Frequently Asked Questions

I just received a prescription written by a nurse practitioner from Alberta. Do out-of-province nurse practitioners have prescribing privileges in B.C.?

No, out-of-province nurse practitioners are not recognized prescribers in BC.  In order to prescribe, a person must be a “practitioner” as defined by PODSA.  While BC nurse practitioners are authorized under the provincial Health Professions Act to prescribe, out-of-province nurse practitioners do not fall within the definition of a “practitioner” in BC.

Depending on the drug and the situation, pharmacists should use their professional judgment to decide if it is appropriate to process a new or transferred nurse practitioner (out-of-province) prescription as an emergency supply prescription using the pharmacist’s ID as the prescriber. In all cases, clearly document the situation on the prescription.

Can I fill a prescription using product compounded by another pharmacy?

Pharmacists who do not provide specialty compounding services have two options:

1. Refer the patient to a pharmacy that can prepare the product.

2. Obtain the specialty compound by contracting with another pharmacist who provides the service. A contract between the two pharmacies must be signed and retained by both pharmacy managers if the service is contracted out.

If you have any questions or concerns, please email [email protected]. 

I just received a request for a prescription transfer from a pharmacist in Seattle, Washington. May I transfer the prescription?

According to the Health Professions Act - Bylaws Schedule F Part 1, upon request a pharmacist must transfer prescriptions to another pharmacy licensed in Canada, if the drug does not contain a controlled drug substance and the transfer occurs between a registrant and another registrant or an equivalent of a registrant in another Canadian jurisdiction. The Bylaw does not address transferring a prescription to the U.S. In the interest of positive patient outcomes registrants may use professional judgement and decide to transfer a prescription to a state that is allowed to accept transfers from Canada. However, once the prescription is transferred out of B.C. the pharmacy is not allowed to transfer the unused refills back to B.C.

I suspect my coworker may have a substance use issue. Do I need to report this to the College?

I think that a pharmacist may have a substance use issue. I've never seen him use drugs on the job but his behaviour and appearance indicate that there may be a problem. He makes a lot of dispensing errors and since I hired him, I've noticed that a number of narcotics have been missing. Do I need to report this to the College even if I'm not sure that he has a substance abuse disorder and even though I'm not sure he is the cause of the missing narcotics?

Section 32.1 to 32.4 of the Health Professions Act states that “If a practitioner or registrant has reason to suspect that a person registered under this Act is suffering from a physical or mental ailment or an excessive personal use of alcohol or drugs that might constitute a danger to the public, the practitioner or registrant must immediately report this to the registrar.” This means that even if you don’t know for sure that a problem exists, but you have reason to be suspicious, you must report your concern to the college. College staff will ask you a number of questions and may suggest strategies for improving your monitoring systems so you can find out more about what is happening to your drug supply. They will also need to gather information about the pharmacist’s behaviour. If it turns out that the pharmacist does have a substance abuse problem, the College’s key interest will be to work with the pharmacist on a recovery program. This can be done through a mutual agreement with the pharmacist; an adversarial discipline process is not usually required. 

A deceased patient's wife recently brought the patient's unused narcotic medications to my pharmacy. Do I have to obtain authorization from Health Canada before I can destroy these narcotics?

Although the pharmacist accepts legal responsibility for the drug and its destruction, Health Canada no longer requires pharmacies to request and receive pre-authorization for local destruction of unserviceable narcotics and controlled drugs. This means that pharmacists may proceed with destruction without notifying and receiving acknowledgment from Health Canada in advance. All other requirements, including documentation, remain in place.

Guidance Document: Handling and destruction of post-consumer returns containing controlled substances

 

I have a patient with cancer who wants to receive medical marijuana. What does the patient need to do to?

Medical use of cannabis is federally regulated by Health Canada. Please visit this link for more information: https://www.canada.ca/en/health-canada/topics/cannabis-for-medical-purposes.html

Can a pharmacist accept a prescription for a Schedule 1A drug (Controlled Prescription Program) written by an out-of-province physician?

In certain exceptional circumstances, a pharmacist can dispense a prescription for a Controlled Prescription Program (CPP) drug from an out-of-province physician or Canadian Armed Forces (CAF) physician practitioner that's not on the Controlled Prescription Program form. In these situations, as with any exceptional cases, the pharmacist must use their professional judgment in their decision to dispense. The pharmacist can base their decision on the medical condition of their patient and surrounding circumstances.

However, it is the pharmacist’s responsibility to ensure that the prescription is legitimate, and that the practitioner is licensed to practise medicine, podiatry or veterinary medicine in Canada. It may be reasonable for some patients, for example those who live close to the B.C./Alberta border, to have a physician in Alberta, and their pharmacy in B.C. In those cases, it may be appropriate to continue to dispense a controlled drug prescription from outside of B.C.

In most other circumstances, however, if a particular patient makes a habit of asking for drugs without a CPP form, the pharmacist should refer the patient to a practitioner licensed to practise in B.C. or a CAF physician with CPP forms. Pharmacists should not continue to dispense the prescriptions.

A patient brought in a prescription for two drugs. The patient only wants me to dispense one of these drugs and wants another pharmacy to dispense the other drug. What do I need to do?

The process you need to follow is different, depending upon which drug you dispense.

Amoxil® dispensing (non-narcotic) - you need to return the original prescription to the patient:

  • Process the prescription for Amoxil®.
  • On the original prescription, indicate that you have dispensed the Amoxil® and note your pharmacy name, your initials, and the date.
  • Photocopy the original prescription for your records.
  • On the photocopy, make a note that the original prescription was returned to the patient.
  • Return the original prescription to the patient. The patient can then have the undispensed narcotic prescription dispensed at the pharmacy of his/her choice.

Tylenol with Codeine No.3® dispensing (narcotic) - you need to keep the original prescription:

  • Process the prescription for Tylenol with Codeine No.3®.
  • Log the prescription for Amoxil®.
  • Photocopy the original prescription for your records.
  • On the original prescription, indicate that you have dispensed the Tylenol with Codeine No.3® and logged the Amoxil®. Note your pharmacy name, your initials, and the date.
  • You may photocopy the original prescription and provide the photocopy to the patient. Be sure to note your pharmacy name and telephone number on the photocopy so that the other pharmacy can contact you to transfer the Amoxil® prescription.
We were working on a prescription for a narcotic liquid and the bottle tipped over. The contents spilled onto the counter and floor - what should I do?

To determine whether a loss should be reported and how to document, please see Health Canada’s Guidance on reporting loss or theft of controlled substances and precursors.

Do all pharmacies dispense Mifegymiso?

Any pharmacy where pharmacy professionals have the appropriate knowledge, skills and abilities, may dispense Mifegymiso®.

If a pharmacist declines to dispense Mifegymiso® on the basis of a conscientious objection, they are required to adhere to the Colleges’ Code of Ethics, Standard 1 (g)(iii), cooperating in effective transfers of care initiated by the patient (without needing to make a referral). Pharmacies must also have a process in place to ensure that, in the case where a pharmacy professional conscientiously objects to providing a service, the patient can be directed to an alternate provider for the service in a timely manner.

Learn more about the options for providing Mifegymiso® to patients in BC at bcpharmacists.org/mifegymiso.

Are registered pharmacy technicians and pharmacists still required to comply with legislated requirements and their professional obligations, even if they are not working as a pharmacy technician or pharmacist?

Pharmacy technicians and pharmacists registered with the College are health professionals under the Health Professions Act and must uphold legislative requirements and professional obligations at all times.

This means that regardless of job title or role, a registered pharmacy technician or pharmacist must meet requirements under the Health Professions Act, Pharmacy Operations and Drug Scheduling Act and in the College’s bylaws. As health professionals, they are held responsible to their own scope of practice and can be subject to disciplinary action for practice issues.

Are all pharmacies required to comply with the new technology requirements?

Bylaw Reference: PODSA Bylaws s. 23.3(1):

23.3(1) A pharmacy may maintain electronic records containing personal health information if the pharmacy has the equipment, software and systems necessary for the input, storage, use, protection and retrieval of records that are required to be kept under bylaws of the college or other legislation that regulates the practice of pharmacy.

In addition, the detailed technology requirements are set out in s. 23.3 of the PODSA Bylaws.

A pharmacy must comply with the new technology requirements if it maintains electronic records containing personal health information.  Since most pharmacies keep some form of electronic records containing personal health information, most pharmacies will be required to comply with the new technology requirements.  However, pharmacies will have until May 13, 2019 to comply.

Are all pharmacies now required to keep electronic records?

No, pharmacies may either keep only electronic records, only hard copy records, or a combination of both.  Pharmacies that keep any form of electronic records containing personal health information must comply with the new technology requirements in s. 23.3 of the PODSA Bylaws by May 13, 2019.

Are electronic equivalents acceptable for all College-required documentation, including invoices and documentation in respect of the purchase, receipt or transfer of drugs, confidentiality forms, narcotic reconciliation records etc.?

Yes, pharmacies may keep all records required by the College in electronic format. Only records containing personal health information are required to be maintained in a system that complies with s. 23.3 of the PODSA Bylaws.  

Are all electronic records required to be maintained in a system that complies with the new technology requirements?

Bylaw reference: PODSA Bylaws, s.23.3(1):

23.3. (1) A pharmacy may maintain electronic records containing personal health information if the pharmacy has the equipment, software and systems necessary for the input, storage, use, protection and retrieval of records that are required to be kept under bylaws of the college or other legislation that regulates the practice of pharmacy.

Only records containing personal health information are required to be maintained in a system that complies with s. 23.3 of the PODSA Bylaws.  This means that records such as invoices and documentation in respect of the purchase, receipt or transfer of drugs, confidentiality forms, narcotic reconciliation records, and other non-patient related records may be kept in electronic form in a system of the pharmacy’s choice.

Can prescriptions be destroyed after scanning and storing electronically?

MOST prescriptions may be destroyed after scanning and storing, as long as all notes made on the prescription are captured in the colour scan. As per Pharmacy Operations and Drug Scheduling Act Bylaws s.23.3(1): “A pharmacy may maintain electronic records containing personal health information if the pharmacy has the equipment, software and systems necessary for the input, storage, use, protection and retrieval of records that are required to be kept under bylaws of the college or other legislation that regulates the practice of pharmacy.”

However, if the pharmacy has received an original or a faxed Controlled Prescription Program (CPP) form, then it must be retained, regardless of whether the form has been stored electronically.

It is also recommended that pharmacies confirm with other parties such as Pharmacare and third-party insurers to ensure retention requirements for audit purposes are met.

Can electronic records be stored on a cloud? If yes, does the cloud need to be located in Canada?

The College does not have restrictions on cloud storage.  However, as with all records, pharmacies must ensure that data is stored and accessed in accordance with applicable privacy law.

Pharmacies that are private-sector organizations are governed by B.C.’s Personal Information Protection Act (PIPA).  PIPA does not contain restrictions on the storage of, or access to, personal information from outside Canada.  Organizations subject to PIPA may therefore use cloud-based storage services outside Canada. Many community pharmacies will fall under this category.

Pharmacies that are “public bodies” are governed under B.C.’s Freedom of Information and Protection of Privacy Act (FIPPA).  Public bodies covered by FIPPA are, with some exceptions, required to ensure that personal information is stored and access only in Canada.  There is no exemption for cloud storage.  Hospital pharmacies and pharmacies run by a provincial health authority may fall under this category.  A private sector pharmacy that is under contract to a public body to provide pharmacy services for the public body may also fall under this category.

The PharmaNet database is subject to FIPPA.  Therefore, any information in PharmaNet or obtained from PharmaNet must be accessed, disclosed and stored in Canada. 

I just received a prescription written by a pharmacist from Alberta. Do out-of-province pharmacists have prescribing privileges in B.C.?

No, out-of-province pharmacists are not recognized prescribers in BC.  Although some pharmacists may have certain prescribing privileges in their own provinces, a valid prescription in BC must be written by a “practitioner” as defined by PODSA.  Out-of-province pharmacists do not fall within this definition of a “practitioner” in BC.

Depending on the drug and the situation, pharmacists should use their professional judgment to decide if it is appropriate to process a new or transferred pharmacist prescription as an emergency supply prescription using the pharmacist’s ID as the prescriber. In all cases, clearly document the situation on the prescription.

Is it within a pharmacist’s scope to apply patches that contain medication on a patient, if requested?

Pharmacists are permitted to apply medicated patches on a patient, if requested to do so. However, prior to performing this activity, the pharmacist must ensure that they have the knowledge, skills and abilities to apply the patch in a manner that is safe and appropriate. The pharmacy would also be expected to have policies and procedures in place regarding this activity, including but not limited to, addressing how patients’ privacy needs will be met. 

Can a community pharmacist accept a faxed prescription for a drug in the Controlled Prescription Program (CPP) that is not written on a CPP duplicate prescription form?

The CPP aims to reduce inappropriate prescribing of selected controlled drugs and to prevent forgeries. Prescriptions for the controlled drugs specified in the program must be written on the duplicate prescription pad specially developed for this purpose. 

Verbal and faxed prescriptions for Schedule 1A drugs may not be accepted by a pharmacist in a community pharmacy; however, temporary amendments to the Pharmacy Operations and Drug Scheduling Act Bylaws and Community Pharmacy Standards of Practice are currently in place that allow the following: 

Verbal Prescriptions: 

  • A registrant may only accept a verbal prescription for a drug listed in the CPP if doing so is permitted under a section 56 exemption to the Controlled Drugs and Substances Act. The pharmacy must receive either the original or a faxed copy of the CPP prescription form from the practitioner as soon as reasonably possible. 

Faxed Prescriptions: 

  • A registrant may only accept a CPP prescription received by fax, during a public health emergency declared by the Provincial Health Officer. This includes the overdose crisis. Faxed prescriptions must still be written on a CPP form.   

In both cases, the faxed copy of the CPP prescription received by the pharmacy must be written on a CPP duplicate prescription form, thus upholding the purpose of the CPP. 

CPP duplicate prescription forms must still be used when using Electronic Medical Records (EMRs). As with all prescriptions, prescribers must ensure that all fields on the Controlled Prescription Program forms are completed correctly including those generated from an EMR. If the EMR is not capable of printing onto a CPP form, a copy of the completed CPP prescription form must be faxed as well. 

When a pharmacist receives a verbal prescription for a drug in the Controlled Prescription Program (CPP), must the pharmacist wait to receive a faxed or hard copy of the CPP duplicate prescription form before dispensing the drug?

A pharmacist may dispense the CPP drug after receiving a verbal prescription. The pharmacy must receive the original prescription form, or a copy of the completed form transmitted by facsimile, from the practitioner as soon as reasonably possible after dispensing the drug. 

Can pharmacists administer drugs or perform pharmacist/patient consultations from a remote location?

Pharmacy professionals may administer medications or provide consultations from any location where security, privacy and confidentiality can be maintained. They must make sure that proper conditions and equipment needs are met when providing these services (e.g. anaphylaxis kits). Please note that the storage of drugs and personal health information outside licensed pharmacy premises is restricted under the PODSA bylaws.

Can patients send in photos of their prescriptions to the pharmacy for dispensing?

Only fax transmission of prescriptions directly from the practitioner is allowed. Otherwise, the pharmacy must have an original prescription or have received a verbal prescription from a practitioner before dispensing prescription medications. 

Useful links: 

What should the pharmacy do if they receive a request for information from law enforcement? (e.g. video surveillance footage)

Information can be disclosed when complying with a court-ordered subpoena, warrant or order, or otherwise compelled by a person or body with appropriate jurisdiction. Also, you may disclose the information if you believe doing so will reduce a risk of significant harm to the health and safety of any person. This does not constitute legal advice, and we recommend you seek your own legal counsel. Please refer to the Health Professions Act Bylaws, section 72, for more information.  

Useful links: 

A family member of a deceased patient is asking for records related to prescriptions. Are pharmacy professionals allowed to release this information?

Pharmacy professionals must release personal health information if requested to do so by a person who is legally authorized, in writing, such as an executor of the estate. 

Useful links: 

An unexplained discrepancy was discovered with the pharmacy’s narcotic inventory. What should be done?

Unexplained losses of controlled drugs, including narcotic medications, must be reported to Health Canada within 10 days of discovery and a copy of the report sent to Health Canada must be forwarded to the College. 

Useful links:

 

Can practitioners use another practitioner’s Controlled Prescription Program (CPP) form?

No, practitioners must use the Controlled Prescription Program form they were issued. If a practitioner has not defined a place of practice, the form will be missing the practice address, but the name and the registration number will be printed on the form.

A patient is requesting the remaining 3 months of a refill on a prescription that expires next week. Are pharmacists allowed to dispense the full 3 months?

The Community Pharmacy Standards of Practice state that a registrant must not dispense prescriptions more than two years from the prescribing date, but it does not limit the duration of therapy that may be dispensed. However, pharmacists must use their professional judgement to assess the appropriateness prior to dispensing any prescription.

Useful links:

Is a cover letter required when receiving faxed prescriptions?

The fax cover letter is not a requirement of pharmacy record-keeping, however it may contain information required by bylaws that is not on the prescription. For a faxed prescription to be valid, it must have the practitioner’s phone number, fax number, time/date of transmission, pharmacy name and pharmacy fax number.

Useful links:

Can all refills be combined when filling a prescription? For example, if the prescription is written 90 tablets + 3 refills, can all 360 tablets be dispensed at once?

Pharmacists may reduce the dispensing quantity in some cases, but they are expected to dispense the prescription as written by the practitioner. Otherwise, pharmacists must consult with the prescriber before adjusting quantities to be dispensed.

Useful links:

Can the pharmacist refuse to sell Tylenol #1 (acetaminophen, caffeine, codeine) to a patient?

Depending on the reason, pharmacists can refuse to sell Tylenol #1. Health Canada forbids the sale of low-dose codeine products if the pharmacist has reasonable grounds to believe that it is not being used for recognized medical or dental purposes. The pharmacist has an obligation to resolve any drug therapy problems when selling any Schedule II medications.

Useful links:

What is the procedure the pharmacy must follow when narcotic medications must be destroyed?

Please follow the instructions provided by Health Canada: https://www.canada.ca/en/health-canada/services/health-concerns/controlled-substances-precursor-chemicals/controlled-substances/compliance-monitoring/compliance-monitoring-controlled-substances/unserviceable-stock.html 

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