Board Highlights - September 13, 2019

Board Highlights - September 13, 2019

Highlights from this meeting include Medication Incident Reporting, the Rescheduling of Codeine Containing Liquid Preparations, Amendments to the Committee Members Terms of Office, Amendments to PPP-3: Pharmacy References, the College's next Strategic Plan and more.

You can re-watch all the Board meeting presentations through the College’s Periscope Channel.

Medication Incident Reporting

The Board approved a motion requiring mandatory anonymous medication incident reporting in all pharmacies. Over the next several years, the College will be developing standards and criteria, as well as bylaw and policy changes to enable implementation of a mandatory anonymous Medication Incident Reporting Program by 2022/23.

Ultimately, the goal is to allow non-hospital pharmacies to use any medication incident reporting platform they choose, provided it is among those that meets the College’s criteria (to be developed), including the capability to transfer a minimal data set into a national repository that is administered by an independent third party. There is an information system currently in use within hospital pharmacies; the minimal data set will also be transferred into a national repository.

There is currently no way to quantify the number and types of medication incidents that are occurring in community pharmacy settings, and there is no central information system to which community pharmacy staff can report medication incidents. As a result, there is a missed opportunity for the majority of pharmacies and pharmacy professionals in BC to learn from incidents occurring in other pharmacies. 

Medication errors are a leading cause of preventable injuries and result in significant costs to health systems across the world. In 2017/18 and 2018/19, the most common complaints received by the College were related to medication dispensing errors by pharmacy professionals.  

In 2017, Melissa Sheldrick, a patient safety advocate whose son passed away due to a drug dispensing error in Ontario, requested that the College consider implementing mandatory medication incident reporting.  After the issue was presented to the Board, the decision was made to begin explore potential alternatives to the College’s existing quality management requirements. 

In 2018, potential options for medication error reporting were presented to the Board and the College moved forward with the option of exploring implementation of mandatory medication incident reporting to an independent third party. 

With the Board approval now to require mandatory anonymous medication incident reporting in all pharmacies, the following next steps are planned:

Data analysis of medication incidents has the potential to improve public safety nationally and provincially. Mandatory anonymous medication incident reporting provides data that can be analyzed to help identify trends in incidents that are occurring and provide opportunities to learn from mistakes, improve practice and better protect the public.

As part of exploring the best path forward for medication incident reporting in BC, the College has been participating in national conversations on the implementation of medication incident reporting systems, including the NAPRA Medication Incident Reporting Working Group. Moving forward, the College will be continuing to work with the NAPRA Working Group to develop medication incident reporting standards and criteria, and establish a single national data repository.

Status Update - Drug Administration Authority

Board Chair Arden Barry provided the Board with an update on the progress of the Drug Administration Committee’s (DAC) work to remove the restrictions on pharmacist injection and intranasal administration of medications, while restricting the administration of injections for cosmetic purposes and retaining current age limit restrictions. 

The Standards, Limits and Conditions governing pharmacists’ administration of drugs by injection or intranasal route are established in Schedule “F”, Part 4 under the Health Professions Act (“HPA”) Bylaws. The HPA confers broad injection authority, allowing pharmacists to administer Schedule 1, 1A or 2 drugs or substances through the intradermal, intramuscular, or subcutaneous injection or intranasal routes. However, the College places limits on injection drug administration such that practicing pharmacists may only administer drugs by injection or intranasal routes for the purposes of immunization. 

The DAC convened in 2018 to review the College’s Standards, Limits and Conditions on drug administration and consider evidence, including potential benefits and risks for patient safety and public protection, related to removing the current restrictions.

Based on the review and recommendations from the DAC, in February 2019, the Board directed the Registrar to remove current restrictions on pharmacist injection and intranasal administration of medications, while restricting the administration of injections for cosmetic purposes and retaining current age limit restrictions. 

Since then, the College has been invited to work with the Professional Regulation and Oversight Branch of the Ministry of Health to establish a working group to determine the impacts of removing these restrictions on other health profession regulators, interprofessional practice and patient care.

The first meeting of the Safe Drug Administration by Pharmacists Working Group is expected to occur in October 2019. 

Pharmaceutical Services Division: Defining and Delivering on its Mandate

Mitch Moneo, Assistant Deputy Minister or the Pharmaceutical Services Division (PSD) of the Ministry of Health presented to the Board some of the key highlights and achievements of the PSD, and the evolution of the PSD’s mandate to improve patient outcomes in the BC Health System.

Key achievements of the Pharmaceutical Services Division include:

• Reduced or eliminated Fair PharmaCare deductibles for low income families
• Reduced generic drug prices through five-year pCPA Generic Drugs 2.0
• Lead the provincial and territorial response to National Pharmacare
• Collaborated with the Therapeutics Initiative to support and enhance evidence-based decision-making
• Lead an initiative to deploy Primary Care Pharmacists to work collaboratively within team-based primary care networks

HPA Bylaws: Amending Committee Member Terms of Office

The Board approved for filing with the Ministry of Health, amendments to the bylaws under the Health Professions Act to change the length of committee member terms of offices. As a result of the changes, terms shall not exceed three years, and members shall not serve more than six consecutive years in total. 

Currently, terms for committee members must not exceed two years, and members cannot serve more than three consecutive terms (i.e., six years total).

The proposed amendments align more closely with the three-year term limit for Board members. They also provide flexibility when establishing term lengths for those appointed to committees.

Following the April 2019 Board meeting, the proposed amendments were publicly posted on the College website until July 2019. No comments were received, and no further amendments were recommended.

The amended bylaws will now be filed with the Ministry of Health and are expected to come into effect in mid- November 2019. 

Authorizing the Registrar to Act under s.32(3) of the HPA

The Board approved for filing with the Ministry of Health, amendments to the Health Professions Act Bylaws to authorize the Registrar to act under s. 32(3) of the HPA. 

This authorizes the Registrar to dismiss complaints made to the College that were eligible for disposal, as outlined in s. 32(3):

(3) Despite subsection (2), the registrar, if authorized by the board, may dismiss a complaint, or request that the registrant act as described in section 36 (1), without reference to the inquiry committee if the registrar determines that the complaint

1. is trivial, frivolous, vexatious, or made in bad faith;
2. does not contain allegations that, if admitted or proven, would constitute a matter subject to investigation by the Inquiry Committee; or, contains allegations that, if admitted or proven, would constitute a matter, other than a serious matter, subject to investigation by the Inquiry Committee.

For the purposes of enhanced transparency and to align with several other colleges established under the HPA who have placed this authority in bylaw, at their April 2019 meeting, the Board approved, for public posting, proposed HPA Bylaw amendments to authorize the Registrar to act under s. 32(3). No comments were received. 

The amended bylaws will now be filed with the Ministry of Health and are expected to come into effect in mid- November 2019. 

PODSA Bylaws: Fee Amendments

The Board approved amendments to the Pharmacy Operations and Drug Scheduling Act (PODSA) Bylaws Schedule A – Fee Schedule, in accordance with the College’s 2019/2020 budget. These fee increases were initially approved at the February 2019 meeting as part of the College’s 2019/2020 budget. 

At their April 2019 meeting, the Board approved publicly posting the proposed PODSA Bylaws Schedule A – Fee Schedule for comment until July 2019. No comments were received. 

The amended bylaws will now be filed with the Ministry of Health and are expected to come into effect in mid-November 2019. 

DSR Amendment: Rescheduling of Codeine Containing liquid Preparations as Schedule 1A

The Board approved amendments to the Drug Schedules Regulation (DSR) under the Pharmacy Operations and Drug Scheduling Act (PODSA) to move certain Schedule 1 codeine containing liquid preparations to Schedule 1A. 

Earlier this year, the members of the Controlled Prescription Program Advisory Committee (CPPAC) discussed public safety concerns regarding certain Schedule 1 codeine containing liquid preparations.

Note: CPPAC includes representatives from the Ministry of Health and the health regulators of professions that prescribe or dispense Schedule 1A drugs. The purpose of CPPAC is to regularly review and recommend updates to the Controlled Prescription Program (CPP) drugs (i.e., Schedule 1A) list, and provide a forum to share knowledge and coordinate practices around drugs with a high-risk profile. 

Key public safety concerns related to codeine containing liquid preparations for include the accessibility of these drugs, the potential for misuse, and evidence of break and enters, robberies and forged prescriptions for them.

After discussing the concerns raised, CPPAC recommended moving Schedule 1 codeine containing liquid preparations to Schedule 1A. And, at their May 2019 meeting, the Board of the College of Physicians and Surgeons of BC (CPSBC) approved rescheduling codeine containing liquid preparations that are currently listed as Schedule 1 to Schedule 1A. The College Board decision to reschedule these drugs is aligned with those CPPAC and CPSBC decisions, and helps to operationalize them.

Moving Schedule 1 codeine containing liquid preparations to Schedule 1A will improve oversight of these drugs. For example, prescriptions for them will need to be written on a CPP duplicate prescription, which is designed to prevent forgeries. In addition, as Schedule 1A drugs, they will need to be stored in a time-delayed safe designed to deter theft and robbery. As a result, rescheduling will help to mitigate the public safety risks associated with the forgeries, thefts and robberies of these drugs.

This amendment is set to come into effect on January 2, 2020. 

Stay tuned for more information from the College on these upcoming changes.

PPP Amendment: PPP-3 Pharmacy References

The Board approved amendments to Professional Practice Policy – 3: Pharmacy References, removing the requirement for all community pharmacies and telepharmacies to have a copy of the BC Pharmacy Practice Manual. 

This policy currently requires all community pharmacies and telepharmacies to have access to the most current version of the BC Pharmacy Practice Manual, either electronically or by purchasing a printed copy through eServices. 

The BC Pharmacy Practice Manual includes duplicative links to information such as the College’s mission statement, Framework of Professional Practice, legislation, drug distribution, PharmaNet and ReadLinks articles. While originally intended to serve as a useful tool for pharmacies to be able to access relevant information from the College’s website in one place, the College recently assessed how often the BC Pharmacy Practice Manual was accessed over the last three years. The College’s findings indicate a very low usage rate over that period. As a result, the Board decided to remove the requirement for community pharmacies and telepharmacies to have a copy of the BC Pharmacy Manual (electronic or print) as all the information contained within it, is available on the College website. 

Instead, PPP-3 will now require that all community pharmacies and telepharmacies have access to current versions of the following: 

1. All legislation relevant to pharmacy practice and management; 
2. The College’s Professional Practice Policies and Guides; and
3. The College’s ReadLinks published within the last three years. 

PODSA Ownership Update

Board Vice-Chair and Chair of the Application Committee, Christine Antler provided the Board with an update on the progress of the new ownership requirements under the Pharmacy Operations and Drug Scheduling Act, introduced on April 1, 2018.

These changes permit the College to know the identity of all pharmacy owners, determine their suitability for pharmacy ownership and hold them accountable for providing safe and effective care by ensuring their pharmacies are compliant with legislative requirements for pharmacies in BC.

As of May 31, 2019, 1445 licensed pharmacies have gone through the renewal process under the new ownership requirements. The College has also identified 874 Direct Owners of these pharmacies.

The last group of pharmacies to complete the new requirements for their renewals during the transition period were those with a license expiry date of May 31, 2019. The post-transition period started with the June 30, 2019 pharmacy licence renewals. 

The difference in requirements post transition are as follows: 

• Proof of Eligibility is still required.
• New indirect owners and indirect owners of a new direct owner and new managers will still have to continue completing their Proof of Eligibility.
• Criminal Record Histories are only required once every 5 years.  Therefore, direct owners, indirect owners and managers who completed their CRH requirement for their pharmacy renewal during the transition period will not have to complete it again for 4 years.

During the transition period, information about trustees was not collected, as trustees were not initially considered to be indirect owners and therefore not subject to the ownership requirements under PODSA. 

Upon further review, it was determined that trustees do in fact fit within the definition of an indirect owner. Trustees will now be subject to the requirements for indirect owners and must complete the Proof of Eligibility requirement.

As such, an updated CSR (if necessary) and POE from trustees who did not complete their POE during the transition period must now be submitted no later than 30 days before the current pharmacy licence expires. 

Medical Delegation Request: Pro-Health Pharmacy

The Board approved a Delegation of a Medical Act from a Chilliwack physician allowing the administration of antipsychotic depot injections and both intramuscular and subcutaneous injections to pharmacists from the Pro-Health Pharmacy. 

Chilliwack has seen an increasing mental health and homeless problem. In May 2017, the official homeless count was 221. However, over the past year it is estimated to be closer to 350 homeless. This number puts a huge strain on local walk-in clinics and hospital services. Even without counting the homeless population our mental-health services are over capacity and unable to keep up. Pro-Health Pharmacy is situated a couple blocks from the Chilliwack General Hospital and Chilliwack Mental Health which is an ideal location for depot antipsychotic medication administration.

The College of Physicians and Surgeons of BC (CPSBC) allows persons other than physicians to be entrusted with performing a medical act via a Delegation of a Medical Act. According to CPSBC guidelines, when a medical act that is outside the scope of practice of another discipline is delegated, the responsibility for that act is shared. The physician who delegates the act still has a responsibility to the patient, and the person who carries out the act must do so with care and diligence and is legally liable if negligent. 

Currently, the administration of injections, except for immunization, is beyond the scope of practice of B.C. pharmacists. So, for B.C. pharmacists to provide injections of a drug or substance that is not an immunization, the Delegation of a Medical Act process between the CPSBC and CPBC needs to be followed.

The CPSBC Board previously approved this request. As per the existing approval process between CPSBC and CPBC, the CPBC Board must also approve this delegation request for it to be effective.

The approved delegation will allow the aforementioned physician’s patients to receive prescribed injections at his office or at the Pro-Health Pharmacy. 

Strategic Plan 2020/2021 to 2024/2025 Budget Implications

Vice-Chair of the Audit and Finance Committee, Tracey Hagkull presented to the Board the draft Strategic Plan goals and revised objectives and related budget implications for consideration, by the Registrar, of the multi-year budget impact.

In reviewing the draft goals and objectives, consideration was given to the resources required to fulfill the objectives. For most goals the incremental (over and above normal operating) costs are fairly minimal, with the exception of Goal One, which will require one full time employee as well as legal and other outside consulting.

The College has reviewed the above costs and factored this information into the multi-year budget plan format in order to assess the impact over time and the fee increases required to support this.

The Board will review and approve the 2020/21 budget at the February 2020 Board meeting.

Approval of Joint Venture

The Board approved, in principle, the transfer of the College’s portion of the extraordinary costs, approximately $600,000, to the Joint Venture for repairs to College Place’s curtain wall and the replacement of windows.

Approval of Strategic Plan 2020/2021 to 2024/2025 Goals and Objectives

The Board approved the Goals and Objectives for the College’s 2020/2021 to 2024/2025 Strategic Plan.

After being reviewed by College staff in June, the draft goals and objectives were adjusted to increase focus on public and patient-centred care, and to ensure alignment with the College’s mandate.

The College’s Strategic Plan 2020/2021 to 2024/2025 Goals and Objectives are as follows:

• Goal One: The Public is given evidence-informed, patient-centred, team-based care.
  • Objective: To develop a plan to support the provision of evidence-informed, patient-centred, team-based care that includes cultural safety and humility​
• Goal Two: To enable practice innovation through regulation that enhances health and wellness of the public and ensures patient safety.
  • Objective: Ensure patient safety and health and wellness of the public by implementing a transparent plan that engages the public in identifying practice innovations and determining the College’s role.
• Goal Three: To have the public and health professionals see pharmacy professionals as valuable resources who are acting first and foremost in the public interest.
  • Objective: To communicate what the public and health professionals can expect from pharmacy professionals.
• Goal Four: To have strong, collaborative engagement with all healthcare providers to advance patient-centred, team-based care.
  • Objective: Enhance patient health and wellness through collaborative engagement with all healthcare providers.

Stay tuned for more on the College’s Strategic Plan for 2020/2021 to 2024/2025 which will be launched in March 2020.

Approval of Updated Registrar’s Job Description

The Board approved updates made to the Registrar job description.

At its first meeting on July 15, 2019, the Registrar Evaluation & Succession Planning Committee identified the need to review and update the Registrar’s job description. 

These revisions were finalized on August 20, 2019. The Chair of the day will continue to work on the job description and bring it for further consideration to the Committee.

Approval of Registrar Evaluation Calendar

The Board approved a Registrar Evaluation Calendar.

The approved evaluation calendar was created by the Registrar Evaluation and Succession Planning Committee in order to provide a schedule for the Registrar’s evaluation process.

Establishment of Past Chairs Advisory Committee

The Board approved the establishment of a Past Chairs Advisory Committee.

At the June 2019 Board meeting, the Governance Committee proposed the establishment of the Past Chairs Advisory Committee. At this meeting the Board could not come to a consensus on the requirement of Board membership on the, therefore, the motion to approve the establishment of the Past Chairs Advisory Committee with the Terms of Reference as circulated was rescinded.

Since this time, the Governance Committee has further discussed the proposed committees’ Terms of Reference and made necessary revisions.

Approval of Revised Board Reference and Policies

Approve a revision to the College of Pharmacists of BC Board Reference and Policies document to include the option of approving honoraria for Board or committee members who are requested to attend conferences, training sessions, etc. on a case by case basis.

RECAP OF THE BOARD MEETING ON SOCIAL MEDIA