May 4, 2020
Practicing Pharmacy During the COVID-19 Pandemic: What You Need to Know
In response to the COVID-19 pandemic, many elements of healthcare have been forcibly put on hold. However, ensuring that all members of the public have continued access to necessary medication, and that prescribers and pharmacists can deliver those medications to the public in a safe way, is of critical importance. In Ontario, pharmacies have been deemed “an essential service” since the outset of the pandemic, and pharmacists are among the few regulated health professionals who continue day-to-day operations.
What follows is an overview of four (4) areas of pharmacy practice to which significant (and temporary) changes have been made in response to the pandemic.
1) Relaxing of Requirements Surrounding Controlled Substances
The prescribing and dispensing of controlled substances have always been subject to their own stringent set of rules. However, for the time being, certain exemptions from these rules are being permitted (the "Exemptions”). The Exemptions, in combination with some recent changes to the provincial Pharmacy Act, mean that Ontario pharmacists can now temporarily:
- Accept verbal orders for controlled substances;
- Transfer prescriptions for targeted substances including (but not limited to) narcotics and controlled drugs to other pharmacists in Ontario;
- Refill prescriptions for some targeted substances which are more than one (1) year old;
- Renew prescriptions for controlled substances; and
- Adapt prescriptions for controlled substances, including part-fillings or de-prescribings.
The Exemptions will expire on the earlier of September 30, 2020, or the date on which they are revoked or replaced.
2) Preventing Drug Shortages
In an attempt to prevent and/or alleviate drug shortages during the pandemic, the federal Minister of Health has made an interim order, the effect of which allows for some importation and sale of drugs which may not fully comply with Canadian requirements but which comply with comparable standards abroad.
At the same time, the provincial Ministry of Health has made various recommendations with respect to the dispensing of drugs pursuant to the Ontario Drug Benefit (“ODB”) program. These include limiting dispensings to no more than a 30-days’ supply, and not refilling prescriptions more than ten (10) days in advance of the depletion of a patient’s supply. To facilitate compliance with these recommendations, the provincial Minister of Health has temporarily suspended the prohibition on dispensing less than the maximum quantity prescribed or payable under the ODB program, and has temporarily suspended the rule which limits payment of dispensing fees for many chronic medications to five (5) fees per year.
3) Virtual and/or Telephone MedsChecks
Also in relation to the ODB program, in an attempt to limit unnecessary in-person interactions, reimbursement is temporarily available for some MedsChecks (one-on-one interviews between pharmacists and patients to review patients’ prescription and non-prescription medications) which are performed virtually or over the telephone. Proper documentation is still required, though patients are not required to sign the documentation as is typically the case. Nonetheless, it is being recommended that MedsCheck appointments be rescheduled where possible, and should only occur where medically necessary, i.e. to ensure that a patient understands their medications, or to resolve urgent issues.
4) E-mailed Prescriptions
In Ontario, prescribers can typically authorize prescriptions in a number of different ways including in person (i.e. handwritten), telephone, fax, or secure e-prescribing systems. However, the Ontario College of Pharmacists (the “OCP”) has acknowledged that many prescribers are currently working remotely and may not have consistent access to these systems. Thus, although use of the prescribing methods referenced above is still being reinforced, the OCP has indicated that pharmacists may receive some prescriptions via unsecured email. It is important to note that, according to the OCP, the onus is on the dispensing pharmacist to use their professional judgment to ensure that the source of the emailed prescription is authentic, that its contents are appropriate, and that patient privacy is respected. Finally, the OCP has made it clear that this is a temporary measure aimed at supporting timely access to patient care during the pandemic.
Please note that unsecured email cannot be used to transmit prescriptions for drugs listed under the Narcotic Control Regulations, though such drugs can temporarily be prescribed verbally pursuant to the Exemptions, as set out above.
There is no doubt that the rules and regulations governing the prescribing and dispensing of medications in Ontario will continue to evolve during, and after, the pandemic. Ensuring compliance with these evolutions is of utmost importance, as failure to do so could result in a complaint to the OCP or even formal charges of professional misconduct.
If you have any questions, please contact a member of our team. For more information about dealing with COVID-19, please visit our COVID-19 Resource Center.