Frequently Asked Questions from Pharmacy Practice


FAQ logoNote that these answers were current at date of publication and are meant as guidance for pharmacy professionals. The College cannot tell a registrant what course of action to take, provide legal advice or opinions, or make any decisions for a registrant.


RELEASING INFORMATION ABOUT A DECEASED PATIENT

Q: Can we give the details of a deceased patient’s profile to family members, including medical history and medical expenses for tax purposes?

ANSWER

A: Pharmacies and pharmacy professionals in Ontario have responsibilities to safeguard the personal health information of their patients as health information custodians under the Personal Health Information Protection Act (PHIPA). One of the additional resources on the OCP website is called Quick Links to the Office of the Information and Privacy Commissioner of Ontario (IPC). These resources have been selected to assist registrants in understanding their obligations under PHIPA, such as the Fact Sheet #15 –Obtaining Personal Health Information About a Deceased Relative. Additional information can be found on the IPC website.


RECORD KEEPING

Q: Our community pharmacy has original prescriptions and hard copies dating back to before we started scanning. How long do we need to keep these?

ANSWER

A: Please refer to the Guideline — Record Retention, Disclosure, and Disposal and the Fact Sheet – Record Keeping and Scanning Requirements.

Regulations under the Drug and Pharmacies Regulation Act (DPRA) require pharmacies to make and retain a scanned copy of all original prescriptions.  All prescription records in the pharmacy’s possession, scanned or in hardcopy form, are subject to the retention period of a minimum 10 years after the last date of service provided to the patient.

Since records cannot be destroyed until at least 10 years after the patient has ceased to use a pharmacy’s services (notwithstanding the provision for children under 18 years of age), the date of when a record can be destroyed cannot be pre-determined.  If the patient continues to use the services of the pharmacy, the patient record would need to be retained on file for an indefinite period of time (i.e. forever).

Also, the patient record must be maintained as a whole, therefore dispensing records (hard copies) and prescriptions (originals or scanned originals) cannot be singled out for destruction. The decision to destroy paper based records after they have been scanned is at the discretion of the Designated Manager who should evaluate the backup processes in place to safeguard records for the required timeframe.


BEST POSSIBLE MEDICATION HISTORY AND PHARMACY TECHNICIANS

Q: Does a pharmacy technician have the scope of practice to perform a Best Possible Medication History (BPMH) when a patient is admitted to – or discharged from – hospital?

ANSWER

A: The Pharmacy Act and Ontario Regulation 202/94 – General define Scope of Practice and Authorized Acts for all pharmacy professionals. The steps involved in conducting a BPMH, such as gathering patient records from various sources and identifying discrepancies, are not necessarily governed by legislation. However, the regulation does set out Terms, Conditions and Limitations on a pharmacy technician’s certificate of registration, and pharmacy technicians cannot provide information or education relating to drug use which requires therapeutic knowledge, clinical analysis or assessment (s18.4).

Pharmacy technicians responsible for performing a BPMH must have the appropriate knowledge, skills and training to meet the Standards of Practice for Pharmacy Technicians outlined in #9-#12. When collaborating to provide patient care, technicians are expected to document their decisions and actions in the patient’s health record, including the relevant health and drug information they’ve obtained and their interpretation of this information.

The Pharmacy Manager/Administrator should establish policies and procedures for conducting medication reconciliations, outlining the respective roles for pharmacy technicians and pharmacists. OCP resources to consult include the Hospital Assessment Criteria, Standards of Operation, and the Pharmacy Technician Practice Assessment Criteria.  External resources are also available from organizations such as the Canadian Society of Hospital Pharmacists (CSHP), ISMP Canada, the Canadian Patient Safety Institute (CPSI), etc.  Collaborating with peers at other hospitals to share operational advice and best practices is also encouraged.


NEW ASSISTANCE PROGRAM FOR REGISTRANTS EXPERIENCING MENTAL HEALTH OR SUBSTANCE USE CONCERNS

Since 2004, the College has offered an assistance program offering intervention, assessment, and monitoring to its registrants experiencing work/life stress, concerns about their mental health or substance use problems.

As of July 5, 2019, Lifemark Health Group provides case management and monitoring services for registrants on behalf of the College. Under the Ontario Pharmacy Health Program (OPHP) administered by Lifemark, the primary objective is to ensure that registrants receive appropriate treatment and monitoring services and remain in stable recovery thereby allowing them to practise safely when they return to the practice environment.

The program is available to all registrants of the College. Registrants can access the program directly and anonymously. Access can also be facilitated on behalf of the registrant by the College.

Note: The program was previously administered on behalf of the College as the Ontario Pharmacy Support Program by the Centre for Addiction and Mental Health (CAMH). CAMH no longer provides this service. Those currently participating in the CAMH program have been notified of the transition to Lifemark and the College is working closely with both Lifemark and CAMH to ensure an effective and seamless transition to the new program.

STAYING ALERT TO FRAUDULENT PRESCRIPTIONS

In June and September 2019, the College shared an alert in e-Connect from the Ontario Provincial Police regarding a specific ongoing fraud occurring at pharmacies involving false oxycocet prescriptions. Specifically in this case:

Police have been advised that a particular amount of oxycocet has been used in a series of frauds across Ontario.

The prescription is for 120 oxycocet pills. Suspects are using the agent system to pick up the prescription for a parent, relative, or neighbour. The patient will present the identification of the person as a facsimile as either a picture on a phone or a copy of the health card or accepted Identification.

The College is pleased to let registrants know that as a result of increased awareness of this fraud, numerous individuals were arrested and charged. Registrants should continue to be vigilant and report any fraudulent prescriptions to the police.

To assist registrants in identifying and handling fraudulent prescriptions, the College provides two fact sheets on our website, Forgery: Management and Reporting of Fraudulent Prescriptions and Forgery: Tips for Identifying Fraudulent Prescriptions.