Feedback on Standards of Practice Changes
Recently, the Alberta College of Pharmacy (ACP) underwent a consultation period to gather feedback about proposed amendments to the ACP Bylaws and Standards of Practice for Pharmacists and Pharmacy Technicians. The amendments were made in response to changes to legislation enacted as a result of Bill 46 and Bill 10. Bill 10, also known as the Health Professions (Protecting Women and Girls) Amendment Act, 2022 strengthens existing laws that ban female genital mutilation in Alberta. Bill 46 outlines amendments to the Health Professions Act that requires redistribution of some information from the current Pharmacists and Pharmacy Technicians Profession Regulation to the Standards.
The PTSA Advocacy committee reviewed the proposed amendments and provided a written response to ACP, which outlined concern regarding some of the changes. While the proposed changes regarding supervision and direction did not change policies that already exist, it also did not acknowledge changes needed to current policy documents to reflect the current, and future state, of pharmacy technician practice, more accurately. Read the response letter here.
In 2020, PTSA published the position paper: Changes to Pharmacy Technician Practice Framework. It outlines changes that should be made for pharmacy technicians to realize our practice potential and ultimately contribute to improving overall health outcomes for Albertans. PTSA has made several recommendations regarding the application of direction compared with supervision. We feel that adding certain language to the proposed standards does not support the recommendations and instead could cause greater confusion among pharmacy professionals. Pharmacists are not responsible for supervising the practice of pharmacy technicians and the concept of direction is intended to facilitate the complimentary practice of pharmacy technicians and pharmacists. PTSA asked ACP Council to delay proposed changes related to Standard 20 so that wording could be improved.
Additionally, PTSA noted that amending the Standards also offers the opportunity to provide greater clarity surrounding appropriate roles for non-regulated pharmacy employees. We feel strongly that additional amendments are needed to sections 20.12 and 20.13. In June 2016, Council adopted recommendations regarding the use of non-regulated personnel for compounding sterile preparations. “Because of the unique training and technical competencies required to compound sterile preparations and because of the limitations to providing continuous direct supervision…the implementation of the Model Standards restrict sterile compounding activities to regulated pharmacy personnel…”. To the best of our knowledge, this restriction is not clearly included in any component of the practice framework and should be reflected in the Standards of Practice. There are other activities that should be restricted for pharmacy employees for similar reasons. The Role Clarification of Non-Regulated Pharmacy Employees publication outlines appropriate tasks for trained and supervised pharmacy employees.
Around the same time this consultation period was open, the following article was shared: ACP to introduce new standards of practice in 2023 | Alberta College of Pharmacy (abpharmacy.ca). In order to achieve the goal of a modern and relevant framework to regulate pharmacy practice, ACP plans to make significant changes to the Standards of Practice this year. PTSA has offered to help ACP with this work so that updates capture pharmacy technician practice and appropriate roles for pharmacy assistants as accurately as possible. At their January meeting, the PTSA board discussed the upcoming Standards amendments and started planning an approach to ensure this happens. ACP has not directly invited PTSA to participate in this work but several Board Directors have been invited to attend focus groups along with other pharmacy professionals.
When the time comes, we will need the collective feedback of all Alberta pharmacy technicians to ensure that the new Standards of Practice are relevant and applicable to all practices. If you have been invited to participate in a focus group or would like more information about how you can help guide the feedback provided by PTSA, please contact us at firstname.lastname@example.org.
Did you provide feedback to ACP during the recent consultation? What are your thoughts on changes needed to the Standards of Practice? Share your comments below.