Prescribing and Providing Controlled Substances during the Coronavirus Pandemic


Published: April 8, 2020

Legislative References:

Additional References:


To maintain patient access to prescriptions for controlled substances during the novel coronavirus (COVID -19) pandemic, Health Canada has issued a class exemption under subsection 56(1) the Controlled Drugs and Substances Act (CDSA) and its Regulations.

Prescribers and pharmacists, authorized within their scope of practice defined in provincial legislation, are exempted from the certain provisions of the legislation when prescribing, selling, or providing a controlled substance to a patient, or transferring a prescription for a controlled substance to another pharmacist for the purposes of facilitating continuing of their treatment.

This information is intended to support pharmacists in implementing this temporary exemption, and should be applied within the framework established by the Standards of Practice, Code of Ethics, and existing policies and guidelines. Pharmacists must continue to use their professional judgement to promote the safe and optimal use of controlled substances while ensuring continuity of care and patient access are maintained.

Verbal Prescription Orders
  • The Narcotic Control Regulations (NCR) define narcotic and verbal prescription narcotic
  • This exemption allows prescribers to issue verbal orders for all narcotics and controlled drugs
Transferring a Prescription for a Controlled Substance

Additional reference: Fact Sheet – Prescription Transfers

  • Pharmacy technicians are not exempted and cannot transfer prescriptions for controlled substances
  • Transfer information must be accompanied by a copy of the original prescription, which should be clearly marked as such
  • If the transferring pharmacy is not available, the pharmacist may be reasonably satisfied about the existence and details of the prescription by obtaining sufficient information from an alternative source such as:
    • The prescription label from a previous prescription
    • The prescription receipt from a previous prescription, medical history report or printout
    • A photograph or facsimile of the prescription
  • Alternatively, the prescribing physician could be contacted by the pharmacist to obtain a verbal prescription.
  • When dispensing a refill under the above circumstances, the pharmacy where the prescription originated should be contacted as soon as possible to complete the transfer details, ensuring that only one active prescription record exists and that all required information is shared
  • Pharmacists must be diligent in preventing opportunities for diversion, as alternate sources of information are less reliable and secure, and may be available to more than one pharmacy
    • Additional precautions, such as performing a Narcotic Monitoring System (NMS) inquiry (using intervention code “DU”), dispensing a lesser amount[1], retaining the vial/label/receipt, etc. may be warranted based on the pharmacist’s professional judgement and assessment

Additional reference: Fact Sheet – Delivery of Prescriptions

  • Exemption from s5 of the CDSA reinforces that pharmacy personnel or other persons may legally deliver a controlled substance on behalf of a pharmacist
  • In addition to the requirements outlined in the Fact Sheet – Delivery of Prescriptions, Health Canada requires that the delivery person has a copy of the exemption in their possession while transporting any controlled substances
Managing Patients on Opioid Agonist Treatment
Renewing/Adapting a Prescription for a Controlled Substance or Monitored Drug

Additional reference: Guideline – Initiating, Adapting and Renewing Prescriptions

  • Prior to adapting or renewing, pharmacists are expected to collaborate with the prescriber or primary care provider. If collaboration is not possible, in order to maintain continuity of care for the patient, pharmacists may proceed with the adaptation or renewal and notify the prescriber within a reasonable period of time
  • Where the pharmacist is not in possession of the existing order and cannot receive a copy or verbal confirmation of the prescription directly from the pharmacy where the prescription was dispensed, the pharmacist may be satisfied as to the existence and details of the prescription from an alternative source as described above
  • The pharmacist issuing the prescription renewal must also record on it the identifying number and type provided by the patient to meet Narcotic Monitoring System (NMS) requirements
  • For the purposes of submitting a prescription renewal or adaptation issued by a pharmacist to NMS, the Prescriber ID Reference Number for Ontario pharmacists is 09
Prescriber Notification
  • Provincial regulations specify that the original prescriber and/or primary care provider must be notified within a reasonable time after renewing a prescription or making an adaptation that is clinically significant (including de-prescribing)
  • If the prescriber is unreachable, there may other ways to ensure the patient record is complete and consistent across health care providers, such as
    • Providing the patient/agent with a copy of the prescription, clearly marked as such
    • Providing the patient/agent with an up-to-date prescription history from the pharmacy
    • Any other manner deemed suitable by the pharmacist that will achieve the intended purpose (i.e., continuity of care and a complete patient record)
  • Depending on the circumstances, pharmacists must use professional judgment in determining how much information to convey to the original prescriber and/or primary care provider
  1. A drug may be dispensed in less than the entire quantity prescribed, if the proper exercise of professional judgment by the dispenser so requires; R.R.O. 1990, Reg. 936: NOTICE TO PATIENTS