UPDATE – Advisory Notice– August 27, 2013
Clarification: Record Keeping and Scanning Requirements
As outlined in the March 8, 2013 – Update Advisory Notice (see below) pharmacy managers or their corporate representatives, of pharmacies who had not yet met the requirement (Ontario Regulation 58/11 – Drug and Pharmacies Regulation Act) to implement technology capable of electronically storing patient records, were asked to inform the College before May 2013 of their intent to do so.
The College would like to acknowledge that this request has been met and is satisfied that pharmacies are either currently compliant with the regulation or are actively engaged in a process to achieve compliance in the near future. No further correspondence between individual pharmacies or their corporate representatives and the College is required.
Members are reminded that the intent of the regulation is to enable pharmacies to store patient records electronically in a safe and secure environment that provides easy access and retrieval of patient records. This also provides a practical means to meet the increased record retention requirement, of 10 years, for patient records which is consistent with other health care professionals.
It is understood that there are a variety of ways in which a pharmacy could achieve compliance with this regulation and the College is not prescribing, nor approving, any specific method. Whether the method involves scanning the original prescription as well as the paper ‘hard’ copy with ‘wet’ signatures or the adoption of a paperless solution which utilizes a secure technology to affix and authenticate electronic signatures, pharmacies have the discretion to choose the process that works best for them.
As with other systems and processes within a pharmacy the designated manager is responsible and accountable for ensuring that the chosen method meets all applicable standards and is compliant with relevant legislation and regulation.
The corresponding FAQs have also been updated or revised to provide further clarity:
- How long are patient records to be retained? (revised for clarity)
- When do I have to have the scanning technology implemented? (updated)
UPDATE – Advisory Notice – March 8, 2013
Clarification: Record Keeping and Scanning Requirements
As outlined in the October 26, 2012 – Advisory Notice (see below) a transitional period to the end of May 2013 was established to assist pharmacies with meeting this important obligation. Pharmacy managers or their corporate representatives that anticipate difficulty meeting this date should contact the College (pharmacypractice@ocpinfo.com) before May 2013 to communicate their transition plan and anticipated date of full implementation, in order to demonstrate commitment to meeting the new requirements in a reasonable timeframe.
Pharmacists are reminded that the requirement in the DPRA to retain patient records for 10 years from the last date of service, common to all health care professionals, remains in place. For more information regarding this regulation, please refer to FAQs on Record Keeping.
Note: Pharmacies who are part of a banner or chain do not need to report to the College individually if their head office has already done so. Pharmacies should check with their head office before contacting the College.
Advisory Notice – October 26, 2012
Clarification: Record Keeping and Scanning Requirements
In accordance with Ontario Regulation 58/11 (Drug and Pharmacies Regulation Act), which was proclaimed in March 2011, all pharmacies are required to keep patient records for a period of at least 10 years from the last recorded professional pharmacy service provided to the patient or until 10 years after the day on which the patient reaches or would have reached the age of 18 years, whichever is longer.
The regulation also established a deadline of May 11, 2012 for all pharmacies to have implemented technology capable of generating scanned electronic copies of every original prescriber generated prescription. A copy of the dispensing record of all prescriptions (hard copy containing pharmacist/technician signatures), both new and refill, must also be stored electronically. Note: new pharmacies are required to meet this standard prior to opening.
When it became clear that not all pharmacies could meet the deadline, the College met with software vendors and technology experts to ensure that the base requirements outlined in the regulation were understood. Subsequently the College established a transitional period, to the end of May 2013, to assist pharmacies with meeting this important obligation.
For more information regarding this regulation, which ensures consistency of patient record retention standards amongst all health care professions, please refer to the FAQs on Record Keeping.