Board Highlights - February 16, 2018

BOARD HIGHLIGHTS - February 16, 2018

Highlights from this meeting include results of the Methadone Maintenance Treatment Four-Year Action Plan; amendments to the Health Professions Act (HPA) Bylaws for dispensing drugs for the purposes of medical assistance in dying (MAiD) Telepharmacy Standards of Practice; and the approval of a new records management framework.

Board Welcomes New Public Members 

The College of Pharmacists of British Columbia welcomes the appointment of three public representatives to its Board. 

Tracey Hagkull and Justin Thind have been appointed by Minister of Health, Adrian Dix, to serve as public board members for a term of two years. Ryan Hoag has been appointed for a one year term. 

Learn more about them here.  

Results of Methadone Maintenance Treatment Action Plan 

The College’s Deputy Registrar, David Pavan, presented to the Board the results of the Four Year Action Plan for Methadone Maintenance Treatment. 

The four-year action plan was approved in June 2015 in response to numerous concerns and allegations received from members of the public, registrants, and other health care professionals regarding the dispensing of Methadone Maintenance Therapy (MMT) from pharmacies.

Such issues of alleged non-compliance included (but were not limited to): 

• The provision of inducements (both monetary and non-monetary) to patients to retain or attract methadone patients;
• Instructing patients to request an increased frequency of medication dispensing (either daily or weekly) from their prescribing physicians, thereby providing the pharmacy with increased dispensing fees; 
• Providing unauthorized advances of medications to patients at the patient’s request without notifying the prescribing physician; 
• Processing prescriptions on PharmaNet even if patients did not attend at the pharmacy to receive their medications; 
• Failing to reverse entries on the patient’s PharmaNet record for prescribed medications that were not dispensed to patients in accordance with the instructions of the prescribing physician; and 
• Failing to maintain accurate local patient records and PharmaNet patient records. 

Action Plan Goal: Undercover Investigations 
Between 2015-2017, as part of the MMT action plan, and in collaboration with the Ministry of Health, the College conducted undercover investigations. 

The undercover investigations focused on the identification of non-compliance with legislative requirements, practice standards, and ethical standards. 

Action Plan Goal: Focused Inspections 
The College conducted 41 focused Methadone Maintenance Treatment inspections between May 2015 and July 2017. 

Pharmacies were selected based on the volume of methadone dispensing as well as previous complaints/tips related to methadone dispensing. Additionally, a number of pharmacies outside the Lower Mainland were selected to assess how methadone dispensing practices varied with geography and population. 

In general, compliance with dispensing and patient care standards was very high. However, some challenges remain in rural areas where the lack of prescribers results in patients being unable to be reassessed immediately, and geographic distances that necessitate long duration carries. 

Action Plan Goal: Stakeholder Relations
Throughout the action plan process, the College has built a number of positive working relationships with various health stakeholders. As a result, the College has become a primary resource for MMT information and guidance.

Pharmacy Manager Training Program Proposal/Product 

The College’s Deputy Registrar, David Pavan, provided an update on the Pharmacy Manager Training Program Proposal. 

Pharmacy Software Requirements 

The Board directed the Registrar to begin exploring the development of new requirements regarding the security of information in the local computer systems of pharmacies.

This comes after a review of recent complaint files revealed a lack of security requirements for the local computer systems and software in pharmacies. In particular, it has been noted that certain software lack appropriate security controls, making local systems records vulnerable to user manipulation. Additionally, as potential manipulations of the system are not recorded; it is currently not possible to track who may have manipulated a record. This limits the College’s ability to investigate cases of record manipulation, which ultimately limits the College’s ability to adequately protect the public. 

The Board’s direction will enable the College to assess the need for new software requirements to increase public safety such as, developing consistent software requirements when dispensing prescriptions; increasing the accountability of registrants in maintaining accurate patient records; and creating an automatic enforcement mechanism by proposing amendments to the PharmaNet Professional and Software Compliance Standards. 

Budget 2018/2019

The Board approved the College’s 2018/2019 operating budget which will be put toward the following major initiatives: 

• Implementation of PODSA Ownership licensure process. 
• PODSA Modernization bylaw review and process review. 
• Completion of a draft of Excellence Canada’s Silver Certification application. 
• Records Management process implementation and staff training. 
• Privacy Management processes review and staff training. 
• IT department processes review, Policies and Procedures update and staff training. 
• Continued improvement on IT Roadmap projects. 
• Quality Assurance project – auditing CE credits. 
• Submitting the Pharmacist Prescriber framework to the Ministry of Health. 
• First full year of Hospital practice reviews. 
• Planning for the next Strategic Plan development. 

Medical Assistance in Dying – Standards, Limits and Conditions 

The Board approved amendments to the standards in the Health Professions Act (HPA) Bylaws regarding dispensing drugs for the purposes of medical assistance in dying (MAiD), for filing with the Minister of Health.

The current HPA Bylaws – Schedule F – Part 5, Standard 6 states that “pharmacists must contact the prescribing medical practitioner or nurse practitioner within 48 hours of the scheduled date and time of drug administration to confirm that the medical administration record documents what drugs were consumed and to ensure appropriate return of any unused medications for disposal.” 

The MAID Sub-Committee on Pharmacy has agreed to revise the time period for returning medications from 48 to 72 hours after the patient’s death. 

In order to align with the timeline changes, the Board approved revising the requirement noted above to 72 hours, and to make other minor amendments to be more consistent with current practice.  

While these amendments are not required to be publicly posted on the College’s website, they have been filed with the Minister of Health and will become effective 60 days after filing. 

Amendments to the Telepharmacy Standards of Practice 

The Board approved minor amendments to Schedule F, Part 6 – Telepharmacy Standards of Practice, under the Health Professions Act (HPA) Bylaws, for filing with the Minister of Health. 

These amendments consist of minor housekeeping changes. They were made to appropriately reference new Pharmacy Operations and Drug Scheduling Act (PODSA) Bylaws sections, expected to come into effect on April 1, 2018.

Electronic Record Keeping 

The Board approved, for a public posting period of 90 days, amendments relating to electronic record keeping requirements. 

The College has received a number of requests from registrants to formally allow electronic record keeping. In practice, we understand that many pharmacies are already keeping electronic records and also maintaining hard copy files to comply with our requirements. 

A new records management framework is being proposed–under which pharmacies and registrants will be permitted to retain both electronic and hard copies of the records under the College’s bylaws and other applicable legislation–enables the College to achieve the following goals: 

• Record keeping can be completed efficiently and in a manner that promotes patient safety and the accountability of registrants; 
• Records are filed systematically; 
• Records are easily retrievable; 
• Registrants’ interactions with records are auditable (i.e. who did what and when); and
• Patient records and other personal and confidential information are stored securely, with appropriate back-ups. 

The key proposed amendments involve removing existing restrictions on electronic record keeping, and establishing minimum technology requirements.

Please see the Bylaws for Comment: Electronic Record Keeping page for a more detailed outline of the key proposed amendments.

Recap of the Board Meeting on Social Media