New Reporting Requirements for Medical Assistance in Dying come into effect November 1, 2018

Starting November 1, 2018, new reporting requirements for Medical Assistance in Dying (MAiD) come into effect. The new Federal regulations and Provincial requirements identify the reporting requirements for pharmacists, physicians, and nurse practitioners.

Provincial oversight and reporting related to MAiD is currently conducted by the BC Coroners Service. Starting November 1, the Ministry of Health will become the designated recipient of all reportable information from pharmacists, physicians, and nurse practitioners.

Amendments to the College’s Standards Limits and Conditions for MAiD will also come into effect at the same time, which reflect the new Federal and Provincial reporting requirements.

Reporting Medical Assistance in Dying in British Columbia

Pharmacists who dispense drugs for the purposes of MAiD will be required to submit both the federally and provincially required information to the Ministry of Health within 6 business days after the scheduled date of MAiD Protocol.

As part of its oversight and monitoring of MAiD in the province, BC’s Ministry of Health requires additional information to be provided as part of the reporting requirements. This includes:

Confirmation of the dispensing of drugs signed by the prescriber and pharmacist; and,
The pharmacists’ reconciliation of unused drugs returned to the pharmacy.

In BC, pharmacists who dispense drugs for the purposes of MAiD will be required to submit all required information to the Ministry of Health within 6 business days after the scheduled date of drug administration.

The reporting requirements are explained in detail on the related Ministry of Health MAiD forms and accompanying instruction guides. They will also be available on the Ministry of Health’s website on November 1, 2018.

Reporting Process for Medical Assistance in Dying in British Columbia

All required provincial forms for MAiD must be submitted to the BC Ministry of Health’s MAiD Oversight Unit starting November 1, 2018.

Pharmacists who dispense drugs for the purposes of MAiD will be required to complete and submit the Ministry of Health’s designated Dispensing Record (Pharmacist) form. The new form will collect all the information necessary for prescription accountability and meeting the Federal and Provincial MAiD reporting requirements.

Dispensing Record (Pharmacist) form HLTH 1641

The new Dispensing Record (Pharmacist) form HLTH 1641 will replace the Prescription Planning and Prescription Accountability sections on page 5 of the current Prescription document for MAiD. As a result, the Prescription Planning and Prescription Accountability sections will no longer be included as part of the Prescription document (which will include the Prescription order and Medication Administration Record).

Starting November 1, 2018, pharmacists will need to download a Dispensing Record (Pharmacist) form HLTH 1641 directly from the BC Ministry of Health’s website.

The new form will be available through the Ministry of Health's website on November 1, 2018

Return of Medications

As part of the prescription planning and accountability process for MAiD, procedures need to be established for the prescriber’s return of any unused and partially used medication(s) within 72 hours of the patient’s death to the pharmacy for secure and timely disposal. Collaboration between the prescriber and pharmacist involved will be needed to ensure this process is followed.

When the prescriber returns the medication(s) to the pharmacy together with the completed Medication Administration Record, the receiving pharmacist will reconcile and document the return of the medication(s) using the Ministry of Health’s Dispensing Record (Pharmacist) form.

Both the prescriber and the receiving pharmacist will need to sign the Dispensing Record (Pharmacist) form following the medication return.

Records Submission to the Ministry of Health

(Starting November 1, 2018)

Competed Dispensing Record (Pharmacist) HLTH 1641 forms need to be faxed to the Ministry of Health’s Medical Assistance in Dying Oversight Unit within 6 business days after the scheduled date of drug administration.

Fax: 778-698-4678

Federal Regulations for the Monitoring of Medical Assistance in Dying

Federal reporting requirements for pharmacists who dispense substances in connection with the provision of Medical Assistance in Dying are included under section 11 and Schedule 7 of the Regulations for the Monitoring of Medical Assistance in Dying under the Criminal Code of Canada.

SCHEDULE 7

(Section 11 and subsection 16(1))

Dispensing a Substance

1. The following information in respect of the patient for whom the substance was dispensed:

(a) date of birth;

(b) health insurance number and the province or territory that issued it or, in the case where they do not have a health insurance number or the pharmacist does not know the patient’s health insurance number, the province or territory of their usual place of residence on the day on which the pharmacist dispensed the substance.

2. The following information in respect of the pharmacist:

(a) name;

(b) the province or territory in which they practise and, if they practise in more than one province or territory, the province or territory in which they dispensed the substance;

(c) the licence or registration number assigned to the pharmacist in the province or territory in which they dispensed the substance;

(d) the mailing address and email address that the pharmacist uses for work.

3. The following information in respect of the practitioner who prescribed the substance or obtained the substance from the pharmacist:

(a) name;

(b) the licence or registration number assigned to the practitioner in the province or territory in which they received the request.

4. The following information in respect of the dispensing of the substance:

(a) the date on which the substance was dispensed;

(b) an indication of which of the following places describes where the pharmacist dispensed the substance or, if they dispensed the substance elsewhere, a description of that place:

(i) hospital pharmacy,

(ii) community pharmacy.

(Note: Requirements currently published through the Canada Gazette, Part II, Volume 152, Number 16 will come into effect and be reflected in the Criminal Code on November 1, 2018)

For an overview of Health Canada’s new reporting requirements for Medical Assistance in Dying, including who needs to report and what kind of request triggers reporting requirements and example scenarios See Health Canada: Reporting requirements for medical assistance in dying.

Provincial Requirements for the Dispensing Drugs for the Purposes of Medical Assistance in Dying

Provincial requirements are included within the Health Professions Act Bylaws – Schedule F – Part 5 – Dispensing Drugs for the Purposes of Medical Assistance in Dying – Standards, Limits and Conditions.

6. The full pharmacist who dispenses a substance in connection with the provision of medical assistance in dying must provide the B.C. Ministry of Health with the information referred to in Schedule 7 of the Regulations for the Monitoring of Medical Assistance in Dying made under the Criminal Code (Canada), as well as the additional information required for provincial oversight, monitoring and reporting purposes. The information shall be documented on the provincial form designated for this purpose and submitted to the B.C. Ministry of Health within 6 business days after the day on which the substance is scheduled to be administered to the patient. The information to be documented by the full pharmacist includes but is not limited to the following:

(a) The date and time the drugs were dispensed;
(b) The name and signature of the medical practitioner or nurse practitioner to whom the drugs were dispensed; and
(c) If the medical practitioner or nurse practitioner to whom the drugs were dispensed is not known to the pharmacist, that the pharmacist confirmed the prescribing medical practitioner’s or nurse practitioner’s identity by means of photo identification.

6.1. The full pharmacist must comply with any request for information or provision of records sought by the B.C. Ministry of Health for the purpose of oversight and monitoring of medical assistance in dying.

(Note: Requirements will come into effect and be reflected in the College’s Schedule F – Part 5 – Dispensing Drugs for the Purposes of Medical Assistance in Dying – Standards, Limits and Conditions on November 1, 2018)

Questions

For questions or concerns regarding the new regulations and reporting requirements, please contact the Ministry of Health’s Medical Assistance in Dying Oversight Unit or Health Canada.

BC Ministry of Health - Medical Assistance in Dying Oversight Unit
h [email protected]
778-698-7497

Health Canada (Federal Regulations)
[email protected]
1-833-219-5528

Pharmacists and pharmacy technicians are always welcome to contact the College’s Practice Support with questions or concerns about pharmacy practice.

Practice Support
[email protected]

Oct 25, 2018