Share
PRP Insights: Areas of Non-Compliance for Pharmacist Drug Administration
The Practice Review Program (PRP) has recently introduced community pharmacy review criteria for drug administration. During reviews, Compliance Officers are reviewing drug administration services to ensure that pharmacists are practicing in accordance with the established standards, limits and conditions. Compliance Officers may identify areas of non-compliance, for which they will then work with pharmacy managers to ensure deficiencies are addressed through establishment and implementation of corrective measures. This article will focus on some of the early findings regarding areas of non-compliance observed by Compliance Officers when reviewing these services.
In October 2022, practice changes for BC pharmacists were implemented to remove restrictions on drug administration, allowing pharmacists to administer most schedule I, IA and II drugs by intradermal, intramuscular or subcutaneous injection or intranasally with the following limits:
1. A practising pharmacist may only administer a drug or substance if it has been prescribed by a practitioner, unless it is for the purpose of immunization, to treat anaphylaxis arising from administering a drug or substance, or to administer naloxone to a person suspected of suffering from an overdose of opioids.
2. A practising pharmacist must not administer allergy serums, nor administer drugs and substances for cosmetic purposes by injection.
3. A practising pharmacist must not administer an injection to a child under 4 years old.
4. A practising pharmacist must not administer a drug by intranasal route to a child under 2 years old.
ADMINISTRATION OF INJECTABLE VITAMIN B12 WITHOUT A PRESCRIPTION
Pharmacists may only administer a drug or substance if it has been prescribed by a practitioner, unless it is for the purpose of:
- Immunization,
- Treating anaphylaxis arising from administering a drug or substance or,
- Administering naloxone to a person suspected of suffering from an overdose of opioids
If a pharmacist administers a drug for a purpose other than those listed above, the patient must have the drug prescribed by a practitioner, prior to doing so. It is important to note that pharmacists are only able to prescribe for conditions and drug categories indicated in the Pharmacists Regulation. If a pharmacist does not have authority to prescribe the drug to be administered, the prescription must be issued by an authorized prescriber.
A common example of a drug that has been observed to be administered without a prescription, despite not meeting the prescription exemption criteria above, is vitamin B12 injections. Although injectable vitamin B12 (without intrinsic factor concentrate) is a schedule II product and can be entered into a patient’s PNET profile under the pharmacist’s name, this would be for record keeping and billing purposes only. Since pharmacists are not authorized to prescribe vitamin B12 under the Pharmacists Regulation, this entry would not be considered a prescription. As such, a pharmacist can sell vitamin B12 as a schedule II product but cannot administer it unless they have received a prescription from an authorized prescriber.
DOCUMENTATION OF DRUG ADMINISTRATION IS MISSING OR INCOMPLETE
The documentation requirements for drug administration apply to all drugs administered by a pharmacist by injection and intranasal route. For vaccines, Compliance Officers often see this documentation captured on patient consent forms. During reviews, Compliance Officers have noted that some pharmacists have not been documenting administration of non-vaccine drugs to the same extent and are missing some aspects of the required documentation.
DRUG ADMINISTRATION POLICY AND PROCEDURES
Development and implementation of written policy and procedures is important for the delivery of consistent and safe patient care.
HPA Bylaws Schedule F Part 4 – Drug Administration by Injection and Intranasal Route Standards, Limits and Conditions outline the requirements for establishing policies and procedures for drug administration services:
11. Develop, maintain and review, at least annually, a policy and procedure manual including:
(a) Emergency procedure and treatment protocol
(b) Precautions required for patients with latex allergies
Compliance Officers have observed that drug administration policy and procedures, per the above requirements, have not been developed or maintained at some community pharmacies. Pharmacy managers must ensure that prior to providing drug administration services, appropriate policies and procedures are in place at their pharmacy.
To learn more about the Practice Review Program, including how to prepare for your review, visit: