Supplemental Guidance

This supplemental guidance is a resource intended to support registrants’ understanding of the Supervision of Pharmacy Personnel Policy. 

Supervision of Pharmacy Personnel
Introduction

A domain of the Model Standards of Practice[1] for pharmacy professionals is the demonstration of leadership and stewardship of the profession. Registrants contribute to the profession by providing oversight and leadership to other pharmacy personnel, and mentoring students and interns, through supervision. Supervisory relationships can take many forms, including between regulated pharmacy professionals and between regulated and unregulated pharmacy personnel, and the extent of supervision provided can vary. This document provides additional information and guidance to support interpretation and implementation of the Supervision of Pharmacy Personnel Policy (‘the policy’). This supplemental guidance is intended to be used alongside the policy and does not replace the policy. Definitions of terms in this guidance document can be found in the Supervision of Pharmacy Personnel Policy.

Principles
  • Professionalism: Effective supervision requires professionalism, mutual respect and an ongoing learning mindset to support positive supervisory relationships and the provision of best possible patient care. Registrant should strive to exemplify the tenets of professionalism as described in the Principles of Professionalism for the Profession of Pharmacy (NAPRA).
  • Ethical behaviour: Registrants are bound by the Code of Ethics[2] and must maintain these ethical standards at all times. Professional and ethical behaviour is relevant to supervision as there is a natural power imbalance between the supervisor and the person they are supervising. Any boundary violations or acts of professional misconduct are not tolerated.
  • Public protection: Pharmacy professionals must protect the public by ensuring that the care they and other pharmacy personnel provide to patients is safe, competent and ethical care. Any risk to public safety that is observed as part of supervisory duties should be addressed diligently.
  • Judiciousness: The level of supervision provided to an individual will vary depending on the circumstances. It is up to the supervisor to thoughtfully determine the appropriate level of supervision that is required for the individual they are supervising.
  • Shared accountability: Pharmacy professionals are responsible for the safety and quality of care they provide, as well as the care provided by those they supervise. Supervisors may be held responsible, depending on the issue, if the pharmacy personnel they are supervising is the subject of a complaint.
Guidance

Interpretation of Definitions

Supervision vs direct supervision

Definitions of terms, found in the policy, are specific to the policy and the pharmacy profession in Ontario.

The intention of direct supervision is to ensure that a certain level of supervision occurs to allow for observation and prompt intervention. This is achieved by physical proximity – the physical presence of the supervisor on the premises (always) and remaining close to the person being supervised (when necessary). The extent of this proximity, as with many other decisions related to supervision, is at the discretion of the supervisor, and their judgment of the situation (e.g., is this person experienced enough to do this task? Should I stay close enough to observe?).

When the term supervision is used, by definition, it means that the person supervising the pharmacy personnel does not need to be on the premises; however, they are not precluded from being on the premises.

Supervision vs delegation

In practice, it is possible that the pharmacy professional responsible for supervising personnel performing their duties is also the person assigning those duties. In this situation, the term delegate might be used interchangeably with assign; however, in the context of pharmacy practice, “delegation” has a specific meaning associated with performing controlled acts as per section 27(1)(b) of the Regulated Health Professions Act, 1991 (RHPA). This can cause confusion between “supervision” and “delegation.”

The College’s Medical Directives and the Delegation of Controlled Acts policy explains that a pharmacist can delegate their authority to perform a controlled act to a person, who may or may not be regulated, and who does not have that authority. The pharmacist is responsible for ensuring that the delegated act is performed competently. A supervising pharmacy professional should not say they are “delegating” when they are assigning duties to personnel. This term should only be used in situations involving delegation of authority to personnel to perform a controlled act in accordance with the RHPA and OCP policy.

Determining the Extent of Supervision

It is the responsibility of the supervisor to determine the appropriate level of supervision to provide to a person they are professionally obligated to supervise. Failing to do so is considered an act of professional misconduct, under O. Reg. 130/17 of the Pharmacy Act, 1991.[3] When determining the extent of supervision required, consider the scope of practice of the pharmacy personnel being supervised, the practice setting (e.g., is direct supervision required?), the knowledge, skills and experience of the person to be supervised, and the timing of supervision (i.e., supervision may be needed before, during and/or after the performance of a controlled act or other professional service). The Pharmacy Connection article, Six Things to Consider when Supervising Pharmacy Practice, is an additional helpful resource in determining the level of supervision needed. The level of supervision may change over the course of a supervisory relationship, or at the discretion of a temporary, interim supervisor.

Documentation of supervisory relationships, and the supervisor’s rationale of what a person under their supervision can and cannot do is required, as noted in the policy. This documentation can be made in human resources files, an email between the supervisor and the person being supervised or any other reasonable form of documentation that can be readily retrieved and shared with others, if needed.

Supervision Authority and Accountability

In addition to the supervision authority as described in the policy, there is additional guidance related to accountability and responsibilities when supervising different pharmacy personnel.

Guidance for the Supervisor

As described in the policy, registrants acting as supervisor must assess their own competence, skills and training needs to ensure they can safely provide supervision. This includes ensuring they meet any necessary requirements to perform assigned duties themselves. For example, if a pharmacy professional supervises someone in performing injections, the pharmacy professional must have registered their own injection training prior to supervising this clinical skill.

Facility-specific supervision policies and procedures may assist a supervisor in communicating information and expectations related to supervision to all involved parties (e.g., supervisors, the person(s) being supervised and all other pharmacy personnel).

Guidance for Supervising Interns and Intern Technicians

Unlike their pharmacy technician counterpart, intern technicians (introduced as a new registrant class in October 2024) are not authorized to administer injections. While these individuals may have previously been performing these controlled acts during their time as a pharmacy technician student, it is important to highlight that the provisions to do so as an intern technician do not currently exist in legislation. Until this practice scope changes, medical directives or direct orders may serve as a means to enable this practice. As noted previously, it is important for supervisors to be familiar with the scope of practice of the pharmacy professionals they are supervising.

Guidance for Supervising Students

On October 1, 2024, the registered pharmacy student class of registration was removed students are no longer regulated by the Ontario College of Pharmacists (OCP). This change does not impact how students are supervised nor change the existing responsibilities of the supervising pharmacy professional. Pharmacy students and pharmacy technician students, in fulfilling the requirements to become a registered pharmacy professional, are authorized through the Regulated Health Professions Act, 1991 (RHPA)[4] to perform controlled acts under the supervision of a pharmacy professional while fulfilling the requirements to become a member of a health profession (i.e., during experiential learning placements). Supervisors determine the degree of oversight required for students based on an assessment of their level of education and experience in the context of the duties assigned (e.g., the complexity of the patient’s condition, the level of risk in clinical decision-making).

Supervisors should set clear expectations regarding the student’s role during their time at the pharmacy, and these expectations are made clear to all pharmacy personnel. Pharmacy-specific policies and procedures may assist in setting these expectations. As delineated in the policy, a student’s time in pharmacy during experiential learning placements should be prioritized for experiential learning and skill development, rather than performance of administrative tasks or meeting any pharmacy-specific metrics. This does not mean that students cannot perform administrative or other duties; rather, these should not be prioritized over clinical learning activities. The educational institutions organizing placements may have additional resources and best practices to assist with setting clear boundaries and expectations in the workplace around the student role.

Students are no longer registered with OCP, therefore any complaints made against a student related to patient care could be filed against the supervising pharmacy professional, as they are held responsible for the conduct or actions of those under their supervision. Designated Managers or pharmacy owners are responsible and liable for the actions of students.[5]

There may be instances where a pharmacy student, in completing a student placement, is approved by their faculty to be supervised by a regulated non-pharmacy health professional. This may occur if the program, education or training includes a clinical component in a non-pharmacy premises. Supervision by a non-pharmacy regulated health professional may occur in these instances when students are not performing the controlled acts of the pharmacy profession. As outlined in s.29(b) of the RHPA (and noted in the policy), students must be supervised by a Part A pharmacy professional when performing the controlled acts of the profession.

Guidance for Supervising Part B Pharmacists and Part B Pharmacy Technicians Transitioning to Part A

Part B pharmacists and Part B pharmacy technicians are practising pharmacists who do not provide patient care. However, as outlined in O.Reg. 256/24 (General) of the Pharmacy Act, 1991, a Part B registrant transferring to Part A may, in meeting the requirements to transfer from Part B to Part A and only with written approval from the Registrar, provide patient care and perform controlled acts. In these situations, Part B registrants require direct supervision and should not be viewed, or utilized in practice, as Part A registrants.

Guidance for Supervising Pharmacy Assistants or Other Unregulated Personnel

Pharmacy assistants and other personnel working in pharmacies (e.g., cashiers, clerks, volunteers, students employed outside of an experiential learning placement) are unregulated staff. OCP has no authority over their actions, and therefore does not have a policy regarding who must supervise their work. It is at the discretion of the employer, the Designated Manager or pharmacy manager to determine who supervises pharmacy assistants and other unregulated personnel, and how.

To support a pharmacy professional in the dispensing or compounding processes, pharmacy assistants may be assigned certain tasks (e.g., counting, measuring, labelling, packaging, managing inventory), as part of those controlled acts. However, the college cannot hold unregulated staff members accountable, and the supervising pharmacy professional remains responsible and accountable for the controlled act. This accountability requires that the supervising pharmacy professional implement whatever safeguards are necessary to ensure the steps performed by the pharmacy assistant are done correctly, such as with intermittent checks at each step of the controlled act and a final check. As noted earlier, Designated Managers or pharmacy owners are responsible and liable for the actions of unregulated personnel.

Practice Settings without Pharmacist Supervision

Pharmacy professionals who require pharmacist supervision to perform the controlled acts authorized for the profession may work in a setting where this is not available or possible, such as a non-accredited workplace or a hospital without a pharmacist (either on site or available remotely). In these situations, the ability to practice under independent authority is limited; however, they could accept delegation of authority from another regulated health professional (e.g., physician, nurse practitioner) to perform controlled acts as described in the Medical Directives and the Delegation of Controlled Acts Policy.  In these instances, workplaces that are not listed in the College’s system are brought to the attention of the College through the New Workplace Information form.


Creating a Healthy Environment for Supervision

Supervisors should strive to create a work environment that is psychologically safe and promotes learning and quality improvement. This can be achieved through positive interpersonal relationships, mutual trust, supportiveness, openness and behavioural integrity of supervisors.[6] The nature of supervisory relationships intrinsically presents an imbalance of power and an underlying hierarchy, which, if not well-managed, can lead to negative interpersonal experiences in the pharmacy environment. Pharmacy professionals are expected to be stewards of the profession; each member of the pharmacy team has an important role to play, and an environment of mutual respect and acknowledgement of the value of all roles, including learners and trainees, will result in better patient care.

Remediation Processes: Terms, Conditions or Limitations Related to Supervision

Occasionally, a registrant may have specified terms, conditions or limitations (TCLs) imposed on their certificate of registration, as part of disciplinary actions to address issues of misconduct or incompetence. Supervision, for a specified period of time or with respect to certain aspects of practice, may be part of those TCLs. These disciplinary decisions and related TCLs on a registrant’s certificate of registration are publicly posted on the Public Register.

Initial Publish Date: October 1, 2024

Additional Resources

 

    1. Model Standards of Practice for Pharmacists and Pharmacy Technicians in Canada ↑
    2. Ontario College of Pharmacists Code of Ethics ↑
    3. Regulation 130/17 (Professional Misconduct and Conflict of Interest) under the Pharmacy Act, 1991 ↑
    4. Regulated Health Professions Act, 1991 (RHPA) (Section 29(1)(b)) ↑
    5. Drug and Pharmacies Regulation Act, 1990 ↑
    6. Safe Pharmacies Need PSYCHOLOGICAL SAFETY ↑
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