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The College is asking for your feedback on proposed amendments to the Pharmacy Operations and Drug Scheduling Act (PODSA) Bylaws and the Health Professions Act (HPA) Bylaws, to implement the National Association of Pharmacy Regulatory Authorities (NAPRA) Model Standards of Practice for Continuous Quality Improvement and Medication Incident Reporting (National Standards) by integrating them into the College bylaws.
The proposed amendments are open for public comment for a notice period closing on January 10, 2025.
BACKGROUND
A Key Action in the College’s Strategic Plan 2022/23 – 2027/28 is the development and implementation of medication incident reporting (MIR) in community and hospital pharmacies. MIR aims to identify trends in medication incidents across the province, providing valuable insights for learning and improving practices and health outcomes. Analyzing medication incident data can enhance public safety, pinpoint recurring issues, and foster opportunities for continuous quality improvement (CQI) in health care delivery to the public.
To achieve this, the College has developed proposed amendments to the PODSA Bylaws and HPA Bylaws to put in place the regulatory framework for pharmacies and pharmacy professionals to engage in enhanced CQI and MIR activities. Pending Board approval, it is anticipated the amendments will come into effect mid-2026 to ensure pharmacies and pharmacy professionals have time to get ready for compliance.
In 2017, Melissa Sheldrick, a client safety expert and family advisor with the Institute for Safe Medication Practices Canada (ISMP Canada), requested that pharmacy regulatory authorities across Canada consider implementing mandatory MIR following the loss of her 8-year old son due to a drug dispensing error. The College Board subsequently directed the Registrar to explore potential alternatives to the College’s existing quality management requirements, including a standardized quality management program that includes mandatory medication error reporting to an independent third party. Since then, the College has participated with other pharmacy regulators within NAPRA to develop the National Standards, and seven out of ten provinces have already implemented the National Standards including both CQI and MIR components.
To inform the development of the proposed amendments, the College initiated an engagement process with the following partners:
- CPBC Pharmacy Advisory Committee (June 2023);
- BC Health Authority Hospital Pharmacy Directors (July 2023);
- BC Pharmacy Association (BCPhA) (November 2023);
- Canadian Society of Hospital Pharmacists BC Branch (November 2023);
- Neighbourhood Pharmacy Association of Canada (December 2023);
- Lower Mainland Pharmacy Services (January 2024);
- First Nations Health Authority (January 2024);
- Interior Health (January 2024);
- Island Health (February 2024); and
- BC Public Advisory Network (March 2024).
A key aspect of the proposed amendments includes enhanced CQI requirements that when implemented together, can mitigate risks and improve the quality and safety of client care. Components of enhanced CQI include identifying root causes and contributing factors for medication incidents and near misses, holding team meetings on a routine basis to proactively review and assess summary reports to identify areas for learning and improvement, conducting safety self-assessments to identify potential safety concerns within the pharmacy, and promoting a culture of client safety and just culture in the workplace environment, among others.
Summary of Amendments
The following are the proposed changes to sections 18, 24, and 29 of the PODSA Bylaws, posted on October 4, 2024.
Schedule of Amendments - PODSA Bylaws
Redline - PODSA Bylaws
The following are the proposed changes to Schedule A and F of the HPA Bylaws, posted on October 4, 2024.
Schedule of Amendments - HPA Blaws
Redline – HPA Bylaws – Schedule A – Code of Ethics
Redline – HPA Bylaws – Schedule F Part 1 – Community Pharmacy Standards of Practice
Redline – HPA Bylaws – Schedule F Part 1 – Hospital Pharmacy Standards of Practice
SUBMITTING COMMENTS
Please submit your feedback no later than January 10, 2025.
The collection of personal information is permitted under section 26(c) and (e) of the Freedom of Information and Protection of Privacy Act (FIPPA). Any feedback provided, including any personal information, may be made available to the College’s Board and may be provided to the Ministry of Health. The disclosure of personal information is authorized under section 33(2)(d), (e), and (h) of FIPPA. If you have any questions regarding the collection, use, or disclosure of this information, please contact the College’s Privacy Officer at 604-676-4225 or [email protected].
| College of Pharmacists of British Columbia |
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Comments on proposed changes to College bylaws may be submitted to the College by email, feedback form or regular mail. These submissions should be addressed to the attention of the Director of Policy and Legislation. Email: [email protected] Fax: 604-733-2493 or 800-377-8129 |
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Mailing Address: |
| Ministry of Health |
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Comments on proposed changes to College bylaws may be submitted directly to the Ministry of Health by email or regular mail. These submissions should be addressed to the attention of the Executive Director, Professional Regulation and Oversight. Email: [email protected] |
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Mailing Address: Executive Director
3rd Floor, 1515 Blanshard Street |