Q: Which pharmacists are authorized to prescribe?
A: All pharmacists licensed to practice in the province of Nova Scotia are authorized to prescribe, but only in accordance with the regulations and standards. Therefore, it is essential that each pharmacist know and understand these rules. Each pharmacist is responsible for taking the necessary steps to meet their learning needs.
Q: What if a pharmacist doesn’t want to prescribe?
Pharmacists are the experts on drug therapy and are one of the most accessible health professionals. Nova Scotians and our health system will benefit if pharmacists exercise their full scope of knowledge, skills and abilities to maximize the effectiveness of medication therapy. It is not compulsory that a pharmacist prescribe, but pharmacists are reminded of the Code of Ethics, which states that pharmacists are expected to use their unique knowledge and skills to benefit their patients.
(Section 3.3.2 and NSCP Code of ethics, Value 1)
Q: Are there any issues with pharmacists both prescribing and dispensing for the same prescription?
A: Other practitioners such as physicians, veterinarians, dentists, nurse practitioners and physiotherapists, also assess their patients, develop a plan of care, and if the patient agrees, provide the agreed upon services to the patient. The Standards of Practice apply a stringent structure to the activity so as to provide for accountability, safety, informed decision making and where appropriate, to separate the prescribing activity from dispensing as much as possible. Like other health professionals, pharmacists must practice according to the College’s Code of Ethics, which requires that the pharmacist’s primary responsibility must be the health and safety of the patient.
Q: Will the pharmacist need special training to prescribe?
Each pharmacist will need to ensure that they know and understand the requirements for prescribing as outlined in the Standards of Practice: Prescribing of Drugs by Pharmacists. These standards state that the pharmacist shall only undertake prescribing of drugs in accordance with their individual knowledge, skills, competencies and experiences. The onus is on each pharmacist to judge whether or not they have the appropriate knowledge and understanding of the patient, the condition being treated and the drug being prescribed. Therefore, pharmacists may need to seek out special training in order to undertake prescribing activities such as patient assessment, disease management for specific conditions and effective communication. Pharmacists assume the responsibility of continually evaluating and improving their professional competence and for accessing the appropriate opportunities to meet their learning needs.
Q: Do the new regulations and standards apply to certified dispensers?
A: No. The prescribing regulations as approved by the government do not authorize certified dispensers to prescribe.
(Section 3, Pharmacist Drug Prescribing Regulations)
Q: What will happen to the Continued Care Prescriptions?
A: They will still be in effect during the transition but will eventually be phased out once the terms of the standards are fully integrated into practice.
Q: Can pharmacists prescribe narcotics, controlled drugs or benzodiazepines?
A: No, all substances regulated by the Controlled Drugs and Substances Act, including narcotics, benzodiazepines, barbituates and anabolic steroids can only be prescribed by those authorized by the federal legislation.
(Sec. 4.1, 5.2, 6.1, 7.2, 8.1)
Q: What are the types of pharmacist prescribing?
A: The Pharmacist Drug Prescribing Regulations authorize prescribing for:
- Conditions approved by Council (includes prescribing for minor ailments and preventable diseases and for collaborative prescribing when a diagnosis is provided)
- Prescription renewal
- Prescription adaptation (by modifying the dose, formulation and/or regimen of the drug and how long the drug is to be taken)
- Therapeutic substitution (within the same therapeutic class)
- Schedule II and III Drugs
Q: Section 3.6 of the Standards requires the pharmacist to obtain informed consent each time they undertake the prescribing process. Is the pharmacist required to get consent from the patient in order to prescribe?
A: Yes, the pharmacist shall obtain informed and voluntary consent to undertake the prescribing process and also to communicate the prescription decision and details to other providers. See the section 3.6 for further information.
(Section 3.6 and Appendix D)
Q: Should the consent be provided in writing?
A: Consent can be obtained verbally or in writing and must be obtained each time the pharmacist prescribes. The pharmacist is expected to document consent on the patient’s pharmacy record including that informed and voluntary consent has been obtained and from whom. Where applicable, confirmation of the consent for the pharmacist to dispense the drug which he/she prescribed shall be documented directly on the prescription record.
(Section 3.5. and Appendix D)
Q: Will pharmacists be paid for prescribing?
A: The Pharmacy Association of Nova Scotia is working with the Department of Health to address the remuneration for pharmacists prescribing.
Q: Can pharmacists prescribe for “off-label” indications?
A: The pharmacist will prescribe when the intended used reflects an indication approved by Health Canada. Otherwise, the pharmacist shall be satisfied that the intended use of the prescribed drug is widely accepted as best practice in Canada, supported by extensive medical literature demonstrating safety and efficacy, or consistent with a research protocol in which the patient is enrolled.
Q: When the pharmacist prescribes, should they notify other Health Care Providers?
A: Yes, the regulations require that the prescribing actions will be communicated to the patient’s primary care provider. As part of the process for obtaining the patient’s informed consent, the pharmacist needs to advise the patient that communication to the primary care provider will occur as part of the prescribing process. The pharmacist will communicate in writing to the patient’s primary healthcare provider, other professional staff in the pharmacy, the original prescriber (if different from primary healthcare provider) and/or with other appropriate health care providers.
(Section 3.8 and Appendix E)
Q: With respect to providing information to other healthcare providers, what information needs to be provided, how, when and to whom?
A: The pharmacist will:
- Communicate the patient’s presenting health condition or drug related problem, patient assessment details / findings, prescribing decision, associated details and rationale, supporting information (e.g. instructions to patient) and follow-up plan/responsibilities.
- Provide written communication using the standard Pharmacist Prescribing Notification form (provided in Appendix E).
- Use communication methods which maintain confidentiality.
- Complete communication within 24 hours of writing the prescription or as soon as possible thereafter.
Q: Does the pharmacist need to notify the original prescriber when the dosage form of the prescription is being changed (i.e., from a cream to an ointment, or a liquid to a chew tab)?
A: The pharmacist need not notify the original prescriber when only the formulation is being changed unless the pharmacist in his/her professional judgment feels there is a reason to do so.
Q: Can transferred prescriptions be adapted, renewed, etc?
A: If a prescription is transferred from Pharmacy A to Pharmacy B, then Pharmacy A can no longer fill the prescription and therefore it cannot be renewed, adapted etc. However, Pharmacy B could adapt, renew, etc. the prescription and transfer the new prescription back to Pharmacy A to be dispensed to the patient.
A: No, these forms were approved by the College of Physicians and Surgeons as being uniform and recognizable by the physicians who receive them, so modifications changing their appearance would be contrary to that approval.
Q: Is the documentation form in the Standards document (i.e., Appendix F) mandatory to use?
A: Appendix F is intended as a list only. We recognize that pharmacies or pharmacy groups will create a documentation form, either paper or electronic, but all the elements in the list must be included.
Q: What is the difference between “Collaborative Prescribing When Diagnosis Provided” described in Appendix G of the Standards and “prescribing in a practice setting where collaborative relationships are established” referred to in Section 3 (3) f of the regulations?
A: The reference to “Collaborative Prescribing When Diagnosis Provided” described in Appendix G (III) is not to be confused with Section 3 (3) (f) of the regulations authorizing pharmacist to prescribe drugs “in a practice setting approved by Council—such as a hospital, a home for special care or a multi disciplinary environment—where collaborative relationships or appropriate protocols are established”. The situation in G(III) is where, on a prescription by prescription basis, a pharmacist may prescribe in a practice setting where he/she works closely with a healthcare professional who is authorized to diagnose and prescribe (such as a physician) and who provides written documentation to the pharmacist indicating the patient’s diagnosis and management plan. He/she may request that the pharmacist select and prescribe the appropriate drug therapy for that diagnosis.
(Appendix G (III))
Q: With respect to Collaborative Prescribing (Appendix G (III)), how will a doctor be able to provide written documentation?
A: The documentation could be as simple as written instruction to the pharmacist on a prescription pad. Example: “Please prescribe and dispense for this patient with Community Acquired Pneumonia and moderate renal failure”.
Q: If a pharmacist writes a prescription as provided for in Appendix G (III) of the Standards, i.e. “Collaborative Prescribing When Diagnosis Provided”, how will the dispensing pharmacist at another location know that the prescription is valid?
A: The prescribing pharmacist will note the diagnosis and the name of the healthcare professional providing it on the prescription.
Q: Are there any expectations as to where prescribing related communications with the patient should take place?
A: Prescribing related communications with a patient or their agent are to be conducted in a manner that respects patient confidentiality. As required by the Standards, this means conducting patient communications in a separate counseling room that provides visual and sound barriers and adheres to any relevant privacy legislation. The standard qualifies this issue by listing what needs to be communicated in confidence: the assessment, follow up, counseling, patient/sensitive information. The phrase “or other matters in accordance with the patient’s wishes” recognizes that there may be other matters that the patient may wish to be communicated in confidence that are over and above the list.