Rina

Nature of Action: The Inquiry Committee of the College of Pharmacists of British Columbia (the “College”) conducted an investigation into the practice of now former registrant Rina Serjeant (the “Former Registrant”), pursuant to section 33(4) of the Health Professions Act, R.S.B.C. 1996, c. 183.

The Inquiry Committee and the Former Registrant have agreed to resolve all matters arising from the investigation by way of a Consent Agreement under section 36(1) of the Health Professions Act.

Effective date: January 7, 2021

Name of registrant: Rina Serjeant

Location of Practice: N/A

Admissions and Acknowledgements:

Multiple registrants were involved in this matter.

The College’s investigation found that between January 2012 and June 2018, over 20,000 false transactions were processed on patient PharmaNet records at two pharmacies, where the Registrant had worked as a pharmacy manager at one of the pharmacies. These transactions were considered false because:

• Schedule I (prescription) medications associated with these transactions had not been authorized or prescribed by the prescriber associated with each transaction;
• Medications associated with these transactions, which included Schedule I, Over-The-Counter (“OTC) medications and vitamins, were not actually dispensed to the “patient” in each case;
• Transactions were processed as one-day supplies or seven-day supplies, for the sole purpose of artificially inflating prescription counts; and
• Transactions were processed not for the purpose of providing health care and were not processed with each patient’s voluntary consent.

The College’s investigation also found that during the same time period, over 10,000 transactions were processed on patient PharmaNet records for medications that were actually authorized but processed as one-day supplies or seven-day supplies when there was no clinical indication to do so. The medications for these transactions were not actually dispensed to the patient on a daily or weekly basis, making each patient’s PharmaNet records inaccurate and not current. These transactions were processed in this manner for the sole purpose of artificially inflating prescription counts.

The “patients” whose PharmaNet records were affected were all either current or former employees of the two pharmacies, or family members of former employees of the two pharmacies. Reportedly, the owner of the two pharmacies had directed for transactions to be processed in the above manner in order to artificially inflate prescription counts at both pharmacies.

The Registrant's Involvement and Acknowledgements:

Regarding the Former Registrant’s involvement in this matter, the Inquiry Committee considered it substantiated, and the Former Registrant has acknowledged, that:

1. On the PharmaNet record of her colleague, her name was associated with false PharmaNet transactions for vitamins and supplements, as the “prescriber” of these vitamins and supplements. The Former Registrant’s signature was on the prescription hardcopies of these transactions, meaning that she had checked these prescriptions before the hardcopies had been filed away;

2. The majority of these transactions had been backdated, meaning that the transaction records were created on a date later than the date that appears on PharmaNet. The Former Registrant’s signature appeared on the prescription hardcopies of the backdated transactions, meaning that she knew, or ought to have known, that the transactions had been backdated;

3. She processed medications on PharmaNet for herself;

4. She enabled the inappropriate use of personal health information and the creation of inaccurate PharmaNet records, placing her colleague at risk of harm, in case their PharmaNet record ever needed to be accessed for legitimate medical reasons;

5. She failed to report to the College or to another person of authority regarding the improper practices occurring at the pharmacy, even though she knew that these practices were improper; and

6. As pharmacy manager, she enabled the false transactions on patient PharmaNet records, did not set or enforce policies and procedures at the pharmacy to ensure compliance with practice standards, and did not actively participate in the day-to-day management of the pharmacy.

Disposition

The Former Registrant entered into a Consent Agreement with the College’s Inquiry Committee, wherein the Registrant consented to the following terms (in part):

1. To pay a $3000.00 fine;
    
2. To have a letter of reprimand placed permanently on the College register;
    
3. If she reinstates her registration to Full Pharmacist status, upon reinstatement:
    
   1. To successfully complete and pass an ethics course for healthcare professionals within two years. If she fails to complete this within the specified time period, her registration will be suspended for a period of 60 days;
       
   2. To appear before the Inquiry Committee for a verbal reprimand;
       
   3. To not be a pharmacy manager and/or a preceptor for pharmacy students for a period of 2 years;
       
   4. To successfully pass the College’s Jurisprudence Exam; and
       
   5. To successfully complete and pass the “BC Community Pharmacy Manager Training Program” offered by the British Columbia Pharmacy Association.
       

Rationale:

The Former Registrant’s actions were considered serious contraventions of legislation involving pharmacy practice standards, the appropriate access, use and protection of personal health information and PharmaNet records, and her role as a pharmacy manager. Her misconduct placed others at risk of harm. The Former Registrant also contravened standards of the Code of Ethics involving protecting and promoting the well-being of patients, benefitting society, committing to personal and professional integrity, participating in ethical business practices, and conflicts of interest.

In determining an appropriate disposition for the Former Registrant, the Inquiry Committee considered the Former Registrant’s report of feeling pressured by her employer (the pharmacy owner) to commit these actions, and that she personally did not stand to gain financially from what occurred.

The Inquiry Committee considered the terms of the Consent Agreement necessary to protect the public, as well as send a clear message of deterrence to the profession. Inappropriate access and use of personal health information compromises the public’s trust in the pharmacy profession as a whole. At all times, registrants must uphold legislative requirements and ethical obligations to appropriately access, use and protect personal health information.