Proposal

Consultation on proposed changes to advance the pharmacy sector in Ontario.

Regulation Number(s):
N/A
Instrument Type:
Proposal
Bill or Act:
N/A
Summary of Proposal:
In February 2023, the ministry released Your Health: A Plan for Connected and Convenient Care (the Plan). At its core, the Plan prioritizes making it easier for the people of Ontario to connect to the care they need. The Plan is built on three pillars: The Right Care in the Right Place, Faster Access to Care, and Hiring More Health Care Workers.

Maximizing the expertise of the province's workforce is one of the province's strategies that straddles the pillars noted above. The Plan indicates that as the province expands education and training opportunities, it is also supporting regulated health professionals to work to their full training and expertise. The Plan includes exploring the expansion of pharmacists' scope of practice and care services.

Optimizing the scopes of practice of pharmacists improves access to the care Ontarians need, when they need it, easing stressors in practice settings and creating a more effective and efficient healthcare system. For instance, health human resources (HHR) supply issues have resulted in greater pressure on the health care system throughout the province resulting in Ontarians experiencing challenges in accessing primary health care services and seeking treatment in emergency departments.

To improve access to routine care for Ontarians, the ministry leveraged the expertise and convenience of community pharmacies by expanding the scope of practice of pharmacists to allow them to administer more vaccines such as COVID-19, influenza, and RSV vaccines and to prescribe for 19 minor ailments. The minor ailment program has resulted in over 1,000,000 assessments and over 850,000 prescriptions provided to Ontarians.

To build on this success, the ministry is consulting on additional minor ailments and further scope expansions to better meet the needs of patients in Ontario. The ministry is seeking feedback on whether these potential expansions to the scope of practice for pharmacists would improve access to more timely, safe, and competent care with a more connected and convenient health care experience.

The ministry is also seeking feedback on the implementation of additional vaccine services in community pharmacies for adults and improving the MedsCheck program.

1. Scope of Practice Expansions
In January 2023, the ministry launched the pharmacist minor ailment program. Minor ailments are health conditions that are typically short-term and can be managed with minimal treatment and/or self-care strategies. Currently, pharmacists can assess and prescribe for 19 minor ailments. As the program's list of minor ailments continues to grow, other scope expansions may be needed to support safe and accurate assessment and prescribing by pharmacists.

The ministry is consulting on several changes to the scope of practice for pharmacists and is looking for feedback on:
• Adding more minor ailments to the program. This will also include the drugs and any limitations or conditions on those drugs from which pharmacists (Part A) may prescribe;
• Allowing pharmacists to order certain laboratory tests and to perform more point-of-care tests (POCTs) to support the minor ailments program;
• Allowing pharmacists to communicate a diagnosis for specific minor ailments; and
• The barriers that limit pharmacists from ordering laboratory and POCTs in hospital settings.

1.1 Prescribing for Additional Minor Ailments:
• The ministry is consulting on adding more minor ailments to the program including:
o Acute pharyngitis (sore throat), calluses and corns, headache (mild), shingles, minor sleep
disorders (insomnia, could also include disturbances in circadian rhythm), fungal nail
infections, swimmers' ear, head lice, nasal congestion, dandruff, ringworm, jock itch, warts,
and dry eye.
1.2 Ordering Specific Laboratory and Performing Additional POCTs
• Some of the newly proposed minor ailments may require additional laboratory and POCTs to better support the assessment, management, and treatment of these conditions.
• The ministry is seeking feedback to determine whether laboratory tests and POCTs are required and if so, which ones would be best suited to support pharmacist assessment and prescribing.

1.3 Communicating a Diagnosis for Specific Minor Ailments:
• As the minor ailment program grows pharmacists may need to communicate a diagnosis.
• The ministry is seeking feedback to determine whether communicating a diagnosis is required to support pharmacist assessment and prescribing.

1.4 Identifying Barriers in Hospital Settings
The Public Hospitals Act, 1990 (PHA) establishes a scheme for the appointment of physicians to a hospital's medical staff that grants them privileges to use hospital resources. Regulations under the PHA allow hospital boards to pass by-laws for the appointment of dentists, midwives, and registered nurses in the extended class. The PHA only allows these physicians, dentists, midwives, and registered nurses in the extended class to issue orders for treatments or diagnostic procedures of a patient in a public hospital. The Ministry is exploring if there are barriers outside of the PHA that are preventing pharmacists from working to their full scope of practice in a hospital setting, including the ordering of laboratory and point-of-care tests.
The ministry is seeking feedback on the barriers in hospital settings, other than legislative amendments, that limit hospital pharmacists from ordering laboratory and POCTs.

2. Vaccines in Community Pharmacies
The ministry is looking for feedback on the implementation of two vaccine-related initiatives in community pharmacies, listed below.

2.1 Pharmacy Technicians Administering Additional Schedule 3 Vaccines
• Currently, pharmacy technicians are allowed to administer COVID-19, influenza, and RSV vaccines.
• The ministry is expanding the vaccines pharmacy technicians can administer to include those listed under Schedule 3 of the General regulation made under the Pharmacy Act, 1991.
• This includes certain travel and other vaccines:
o Bacillus Calmette-Guιrin (BCG) Vaccines
o Haemophilus Influenzae type b (Hib) Vaccines
o Meningococcal Vaccines
o Pneumococcal Vaccines
o Typhoid Vaccines
o Combined Typhoid and Hepatitis A Vaccines
o Hepatitis A Vaccines
o Hepatitis B Vaccines
o Hepatitis A and B combined Vaccines
o Herpes Zoster Vaccines
o Human Papillomavirus (HPV) Vaccines
o Japanese Encephalitis Vaccines
o Rabies Vaccines
o Varicella Vaccines
o Yellow Fever Vaccines
o Respiratory Syncytial Virus (RSV) Vaccines
o Influenza Vaccines
o Coronavirus (COVID-19) Vaccines
• Patients who choose to receive vaccines in a community pharmacy will need to pay for the vaccine and the administration. Patients will not have to pay any fees for COVID-19 and influenza vaccines.
• This proposed change would require the College to amend O.Reg 202/94 under the Pharmacy Act, 1991. This would need to be approved by the College's Council prior to bringing it forward for the Minister's review and the Lieutenant Governor in Council's approval.

2.2. Adult Vaccine Bundle
• The ministry is implementing a publicly funded adult vaccine bundle and is seeking additional feedback to shape the implementation of this initiative.
• This includes the development of clinical guidance, education and training, inventory and documentation protocols and guidance.
• It is being proposed that the publicly funded vaccines for adults available in community pharmacies will include tetanus, diphtheria, pertussis, pneumococcal, shingles, and RSV (potentially based on eligibility for publicly funded programming).

3. MedsCheck
MedsCheck is a one-on-one consultation between a pharmacist and a patient to review the patient's medication profile, provide education, resolve drug therapy problems, and improve medication adherence and patient clinical outcomes. Current MedsCheck eligibility criteria include patients taking three or more chronic-use prescription medications, or those diagnosed with type 1 or 2 diabetes.
The ministry is committed to supporting an effective and sustainable MedsCheck program that supports both patients and health care providers. As part of this, the ministry is exploring opportunities to improve the program.

The ministry is seeking to consult on current issues and opportunities to improve the MedsCheck program to support optimal medication and chronic disease management, including considerations for point-of-care testing.

A full list of questions on these proposals can be found in the attached document.
Analysis of Regulatory Impact:
1. Scope of Practice Expansions

1.1 Prescribing for Additional Minor Ailments:
• Should the proposed additional minor ailments be included as part of the minor ailment program, service providers may need to invest in additional resources, for example, equipment, personnel, training, and dedicated space to participate in the expansion of these minor ailment services.

1.2 Ordering Specific Laboratory and Additional POCTs:
• Should laboratory testing and additional point of care tests be added to the pharmacy scope, there may be costs to the Ontario College of Pharmacists and/or other system partners to invest in education and training and equipment to order laboratory and / or POCTs.
• Consultations will inform any other costs that may be associated with this proposal item.

1.3 Communicating a Diagnosis for Specific Minor Ailments:
• Should communicating a diagnosis be added to the scope of practice for pharmacists, there may be additional costs to the Ontario College of Pharmacists and pharmacy service providers to complete additional education and training to perform this scope expansion.

1.4 Identifying Barriers in Hospital Settings:
• Should additional work be considered in this space, the Ontario College of Pharmacists, hospitals, and impacted pharmacy service providers may incur additional costs for education and training, as well as system and operation updates.

2. Vaccines in Community Pharmacies

2.1 Pharmacy Technicians Administering Additional Schedule 3 Vaccines
• There will be no additional costs to patients. Patients would continue to pay for both the cost of the vaccines and the fees for administration of non-publicly funded vaccines.
• There may be additional costs to the College to provide further training/education for pharmacy technicians to administer more vaccines.

2.2 Adult Vaccine Bundle
• Introducing a publicly funded adult vaccine bundle into pharmacies aims to enhance public health by increasing vaccine access and vaccination rates.
• The anticipated benefits include reduced incidence of these diseases, decreased healthcare costs associated with treating illness, decreased cases and outbreaks, and improved access in the community aligned with influenza and COVID-19 vaccines.
• As part of the implementation, pharmacies will need to plan for staff training, vaccine storage and handling requirements (e.g., vaccine fridge), vaccine ancillary supplies for administration (e.g., syringes), potential upgrades to physical space, and provision of a vaccine record.
• Additional program factors for implementation planning include provincial vaccine procurement and program operations (e.g., logistics for distribution), potential impacts to primary care (e.g., administration perspective, such as adding records into local electronic medical records), and impacts for local public health units such as vaccine (e.g., fridge inspections) and excursion management.
• Feedback from stakeholders will be instrumental in refining the implementation strategy and informing potential resource needs and costs.

3. MedsCheck
• There will be no additional costs related to consulting on MedsCheck. Further analysis would be conducted upon decisions regarding any changes to the program.
Further Information:
Proposal Number:
24-HLTC025
Posting Date:
September 5, 2024
Comments Due Date:
October 20, 2024
Contact Address:
Health Workforce Regulatory Oversight Branch
Nursing and Professional Practice Division
438 University Avenue, 10th Floor
Toronto ON M5G 2K8
Regulatoryprojects@Ontario.ca
Comment on this proposal via email