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PRP Insights: Areas of Non-Compliance for Pharmacist Prescribing for Minor Ailments and Contraception (PPMAC)
On June 1, 2023, new regulatory standards came into effect that provided pharmacists in BC with the authority to diagnose and prescribe medications to clients in British Columbia for minor ailments and contraception. To ensure patient safety and effective care, pharmacists are required to complete the College’s mandatory Regulatory Education Module before making diagnoses or prescribing medications for minor ailments and contraception. Completion of this module is required to ensure that pharmacists providing PPMAC are aware of and practicing in accordance with the regulations, standards, limits and conditions that enable and govern this practice.
The Practice Review Program (PRP) has recently introduced community pharmacy review criteria for PPMAC. This article will focus on some of the early findings regarding areas of non-compliance observed by Compliance Officers when reviewing PPMAC services.
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REGULATIONS, STANDARDS, LIMITS AND CONDITIONS FOR PPMAC |
Prescribing Out of Scope
Under the regulations for PPMAC, pharmacists can make a diagnosis and prescribe drugs for the conditions listed in Schedule A of the Pharmacists Regulation. Pharmacists may only prescribe schedule I drugs for these conditions if the drug is in a drug category shown opposite the condition listed in Schedule A of the Pharmacists Regulation.
Compliance Officers have identified instances where pharmacists have prescribed drugs that were not within the specified drug categories in Schedule A for the diagnosed condition. Examples include prescribing “triptans” for headaches and muscle relaxants for musculoskeletal pain. In both examples, pharmacists are limited to prescribing non-steroidal anti-inflammatories for these conditions.
Additionally, Compliance Officers have observed instances of pharmacists diagnosing and prescribing for urinary tract infections (UTIs) in cases where the patient presented with signs and symptoms of a complicated infection. As per the Pharmacists Regulation, pharmacists may only prescribe for uncomplicated UTIs.
Pharmacists are responsible for ensuring that they have the necessary knowledge, skills and abilities to diagnose and prescribe for the conditions permitted under PPMAC. This includes possessing the necessary clinical knowledge and understanding of the regulatory framework that enables pharmacists in BC to prescribe for minor ailments and contraception.
Pharmacists using clinical tools such as assessment checklists and treatment algorithms to aid prescribing decisions are still independently responsible for ensuring their prescribing decisions align with the regulatory requirements for prescribing in BC. It is important to recognize that not all clinical tools will reflect the provincial standards, limits and conditions set by the College of Pharmacists of BC or the requirements outlined in the Pharmacists Regulation. Pharmacists should be aware of the limitations of the clinical tools being utilized, including whether the prescribing algorithm deviates from the scope of prescribing as outlined in the regulatory framework.
Documentation
Documentation is an important component of the pharmacist’s responsibilities when providing PPMAC as it creates a record of the prescribing decision, the pharmacist’s rationale and the information conveyed to the patient. If a pharmacist prescribes a drug for a patient, the standards require that the pharmacist documents:
- patient information, including personal health number (PHN), if available;
- acknowledgement of informed consent;
- patient assessment;
- prescribing decision and rationale, including diagnosis;
- prescription information, including all information that is required for a prescription;
- instructions provided to the patient, including the monitoring and follow-up plan;
- name of the patient’s primary health care provider or other health care provider that was notified and the date of notification, if applicable; and
- patient response to treatment, if applicable.
When reviewing PPMAC documentation, Compliance Officers have noted areas of non-compliance, including missing or incomplete documentation. Required components such as the pharmacist’s rationale and the instructions provided to the patient, including the monitoring and follow-up plan, were the most common pieces missing from the documentation. Pharmacists are expected to document PPMAC fully, as required by the standards, to ensure that there is a clear record of the actions taken and the reasons behind them. If templates are used to aid documentation, required sections of the template are expected to be filled out completely, including adding checkmarks, where necessary in the template to indicate positive action and/or decision making. Pharmacists should review templates to confirm all of the required pieces of documentation are accounted for. If a template is missing sections that are required by the standards, the pharmacist is still responsible for ensuring these pieces are documented.
To learn more about the Practice Review Program, including how to prepare for your review, visit: