Commonly asked questions and feedback obtained during the consultation regarding the Virtual Care Policy.
The COVID-19 pandemic has increased the provision of virtual care in a variety of healthcare settings, including pharmacy. As a result of these factors, this policy was developed to provide pharmacy professionals with the College’s practice expectations for engaging in virtual care.
The College is not mandating virtual care for pharmacy professionals. The Virtual Care policy outlines requirements for pharmacy professionals to fulfill when providing virtual care, however the decision to provide virtual care must be made in conjunction with, and consent of the patient, and when the benefits to the patient outweigh any risk. Registrants must determine whether virtual care and the manner in which it is delivered is a suitable method of care delivery for the patient interaction and whether providing care virtually will enable them to meet all legal and professional obligations before deciding to provide virtual care to their patients.
The Virtual Care policy defines virtual care as a professional interaction between a registrant and a patient that occurs remotely using secure enabling technology that facilitates registrant-patient interaction for example, videoconferencing. Care provided over the telephone, if it is in accordance with the definition above, would classify as virtual care. On the other hand, routine phone calls that are administrative or clerical in nature would not be classified as virtual care.
Key elements for the registrant to consider when determining if an interaction would be classified as virtual care might include:
- The interaction is within the scope of practice of a pharmacy professional as described in the Pharmacy Act and the Standards of Practice (e.g., the provision of information and education related to drugs and devices; the monitoring and management of medication therapy; recommending or prescribing self-care or drug therapies, etc.)
- The interaction and patient care provided should be documented on the patient record to ensure continuity of care as per standards and guidelines.
- The interaction is not appropriate for assigning to an unregulated personnel due to the nature or content of the discussion
Examples of virtual care interactions include:
- Educating a patient on the use of a medical device
- Educating a patient about their medication therapy
- Conducting a medication review
Registrants must assess whether virtual care is appropriate for the patient as explained in the Virtual Care Policy. When making this assessment, registrants should consider a variety of factors including the patient’s circumstances such as their availability, willingness, location, the suitability of the technology being used in light of the patient’s characteristics, urgency or timeframe, etc. and adapt and tailor the provision of care accordingly. Pharmacy professionals have an ethical obligation to consider what is in the patient’s best interest and that the chosen method is conducive to achieving positive health outcomes. Patient autonomy and choice should be respected, as demonstrated through informed consent to the provision of virtual care.
The scope of practice and authorized acts for pharmacy professionals is defined in the Pharmacy Act s 3, 4. Out of these, only the “dispensing, selling or compounding a drug or supervising the part of a pharmacy where drugs are kept” must take place in an accredited pharmacy, as per the Drug and Pharmacies Regulation Act. A pharmacy professional’s cognitive skills and knowledge reside with the individual registrant and may be used in a variety of practice settings. The Virtual Care Policy reminds registrants of their obligations to maintain privacy and confidentiality and, as health information custodians, to meet the requirements of the Personal Health Information Protection Act. There are Quick Links to the Office of the Information and Privacy Commissioner of Ontario (IPC) available as additional resources on the OCP website for more information on this topic, including the IPC Guideline – Privacy and Security Considerations for Virtual Healthcare Visits.
Expectations for documenting the care provided are the same whether care is provided virtually or in person. Specific record-keeping and length of retention requirements, set out in PART VII.3 of O. Reg 202/94 and in the Record Retention, Disclosure, and Disposal Guideline, must also be met. When practicing outside of a pharmacy, it is the registrant’s duty to exercise due diligence implementing procedures that will fulfill these professional and legal responsibilities.
If remote access to a pharmacy’s practice management (software) system (PPMS) or electronic records is available, NAPRA standards expect that such access uses secure transmission, incorporates access control, and does not store unencrypted personal health information on the user’s remote computer that could later be accessed by an unauthorized third party. NAPRA states, “The flexibility provided by working outside of a dispensary cannot come at the expense of patient confidentiality and data security. Remote access can represent a serious threat to patient privacy if it leaves unencrypted copies of patient records on laptops, mobile devices, or shared desktop computers.”