January 1, 2020 marked the beginning of Phase 2 of the Implementation of the NAPRA Model Standards for Pharmacy Compounding of Non-Sterile Preparations. The final and third phase deadline to meet the Standards is January 1, 2021.
By now, Phase 1 of the three-phase implementation plan should be completed. This means all pharmacies engaged in any degree of non-sterile compounding should have completed a risk assessment for the types of preparations compounded by the pharmacy. Phase 1 also required pharmacies to perform a gap analysis to evaluate their current practices against the NAPRA Standards in each area, as a tool for planning Phase 2 and Phase 3 implementation.
The College posted a Self Assessment Criteria to be used for this gap analysis process on the OCP website. Pharmacies may now access and use the new Non-Sterile Compounding Self Assessment Criteria for this purpose. For more information about the implementation phases and timelines, please visit the Non-Sterile Compounding Standards and Implementation page on the College website and review the "Preparing for Phase 2 of the Non-Sterile Compounding Standards" article.
Pharmacy professionals are reminded of their professional and ethical obligations during the transition from OCP’s former 2006 Guidelines on Compounding Preparations and the NAPRA Standards adopted in December 2017. Patient care should not be jeopardized by abrupt cessation of compounding services.
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The College recently published the Framework for Improving the Safety and Security of Controlled Substances in Hospital High Risk Areas on the OCP website. The framework contains 13 recommendations to enable healthcare system stakeholders to proactively identify and prevent the diversion of controlled substances in hospitals.
The diversion of controlled substances can have a substantial impact on patients, staff and organizations. Identifying gaps in awareness, policies, procedures and capacity that increase avenues for diversion, and acting to bridge these gaps, is vital to preventing diversion in hospitals.
The framework was developed by The Partnered Table to Improve the Safety and Security of Controlled Substances in Hospital High Risk Areas, which was sponsored and initiated by the College and includes healthcare providers, hospital leadership, regulators and other subject matter experts among its membership.
Pharmacists and pharmacy technicians working in hospitals are encouraged to become familiar with the recommendations, identify any gaps that might exist in their practice setting, and bring the framework to the attention of pharmacy and hospital leadership. It will be important to look for opportunities for collaboration with other healthcare professionals to identify where there is a role for pharmacy professionals to adjust, enhance or share practices around Controlled Substances.
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The Narcotics Monitoring System (NMS) is an important tool to track dispensing and prescribing activities for narcotics and other controlled substances. By submitting correct information into the NMS, community pharmacies are making a valuable contribution to efforts to address the opioid crisis, as it will help to reduce the misuse, addiction, unlawful activities and deaths related to monitored drugs.
For the NMS to work effectively in identifying and alerting pharmacies of potential misuse issues, it’s critical that accurate information is submitted when dispensing a monitored drug. A recent analysis of NMS usage suggests that errors are being made when entering data into the system.
Here are some important tips to remember:
- Confirm the prescriber’s identity.
- Enter the day’s supply as accurately as possible. Don’t enter 1 or 100 in place of making an informed estimate.
- To ensure accurate records, reversals and/or changes should be made as soon as possible.
- Enter the proper information for drugs that are for “office use.” Review the notice from the Ministry of Health, "Proper Submissions to the Narcotics Monitoring System" for more details.
- Don’t use it for inter-store sale or transfers between pharmacies.
- Don’t use it for returns to manufacturers or wholesalers, or destruction of expired or damaged drugs.
For more detailed information, please refer to the notice from the Ministry of Health, "Proper Submissions to the Narcotics Monitoring System" on submitting NMS information correctly.
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Council is seeking feedback on proposed amendments to the College’s By-Law No. 5 to enable changes to the governance structure of the College as well as put into place annual cost of living fee increases.
As part of a decision to review the governance structure of the College, Council has considered and approved changes related to Council composition, competencies, and selection, as well as the composition of statutory committees.
Moving forward with governance reform ultimately delivers on Council’s belief that these changes represent an important opportunity to demonstrate the profession’s and the College’s ongoing commitment to the public by reflecting the emerging best practices that are critical to modernizing health regulatory governance in a rapidly changing healthcare landscape.
Council has also proposed by-law amendments that would see the fees prescribed in Schedule D of the By-Law increased each year by the percentage increase, if any, in the consumer price index (CPI) for goods and services in Canada as published by Statistics Canada, to help prevent the need for future large fee increases over a single year. This change would take effect for 2021 renewal fees. The proposal to switch to an annual cost of living fee increase is a result of reflection on the feedback received from the consultation on the 2018 fee increases.
Nearly half of health regulators in Ontario have already implemented by-laws to allow for annual increases tied to the CPI. Decisions to adjust fees are never taken lightly, but are guided by our obligations as a regulator to serve and protect the public. The College has and will continue to identify and act on efficiencies and new processes to streamline our work.
Learn more about the proposed revisions to By-Law No. 5 regarding governance changes and cost of living fee adjustments and provide your feedback by February 15, 2020!
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