Cross-Jurisdictional Pharmacy Services Policy

Pupose:

This policy articulates the Ontario College of Pharmacist’s (OCP) expectations for the provision of cross-jurisdictional pharmacy services regardless of the location of the registrant or their patients.

Additionally, for the provision of virtual care to patients located in another jurisdiction, OCP expects registrants to comply with this policy as well as the Virtual Care Policy.

Definitions:

Informed Consent: Consent to treatment is informed if, before giving it, the person received the information about the nature, expected benefit, potential risks or side effects, other options and consequences of not having the treatment (or any information that a reasonable person in the same circumstances would require in order to make a decision about the treatment) and the person received responses to their request for additional information (Health Care Consent Act, 1996, s.11(2)).

Practitioner: a person who is entitled under the laws of a province/territory to treat patients with a prescription drug, and is practicing their profession in that province/territory. (Food and Drug Regulations, C.R.C., c. 870, C.01.001 (1))

Policy:

Registrants are required to comply with all professional expectations and legal requirements of OCP regardless of the location of the registrant or their patients. Registrants are also expected to adhere to the Model Standards of Practice for Pharmacists and Pharmacy Technicians in Canada, as applicable.

Registrants licensed in Ontario who are Providing Services across Canadian Jurisdictions
Registrants who provide services to patients who are located out of province/territory in another Canadian jurisdiction are expected to adhere to the professional expectations and legal requirements of both OCP and that of the province/territory in which the patient is located.

Informed Consent
Registrants who choose to provide pharmacy services to patients located in another Canadian jurisdiction must act in compliance with the Personal Health Information Protection Act (PHIPA) and the Health Consent Act. Registrants must obtain informed consent from the patient (or their substitute decision-maker), either orally or in writing, before delivering cross-jurisdictional pharmacy services. Informed consent must be documented whether it is obtained orally or in writing.

Dispensing for Canadian prescriptions
It is expected that Registrants will conduct due diligence and exercise professional judgement to establish that a sufficient patient/practitioner relationship exists in relation to any prescriptions being written out of jurisdiction.

Registrants are required to adhere to the NAPRA Model Standards of Practice when dispensing a prescription for a patient who is out of province/territory. For pharmacists, this includes, but is not limited to assessing the appropriateness of the prescription by collecting and interpreting relevant information to ensure there are no significant drug interactions, contra- indicators or adverse effects, the dose and instructions for use of the drug are correct, the drug is properly indicated and adherable, any red flag situations are addressed, and that the patient is receiving appropriate monitoring for this drug and disease. For technicians, this includes reviewing prescriptions to confirm that they are complete, authentic and meet all current laws, regulations and policies.

Registrants can accept prescriptions, including refills for prescription drugs, if in the registrant’s professional judgement the prescription is deemed legitimate and in dispensing the prescription continuity of care is maintained. Registrants must ensure the communication of relevant clinical information is shared with the patient’s primary circle of care.

Registrants can accept prescriptions, including refills authorized by an out of province/territory practitioner who:

a) Is entitled under the laws of their Canadian jurisdiction to treat patients with a prescription drug.
b) Is practicing their profession in that same Canadian jurisdiction.
c) Has an existing therapeutic relationship with the patient.

With regards to Controlled Substances (narcotics, controlled drugs, benzodiazepines and other targeted substances) there are no restrictions on accepting new prescription orders from other Canadian jurisdictions, provided registrants use professional judgement and practice due diligence in verifying the prescription’s authenticity and appropriateness.

Registrants licensed in Ontario that are Providing Services to Patients outside of Canadian Jurisdictions
Registrants are permitted to provide care to patients where there is an existing therapeutic relationship, and the patient is temporarily located outside of Canada. In doing so, registrants must comply with the laws, regulations, standards and policies, and any other professional practice requirements as stipulated by the Ontario College of Pharmacists and the laws, standards and policies of where the patient is located to ensure continuity of care.

Out-of-Country Prescriptions
Dispensing for Out-of-Country Prescriptions
Registrants must not dispense a drug that has been authorized by a practitioner who does not hold a valid certificate of registration in a Canadian jurisdiction.

  • As per Canada’s Food and Drug Regulations, an authorized practitioner must hold a valid certificate of registration to practice their profession in a Canadian jurisdiction and maintain an active practice in the Canadian jurisdiction where they are registered.
  • In situations where a registrant suspects that a practitioner does not maintain an active practice in the Canadian jurisdiction that issued their certificate of registration, it is the registrant’s professional responsibility to make appropriate inquiries with the practitioner before dispensing the drug.

Co-signing of prescriptions refers to Canadian practitioners providing signatures to prescriptions issued by another prescriber not licensed in Canada, for the purposes of them being filled by a Canadian pharmacy. Registrants must not facilitate the co-signing of prescriptions authorized by practitioners not licensed in Canada.

  • Registrants are reminded that the practitioner must have an established therapeutic relationship with the patient for whom the prescription is provided. (e.g., College of Physician and Surgeons of Ontario’s Prescribing Drugs policy).
  • It is the professional responsibility of registrants to follow up with the practitioner if there is any uncertainty about the validity of the prescription or whether the prescribing practitioner has an established therapeutic relationship with the patient.

Registrants not licensed in Ontario that are Providing Services to Ontario patients
To support access to pharmacy services, pharmacy professionals located in another Canadian jurisdiction and who are not licensed to practice in Ontario may provide care to Ontario patients if the following conditions are met:

a) They hold a certificate of registration from another Canadian jurisdiction; and,
b) They comply with the laws, regulations, standards and policies, and any other professional practice requirements as stipulated by their province of registration in addition to those of the Ontario College of Pharmacists and the NAPRA Model Standards of Practice for Canadian Pharmacists.

Legislative References:
Implementation

Published: August 25 2022
Version #: 2.00
College Contact: Pharmacy Practice

Revision History
Version # Date Action
1 2003;

2013

Out-of-Country prescriptions policy
2 2022 Out-of-Country prescriptions policy and Out-of- Province Prescriptions fact sheet combined and updated into new Cross Jurisdictional Pharmacy Services policy; Out-of-Country prescriptions policy and Out-of-Province Prescriptions fact sheet retired.