bc - jurisprudence - faq

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0. A. o. A. I ,g#m mff#s?f*e*fv* #s ##f# FREQUENTLY ASKED QUESTTONS * PHARMACISTS Any pharmacy manager or pharmaoist who is employed in a community pharmacy that provides MMT services is required to takethe mandatory MMT Training Program. As per professional practice Policy-66 (PPP-66) Methadone Maintenance Treatment, all pharmacy managers employed in a community pharmacy thatcurrently provides pharmacy services related to Methadone Maintenance Treatmen,t andall staff pharmacists whocurrently provide community pharmacy services related to Methadone Maintenance Treatment or those pharmacy managers or staff pharmacists whoanticipate providing community pharmacy services related to Methadone Maintenance Treatment: . successfully complete the mandatory CPBC training program by september 30,2011 o lmplement all necessary practice requirements identified in the CPBC Methadone Maintenance Treatment Policy Guide byJanuary 1,2012 All practice requirements thataredescribed in the PPP-66 Policy andPolicy Guide should be implemented as soon as youhave completed themandatory training butMUST be implemented no later than January 1,2012. They include, butarenotlimited to,thefollowing: . Obtain all required references as stated in Professional Practice Policy-66 o Obtain all appropriate forms thatare necessary for documentation purposes as discussed throughout the MMT Training Session, available in thePolicy Guide andindividually (inWord and PDF format) on the Gollege website (wvwv.bcpharmacists'orq) under Key lnitiatives/Methadone Maintenance Treatment (MMT) o Obtain any necessary equipment as stated in the Policy Guide, for example glass cylinders A. As per professional practice Policy-66 (PPP-66) Methadone Maintenance Treatment, any pharmacy manager employed in a community pharmacy thatwants to provide pharmacy services related to Methadone Maintenance Treatment andanystaff pharmacist whowants to provide community pharmacy services related to Metfradone Maintenance Treatment must: . Successfully complete the mandatory CPBC training program andhave all the necessary practice requirements, as identified in the CPBC Methadone Maintenance Treatment Policy Guide, in place @t to providing Methadone Maintenance Treatment services' A. The PPP-66 Policy Guide, Policy 6.3,Principle 6'3'1,states ""'ln an emergency situation related to continuity of care, where a referral to a quaiitied pharmacist (ie.a pharmacist who has completed the MMTtraining) is not possibte, a pharmacist, who has not compteted the mandatory training' may dispense the methadone if theyadhere to the Seven Fundamentals established in Professional 0. A.

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  • 0.A.

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    FREQUENTLY ASKED QUESTTONS * PHARMACISTS

    Any pharmacy manager or pharmaoist who is employed in a community pharmacy that provides MMTservices is required to take the mandatory MMT Training Program.

    As per professional practice Policy-66 (PPP-66) Methadone Maintenance Treatment, all pharmacymanagers employed in a community pharmacy that currently provides pharmacy services related toMethadone Maintenance Treatmen,t and all staff pharmacists who currently provide communitypharmacy services related to Methadone Maintenance Treatment or those pharmacy managers orstaff pharmacists who anticipate providing community pharmacy services related to MethadoneMaintenance Treatment:

    . successfully complete the mandatory CPBC training program by september 30, 2011o lmplement all necessary practice requirements identified in the CPBC Methadone

    Maintenance Treatment Policy Guide by January 1,2012

    All practice requirements that are described in the PPP-66 Policy and Policy Guide should beimplemented as soon as you have completed the mandatory training but MUST be implemented nolater than January 1,2012. They include, but are not limited to, the following:

    . Obtain all required references as stated in Professional Practice Policy-66o Obtain all appropriate forms that are necessary for documentation purposes as discussed

    throughout the MMT Training Session, available in the Policy Guide and individually (in Wordand PDF format) on the Gollege website (wvwv.bcpharmacists'orq) under Keylnitiatives/Methadone Maintenance Treatment (MMT)

    o Obtain any necessary equipment as stated in the Policy Guide, for example glass cylinders

    A. As per professional practice Policy-66 (PPP-66) Methadone Maintenance Treatment, any pharmacymanager employed in a community pharmacy that wants to provide pharmacy services related toMethadone Maintenance Treatment and any staff pharmacist who wants to provide communitypharmacy services related to Metfradone Maintenance Treatment must:

    . Successfully complete the mandatory CPBC training program and have all the necessarypractice requirements, as identified in the CPBC Methadone Maintenance Treatment PolicyGuide, in place @t to providing Methadone Maintenance Treatment services'

    A. The PPP-66 Policy Guide, Policy 6.3, Principle 6'3'1, states ""'ln an emergency situation related to

    continuity of care, where a referral to a quaiitied pharmacist (ie. a pharmacist who has completed theMMT training) is not possibte, a pharmacist, who has not compteted the mandatory training' maydispense the methadone if they adhere to the Seven Fundamentals established in Professional

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    Practice Policy (PPP-58) - Adapting a Prescription as outtined in the ". TheGuideline to this Principle goes on to say " should the patient require ongoing care the pharmacistmust ensure that they comply, as quickty as possrb/e, with the requirements laid out in PPP-66. Thisincludes, but is not limited to, the successfu/ comptetion of the mandatory training sessron..."

    them?

    The required references can be found at the following:. The College of Pharmacists of BC's PPP-66 Methadone Maintenance Treatment: Policv

    Guidecan be found on the College website (www.bcpharmacists.orq) under KeyInitiatives/Methadone Maintenance Treatment (MMT)

    o The College of Physicians and Surgeons of BC's Methadone Maintenance Handbookeo\gl is available on their website ( ) under About the College/Programs/BCMethadone Program

    o The Centre for Addiction and Mental Health's Methadone Maintenance: A Pharmacist'sGuide to Treatment, ld Edition is available for purchase on the Centre for Addiction andMental Health's website (vyr,nnrv.camh.net) under Publications/CAMH Publications/SubstanceUse

    There are currently no 'LIVE' Training Sessions scheduled, however the 'ONLINE' Training Session is

    available on the College website (unvw.bcpharmacists.orq) under Key lnitiatives/MethadoneMaintenance Treatment (MIVT). lf additional 'LIVE' sessions become available, pharmacists will benotified by email.

    The ,ONLINE, MMT Training Session is available for you to view at any time on the College website(www.bcpharmacists.orq; unOer Key Initiatives/Methadone Maintenance Treatment (MMT)' Theformat of the ,oNLlrugrMur Training session is an audio recorded, PowerPoint presentation justover t hour in length and available 24t7. No registration is required and participants are able to stopand start the session as necessary'

    The'ONLINE, MMT Training Session will be available on the College website indefinitely'

    once you,ve signed the Declaration, please retain it in the files at your primary pharmacy ofemployment.Youarery!requiredtoforwardacopytotheCol|ege'

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    For more information regarding clinicalBCPharmaCare Newsletter

    prease

    What is an ouoriginal" prescription?

    ln the glossary of terms included in the ppp-sg orientation Guide a "new and/or original" prescription

    is defined as: the first fill of a prescription and does not need to be the beginning of a new drug

    therapy. Although this definition remains accurate further clarification is required'

    An ',original" prescription may be a new written, verbal or faxed authorization from any prescriber' In

    addition, an "original" prescription may be a fax-back or verbalrefill request authorized by a prescriber'

    which of the new clinical services fee intervention codes shotlld be usedfor missing information?pharmaCare has not defined a specific intervention code for missing information, however, depending

    on the situation, pharmacists should use their professionaljudgment and choose the code that best fitsthe circumstance. For example:

    o lf no dose or no quantity was provided- use Nl (dosage change)

    . lf no directions were Provided- use NK (directions for use modified)

    services fee processes and procedures refer to the

    December 22'2008, Edition 08-012

    environment) what are the restrictionsmedical conAitions for adapting prescriptions?

    There are differing guidelines for the three distinct ways in which a community pharmacist may adapt a

    prescription (change, renew or substitute), therefore the restrictions vary with each type of adaptation'

    Change:r will not change the dose or regimen of a prescription for: cancer, cardiovascular disease'

    asthma, seizrlres or psychiatric conditions, however pharmacists can complete missinginformationi f thereishistor icalevidencetosupport i t .

    Renew:r With the exception of narcotics and/or controlled substances, which are restricted from

    any type oi ao'aptation and psychiatric medications which are reserved for pharmacists

    working in multi-disciplinary environments there are no restrictions for renewals as long

  • as the condition is stable, chronic (defined as being on the same medication' withoutchange, for a minimum of 6 months). The maximum renewal is up to approximately 6months from the date of the original prescription'

    Therapeutic Substitution:o Limited to: histamine 2 receptor blockers (H2 blockers), non-steroidal anti-inflammatory

    drugs (NSAlDs), nitrates, angiotension converting enzyme inhibitors (ACE inhibitors)'dihydropyridine calcium channel blockers (dihydropyridine ccBs) and proton pumpinhibitors (PPls) - similar to government policies'

    What happens to the authorized refilts when a prescription ls adapted?

    The pharmacist takes responsibility for the adapted prescription as well as the authorized refills' The

    pharmacist could choose io provide an initial adaptation of the prescription but reduce or eliminate the

    authorized refills. lf they did this they would need to provide the rationale for their decision in their

    documentation and inform the patient that they will need to return to their physician earlier than

    intended (note: a pharmacist cannot add refills that were not initially authorized by the prescriber)'whatever the final decision is, it must be properly documented and provided in the notification

    to the

    prescriber.

    lf the pharmacist adapts the prescription and maintains the authorized refills, when the patient returns

    for a refill the pharmacist would process the refill as they would any other refill prescription' The

    processing of a refill of an adapted prescription is not considered an adaptation per se' so the

    documentation and notification requirements of PPP-58 do not apply'

    Should the patient return to the pharmacy for a refill and a different pharmacist is on duty that

    pharmacist would again process the refill as they would any other refill, keeping it under the adapting

    pharmacists lD. lf they have a concern about the appropriateness of the adapted prescription they

    should do what they normally do if they have a concern about refilling a prescription; refuse to fill'

    provide an emergency fill if necessary and in this case either refer the patient back to the adapting

    pharmacist or to the original prescriber.

    Finally it is important to note that when a pharmacist adapts a prescription and maintains the

    authorized refills they must inform the patient that as a result of them doing this the prescription is now

    non-transferable which means the patient will need to return to this specific pharmacy in order to get

    their refills.

    mean that I cannot adapt or renew this prescription?

    Yes. Just like we honour notations like this from prescribers today regarding generic substitution

    pharmacists are expected to honour hand-written "Do Not Renew 8/or Adapt" instructions on

    prescriptions. The college of Physician and surgeons (CPSBC) have agreed that pre-printedprescription pads are not acceptable and if a physician electronically produces their prescription they

    must sign or initial beside the notation

    It is important to remember that should a pharmacist, presented with a valid notation on a prescription'

    still feel that an adaptation or renewal is in the best interest of the patient there are a number of options

    still available to them: contact the prescriber for prior permission to adapt or renew the prescription or

  • provide an emergency fill (PPP-31) to ensure continuity of care giving the patient time to get in to seetheir physician.

    What are the limits and conditions, including length of time, with respect torenewing prescriptions for my patients?

    When considering whether or not to renew a prescription for a patient a pharmacist must ensure the

    following:a. They have the original prescription in their pharmacy and the prescription is still valid' andb. The patients, .ondition is stable and chronic (defined as being on the same medication'

    without change, for a minimum of six months)'

    Assuming these conditions are met a pharmacist, by applying the seven fundamentals ' could provide

    a |."ne*al for up to six months from the date of the original prescription.Example(s):

    e Hydrochlorothiazide 25mg, daily, 100 - pharmacist could provide one renewal ofHydrochtorothiazide 2Smg, oaity, too (note: although this is slightly over the maximum sixmonths timeline it is completely acceptable by the college and the CPSBC) -

    o Hydrochlorothiazide 25mg, daily, 30 - pharmacist could provide one renewal forHydrochlorothiazide 25mg, Oaily, tOO, ihen after the 100 days, after assessment' provide

    a second renewal for 60 daYs'

    Although there are no restrictions with respect to the types of conditions or drugs (other than narcoticsand controlled substances which are restricted for all adaptations) to which a pharmacist couldconsider a renewal, special consideration should be taken with respect to psychiatric medications'

    in which I

    prescriptions dose, formulation or reg

    Assuming that no collaborative relationships or appropriate protocols have been established which

    would provide more detailed patient medical information, therapeutic substitution in most typical

    community practices is limited to the following classifications (similar to government policies):o Histamine 2 receptor blockers (H2 blockers),o Non-steroidal anti-inflammatorydrugs(NSAlDs)'o Nitrates.. Angiotension converting enzyme inhibitors (ACE inhibitors),. Dihydropyridine calcium channel blockers (dihdropyridine ccBs), ando Proton pump inhibitors (PPls)

    With respect to making changes to a prescription dose or regimen, pharmacists working in typical

    community practice settings, as described above, would not adapt prescriptions for patients with:

    cancer, cardio-vascular disease, asthma, seizures or with psychiakic conditions. Changes to

    prescription formulations to ensure continuity of care, such as switching from a tablet to a liquid' as

    well as completing missing information from a prescription, if there is historical evidence to support it'

    would be acceptable.

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    then renew it?No. In order for a pharmacist to even consider adapting or renewing an existing prescription they must

    have the ,original prescription' in their pharmacy. The reason for this is because in order to adapt or

    renew a prescription a pharmacist must have all relevant information available to them and a

    transferred prescription does not physically transfer the 'original' prescription which may have some

    important notations on it. For similar reasons, once a prescription has been adapted it can not be

    transferred.

    Why did the College establish PPP-58?

    You probably already perform many prescription adaptation-related activities now, such as making

    minor adjustments to prescription details or giving patients an interim supply of a medication tomaintain continuity of care. PPP-58 goes beyond what is available today and gives

    pharmacists

    independent authority and accountability for the adaptation of a prescription and provides the

    frameworktoguidepharmacistsinsafeandeffectivepractice.

    The policy, which provides the opportunity for pharmacists to maximize their full educational and

    professional competencies, also provides structure to, and refines the process of' exercising

    professionaljudgment in clinical practice. This becomes increasingly important as pharmacists evolvetheir role as medication exPerts'

    Do I have to adaPt a PrescrlPtion?No. Authorization does mean obligation. The decision to adapt a prescription or not is at the

    discretion

    of the individual pharmacist. Whenever a pharmacist chooses to adapt a prescription however' the

    adaptation must be done in accordance with PPP-58 and within the limits of the pharmacist's own

    competencies.

    actice?

    It makes good practical sense that pharmacists are authorized to adapt prescriptions' with your

    t ra in ing indrugtherapy ,be ingab|e toadaptprescr ip t ionsmeanstha tpa t ien tswi | |haveaccess tomedication management services from pharmacists more effectively than in the

    past' Patients will

    have improved access to drug therapy renewals to ensure uninterrupted continuity of on-going therapy

    for chronic conditions. Pharmacists will be able to eliminate the delays associated with contacting a

    prescriber for clarification, modification or improvement of drug therapy with a prescription' Pharmacist

    involvement with adapting prescriptions will irnprou" inter-professional communication' documentation

    of care and patient involvement in decision-making and consent, which are all positive steps for health

    care .Thebot tom| ine is tha tBr i t i shCo|umbianshaveaskedforqu icker ,moreconven ien taccess toprescription renewals and optimal drug therapies. PPP-58 is the first step in this process

    and has the

    potent ia| toa|sofreeupphysiciant imetoseepat ientsinneedoftheirservices.

  • Are there special requirements needed in order to adapt a prescription?

    yes. In order to adapt a prescription a pharmacist, in addition to having read and understood theOrientation Guide and Amendment to the Orientation Guide, must possess professional liabilityinsurance (minimum $2 million) and must adhere to all of the seven fundamentals for adapting aprescription as outlined in PPP-58.

    H will my patients know that I'm qualified to adapt prescriptions?you are responsible for informing patients of your authority to adapt a prescription and for decidingwhether or not you are prepared to make an adaptation when appropriate. All pharmacists who arelicensed in British Columbia are required to have read the Orientation Guide and Amendment to the

    Orientation Guide by December 31, 2008 and pharmacists' authority to implement PPP-58, andthereby adapt prescriptions, ts effective January 1' 2009'

    How wilt the College ensure quality medication management activities bypharmacists?The College's mission is to protect the public by ensuring that Gollege registrants provide safe andeffective pharmacy care to help people achieve better health. The College's Quality OutcomeSpecialist Staff will include a review of the processes and procedures required to apply PPP-58 in their

    on-going site visits.

    Will I be able to adapt prescriptions for narcotics?

    No. ppp-Sg does not authorize pharmacists to adapt prescriptions for narcotics, controlled drugs or

    targeted substances.

    college council recently, through inclusion in the college's strategic plan, has directed college staff to,,develop a plan to encourage the government to authorize advanced professional practice for

    pharmacists in BC".

    Do I have to eomplete this orientation if I don't plan to adapt prescriptions?

    Yes. Although it is not mandatory that a pharmacist adapt a prescription, given that PPP-58 enhances

    pharmacists, scope of practice, it is mandatory that all registrants acknowledge that they have read

    and understood PPP-58 (by signing the Declaration Form included in the orientation Guide and theAmendment to the Orientation Guide) by December 31, 2008'

    PPP58 FAQSv2011.1