Board Highlights - September 15, 2017

Board Highlights - September 15, 2017

Highlights from this meeting include the College's commitment to improving BC pharmacy professionals' work with First Nations and Aboriginal People; an overview of the engagements completed in the 2016/2017 fiscal year; amendments to the Pharmacy Operations and Drug Scheduling Act bylaws regarding fee changes and telepharmacies; and a summary of results and feedback gathered from the Practice Review Program's efforts in Community Practice.

Ben Ridout, Director of Patient and Public Engagement at the BC Patient Safety & Quality Council, presented to the Board on Patient & Public Engagement. 

The Board also approved the College's new Risk Management Policy.

Committee Updates 

Governance Committee

Public Board Member and Chair of the Governance Committee, Norm Embree provided an update on the activities of the Governance Committee since the previous Board meeting.

Inquiry Committee

In Ming Chang`s absence, Public Board Member Jeremy Walden provided an update on the activities of the Inquiry Committee since the previous Board meeting.  

Jurisprudence Subcommittee 

Kootenay/Okanagan Representative and Chair of the Jurisprudence Examination Subcommittee provided an update on the activities of the Jurisprudence Examination Subcommittee since the beginning of the current fiscal year. 

Legislation Review Committee 

Public Board Member and Chair of the Legislation Review Committee, Jeremy Walden, provided an update on the activities of the Legislation Review Committee since the previous Board meeting. 

Mr. Walden outlined amendments to the PODSA Fee Schedule, as well as amendments regarding telepharmacies. 

More information about the amendments can be found later on in these highlights. 

Practice Review Committee 

Public Board Member and Chair of the Practice Review Committee Kris Gustavson provided an update on the activities of the Practice Review Committee since the previous Board meeting. 

Mrs. Gustavson presented the results from both the Community Pharmacy Practice Review Results Summary Report and the Community Pharmacy Practice Review Feedback Survey Report. 

A more detailed summary of Mrs. Gustavson’s presentation can be found later on in these highlights. 

Quality Assurance Committee 

Northern British Columbia Representative and Chair of the Quality Assurance Committee, Frank Lucarelli, provided an update on the activities of the Quality Assurance Committee since the previous Board meeting. 

The QAC has been working on a mobile app for professional development which is set for release in the near future. 

Registration Committee 

Public Board Member and Chair of the Registration Committee, Jeremy Walden, provided an update on the activities of the Registration Committee since the previous Board meeting. 

Audit and Finance Committee 

In George Walton’s absence, Committee provided an update on the activities of the Audit and Finance Committee since the previous Board meeting. 

Mr. Walton outlined the committee’s Competitive Bid to find a new auditor. Six proposals were received from: 

• BDO Canada LLP
• Deloitte LLP
• Grant Thornton LLP
• KPMG LLP
• MNP LLP
• Smythe LLP

The Board ultimately approved the appointment of BDO Canada LLP, for their extensive experience auditing other regulators and public organzations as the CPBC auditor for fiscal years ending February 28, 2018 through February 28, 2021, with the option to extend for an additional two years. 

Our Commitment to Cultural Humility

The College’s Director of Communications and Engagement, Gillian Vrooman, presented an overview of the College’s strategy to fulfill its pledge to improve BC pharmacy professionals’ work with First Nations and Aboriginal People.

First Nations and Aboriginal people have a right to access a health care system that is free of racism and discrimination and to feel safe when accessing health care. This means individuals, families and communities are able to voice their perspectives, ask questions, and be respected by health care professionals on their beliefs, behaviours and values.

On March 1, 2017, College Registrar, Bob Nakagawa, pledged the College’s commitment to cultural safety and humility alongside BC’s other health regulators, representing the first step toward achieving our collective BC health systems goal of culturally safe health services for First Nations and Aboriginal people in BC.

Cultural Safety is an outcome based on respectful engagement that recognizes and strives to address power imbalances inherent in the healthcare system. It results in an environment free of racism and discrimination, where people feel safe when receiving health care.

Cultural Humility is a process of self-reflection to understand personal and systemic conditioned biases, and to develop and maintain respectful processes and relationships based on mutual trust. Cultural humility involves humbly acknowledging oneself as a life-long learner when it comes to understanding another’s experience.

The strategy includes action on the Declaration’s pillars of creating a climate for change, engaging and enabling stakeholders and implementing and sustaining change.

Cultural Safety and Humility Themes

This strategy is based on key drivers set out by the First Nations Health Authority. Actions are identified under three themes:

• Cultural Safety Concepts
• Partnership and Engagement
• Learning, Knowledge Exchange & Quality Health

Working together with the First Nations Health Authority, other regulators, pharmacy associations, First Nations groups, and others will be essential to create a healthcare environment free of racism and discrimination, where individuals feel safe and respected. This strategy includes many opportunities for collaboration, and the College will welcome partnerships from others who are seeking to make our health system more culturally safe for First Nations and Aboriginal People.

While some elements of the plan have already begun, the College’s Communications and Engagement Department (working with other departments as needed) will begin to operationalize this plan beginning in 2018. 

Patient Voices Network Presentation 

Ben Ridout, Director of Patient and Public Engagement at the BC Patient Safety & Quality Council, presented to the Board on Patient & Public Engagement. Mr. Ridout provided a high level review of how it is being integrated into different sectors of health delivery in BC, followed by a discussion as to how it can be integrated to the work done at the College.

College Engagement in 2016-2017

The College’s Director of Communications and Engagement, Gillian Vrooman, provided the Board with an overview of the College’s engagement process and the scale of engagements completed in the 2016/2017 fiscal year.

Public and stakeholder engagement is integral to the College’s initiative and policy development processes. It helps the College find the “right touch” in regulation and helps build awareness and support for new College initiatives and policies.

The College follows the International Association for Public Participation (IAP2) best practices and core values in planning and executing engagement initiatives. This involves identifying the level of participation, communicating the engagement process with stakeholders, identifying how feedback will be used and how the results of the engagement will be shared. These elements are essential in hosting an effective and transparent engagement session.

2016/17 saw significant engagement across many topics. The College engaged with over 4,200 pharmacy professionals, patients and others through eight different engagement initiatives. 

2016/17 Engagement Projects included:

• Practice Review Program: Hospital Forum
• New Model Standards for Pharmacy Compounding
• Certified Pharmacist Prescriber
• Palliative Care Home Kits
• New Standards for Prescription Product Preparation, Final Check and Patient Identification
• College Name Change
• Pharmacy Security
• Naloxone

While the number of participants is always important, it is not the only measure of success. Other important measures include the quality of input provided, usefulness in decision making, diversity of the participants and their view points, and opportunities to build trust.

All of the College’s engagements throughout 2016/17 garnered valuable feedback on important topics and proposed changes to pharmacy regulation in BC. While most of the participation came from pharmacy professionals, patients, other health care professionals and stakeholder groups also engaged with the College. Feedback through these eight engagement projects all provided insights that helped the College Board in its decision-making throughout the year. 

PODSA Bylaws

The Board approved amendments to the Pharmacy Operations and Drug Scheduling Act (PODSA) Bylaws Schedule A – Fee Schedule and related forms for filing. 

These amendments actualize PODSA fee increases that were previously approved as part of the College’s 2017/2018 budget as well as related fee changes for telepharmacy. The fee changes include increases to the application fees for community, hospital, telepharmacy and education sites, application fee for change of ownership, application fee for hospital satellite, and application fees for renewal for community, hospital, education site and telepharmacy. 

This comes after the Board approved these amendments for a legislated 90 day public posting period at its April 2017 Board meeting. 

After approval by the Board, the fee changes and forms were posted on the College’s website for public comment. During the public posting period, two comments were received. The first comment supported the fee changes and the College’s need to maintain its finances to operate. The second comment was a suggestion regarding forms, to include a statement stating that credit card information will be destroyed securely. In regards to this comment, the publicly posted forms included a new privacy statement1 that states that the College’s collection of personal information under its enabling legislation, is in accordance with the Freedom of Information and Protection of Privacy Act. However, as this statement does not fully address the issue raised, a statement explaining that credit card information is not kept on file and is destroyed securely, can be added to these forms in future amendments to forms. At this time, no changes are made to the fee schedule or forms.

The next step in the process to finalize the bylaws is to file them with the Minister of Health. Once filed, the bylaws will come into effect 60 days from the filing request date to the Ministry of Health. The bylaw amendments will be in effect by mid-November 2017.

Telepharmacy Bylaws 

The Board approved, for filing with the Ministry of Health, amendments to the Pharmacy Operations and Drug Scheduling Act (PODSA) Bylaws regarding telepharmacies; and a new Schedule F, Part 6 – Telepharmacy Standards of Practice, under the Health Professions Act (HPA) Bylaws. 

The Board also approved rescinding Professional Practice Policy (PPP) 55 – Telepharmacy, which requires Board approval only. 

Telepharmacy is the delivery of traditional pharmacy services, including the dispensing of medications and providing patient counselling, via telecommunications, to patients in locations where they may not have local access to a pharmacist. 

Following concerns raised by the Board about the quality of pharmaceutical care being provided at telepharmacies, College staff have conducted multiple reviews and inspections of these sites since 2014. Based on the information gathered, draft amendments to the PODSA Bylaws regarding telepharmacies as well as telepharmacy-specific Standards of Practice were developed in 2017. 

The Board approved the public posting of these proposed bylaws for a 90-day period at its April 2017 Meeting. 

Some of the key areas of concern raised in the feedback received at the end of the 90-day public posting period included: 

• The definition of “direct supervision” which requires real time audio and visual observation by a full pharmacist of pharmacy services performed at a telepharmacy consistent with a pharmacy manager’s responsibilities.
• No longer allowing community pharmacies to switch from a traditional community pharmacy to a telepharmacy (e.g., switch into “telepharmacy mode”).
• While grandfathering provisions were included allowing pharmacy assistants to staff existing telepharmacies, new telepharmacies will be required to be staffed by a pharmacy technician.
• Increasing the audit and inspection requirement from three to four times per year, consistent with an existing policy that applies to community pharmacies.
• Requiring a telepharmacy to cease providing services after thirty days if it is no longer rural and remote or a community pharmacy is established within 25km of the telepharmacy.
• Requiring the business name of the site to include the term ‘telepharmacy’.
• Requiring that all prescription processing be completed at the central pharmacy, unless a pharmacist is physically present and on duty at the telepharmacy.

Recommended Minor Amendments: 

Staff recommend the following minor amendments to the proposed telepharmacy bylaws:

In addition to the above-noted amendments, s.16(2) of the PODSA Bylaws was also further amended. The original draft provision stated that a telepharmacy licence is valid only for the location and owner as stated on the telepharmacy licence and is not transferrable. This provision was further amended to remove the terms “owner” and “not transferrable.” This permits “grandfathered” telepharmacies to retain that status even if the owners change. However, that status would be removed if it relocated. 

Additional Engagement:

Following the public posting, the College held two engagements on August 11, 2017. One of these sessions was with telepharmacy operators and the Ministry of Health, and the other was held with BCPhA. In addition, David Loukidelis, a former BC Information and Privacy Commissioner, attended the engagement with BCPhA to address privacy concerns raised in that organization’s feedback. The aim of these engagements was to discuss: the feedback received; the College and Ministry of Health staff review of the concerns raised; and, to clarify the policy intent that the College is aiming to achieve by implementing the draft bylaws. The College previously engaged with the telepharmacy operators earlier in 2017, when drafting the proposed bylaws.

Rescinding PPP-55 Telepharmacy

PPP-55 Telepharmacy provides further detail regarding the components of a telepharmacy policy and procedure manual. As a more comprehensive set of requirements regarding the operation of telepharmacies and related standards of practice have been developed, staff recommend rescinding PPP-55 Telepharmacy. Further, PPP-55 can be considered duplicative of the proposed general requirement in s.16.1(8) of the PODSA Bylaws requiring a telepharmacy policy and procedure manual and the requirement in s.10(2) requiring that a quality management program include telepharmacies.

Next Steps

As per section 21(4) of PODSA and section 19(3) of the HPA, bylaws must be filed with the Minister of Health. The amended bylaws will come into effect 60 days from the filing request date to the Ministry of Health. The bylaw amendments will be in effect by mid-November 2017.

PPP-55 – Telepharmacy will be rescinded when the bylaws come into force. 
 

PRC Phase 1 – Community Pharmacy Practice Review Results Summary Report

District 1 and 2 Compliance Officer James Van presented the Practice Review Program’s Community Practice Review Results Summary Report. Data used in this report spans the period from February 16, 2015 to April 17, 2016. This data helps create a baseline picture for future analysis and also has broad use and applications across various departments in the College of Pharmacists of BC. 

Summary of Key Results:

As practice reviews continue, we are finding a shift in non-compliance trends due to the “learning effect” of information dissemination between registrants and from the PRP.

Registrants are learning from the information passed to them and our Compliance Officers are seeing improvements in compliance as a result.

The PRP team continuously monitors this information and also collects continual feedback survey data from our registrants. This data serves as a form of impact validation for the Practice Review Program and allows us to see if key non-compliance issues we are identifying are perceived by registrants to be truly impactful to their practice.

PRC Phase 1 – Community Pharmacy Practice Review Feedback Survey Report 

Public Board Member and Chair of the Practice Review Committee Kris Gustavson presented results from the Practice Review Program’s Community Practice Review Feedback Survey. 
This report provides an aggregate view of registrant practice review feedback received from 138 registrants (51 of which were Pharmacy Managers) during the period of March 1, 2016 to February 28, 2017. The following tables summarize the key findings of the report.

Overall Agreement and Impact Rating Summary

Based on the feedback received, registrants were the most satisfied with the performance of our Compliance Officers and the results which Pharmacy Managers obtained from their Pharmacy Review. 

On the other hand, registrants were the least satisfied with the Practice Review Program Pre-Review and the Action Item Portal.  Concerns were primarily related to the length and duration of time it took to complete the Pre-Review as well as the lack of support for iOS.

The Practice Review Program actively evaluates feedback received from registrants in order to make continual improvements to our program and processes.  Many steps have been taken since our launch to make improvements based on feedback, and we will continue to do so going forward.  

Risk Management Policy and Risk Register

The Board approved the College’s new Risk Management Policy. 

The Policy sets out the level of risk that the College will engage in and who is responsible for ensuring that activities meet that requirement. The Policy and Risk Register are organizational best practices that are part of the College’s efforts toward achieving Excellence Canada’s Silver Standard. 

The Risk Register is a continually updated document that lists: 

• All significant risks 
• The strategies that can be used to mitigate the risk 
• The significance of the risk, etc. 

NAPRA Bylaw Amendments 

The Board endorsed proposed NAPRA Bylaws to amend the structure of the NAPRA Board of Directors, and recommended former College Board Chair and Kootenay/Okanagan Representative Blake Reynolds as NAPRA’S British Columbia representative at its November 9th meeting.

The Board also recommended College Registrar Bob Nakagawa to serve on NAPRA’s Board of Directors, consistent with the proposed NAPRA Bylaws.

In April 2016, NAPRA’s Board of Directors created an Ad-hoc Committee on Governance to identify and/or validate concerns with the current governance approach; to explore options for improvement; and, to make recommendations to the Board regarding governance changes.

The Ad-Hoc Committee recommended a governance structure of 14 individuals, comprised of the registrars from each of the provincial pharmacy regulatory authorities and representatives of the governmental agencies of the territories and Canadian Forces Pharmacy Services, plus up to three directors at-large. Additionally, NAPRA seeks to increase the frequency of Board meetings and streamline its structure with the elimination of the Executive Committee and the Council of Pharmacy Registrars of Canada.

To finalize these changes, NAPRA’s Members will need to amend its two governing documents under the Canada Not-for-Profit Corporations Act – its bylaws and its Articles – as well as elect a new Board for the new governance.

A Meeting of NAPRA Members has been scheduled on November 9, 2017 to have Members accept new proposed bylaws. 

Strategic Plan Update 

College Registrar, Bob Nakagawa, provided a brief update on the 2017/18 – 2019/20 Strategic Plan.

The College’s Management Team recently reviewed the progress of the Strategic Plan, analysing the Operations Plan, Action Items and Tasks set out in Cascade, the College’s Strategic Planning software.

Continued refinement to the structure and use of Cascade will be needed as the College moves closer to publishing the finalized strategic plan and accompanying website, overall however, the College’s implementation plan is going as intended.

Stay tuned for the College’s official Strategic Plan website to be published soon. 

Update on the Methadone Maintenance Treatment Action Plan

The College’s Registrar, Bob Nakagawa, and Deputy Registrar, David Pavan, provided an update on the Methadone Maintenance Treatment Four Year Action Plan (2015-2018).

The action plan sets a 4 year time frame for enforcing standards by identifying pharmacies and pharmacists that are not meeting legislative requirements or are engaging in unethical or fraudulent activity; as well as setting longer term goals that focus on enhancing the legislative structure for greater enforcement capability, continuing effective investigations and discipline and enhancing stakeholder relationships. 

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