Policy Analyses of Scope or Practice Changes in relation to prescribing for Optometry and Pharmacy and the regulation of Pharmacy Technicians (March 2012)

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Title: Policy Analyses of Scope or Practice Changes in relation to prescribing for Optometry and Pharmacy and the regulation of Pharmacy technicians
Principal Applicant Title(s) Institutional Affiliation Funding Amount Anticipated Completion Date
Dr. Rishma Walji Post Doctoral Fellow Department of Health Aging & Society at McMaster University $60,000 March 2012
Co-Applicant(s) Titles(s) Institutional Affiliation(s)
Dr. Michael A. Beazely Assistant Professor School of Pharmacy, Faculty of Sciences at McMaster University
Ms. C. Lisa Prokopich

Clinical Lecturer,



School of Optometry at University of Waterloo,

Ocular Health Clinic

Freeport Hospital Vision Centre


rishma-walji-wellnessBiography of the Principal Investigator: Rishma Walji has advanced training in qualitative methodology and has conducted other research in the past with similar methodology and in similar topic areas (regulatory changes and expanded scope of practice related to prescribing rights). Her experience is largely in health services and policy research and health human resources research. Rishma has studied the pharmacy profession in the past for her doctoral work and is familiar with the profession as well as the regulations around scope of practice. She has completed data collection for her primary post doctoral project and thus will be able to dedicate time to this important topic. She is also being supervised by her postdoctoral advisor, Dr. Ivy Bourgeault, who has conducted similar research in other populations and is willing to provide feedback for any difficulties encountered during this project 

Executive Summary

In 2011, the Ontario Health Human Resources Research Network (OHHRRN) called for the submission of proposals to address the following objective: To partner with the coordinative team at OHHRRN in the conduct of a policy analyses of Bill 171 An Act to improve health systems by amending or repealing various enactments and enacting several Acts (2007) and Bill 179 An Act to amend various acts related to regulated health professionals and other certain other Acts.
Our project focuses on a policy analysis of the scope of practice changes for pharmacists, optometrists and regulatory changes for the newly regulated profession of pharmacy technicians. The purpose of this project was to identify activities, strategies and collaborations taking place at these various levels in preparation for the implementation of these new regulatory changes.
The themes that overarch all professions examined in this initiative include that regulatory changes seem to be more prescriptive than practice based. In particular for pharmacy and optometry such things as including drug lists rather than categories are considered too specific for a self-regulating health profession with professional standards and a college whose mandate is to protect the public and regulate professionals. While professional judgment is discussed and felt to be valued, it is believed to have been overridden by specific regulatory language. All professions included in this report have been very pro-active with respect to both current and anticipated regulatory changes and they have been diligent in planning for these changes in education, continuing education, ensuring public safety, and importantly, encouraging members to react positively to these changes. Generally the professions are enthusiastic about regulatory change but uncertain about actual implications at this stage.
This research was commissioned to examine processes undertaken by the Ontario College of Pharmacists to meet the regulatory requirements. Unfortunately the expected regulatory changes have not yet occurred even during the time of our data collection. The college and various stakeholders (including educational institutions, associations, etc.) have prepared for new regulatory changes by improving both core curriculum and continuing education as well as by developing practice standards, and engaging various working groups to address the needs of pharmacists to prepare for anticipated regulatory changes. Some of these initiatives are well under way while others are dependent on whether anticipated regulatory changes will actually take place. Throughout the process there has been intensive collaboration within the profession and also with other health professions.
Pharmacy Technicians
Pharmacy technicians are newly regulated and many of the professionals have yet to become registered. There are a number of educational programs offered to pharmacy assistants who wish to become registered pharmacy technicians. The move within the profession to become registered has been fuelled by hospitals that now require their pharmacy technicians all become registered by 2014. Community pharmacy assistants have varying circumstances regarding encouragement to become regulated and they express concerns about job security and salary. It is early to understand how they will be affected by the regulatory changes. The educational initiatives were aimed at determining baseline competencies for all pharmacy technicians from accredited programs. While concerns exist about the lengthy and costly process to become regulated, generally the move to becoming a regulated profession has been accepted and encouraged. This profession is unique in that their role came to existence in part because of the need of pharmacists to rely more on their technicians highlighting the interrelationship among the two professions that has manifest in the Ontario College of Pharmacists taking on responsibility for regulating pharmacy technicians. The inter-relationship among the two professional groups is particularly true in hospitals where the roles for pharmacy technicians have typically been broader than those in community. In order for pharmacy technicians to work to their full scope of practice, a number of aspects will become important – including intraprofessional collaboration with pharmacists, as well as the anticipated change in scope for pharmacists so that they can move to a medication management role and pharmacy technicians can cover the medication dispensing functions.
With the regulatory changes having taken place during the course of this project, optometrists seem to have enthusiastically embraced their new scope of practice. Educational preparation had begun many years prior to the regulatory changes, both within the curricula at the schools of optometry as well as within the established profession. The main areas of focus now are on scope limitations due to the listing of specific drugs rather than outlining therapeutic drug categories; specific wording in the regulation that is unclear in terms of practice-based implementation; implications to interprofessional collaborations; as well as billing considerations. The area of most significant concern is the specific detail of the regulations listing individual drug products as opposed to describing categories of drugs used to treat eye diseases. This type of regulation is prescriptive and makes it difficult for the profession to manage their patients in a contemporary manner. The emerging science and drug advancements invariably occur long before regulation change can occur, and in the mean time optometrists would not be able to treat their patients to the standard of care. This also may cause potential risk to patients who require prescriptions from optometrists if their formulary is out of date. The wording in other areas of the regulations is also prescriptive and confusing. Optometrists and other health care professions with whom they collaborate are unclear as to the requirements of optometrists when faced with certain conditions, including some emergency care. This relates directly to interprofessional collaboration as there are concerns about roles and responsibilities in terms of patient management and referrals. The final major issue for this group of practitioners is clarity with billing codes. Optometric services are de-insured for some primary care services, however there remains a concern that only some medical conditions are covered, while others are not, as determined by a list of conditions defined by the Ontario Health Insurance Plan. Patients with certain eye conditions may be insured if examined and managed by one profession, while they not be insured if seeking the same service from an optometrist. There are efficiencies to be gained by improving the definitions of insured medical services and clarifying billing codes.

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