knowledge to determine whether or not the medication is amenable to splitting (e.g. scored or not, accuracy of resulting dose, stability, tablet integrity) and keep the patient’s health outcomes, best interest and safety in mind.
Documentation of one’s rationale is important, in addition to documentation of dialogue with the patient, their understanding of the changes, and their informed consent. Pharmacy professionals are encouraged to reach out to their peers for timely guidance with practice-related questions as well, to leverage their practical experience and get advice on how they approach situations like this, assess the prescription, and exercise professional judgement.
Published in the Pharmacy Connection Fall 2017 edition.
Pharmacy professionals who accept prescriptions for any drug from an out of province prescriber should refer to OCP’s Fact Sheet on Out of Province Prescriptions. In addition, pharmacists should be familiar with OCP’s Opioid Policy prior to dispensing any methadone prescriptions.
Pharmacists should have and refer to the required reference Opioid Agonist Maintenance Treatment: A Pharmacist’s Guide to Methadone and Buprenorphine for Opioid Use Disorder (CAMH). Collaboration with the prescriber may be required to ensure methadone prescriptions are written in accordance with Ontario MMT policies as well as the Narcotic Safety and Awareness Act requirements. If a pharmacy professional is unsure of the scope of practice and prescribing authority of another regulated health professional, they should contact the individual’s regulatory body for clarification.
Published in the Pharmacy Connection Summer 2019 edition.
The College’s Opioid Policy sets out expectations for pharmacists dispensing all opioids, which includes methadone for pain or analgesia.
Pharmacists should adhere to the most recent clinical practice guidelines and the appropriate standards of practice to ensure best patient outcomes for individuals on opioid therapy. The Opioid Practice Tool provides easy access to numerous resources to support pharmacy professionals in safe opioid dispensing, including the 2017 Canadian Guideline for Opioids for Chronic Non-Cancer Pain.
Published in the Pharmacy Connection Summer 2019 edition.
Guidance from the College with respect to buprenorphine/naloxone dispensing for Opioid Agonist Treatment (OAT) can be found in the Opioid Policy. This includes practicing in accordance with CAMH’s Opioid Agonist Maintenance Treatment: A Pharmacist’s Guide to Methadone and Buprenorphine for Opioid Use Disorder.
Additional resources are available in the Methadone and Buprenorphine Practice Tool and practitioners can access the CRISM National Guideline for the Clinical Management of Opioid Use Disorder via the Opioid Practice Tool.
Although the Opioid Policy does not mandate formal training as a prerequisite for dispensing buprenorphine/naloxone, the College lists Continuing Education opportunities on the OCP website as a tool to assist with professional development.
As with any medication, pharmacists are relied upon to ensure they have the necessary knowledge, skills and judgment to provide OAT in a safe and effective manner.
Published in the Pharmacy Connection Summer 2019 edition.
The College’s Opioid Policy specifies that pharmacists dispensing methadone for Opioid Agonist Treatment (OAT), also known as methadone maintenance treatment (MMT), must be in compliance with the Fact Sheet: Key Requirements for Methadone Maintenance Treatment (MMT) Dispensing, which states:
“Community pharmacies must inform the College within seven days of starting to dispense MMT and of any changes in this information, using the approved Methadone Dispensing Notification Form.”
Notification is required to help the College fulfill its mandate to protect the public. All pharmacies undergo routine assessments every one to four years, depending on the activities performed at the pharmacy and the risk of harm those activities pose to the public. A community pharmacy dispensing methadone will be evaluated according to the operational assessment criteria more often than a pharmacy which does not.
Pharmacies dispensing methadone as an opioid analgesic for pain or buprenorphine/naloxone are not required to notify the College.
DISPENSING PRESCRIPTIONS
Published in the Pharmacy Connection Spring 2018 edition.
The prescriber should indicate who is ultimately responsible for the prescription. The College’s Policy – Medical Directives and the Delegation of Controlled Acts explains that “When delegating an act or procedure, the authorizer is responsible for ensuring that the act is performed competently…Accountability for the delegated act remains with the authorizer…”
The Federation of Health Regulatory Colleges of Ontario (FHRCO) has developed an Interprofessional Guide on the Use of Orders, Directives and Delegation for Regulated Health Professionals in Ontario which contains a template for a Recommended Format for a Prescription or Requisition Completed Pursuant to a Directive. The Pharmacy Connection article Physician Assistants (Fall 2014) may also be of interest.
Published in the Pharmacy Connection Fall 2018 edition.
The College does not maintain information on the scope of practice of practitioners other than pharmacy professionals in Ontario. Questions about the scope of practice and prescribing authority of another health professional should be directed to their regulatory body. Collaboration with the practitioner is also encouraged, as self-regulated health professionals should be aware of – and practicing within – their legal scope of authority and the policies and guidelines of their College. This topic was covered in the Summer 2017 Pharmacy Connection article Prescriptions from Other Healthcare Professionals.
The Fact Sheet – Out of Province Prescriptions explains that dispensers may accept a prescription written by a prescriber licensed in any province or territory of Canada. The Drug and Pharmacies Regulation Act (DPRA) defines “Prescriber” as “a person who is authorized under the laws of a province or territory of Canada to give a prescription within the scope of his or her practice of a health discipline”. An out-of-province prescriber is registered and regulated by their province’s (or territory’s) health disciplinary college. Therefore, the regulations and corresponding scope of practice of the same health discipline in Ontario cannot be applied to an out-of-province practitioner. Similarly, a pharmacist licensed in another province whose scope includes prescribing authority (for example, to initiate treatment for minor ailments or to renew a prescription) is considered a prescriber for the purposes of the Act.
Published in the Pharmacy Connection Winter 2020 edition.
The requirements for a prescription to be “signed” are established in the federal regulations relevant for the schedule of the drug. There is nothing in the regulations mandating the use of a “wet” signature. As explained in the related 2014 article, Navigating Electronically Generated Prescriptions, “Health Canada has broadly defined ‘signing’ as whatever is determined to be necessary to authorize and validate the order”.
The College’s Position Statement Authenticity of Prescriptions using Unique Identifiers for Prescribers (July 2013) describes three examples of distinct authorization methods:
There may be many different technologies available to prescribers, especially as computerized order entry and electronic prescriptions become increasingly common, to implement a unique authorization process and generate an order without an actual image of a signature.
Dispensers should review the Position Statement in its entirety, especially the guidance provided in the section “The Responsibility of the Registrant”. If the pharmacist decides that they need to verify the authenticity of the order, this may be done verbally or in writing (via fax). Prescribers should seek guidance from their regulatory College.
DOCUMENTATION, RECORDKEEPING & PRIVACY
Published in the Pharmacy Connection Summer 2018 edition.
Please refer to the Fact Sheet — Releasing Personal Health Information, which describes a few of the more common disclosures permitted by health information custodians, which pharmacists are, under the Personal Health Information Protection Act (PHIPA). You can also to refer to the legislation directly for complete details or contact the Information and Privacy Commissioner of Ontario.
Regarding requests from health regulatory colleges in Ontario, all colleges – including OCP – must follow the same Health Professions Procedural Code (set out in the Regulated Health Professions Act). Colleges also establish Rules of Procedure, as any hearings in Ontario must meet the standard for procedural fairness mandated by the Statutory Powers Procedure Act. You could reach out to the investigator directly regarding questions about their rules of procedure.
Specific to fentanyl, please refer to the Patch-For-Patch Fentanyl Return Program: Fact Sheet. Regulation 305/16 under the Safeguarding Our Communities Act (Patch for Patch Return Policy) has specific provisions for dispensers providing information to law enforcement. Please refer to section 4(3) under ‘Contingency Plan’ in the regulations.
Additional Resource
Published in the Pharmacy Connection Summer 2018 edition.
When closing a pharmacy, the patient files and prescription records are “transferred” or relocated to the receiving Designated Manager (DM)/owner, and the prescriptions will then belong to the receiving pharmacy. Exactly “how” the records are entered or merged into the receiving pharmacy’s software system is sorted out by the DMs and the vendor(s). Ideally, it should be seamless to the patient.
This “transfer of records” process is not the same as a prescription transfer (as permitted by the Drug and Pharmacies Regulation Act) from one accredited pharmacy to another at the patient’s request, where transfer of narcotics and controlled prescriptions is prohibited by federal regulations.
Pharmacies and pharmacy professionals participating in the closure of a pharmacy should review the College’s Closing a Pharmacy webpage. Additionally, the College’s Guideline on Record Retention, Disclosure and Disposal can provide additional information on the management of patient records.
Published in the Pharmacy Connection Fall 2019 edition.
Pharmacies and pharmacy professionals in Ontario have responsibilities to safeguard the personal health information of their patients as health information custodians under the Personal Health Information Protection Act (PHIPA). One of the additional resources on the OCP website is called Quick Links to the Office of the Information and Privacy Commissioner of Ontario (IPC). These resources have been selected to assist registrants in understanding their obligations under PHIPA, such as the Fact Sheet #15 –Obtaining Personal Health Information About a Deceased Relative. Additional information can be found on the IPC website.
Published in the Pharmacy Connection Fall 2019 edition.
Please refer to the Guideline — Record Retention, Disclosure, and Disposal and the Fact Sheet – Record Keeping and Scanning Requirements.
Regulations under the Drug and Pharmacies Regulation Act (DPRA) require pharmacies to make and retain a scanned copy of all original prescriptions. All prescription records in the pharmacy’s possession, scanned or in hardcopy form, are subject to the retention period of a minimum 10 years after the last date of service provided to the patient.
Since records cannot be destroyed until at least 10 years after the patient has ceased to use a pharmacy’s services (notwithstanding the provision for children under 18 years of age), the date of when a record can be destroyed cannot be pre-determined. If the patient continues to use the services of the pharmacy, the patient record would need to be retained on file for an indefinite period of time (i.e. forever).
Also, the patient record must be maintained as a whole, therefore dispensing records (hard copies) and prescriptions (originals or scanned originals) cannot be singled out for destruction. The decision to destroy paper based records after they have been scanned is at the discretion of the Designated Manager who should evaluate the backup processes in place to safeguard records for the required timeframe.
GENERAL PHARMACY PRACTICE QUESTIONS
Published in the Pharmacy Connection Fall 2017 edition.
In general, employers purchase group benefit plans from insurance companies, negotiating and deciding the terms of the plan on behalf of their employees. The College has no jurisdiction over the practices of employers or insurance companies. Although one Pharmacy Act regulation prohibits a pharmacist from restricting a patient’s choice of pharmacy without their consent, often in these arrangements (i.e. “preferred provider” contracts) consent is given by the employee when they opt-in or enroll for benefits. Should a patient have any concerns about how their benefits are administered, they should speak with their employer directly. The pharmacy professional(s) involved in a patient’s care must still uphold the Standards of Practice and their professional responsibilities.
Published in the Pharmacy Connection Summer 2018 edition.
From a scope of practice perspective, a pharmacist may conduct a comprehensive medication review for a patient according to the Standards of Practice.
Establishing the MedsCheck program eligibility criteria for patients and pharmacists falls under the mandate of the Ministry of Health and Long Term Care (MOHLTC). Information related to billing, such as submitting a claim for reimbursement and the required paperwork, can be found in the materials available on the MOHLTC website, such as the Professional Pharmacy Services Guidebook, and the Ontario Pharmacists Association’s MedsCheck Resources. Additional questions can be directed to the ODB HelpDesk or Medscheck.Moh@ontario.ca.
For example, the MOHLTC may require the pharmacist to meet certain education requirements to be eligible to receive reimbursement for providing a MOHLTC professional service program.
As pharmacists are self-regulated professionals, the College cannot interpret the Guidebook on behalf of a registrant and/or determine whether or not the Ministry’s criteria have been met.
Published in the Pharmacy Connection Summer 2018 edition.
As explained in the Guideline Initiating, Adapting and Renewing Prescriptions, pharmacists have the independent authority to initiate treatment for smoking cessation with buproprion or varenicline under O. Reg 202/94 of the Pharmacy Act.
The regulations do not require a pharmacist to complete specific training prior to initiating treatment for smoking cessation. Similarly, OCP does not require or endorse a particular program you may wish to take. As with any patient care scenario, pharmacists are relied upon to practice within the limits of their competence, and to obtain the knowledge and skills necessary to carry out their professional duties.
However, you may be required to complete a certification course for the purposes of obtaining reimbursement for providing a specific smoking cessation service offered through a patient’s third-party insurer or the MOHLTC.
Published in the Pharmacy Connection Fall 2018 edition.
Providing a copy of the original with the transfer would be considered a best practice in the interest of patient safety. Unlike a refill, the logged prescription has never been dispensed and has not gone through the same complete checking process. This is the same reason registrants within their own practice site should be retrieving or viewing the original hardcopy before a logged prescription is dispensed.
The Code of Ethics also expects that when a patient moves from one healthcare provider to another, the relevant information is provided to the receiving healthcare provider, to ensure safe and effective transition of care
Published in the Pharmacy Connection Fall 2018 edition.
Having a degree in pharmacy is one of several requirements needed for a certificate of registration, in order to practice as a licensed pharmacist in Ontario. It does not, in itself, confer the right to practice pharmacy. Should an individual wish to make reference to their educational credentials, this information should be presented in a manner that is not ambiguous, confusing, or misleading to the public. OCP has not established any additional policy or guideline restricting how a degree or credential may be used, however, it must be evident whether an individual is licensed by the College and able to practice pharmacy, or not.
Pharmacy graduates who possess a PharmD (Doctor of Pharmacy) degree should be aware that use of the title “Doctor” (or an equivalent abbreviation, such as Dr.) is restricted by the Regulated Health Professions Act, Section 33. A pharmacist cannot use this title in the course of providing, or offering to provide, health care to an individual. The regulated health professionals who may use this title in practice are defined in the Act. Pharmacists should be mindful when referring to their PharmD degree of the potential for misinterpretation by a patient that the individual is, for instance, a Medical Doctor (MD).
Once registered with the College as a pharmacist, they are permitted to use the title of “Pharmacist” or an equivalent abbreviation, such as the designation “RPh” (approved by Council in 2003). Section 10 of the Pharmacy Act also restricts the use of the titles “Apothecary” and “Pharmaceutical Chemist” to registered pharmacist registrants of the College. Similarly, “Pharmacy Technician” (and its abbreviation RPhT) became a restricted title under the Pharmacy Act in December 2010. All other titles – such as Certified Pharmacy Technician (in use prior to 2008) – must no longer be used. This does not prevent someone from indicating their past achievement of passing the College’s certification exam, such as on a résumé, however the title of “Pharmacy Technician” cannot be used in practice unless they are registered as registrants of the College.
PHARMACY TECHNICIANS
Published in the Pharmacy Connection Winter 2018 edition.
The legislation (O. Reg 202/94) states “Every certificate of registration as a pharmacy technician is subject to the following terms, conditions and limitations: 1. The member shall only engage in the practice of pharmacy (…) when practising in a pharmacy to which the Drug and Pharmacies Regulation Act applies, other than a remote dispensing location, while under the direct supervision of a member holding a certificate of registration as a pharmacist…”
A technician can check any/all prescriptions for technical accuracy and completeness. Every prescription – new and refill, regardless of how they are packaged – must have both the technical and therapeutic check completed prior to release to the patient. Please refer to the page “Understanding What a Technician Can Do” for more details; note that the term “co-signing” is not used, as each registrant is performing an independent “check” for different purposes.
A suitable method for documenting both “checks” for a given prescription may be signatures (or some other identifying mechanism) from both registrants on every hardcopy. However, other methods may be suitable to document the respective actions and associated responsibilities in the dispensing process. As software, workflow, personnel, etc. can vary from pharmacy to pharmacy, the information presented on our website is not meant to be entirely prescriptive for how a pharmacy achieves the desired end result, which is to ensure the patient receives a prescription that is both technically accurate and therapeutically appropriate.
Ultimately, registrants remain accountable for their respective roles in dispensing a prescription, and documentation on the patient record should reliably demonstrate that every prescription has been reviewed for both technical and therapeutic aspects before it is dispensed. It should be readily retrievable, auditable, and be unambiguous. When and how these functions occur, and what form they take (i.e. operational procedures) are at the discretion of the pharmacist and technician in consultation with the Designated Manager.
Additional Resource
Published in the Pharmacy Connection Winter 2018 edition.
As outlined in our MMT and Dispensing Policy under the section Administration of Methadone Dose and in the CAMH course, the pharmacist is responsible for patient assessment, witnessing doses as well as the therapeutic check of the prescription. These functions cannot be delegated to a technician. More information can also be found in the CAMH guide Opioid Agonist Maintenance Treatment: A Pharmacist’s Guide to Methadone and Buprenorphine for Opioid Use.
Registered pharmacy technicians have the independent authority to check the accuracy of the technical components of methadone prescriptions. Pharmacy technicians may also be responsible for other tasks in the workflow that fall under their job descriptions and competencies, such as dose preparation, assisting with documentation and inventory management.
Published in the Pharmacy Connection Fall 2019 edition.
The Pharmacy Act and Ontario Regulation 202/94 – General define Scope of Practice and Authorized Acts for all pharmacy professionals. The steps involved in conducting a BPMH, such as gathering patient records from various sources and identifying discrepancies, are not necessarily governed by legislation. However, the regulation does set out Terms, Conditions and Limitations on a pharmacy technician’s certificate of registration, and pharmacy technicians cannot provide information or education relating to drug use which requires therapeutic knowledge, clinical analysis or assessment (s18.4).
Pharmacy technicians responsible for performing a BPMH must have the appropriate knowledge, skills and training to meet the Standards of Practice for Pharmacy Technicians outlined in #9-#12. When collaborating to provide patient care, technicians are expected to document their decisions and actions in the patient’s health record, including the relevant health and drug information they’ve obtained and their interpretation of this information.
The Pharmacy Manager/Administrator should establish policies and procedures for conducting medication reconciliations, outlining the respective roles for pharmacy technicians and pharmacists. OCP resources to consult include the Hospital Assessment Criteria, Standards of Operation, and the Pharmacy Technician Practice Assessment Criteria. External resources are also available from organizations such as the Canadian Society of Hospital Pharmacists (CSHP), ISMP Canada, the Canadian Patient Safety Institute (CPSI), etc. Collaborating with peers at other hospitals to share operational advice and best practices is also encouraged.
SCOPE OF PRACTICE
Published in the Pharmacy Connection Spring 2018 edition.
Please refer to the Guideline on Administering a Substance by Injection or Inhalation.
Since October 2012, pharmacists have been authorized to administer the influenza vaccine through the Ministry’s UIIP, and to administer a substance specified in the regulation to a patient who has been prescribed a self-administered injection for the purpose of education and demonstration. (Refer to Schedule 1 in O. Reg 202/94 to the Pharmacy Act for a list of these substances). In December 2016, the regulations were amended to allow for the administration of additional vaccines, found in Schedule 3 of O. Reg 202/94.
Situations outside of the pharmacist’s scope of practice as defined in the legislation (i.e. substances not listed in the regulations, or not for the purposes of education and demonstration) would require delegation of authority, such as a medical directive.
Pharmacists who have completed the appropriate training and feel they have sufficient skills and knowledge to perform other injections may wish to explore collaboration with other health care providers to do so. Please refer to the Policy on Medical Directives and the Delegation of Controlled Acts.
Published in the Pharmacy Connection Spring 2018 edition.
Billing a prescription to a third party payer does not have any bearing on the scope of practice of pharmacy defined by the Pharmacy Act and Ontario Regulation 202/94 – General. Vaccines (listed in Schedule 3 of the regulation) may be administered under independent authority in accordance with the Guideline – Administering a Substance by Injection or Inhalation. Vaccines listed in Schedule I of the NAPRA Drug Schedules require a valid prescription in order to be dispensed prior to administration.
To receive reimbursement for influenza, which is a Schedule II vaccine, a claim is submitted to ODB via the Health Network System. This requires the pharmacist to enter information similar to that of a prescription, with the pharmacist’s identification in the ‘prescriber’ field (refer to the Ministry of Health and Long- Term Care’s Executive Officer communications). As this is a billing mechanism (which also creates documentation for the patient) it should not be interpreted as prescribing the vaccine, as pharmacists do not have the independent authority to do so.
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