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FAQ TopicsGENERAL QUESTIONS
Can pharmacists in any practice setting prescribe for minor ailments? Are there any restrictions?
Yes, and yes. Pharmacists may prescribe for minor ailments, regardless of the nature of their workplace. For example, pharmacists in a Family Health Team (FHT) or Nurse Practitioner Led Clinic (NPLC) can issue a prescription for a minor ailment to be dispensed at the patient’s chosen pharmacy.
However, in certain practice settings, a pharmacist cannot order a patient’s treatment. For example:
- In a hospital setting, regulations under the Public Hospitals Act do not permit pharmacists to ‘order treatment’ for inpatients or outpatients. Pharmacists practicing in hospitals may wish to explore delegation of authority to prescribe, such as a medical directive, in accordance with organizational policies.
- In a long-term care home, retirement home, or similar setting, section 5(1)(b) of the Nursing Act does not include pharmacists among the health professionals who can order a registered nurse or registered practical nurse to administer a prescription medication to a patient. The prescribing of medication in these settings may also be subject to other legislation.
What happens if a patient does not have a primary care provider?
The regulations require a pharmacist to notify “the patient’s primary care provider (if any) within a reasonable time” that they prescribed a drug for the patient. If there is no primary care provider to notify at this time, this information is retained on the patient record in accordance with legislation and must continue to be accessible to the patient and their circle of care.
As the prescriber, the pharmacist is responsible for monitoring and follow-up on the treatment plan and prescribed therapy, essentially assuming the role of primary care provider until the patient’s care can be transitioned, if necessary, to another healthcare professional.
Can I issue refills at the time of prescribing for a minor ailment?
Yes. The regulations and OCP guidelines do not specifically address or prohibit refills. However, it is important to remember that a minor ailment is usually a short-term condition where only minimal or short-term follow-up is required, and that if the prescribed treatment is not effective, further assessment and/or a referral to another health care professional may be warranted.
The pharmacist should use their professional judgment to determine whether issuing refills at the time of prescribing is clinically appropriate for the indication and document their rationale. For example, the amount of topical cream the patient might need for their expected duration of treatment can be approximated, but not necessarily exactly calculated, and the pharmacist may decide prescribing an initial quantity with a refill is appropriate. The follow-up and monitoring plan should ensure that the intended timeframe of the patient’s therapy is adhered to. A pharmacist dispensing a refill for a minor ailment must evaluate the request in accordance with the Standards of Practice, taking into account the ongoing need considering the minor ailment and an assessment of the patient.
If a patient chooses to have a lesser amount than the prescribed quantity dispensed, they should be advised if additional dispensing fees will be charged and the patient must authorize this request in writing (as per the Drug Interchangeability and Dispensing Fee Act (DIDFA)).
If all Part A pharmacists have the scope and must take the mandatory Orientation module for minor ailments prescribing, is the College expecting all Part A pharmacists to provide Minor Ailment services?
Having the legislated authority to prescribe for minor ailments does not mean all pharmacists must provide this service. Patients are encouraged to speak to their pharmacist to find out what healthcare services they offer.
Pharmacists have an ethical obligation to ensure that they only practice when they are competent to do so, as self-assessed with respect to both relevant knowledge and skill as well as physical, emotional and mental capacity. The practice environment must also meet the Standards of Operation and be conducive to the safe and appropriate provision of pharmacy services. As such, pharmacists have the autonomy to incorporate minor ailments prescribing into their practice as they see appropriate, which may include a staggered implementation of minor ailment prescribing, or offering services for some, but not all, minor ailments. When unable to provide a requested pharmacy service, the pharmacist assumes responsibility for making reasonable efforts to ensure continuity of patient care, such as a referral to another pharmacist or practitioner.
Can I charge a fee for providing minor ailment services if the patient doesn’t have a health card or is otherwise ineligible for reimbursement under Ministry of Health funding (i.e., exceeded plan maximums)?
As with other services that are not covered by a publicly funded program and which are over and above the services included in the usual and customary dispensing fee, pharmacists may charge fees for professional pharmacy services in accordance with OCP Policy. For example, it should be clear to the patient what the fee is for, and the charge should be reasonable for the service provided. Patients with private insurance or health benefits may inquire with their provider regarding possible reimbursement of any fees for minor ailment services, and pharmacists are encouraged to provide an invoice or receipt upon request for patients to use for this or other purposes.
Is it possible to provide minor ailment services virtually?
Once prescribing for minor ailments is part of a pharmacist’s legislated scope of practice, the Code of Ethics, Standards of Practice, and relevant Policies and Guidelines will apply, including the College’s Virtual Care Policy. Importantly, the pharmacist must first determine that the manner in which virtual care is provided is suitable for the patient assessment and will enable them to meet all legal and professional obligations.
For the minor ailment service to be eligible for reimbursement through the Ontario Drug Benefit Program, it must be provided in-person or virtually (including by phone) from an eligible pharmacy location, as described in the Executive Officer Notice: Funding for Minor Ailment Services in Ontario Pharmacies and Questions and Answers for Pharmacies from the Ministry of Health.
Can the process of gathering information to inform the pharmacist’s patient assessment be performed by a pharmacy technician? What about the process of notifying the prescriber?
Pharmacy technicians can gather and document relevant health information from the patient and conduct a Best Possible Medication History to inform the pharmacist’s patient assessment and support their decision-making. They can also assist the pharmacist in documenting and notifying the patient’s primary care provider about the minor ailment service and, if one is issued, the details of the prescription. The Designated Manager should have processes in place to incorporate pharmacy technicians into the workflow for minor ailment services and to support registrants in practicing to their full scope. Pharmacy technicians cannot “provide information or education relating to drug use, either to or for a patient, where the provision of the information requires therapeutic knowledge, clinical analysis or clinical assessment” due to the terms, limitations, and conditions on their certificate of registration.
Can registered pharmacy students, interns, and Emergency Assignment (EA) pharmacists engage in the new scope of practice to prescribe for minor ailments?
Registered pharmacy students, interns, and Emergency Assignment (EA) pharmacists have the same scope of practice as a pharmacist, subject to the supervision requirements set out in the terms, conditions, and limitations on their certificate of registration. Please refer to the Supervision of Pharmacists (Emergency Assignment) and Pharmacy Technicians (Emergency Assignment) Guideline and the Supervision of Pharmacy Students & Interns Fact Sheet for more information.
As with any area of practice, the supervising pharmacist must assess the registrant’s competence to provide a service and engage in patient care, and the degree of supervision required, to do so safely and effectively. For an EA pharmacist, supervision can be indirect, and the supervising pharmacist does not need to be physically present on the premises. In addition, the registrant is expected to complete the Mandatory Orientation for Minor Ailments (Ailment) Prescribing module to ensure they understand their ethical, legal, and professional obligations associated with this new scope.
Are there any age restrictions for patients seeking treatment for minor ailments?
While the regulations authorizing pharmacists to prescribe for minor ailments do not include age restrictions, it is possible that characteristics such as age may be relevant to the treatment of specific minor ailments. Pharmacists should conduct a patient assessment and use their knowledge, skills and judgment along with available clinical treatment algorithms to determine whether age or any other factor might indicate that prescribing for a particular minor ailment is contraindicated. If a decision is made not to prescribe, that decision must be explained to the patient along with a follow-up plan for monitoring and/or next steps. This could include a referral to another healthcare provider.
Can I use any clinical algorithm to guide my therapeutic decision-making process when assessing a patient for a minor ailment?
Yes. The Standards of Practice expect pharmacists to use evidence from relevant sources to inform their activities and to critically evaluate medication and related information. Pharmacists have an ethical obligation to ensure information provided to patients is current and consistent with the best available evidence.
In pharmacies, it is a standard of accreditation to have available the references and resources pharmacists require to meet the standards of practice of the profession and to support the pharmacy services provided. Pharmacists may choose to subscribe to or use any clinical resources that will enable them to provide safe and effective patient care.
ELIGIBLE DRUGS
To prescribe a product for a minor ailment that contains a combination of drugs, do all the drugs need to be listed in Schedule 4?
Yes. Pharmacists can only prescribe a drug in listed in Column 3 of Schedule 4 for the respective minor ailment, even if it is in a combination product. Each drug found in the combination must be listed in Schedule 4; this was taken into consideration when the proposed regulations were submitted to the Ministry.
I can’t find a drug in Column 3 of Schedule 4, but it belongs to the Drug Class found in Column 2. Can I prescribe it?
No. Pharmacists are only authorized to prescribe the specified drugs listed in Column 3. At this time, expert clinical opinion advises against prescribing high-potency topical corticosteroids and ophthalmic fluoroquinolones for their respective minor ailments, and as such, they are not listed in Column 3.
Why did the regulations change from having only the American Hospital Formulary Service (AHFS) Pharmacologic-Therapeutic Classification to a list of specific drugs?
At the time the medications associated with the minor ailments were being identified, the intent of using drug categories was to have the flexibility to prescribe the most up-to-date medications available on the market. With a list of drugs written into the regulations, adding any new drugs to the Schedule would require going through the regulatory amendment process.
Due to concerns the American Society of Health-System Pharmacists (ASHP) raised about acquiring a license to utilize the AHFS classification system, which is a proprietary product, the College submitted drug lists for all of the previous and new minor ailments as part of these amendments.
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