COVID-19 Registration Protocols

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COVID-19 Registration Protocols

The COVID-19 pandemic has created challenges for some individuals in their ability to meet the requirements to register or re-register as pharmacists or pharmacy technicians with NLPB. Given these challenges, NLPB has been investigating and engaging in extensive discussions with stakeholders to determine what changes to registration requirements and processes within NL could help alleviate disruptions in registration while maintaining safe practice. As the majority of NLPB’s registration requirements are set out in the Pharmacy Act, 2012 (Act), changes could only be made by the Government of NL and not by NLPB independently. On May 5, 2020, the NL House of Assembly passed a bill revising the Act to allow for emergency registration of pharmacists and pharmacy technicians in specific situations. The bill received Royal Assent and became law on May 6, 2020.

The change to the Act does not create a provisional registration category that allows new registrants to temporarily bypass certain registration requirements and enter regular practice pending completion of those requirements–as seen in some other provinces. The change to the Act instead enables NLPB to issue an emergency registration only in very specific circumstances related to an immediate need for pharmacist or pharmacy technician services “due to an actual or potential threat to public safety, health or welfare or where the minister [of Health and Community Services] or federal Minister of Health makes a request.” This change is similar to what is in place for other regulated NL health professionals.

What does this mean for recent pharmacy program graduates?

Recent pharmacy graduates are permitted to continue in their roles as pharmacy interns, unless they are in a situation to be able to apply for the new emergency registration category.

In NL, a pharmacy intern’s scope of practice is very comprehensive, and is quite similar to what other provinces refer to as a provisional pharmacist. A pharmacy intern may perform most tasks within the scope of practice of a pharmacist, as long as they are under the supervision of a pharmacist.

  • The requirement for “supervision” in this case is more open-ended than the requirement for “direct supervision” of pharmacy students. Supervision is not a one-size-fits-all approach, and calls for the active engagement of all participants to ensure a quality learning environment while maintaining the best possible patient care.
  • When determining the appropriate level of supervision required, the supervising pharmacist must assess the intern individually by considering the intern’s level of education and experience and evaluating the intern’s competence in relevant areas of practice.
  • Once the supervising pharmacist is comfortable with allowing some independence, they and the pharmacy intern should have a shared understanding of the types of activities that can be performed independently and the extent to which these activities can be performed without the direct observation of the supervising pharmacist, or their delegate.
  • When providing indirect supervision, the supervising pharmacist or delegate must be readily available for consultation and, if necessary, for providing hands-on assistance to the intern and ensure the intern complies with established standards, policies, and procedures.

There are a few specific exceptions to this, a pharmacy intern may not independently perform an activity that requires specific additional authorization by the NLPB including:

  • administering an inhalation or injection
  • participating in Opioid Agonist Maintenance Treatment
  • prescribing

 

Who is accountable for the pharmacy intern’s practice?

Accountability for the pharmacy intern’s practice is shared between the supervising pharmacist and the intern:

  • The supervising pharmacist is accountable/responsible for ensuring that the appropriate level of supervision is provided to the intern based on ongoing assessment of the individual intern’s competence. The supervising pharmacist is ultimately accountable/responsible for the intern’s practice regardless of the level of independence granted, and must ensure that appropriate oversight and checks of the intern’s practice are in place at all times.
  • The pharmacy intern maintains accountability/responsibility for his or her own practice and should only engage in an activity when competent to do so. It is the intern’s responsibility to seek assistance from the supervising pharmacist (or their delegate), as needed.

 

Key takeaways:

  • Pharmacy interns are not pharmacists and may not be scheduled to work independently without the supervising pharmacist or their delegate present.
  • Pharmacy interns must identify themselves as an intern when communicating or working with the public, other members of the pharmacy profession, and other health professionals as appropriate.

More information will be sent directly to recent pharmacy graduates regarding their status and the ongoing responsibilities associated with being registered as a pharmacy intern.

What does this mean for recent pharmacy technician program graduates?

NLPB does not have a category of registration specific to pharmacy technician students or pharmacy technician interns and this was not specifically addressed in the revision to the Act. Recent graduates of pharmacy technician programs are unable to register with NLPB at this time, unless they are in a situation to be able to apply for the new emergency registration category.

What does this mean for applicants from another province or former registrants who wish to return to practice?

Applicants from another province or former registrants who wish to return to practice will be required to meet all of the general registration requirements of NLPB, unless they are in a situation to be able to apply for the new emergency registration category.

COVID-19 Emergency Registration

The recent change to sections 14.1 and 17.1 of the Pharmacy Act, 2012 enables NLPB to issue an emergency registration only in very specific circumstances related to an immediate need for pharmacist or pharmacy technician services “due to an actual or potential threat to public safety, health or welfare or where the minister [of Health and Community Services] or federal Minister of Health makes a request.”

Pharmacy owners, employers or candidates wishing to apply for emergency registration should contact registration@nlpb.ca for further direction. Applications for emergency registration will be reviewed on a case-by-case basis to assess the circumstances of the indicated immediate need for services, and each potential emergency registrant’s educational background and experience will be considered to determine:

  • whether an “immediate need” has been established, pursuant to the requirements in the Act;
  • what registration requirements NLPB is willing/able to exempt the person from;
  • what conditions (supervision, practice location restrictions, etc.) will be placed on the registrant’s practice; and,
  • the period of time that the emergency registration is to be issued.

 

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