What Went Wrong: Understanding Your Responsibilities as a Pharmacy Manager, Owner, and/or Director
The responsibilities of pharmacy managers, owners, and directors are outlined in Section 3 of the Bylaws to the Pharmacy Operations and Drug Scheduling Act (PODSA). Specific responsibilities include but are not limited to participating in the day-to-day management of the pharmacy (managers only), ensuring that staff levels are commensurate with workload, ensuring appropriate security and storage for all scheduled drugs and controlled substances, ensuring that confidentiality is maintained with respect to all pharmacy records, and ensuring that no incentives are provided to a patient or patient’s representative for inducement purposes.
As these roles hold significant responsibilities, the College strongly encourages all current and future pharmacy managers, owners, and directors to become familiar with the legislated requirements.
Section 10 of the PODSA Bylaws lists additional responsibilities for community pharmacy managers. Pharmacy managers are required to supervise pharmacy staff to ensure that practice is in compliance with practice standards. They have the statutory obligation to develop, implement and maintain policies and procedures to comply with legislative requirements of operating a community pharmacy.
The College has received recurrent complaints whereby policies and procedures were lacking or were not enforced in the pharmacy, leading to multiple errors and omissions. Pharmacy managers, directors, and/or owners have been held accountable even if they were not directly involved with the incidents. In many cases, individuals in these roles lacked understanding of their responsibilities and obligations.
A pharmacist owner delegated methadone deliveries to a non-registrant. The pharmacy manager was a recent pharmacy graduate (3 months of being fully registered), and did not question the owner.
The College’s Inquiry Committee found that in this incident, the pharmacy manager’s inexperience and lack of basic understanding of his role and responsibilities affected the safety of a patient, as methadone was not dispensed in accordance with legislated standards. The Inquiry Committee held the pharmacy manager responsible for overseeing pharmacy staff. The pharmacy manager should have questioned the owner about methadone being delivered by a non-registrant or should have contacted the College to seek clarity and guidance in this regard.
The pharmacy manager was required to meet with the College Deputy Registrar to discuss his role and responsibilities of being a pharmacy manager at a community pharmacy.
This pharmacy was also prioritized for a review under the College’s Practice Review Program.
A pharmacy owner disclosed their pharmacy’s involvement in research when the appropriate ethical protocols had not been obtained.
The College acknowledged that while the pharmacy owner may have been overly enthusiastic about his newly opened pharmacy, he was still responsible for understanding the ethical and legislative requirements on research. The Inquiry Committee provided the pharmacy owner with a letter of advice that reminded him of his responsibilities and compliance with the appropriate legislated requirements, specifically the Schedules under the Bylaws to the Health Professions Act.
At the recommendation of the Inquiry Committee, in June 2017 the College Board directed the Registrar to develop requirements and training tools as it pertains to the role and responsibilities of the pharmacy manager. A more stringent eligibility process and rigorous training requirement for pharmacy managers will greatly improve the overall operation of pharmacies in the province and will ensure safe and effective pharmacy practices for the public.
Amendments to the Pharmacy Operations and Drug Scheduling Act and related College bylaws, which will come into effect in 2018, will permit the College to know the identity of all pharmacy owners, determine their suitability for pharmacy ownership and hold them accountable for providing safe and effective care by ensuring their pharmacies are compliant with legislative requirements for pharmacies in BC.