To clarify the College’s expectations for providing pharmacy care to patients located outside of Ontario, the Board approved the Cross-Jurisdictional Pharmacy Services Policy in June 2022. This policy applies to registrants and patients in other Canadian jurisdictions, as well as those located outside of Canada.
Ontario pharmacy professionals are increasingly providing care to patients who may not be physically located within the province. This practice is more likely to occur in cities and towns along provincial borders where patients may live in one province and work in another. This can lead to confusion for registrants about the regulations they must follow, and for patients around the accessibility of pharmacy services across jurisdictional borders.
The Cross-Jurisdictional Pharmacy Services Policy explains that registrants providing care to patients located outside of Ontario are expected to adhere to the professional expectations and legal requirements of both the College and the province or territory in which the patient is located.
Providing pharmacy care to patients across Canadian jurisdictions
When providing care to a patient in another province, pharmacy professionals may first need to be registered by that province’s pharmacy regulator to comply with their practice requirements. Registrants providing care to patients within Ontario, or in other Canadian jurisdictions, must always obtain explicit informed consent from patients or their substitute decision-maker when providing pharmacy services. Once consent is obtained, registrants can accept a written, verbal, or faxed prescription, including refills from prescriber(s). However, it is important to note that they are expected to use professional judgment and practice due diligence in verifying the prescription’s authenticity regardless of the jurisdiction of origin.
Consent to treatment is informed if, before giving it, the person received the information about the nature, expected benefit, potential risks or side effects, other options and consequences of not having the treatment (or any information that a reasonable person in the same circumstances would require in order to make a decision about the treatment) and the person received responses to their request for additional information (Health Care Consent Act, 2004, s.11(2)).
Providing pharmacy services to patients outside of Canada
Patients may need access to medication-related information from their pharmacy through virtual care if they are temporarily outside of Canada – while on vacation, for instance.
Registrants may only provide pharmacy services to patients temporarily located outside of the country if their prescription has been authorized by a prescriber with a valid certificate of registration in a Canadian jurisdiction, and if both the registrant and prescriber have an existing therapeutic relationship with the patient.
In these instances, pharmacy professionals must comply with the laws, regulations, standards and policies, and any other professional practice requirements as stipulated by the College, and the laws, standards, and policies of where the patient is located to ensure continuity of care. Registrants must not dispense a drug that has been authorized by a practitioner who does not hold a valid certificate of registration in a Canadian jurisdiction.
Registrants must not facilitate the co-signing of prescriptions authorized by practitioners not licensed in Canada. Co-signing refers to a Canadian practitioner providing signatures to prescriptions issued by another prescriber who is not licensed in Canada, for the purpose of them being filled by a Canadian pharmacy.
Providing care to patients in Ontario by pharmacy professionals in other provinces
Pharmacy professionals who are not licensed to practice in Ontario may still provide care to patients located within Ontario if:
- They are currently registered in another Canadian jurisdiction
- They comply with the laws, regulations, standards, policies, and any other professional practice as stipulated by their province of registration in addition to those of the College and its Standards of Practice for Pharmacists and Pharmacy Technicians.
- Registrants providing pharmacy services to patients located outside of Ontario must meet all applicable standards, guidance and legislative requirements that apply when providing care to patients in Ontario.
- Registrants must also comply with the practice requirements of the pharmacy regulatory authority where the patient is located.
- Registrants providing care to patients within Ontario, or in other Canadian jurisdictions, must always obtain explicit informed consent from patients or their substitute decision-maker when providing pharmacy services.
- Registrants may only dispense a medication to patients physically located outside of the country if the prescription has been authorized by a prescriber with a valid certificate of registration in a Canadian jurisdiction, and if both the registrant and prescriber have an existing therapeutic relationship with the patient.
- Registrants must not facilitate the co-signing of prescriptions authorized by practitioners not licensed in Canada.