Scope of Practice, Spring/Summer 2020

College Board Approval of Regulations an Important Step Towards Minor Ailment Prescribing for Ontario Pharmacists

Banner Spring/Summer 2020 - Minor Ailments
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In 2019, the Minister of Health asked the College to submit regulations to enable an expanded scope of practice for pharmacists that, among other things, would allow for prescribing of drugs for certain minor ailments. This expanded scope is intended to help ease the burden on the healthcare system, support streamlined care pathways, improve access to routine care in the community and support better patient outcomes.

At the June 15, 2020 meeting, the OCP Board of Directors approved amendments to Regulation 202/94 of the Pharmacy Act Part VII.3 (Controlled Acts) that would enable pharmacists to prescribe medications in the American Hospital Formulary Service (AHFS) Pharmacologic-Therapeutic Classification system categories for 12 minor ailments (see table below for list.)

The regulatory requirements for prescribing were informed by extensive stakeholder engagement and anchored in the existing provisions for prescribing for smoking cessation, which pharmacists have been authorized to do since 2012. The regulatory requirements include patient assessment, documentation and sharing information with the patient’s primary care provider in support of continuity of care and inter-professional collaboration. In addition, pharmacists are required to provide the patient with the prescription and inform them of their right to fill the prescription at another pharmacy. Please note that the government must approve the regulations before they come into effect.

# CONDITION AHFS CLASSIFICATION
1. Urinary tract infection (uncomplicated)
  • Anti-infective Agents: Antibacterials. Sulfonamides (8:12.20)
  • Anti-infective Agents: Urinary Anti-infectives (8:36)
2. Dermatitis (atopic/eczema, allergic and contact skin rashes)
  • Skin and Mucous Membrane Agents: Anti-inflammatory Agents. Corticosteroids (84:06.08)
3. Insect bites (including tick bites) and urticaria (hives)
  • Skin and Mucous Membrane Agents: Anti-inflammatory Agents. Corticosteroids (84:06.08)
  • Antibiotic Tetracyclines (8:12:24)
4. Conjunctivitis (bacterial, allergic, viral)
  • Eye, Ear, Nose, and Throat Preparations: Anti-infectives. Antibacterials (52:04.04)
  • Eye, Ear, Nose, and Throat Preparations: Antiallergic Agents (52:02)
5. Allergic rhinitis (nasal symptoms from allergies)
  • Eye, Ear, Nose and Throat Preparations: Anti-inflammatory Agents. Corticosteroids (52:08.08)
  • Eye, Ear, Nose and Throat Preparations: Antiallergic Agents (52:02)
6. Candidal stomatitis (oral thrush)
  • Skin and Mucous Membrane Agents: Anti-infectives. Antifungals. Polyenes (84:04.08.28)
7. Herpes labialis (cold sores)
  • Anti-infective Agents: Antivirals. Nucleosides and Nucleotides (8:18.32)
  • Skin and Mucous Membrane Agents: Anti-infectives. Antivirals (84:04.06)
  • Skin and Mucous Membrane Agents: Anti-inflammatory Agents. Corticosteroids (84:06.08)
8. Hemorrhoids
  • Skin and Mucous Membrane Agents: Anti-inflammatory Agents. Corticosteroids (84:06.08)
  • Skin and Mucous Membrane Agents: Antipruritics and Local Anesthetics (84:08)
  • Skin and Mucous Membrane Agents: Miscellaneous Skin and Mucous Membrane Agents (84:36)
9. Gastroesophageal reflux disease (GERD)
  • Gastrointestinal Drugs: Antiulcer Agents and Acid Suppressants. Histamine H2-Antagonists (56:28.12)
10. Dysmenorrhea (menstrual cramps)
  • Central Nervous System Agents: Analgesics and Antipyretics. Nonsteroidal Anti-inflammatory Agents. Other Nonsteroidal Anti-inflammatory Agents (28:08.04.92)
11. Musculosketelal sprains and strains
  • Central Nervous System agents: Analgesics and Antipyretics. Nonsteroidal Anti-inflammatory Agents. COX-2 inhibitors (28:08.04.08)
  • Central Nervous System agents: Analgesics and Antipyretics. Nonsteroidal Anti-inflammatory Agents. Other Nonsteroidal Anti-inflammatory Agents (28:08.04.92)
12. Impetigo (bacterial skin infection common in children)
  • Skin and Mucous Membrane Agents: Anti-infectives. Antibacterials (84:04.04)
  • Skin and Mucous Membrane Agents: Anti-inflammatory Agents. Corticosteroids (84:06.08)

APPROVAL OF MANDATORY EDUCATION REQUIREMENT TO SUPPORT PHARMACIST MINOR AILMENT PRESCRIBING

As the College proposed regulatory amendments to enable pharmacists to prescribe for certain minor ailments, it committed to identifying the appropriate parameters that optimize the knowledge and skills of pharmacists in support of performance of this act and overall delivery of safe, high quality patient care.

The OCP Board reviewed proposed education requirements to support this expanded scope of practice once regulations are formally approved by government. In consideration of the need to ensure pharmacists fully understand their ethical, legal and professional obligations of prescribing for minor ailments while meeting standards of practice, the Board approved the requirement for all Part A pharmacists to complete mandatory education – free to registrants and not to exceed two hours in length – on prescribing for minor ailments and that the education be completed within one year of its availability and before engaging in such practice.

The mandatory education will be focused on ensuring pharmacists fully understand their ethical, legal and professional obligations of prescribing for minor ailments while meeting established standards and providing safe, quality care to their patients. The mandatory education requirement does not relate to clinical training; the College will continue to expect that pharmacists who engage in this new authority, once approved by government, will have the required knowledge, skills and judgement to do so safely and ethically and in accordance with the Standards of Practice, Code of Ethics, and current clinical guidelines.

For complete details on the education requirement, please review the materials from the June 15, 2020 Board meeting.

It is important to note that while other pieces of legislation, such as the Public Hospitals Act, may impact the ability of some pharmacists to practice to the full extent of this new authority, the regulations apply to the profession as a whole and are not specific to practice settings.


A COLLABORATIVE, SYSTEMS-BASED APPROACH TO CONSULTATION

Recognizing that the ability to achieve sustainable, system-wide effects in the health system involves strengthening coordination of care and collaboration, the College has taken a collaborative approach to expanding scope of practice, engaging different parts of the healthcare system – patients, registrants, physicians, nurse practitioners and other healthcare providers, public health experts, professional associations, regulators and others – to gain valuable insights that have and will continue to inform the work to enable expanded scope of practice.

In order to achieve an understanding of where pharmacist prescribing for minor ailments could have the greatest impact on improving system and patient outcomes, the College engaged with key groups extensively over the regulatory development process. These engagements included a formal open consultation, the establishment of the Minor Ailments Advisory Group (MAAG), a survey sent to all registrants, consultation with the public and patients through a series of facilitated focus groups, including the Citizen Advisory Group, consultation with pharmacy associations, and consultation with health professional associations and regulators. In total, the College received feedback from more than 1,000 stakeholders and individuals.


GOVERNMENT MUST APPROVE REGULATIONS BEFORE PHARMACISTS CAN PRACTICE EXPANDED SCOPE

Board approval of the regulations for submission to government is the latest in a series of steps that are required before pharmacists can prescribe for minor ailments in Ontario. Now that the regulations have been submitted to the Ministry of Health, the government will review the submission and post the regulations on the provincial Regulation Registry prior to any final government approval. No timeline has been established for final government approval.

In the meantime, the College is developing a comprehensive implementation plan aimed at supporting and informing the profession as well as the public and other health system stakeholders once regulations are approved. This will include exploring the availability of resources and tools to support the profession, updating policies and guidelines, developing a communications plan to inform the public and stakeholders, and creating an evaluation plan to monitor and assess the impact of these changes on the healthcare system and patient outcomes.

Further details regarding implementation and the mandatory education requirement for minor ailment prescribing will be communicated in the coming months as the College prepares for government approval of the related regulations. Please stay tuned to e-Connect and the College website for updates.

UPDATE ON THE COLLEGE’S FALL 2019 REGULATORY SUBMISSION TO GOVERNMENT

Last November, at the request of the Minister of Health, the College submitted regulations to the Ministry aimed at allowing pharmacists to administer the influenza vaccine to children as young as two years old, renew prescriptions in quantities of up to a year’s supply, and administer certain substances by injection and/or inhalation for purposes that are in addition to patient education and demonstration. These regulations were posted on the provincial regulatory registry on June 12, 2020 as part of the government’s regulation consultation period.

In addition, the College was asked to work with the Ministry to authorize pharmacists to perform certain point of care tests for certain chronic conditions. To enable this, changes need to be made to regulations under the Laboratory and Specimen Collection Centre Licensing Act. These regulations have been posted on the provincial regulatory registry as well.

The posting on the registry is a positive development and is an important step in the regulatory approval process. As a reminder, government approval is required before the regulations come into effect and no timelines for approval have been announced at this time.

Please stay tuned for all the latest updates regarding expanded scope of practice for pharmacists in e-Connect and on the OCP website.


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