Board Highlights - September 22 & 23, 2022

College of Pharmacists of BC's September Board Meeting

Topics include improving the Indigenous patient complaint process, Cultural Safety, Cultural Humility, and Anti-Racism Practice Standard, amendments to the Controlled Prescription Program hard copy requirements for verbal and faxed prescriptions, Drug Schedule Regulation amendments and more.

PODSA 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 2022/23 budget. 

Following the April 2022 Board meeting, the proposed amendments to the PODSA fee schedule were publicly posted on the College website. The posting period ended in August 2022. No comments were received, and no further amendments are recommended.

The College’s new budget provides for a modest fee increase for registrants that will help to return College finances to a balanced budget and fully funded reserves, while enabling operations to meet the College’s mandate and staff to achieve the goals outlined in the Strategic Plan. 

The approved registrant fees are as follows: 

The proposed amendments to the PODSA fee schedule have been filed with the Minister of Health for a period of 60 days and will come into effect in late November. 

Cultural Safety, Cultural Humility, and Anti-Racism Practice Standard 

The Board approved amendments to the Health Professions Act Bylaws to adapt, with permission from the British Columbia College of Nurses and Midwives (“BCCNM”) and the College of Physicians and Surgeons of BC (“CPSBC”), the Indigenous Cultural Safety, Cultural Humility, and Anti-racism Practice Standard.

The development of this Standard comes in response to Dr. Mary Ellen Turpel-Lafond’s December 2020 report: In Plain Sight: Addressing Indigenous-specific Racism and Discrimination in B.C. Health Care.

The report found that “requirements for cultural safety and humility and addressing Indigenous-specific racism are not adequately embedded throughout policy and standards,” and goes on to recommend the implementation of standards, definitions and expectations requiring health services to be free from all forms of racism and discrimination against Indigenous peoples. 

In response to the report, on May 11, 2021, the Registrars of BCCNM, CPSBC, the College of Dental Surgeons of BC (“CDSBC”), and CPBC issued a joint apology to Indigenous peoples and communities in BC. The apology included a pledge by the colleges to take specific actions to uphold Indigenous rights, eliminate racism within the health-care system, and slowly earn the trust of Indigenous people. In particular, the colleges committed to “provide education and develop practice standards to ensure Indigenous people receive culturally safe health care”.

In February 2022, the boards of BCCNM and CPSBC approved an Indigenous Cultural Safety, Cultural Humility, and Anti-Racism Practice Standard. The Standard was developed in collaboration by both colleges, and involved an extensive, 18-month consultation process. 

In May 2022, 11 of BC’s health regulatory colleges met to discuss the adaptation and implementation of the Standard within their own regulatory frameworks. The BCHR colleges agreed to build on the significant work done by BCCNM and CPSBC and adapt and implement the Standard as is, with only minor customization and formatting changes. This will help to promote consistency by ensuring that all regulated health professionals in BC are subject to the same requirements and expectations for providing culturally safe and anti-racist care for Indigenous patients and clients. 

To commemorate the significance of the Standard, the BCHR colleges have committed to participating in a joint blanketing ceremony on September 30th, 2022, led by Sulksun (Shane Pointe), proud member of the Coast Salish Nation, Musqueam Indian Band and Knowledge Keeper to all and Joe Gallagher (k’wunəmɛn), Tla’amin Nation, Principal at Qoqoq Consulting. This ceremony is an important step toward establishing a collective commitment to work as part of the broader group of BCHR colleges, to dismantle Indigenous-specific racism within our health system. September 30 was chosen to coincide with Orange Shirt Day and the second annual National Day of Truth and Reconciliation. 

The proposed bylaws have been filed with the Minister of Health, with a request to shorten the filing period to 4 days. The new standards will be in effect on September 29, 2022, in order to enable our participation at the blanketing ceremony.  

The College acknowledges that we are still very much at the beginning of our journey toward dismantling Indigenous-specific racism within our healthcare system. The implementation of this practice standard is by no means a conclusion. Moving forward, the College will continue to engage with Indigenous peoples to ensure that this standard is adequately and effectively addressing the challenges they face when accessing pharmacy and other health services.  

Bylaw Amendments to the Controlled Prescription Program Hard Copy Requirements for Verbal and Faxed Prescriptions

The Board approved amendments to the Pharmacy Operations and Drug Scheduling Act (PODSA) Bylaws and the Health Professions Act (HPA) Bylaws to change the Controlled Prescription Program hard copy requirements for verbal and faxed prescriptions, for approval for public posting. 

The Controlled Prescription Program (CPP) was established to prevent prescription forgery and reduce inappropriate prescribing of drugs. 

Typically, CPP prescriptions must be provided using a hard copy of the original prescription form. However, in March 2020, the Board approved amendments to the PODSA Bylaws and Community Pharmacy Standards of Practice to allow for CPP prescriptions to be provided verbally or by fax. This was done in consultation with the Ministry of Health in order to reduce barriers to care during the COVID-19 public health emergency. 

As a condition of these amendments, registrants who receive CPP prescriptions transmitted verbally or by fax, must also be sent the original prescription form from the practitioner as soon as reasonably possible. Recently however, the College has received concerns about the need for the original form when CPP prescriptions are provided verbally or by fax. In some cases, pharmacies may not receive them. In these situations, registrants will not be fully compliant with the requirements and left with little recourse, as the CPP drugs will have already been dispensed. This may reduce the likelihood a pharmacist would accept a verbal or faxed prescription for a CPP drug, thus creating barriers to accessing controlled substances and ultimately running counter to the original intent of the amendments. 

As such, the Board approved amendments for public posting that require a CPP form still be received by the pharmacy for verbal CPP prescriptions; however, these amendments would allow for a fax copy of the CPP form to be accepted in place of the hard copy (though hard copies would also continue to be acceptable). This recommendation upholds the purpose of the CPP, as the faxed prescription must still be written on a CPP form. It is anticipated that it will be easier for prescribers to send CPP forms by fax, instead of sending the hard copies, and that pharmacies will be more likely to receive the faxed copies.

Further to this, amendments to the Community Pharmacy Standards of Practice are proposed to remove the requirement for receipt of the original hard copy when a CPP form is faxed. However, the faxed prescription must still be written on a CPP form, thereby upholding the purpose of the CPP. 

Currently, pharmacists must retain the hard copy of all CPP prescriptions received, even if they are stored electronically. Since the proposed changes remove the requirement for an original hardcopy CPP form to be received by a pharmacy, the proposed amendments include changes to the College’s recordkeeping requirements so that pharmacies will be required to retain printed paper copies of faxed CPP forms that are received in place of the original.

These amendments will now be posted for public comment on the College’s website for a period of 90 days.  All registrants and members of the public are encouraged to provide feedback on the proposed bylaws. The public posting period ends on December 24, 2022.

Drug Schedules Regulation Amendments 

The Board approved amendments to the Drug Schedules Regulation (DSR) under the Pharmacy Operations and Drug Scheduling Act (PODSA) to improve alignment with the National Drug Schedules (NDS), and the Prescription Drug List made under the Food and Drugs Act (Canada). 

Health Canada determines whether a drug must be sold by prescription only (listed in the Prescription Drug List) or if it can be sold over the counter (non-prescription status). Provincial regulatory authorities can further restrict the conditions of sale of non-prescription products; however, they cannot be less stringent than the federal requirements.

The National Association of Pharmacy Regulatory Authorities’ (NAPRA’s) National Drug Schedules Advisory Committee (NDSAC) recommends appropriate placement of non-prescription drugs in the NDS within a three-schedule national model. 

British Columbia is one of the few provinces in Canada that maintains its own list of scheduled drugs through the DSR. Nevertheless, almost all amendments to BC’s DSR are based on recommendations from NDSAC. The legislative authority for the Board to amend the DSR is found in subsections 22(1) and (2) of the Pharmacy Operations and Drug Scheduling Act.

Amendments are made regularly to NAPRA’s NDS and the Prescription Drug List. This means that over time, drug scheduling in the DSR becomes misaligned with those sources.

As such, these amendments to the DSR will help to align it with recent scheduling changes made to non-prescription products listed in the NDS, as well as changes to the Prescription Drug List. 

These amendments have been filed with the Ministry of Health for a period of 60 days and are expected to come into force in November 2022. 

Recognized Pharmacy Education Programs

The Board approved housekeeping amendments to the Health Professions Act (HPA) Bylaws Schedule “C” Recognized Education Programs to remove outdated content and reflect current program names. 

Schedule “C” under the HPA Bylaws lists recognized pharmacy education programs in Canada and the United States, injection/intranasal drug administration programs, and recognized pharmacy technician programs in B.C. These programs are already recognized by national accreditation organizations like the Canadian Council for Accreditation of Pharmacy Programs and the Canadian Council on Continuing Education in Pharmacy.

Maintaining a current list of recognized pharmacy and pharmacy technician education programs, including programs for injection/intranasal drug administration certification, enables the College to ensure registrants are appropriately registered with the College and certified to practice. Due to the development of new pharmacy education programs, program name changes and the discontinuation of certain programs, from time to time it is necessary to amend Schedule “C” to accurately reflect those changes. 

These amendments have been filed with the Minister of Health for a period of 60 days and are expected to come into effect in late November.