BC’s COVID-19 Response – Temporary Authorizations for Controlled Drugs and Substances

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BC’s COVID-19 Response

Temporary Authorizations for Controlled Drugs and Substances

[Update - April 7, 2020]

Additional temporary amendments to Professional Practice Policy-71: Delivery of Opioid Agonist Treatment (PPP-71) that allow pharmacists to authorize regulated health professionals to deliver Opioid Agonist Treatment (OAT), are now in effect. 

These temporary amendments also allow pharmacists to authorize pharmacy employees, including pharmacy technicians and pharmacy assistants, to deliver OAT on a pharmacist’s behalf in exceptional circumstances where it is not possible for a pharmacist or other regulated health professional to deliver the OAT drug. 

Learn More: NEWS - Temporary Authorizations for the Delivery of Opioid Agonist Treatment by Non-Pharmacists

BC's COVID-19 Response

The situation regarding COVID-19 continues to evolve here in BC, Canada and other jurisdictions in the world. The College of Pharmacists of BC is working closely with the Ministry of Health and other partners to support the response to this new illness as part of BC’s health system.

The College will provide any updated information or guidance for pharmacy professionals as it becomes available.

Please follow updates provided on bcpharmacists.org/COVID19

Pharmacy professionals exhibiting COVID-19 symptoms should follow the COVID-19 testing process developed for all British Columbia health care workers.

Amendments to the Pharmacy Operations and Drug Scheduling Act Bylaws and the Community Pharmacy Standards of Practice to allow temporary exemptions for prescriptions of controlled substances are now in effect. 

To support continuity of care to patients during the COVID-19 Pandemic, Health Canada has issued temporary exemptions for prescriptions of controlled substances, to maintain Canadians’ access to controlled substances as needed for medical treatments. 

Controlled Drugs and Substances Act - Subsection 56(1) Class Exemption for Patients, Practitioners and Pharmacists Prescribing and Providing Controlled Substances in Canada During the Coronavirus Pandemic.

 

These temporary exemptions, made under the Controlled Drugs and Substances Act (CDSA) will: 

  • Permit pharmacists to extend and renew prescriptions 
  • Permit pharmacists to transfer prescriptions to other pharmacists; 
  • Permit prescribers to verbally prescribe prescriptions with controlled substances; and 
  • Allow pharmacy employees to deliver prescriptions of controlled substances to patients at their homes or an alternate location.
    • [Update - April 7, 2020]: This amendment is not listed below. On April 7, 2020, the College Board approved temporary amendments to Professional Practice Policy - 71: Delivery of Opioid Agonist Treatment that allow pharmacists to authorize regulated health professionals to deliver Opioid Agonist Treatment (OAT). These amendments also allow pharmacy employees, including pharmacy technicians and pharmacy assistants, to deliver OAT on a pharmacist’s behalf in exceptional circumstances where it is not possible for a pharmacist or other regulated health professional to deliver the OAT drug.)

In order to reduce barriers and immediately implement these exemptions within BC’s current regulatory framework, the College Board has reviewed and amended both the Pharmacy Operations and Drug Scheduling Act (PODSA) Bylaws, as well as the Community Pharmacy Standards of Practice. 

Providing Emergency Supplies of Controlled Drugs and Substances

BC’s pharmacies have already been directed by Minister of Health, Adrian Dix and B.C. Provincial Health Officer, Dr. Bonnie Henry, to provide refills of regular prescriptions in an effort to avoid non-essential physicians and nurse practitioners visits and free these practitioners to treat COVID-19 cases. 

The College is asking pharmacists to act in the best interests of patients who require access to controlled drugs and substances (including Opioid Agonist Therapy) by providing emergency supplies to patients with expired prescriptions.  

Section 19(7)(d) of the College’s Bylaws under the Pharmacy Operations and Drug Scheduling Act and Professional Practice Policy 31 – Emergency Supply for Continuity of Care already align with Health Canada’s exemption to permit pharmacists to extend and renew prescriptions. Pharmacists are able to provide emergency supplies to patients with expired prescriptions, including narcotics, psychiatric drugs and anti-psychotics for chronic conditions. The policy provides broad latitude for pharmacist decisions on emergency supplies, provided it is in the patient’s best interest and all decisions are properly documented with rationale.  

Learn More: ReadLinks - BC’s COVID-19 Response - Pharmacists to Provide Prescription Refills and Emergency Supplies of Medication as Needed

TRANSFERRING PRESCRIPTIONS TO OTHER PHARMACISTS

The College Board has amended Section 8(3)(a) of the Community Pharmacy Standards of Practice to allow for the transfer of a prescription for controlled drug substances to other pharmacies licenced in British Columbia. 

(Amendments listed in bold text)

Community Pharmacy Standards of Practice - Prescription Copy and Transfer

  1. (3) Upon request, a registrant must transfer to a pharmacy licenced in Canada a prescription for a drug if
    1. the drug does not contain a controlled drug substance, and
    2. the transfer occurs between a registrant and another registrant or an equivalent of a registrant in another Canadian jurisdiction.

(3.1) 
Despite section 3(a), a registrant may transfer a prescription for a controlled drug substance if the transfer is permitted under a section 56 exemption to the Controlled Drugs and Substances Act. 

PERMITTING VERBAL ORDERS FOR A NEW PRESCRIPTION OR TO EXTEND OR REFILL AN EXISTING PRESCRIPTION

The College Board has amended Section 19(6) of the Pharmacy Operations and Drug Scheduling Act (PODSA) Bylaws to permit pharmacists to dispense drugs included in the controlled prescription program upon receiving a verbal order from a practitioner, if doing so is permitted under a section 56 exemption to the Controlled Drugs and Substances Act.

It is important to note that when taking verbal prescriptions in community practice, a registrant must make a written record of the verbal authorization in accordance with Section 6(7) of the Community Pharmacy Standards of Practice, as well as applicable federal legislation.

This written record MUST include: 

  • The pharmacist’s signature or initial
  • The name of the practitioner providing the verbal order
  • The practitioner’s college identification number 

(Amendments listed in bold text)

Pharmacy Operations and Drug Scheduling Act (PODSA) Bylaws - Sale and Disposal of Drugs

  1. (6) Drugs included in the controlled prescription program must not be sold or​ dispensed unless
    1. the registrant has received the prescription on the prescription form approved by both the board and the College of Physicians and Surgeons of British Columbia, and
    2. the prescription form is signed by the patient or the patient’s representative upon receipt of the dispensed drug.

(6.1) 
Despite subsection (6), a registrant may dispense drugs included in the controlled prescription program upon receipt of a verbal prescription from a practitioner if doing so is permitted under a section 56 exemption to the Controlled Drugs and Substances Act. The pharmacy must receive the original prescription form from the practitioner as soon as reasonably possible. 
 

FAXING OF CONTROLLED PRESCRIPTION PROGRAM FORMS

The College Board has also amended Section 7(3) of the Community Pharmacy Standards of Practice to allow pharmacists to dispense prescriptions received by facsimile transmission for drug referred to on the Controlled Prescription Drug List in exceptional circumstances.

The pharmacy must receive the original prescription form, by mail or any other appropriate method, from the practitioner as soon as reasonably possible.  

(Amendments listed in bold text)

Community Pharmacy Standards of Practice - Transmission by Facsimile

  1. (3) A registrant must not dispense a prescription authorization received by facsimile transmission for a drug referred to on the Controlled Prescription Drug List, except in a public health emergency declared by the provincial health officer. In a public health emergency, the pharmacy must receive
    1. a completed copy of the Controlled Prescription Program form transmitted by facsimile prior to dispensing the medication; and
    2. the original form by mail* as soon as reasonably possible.

*Note: Any method by which a prescriber can safely provide the original form to the pharmacy is appropriate. 

ADDITIONAL AMENDMENTS 

As a result of these amendments, additional consequential amendments have been made to the following Professional Practice Policy Guides: 

Delivering Prescriptions for Controlled Drugs and Substances

Under Health Canada’s temporary exemption, pharmacy employees in British Columbia are permitted to deliver prescriptions of controlled substances on behalf of a pharmacist (excluding opioid agonist treatment) to patients at their homes or alternate locations. Delivery of controlled substances by pharmacy employees must meet the requirements set out in the temporary exemption. At this time, only pharmacists in British Columbia are permitted to deliver opioid agonist treatment, and must do so in accordance with Professional Practice Policy – 71: Delivery of Opioid Agonist Treatment.

Recent amendments to Professional Practice Policy – 71: Delivery of Opioid Agonist Treatment allow a pharmacist to deliver Opioid Agonist Treatment to a patient if they feel it is safe, appropriate and in the best interest of the patient.

For everyone’s health and safety, those delivering medications should confirm if the patient is experiencing symptoms of COVID-19 or are self-isolating prior to delivering medications. In addition, they should consider how to maintain social distancing while delivering medications to a patient.

Learn More: Changes to the Delivery Requirements for OAT Now In Effect

FREQUENTLY ASKED QUESTIONS 

For further clarification on the scope of the exemption for providing controlled substances during the coronavirus pandemic, please refer to the following FAQs provided by Health Canada: 

For questions related to pharmacy practice in BC and continuity of care for patients with substance use disorder, see the College of Pharmacists COVID-19 resource page, and the following FAQs.

See all College COVID-19 FAQS

QUESTIONS

Health Canada recognizes that local pandemic precautions may impact the operations of Supervised Consumption Sites (SCS), and are committed to working directly with SCS Operators to assess each individual situation and develop appropriate modifications to their protocols and practices. Operators are encouraged to contact the Office of Controlled Substances’ Exemptions Section at: 

hc.exemption.sc@canada.ca

 

If you have any questions, please contact Health Canada’s Office of Controlled Substances, at: 

hc.ocs-bsc.sc@canada.ca

 

For additional questions related to pharmacy practice and providing continuity of care for patients during this emergency, contact the College’s practice support at practicesupport@bcpharmacists.org

This article was updated for clarity on March 30, 2020
Mar 26, 2020