How often do I have to complete my Proof of Eligibility?
Proof of Eligibility consists of both an attestation and Criminal Record History (CRH). The attestation must be completed annually for each pharmacy, or when an individual takes on a new role within the pharmacy. The CRH must be completed once every five years.
Note that the CRH is not the same as the Criminal Record Check (CRC) that is completed by registrants of the College. All owners who are registered pharmacists as well as the pharmacy manager must also continue to undergo the separate CRC process to maintain their registration with the College.
What is a Criminal Record History (CRH) and why is it required?
CRH involves a search of criminal record history information in the databases of the Royal Canadian Mounted Police and local police stations to determine whether the eligibility criteria to hold a pharmacy licence is met. Specifically, pursuant to the Pharmacy Operations and Drug Scheduling Act (PODSA), “no direct owner, indirect owner or manager has, within the previous 6 years, been convicted of an offence under the Criminal Code (Canada)”.
If this eligibility requirement is not met by owners and managers, the pharmacy application will be referred to the Application Committee (AC) for review. After reviewing the pharmacy application, the AC may request additional information or evidence and may then issue, renew, or reinstate the pharmacy licence with or without conditions, or refuse to issue, renew, or reinstate the pharmacy licence.
The CRH search will be conducted by the Board-approved external vendor, Sterling Backcheck, a professional private criminal record check provider that partners with local police stations to provide results.
For further information on Criminal Record History, refer to the Pharmacy Licensure Guide.
I have completed my Criminal Record History (CRH) with Sterling Backcheck using instructions provided by the College. How do I share my results with the College? When will the College receive my results?
The CRH results will be sent directly from Sterling Backcheck to the College. Note that although you may have already received your results, it can take up to 7 days for the College to receive this information. Please do not send your results to the College; we only accept this information directly from Sterling Backcheck.
For further information on Criminal Record History results, please refer to the Pharmacy Licensure Guide.
I have submitted my attestation and Criminal Record History (CRH). How can I check to make sure I’ve completed my Proof of Eligibility?
Only Authorized Representative(s) of the pharmacy may check who has submitted their Proof of Eligibility on eServices. Indirect Owner(s) and the pharmacy manager can either contact an Authorized Representative to confirm that their attestation and Criminal Record History (CRH) have been submitted, or they may contact the Licensure Department via email at [email protected]. Note that the Licensure Department will not disclose the eligibility status of the Indirect Owner(s) or pharmacy manager.
Authorized Representative(s) may follow the instructions below to access the Proof of Eligibility information:
- Authorized Representative: Log into eServices and go to ‘My Pharmacies’. Scroll down and expand the list of pharmacies by clicking on the ‘+’ sign next to the name of the Direct Owner. Once you have expanded the list of pharmacies owned by that Direct Owner, scroll down the list to find the pharmacy due for renewal. This initial list view will provide the status of the ownership documents, attestation, CRH, business licence, and payment. To view the detailed list of Indirect Owners, click on the ‘Pending’ link under the Renewal Complete column. This detailed list will display all of the Indirect Owners and pharmacy manager, and whether or not they have submitted their attestation and/or CRH. This list does not disclose the eligibility status of the attestation and CRH.
For further information regarding the status of your pharmacy renewal, refer to the Pharmacy Licensure Guide.
Why do I have to submit a Criminal Record History (CRH) for the pharmacy application? I have already completed a Criminal Record Check (CRC) during my pharmacist registration renewal. What is the difference between the two checks?
All registered pharmacists and pharmacy technicians currently undergo a CRC through the Criminal Records Review Program (CRRP) as required under the Health Professions Act (HPA) at the time of initial registration and at least every 5 years thereafter at the time of registration renewal. This CRC check only reviews selected offences under the Criminal Code, whereas the CRH reviews all the convictions under the Criminal Codes within the previous 6 years. The CRRP is also specific to registrants and does not provide a means for the CRH of non-registrants to be checked.
The College cannot use the same CRC under the CRRP for the pharmacy licensure process since it does not meet the CRH requirements in PODSA.
All Direct and Indirect Owners and managers must submit a CRH as part of the licensure process. All owners who are registered pharmacists and managers must continue to undergo the separate CRC process to maintain their registration with the College.
For further information on the differences between CRC and CRH, refer to the Pharmacy Licensure Guide.
I just had a Criminal Record History (CRH) done for my pharmacy licence renewal application (as I am the manager/indirect owner of a pharmacy). Do I have to complete another Criminal Record Check (CRC) for the College?
Yes, the CRC required for your registrant renewal is different from the CRH for your pharmacy renewal. They are required for different purposes under two different pieces of legislation.
The CRH is required for all pharmacy managers and direct/indirect owners of a pharmacy for pharmacy license applications under the Pharmacy Operations and Drug Scheduling Act. The CRH is processed by Sterling Backcheck, results are sent to the College and reviewed by the College's Application Committee, if required.
The Criminal Codes reviewed for the CRC and CRH are not the same, and therefore, are not interchangeable. The CRC is specific to registrants and is not applicable to pharmacy owners that are not registrants. As such, all direct and indirect owners and managers must submit a CRH as part of the licensure process.