Docstoc

Reg-Consult-Pharmacy-Technicians

Document Sample
Reg-Consult-Pharmacy-Technicians Powered By Docstoc
					                                                 10025 Jasper Avenue
                                                 P.O. Box 1360, Station Main
                                                 Edmonton, Alberta
                                                 T5J 2N3
June 4, 2010

To All Stakeholders:
Via e-mail

Re: Proposal to Regulate Pharmacy Technicians

In November 2006, the Pharmacy Technician Society of Alberta and the Alberta College of Pharmacists
created a joint working group to work towards regulation of pharmacy technicians under the Health
Professions Act. The Alberta Government has committed to regulating pharmacy technicians as
regulation will support improved public safety through mandating educational standards, continuing
education requirements, effective disciplinary processes, use of protected titles, as well as establishing
standards of practice, competencies and a code of ethics.

The Alberta College of Pharmacists (ACP) proposes that pharmacy technicians be regulated as a separate
category under the Pharmacists Profession Regulation and further proposes that the scope of practice for
pharmacy technicians include dispensing Schedule 1 and Schedule 2 drugs (being schedules to the
Pharmacy and Drug Act) and providing for sale or selling Schedule 1 or 2 drugs.

A draft of the amendments to the Pharmacists Profession Regulation, which incorporates the necessary
provisions to regulate pharmacy technicians, is being forwarded to you for your review and comment.
Attached to this package, is the ACP’s Transition Times (Spring, 2010 edition) which is exclusively
dedicated to providing information about the ACP’s policies regarding regulation of pharmacy
technicians. For Ministry stakeholders who may not be familiar with the pharmacy technician profession
or the Health Professions Act (HPA), a background paper summarizing the key features of the HPA and
information on the pharmacy technician profession has been prepared by Ministry staff and attached.

Also attached is a list of stakeholders to whom this consultation package is being sent. If you are aware of
other organizations or individuals who may have an interest in this issue, please let us know and we will
forward this package to them or alternatively, you can refer them to our website at
http://www.health.alberta.ca/professionals/regulated-consultation.html where this consultation package
will be made available for viewing as soon as possible. Finally, with this package is a notice regarding
the Freedom of Information and Protection of Privacy Act. This notice is provided to remind
stakeholders that their input to this consultation process is subject to this Act.

You may submit comments within the four-column consultation document or in a separate e-mail or letter
to Shirley Pate at shirley.pate@gov.ab.ca, Workforce Policy and Planning Branch, Alberta Health and
Wellness, 10th Floor, 10025 Jasper Avenue, Edmonton, AB T5J 2N3 by July 15, 2010.

Yours truly,


Karel Bennett
Director, Health Professions Unit
Workforce Policy and Planning Branch
Attachments
     ALBERTA REGULATION 129/2006                                      Proposed                           Alberta Health and Wellness Comments                    Stakeholder Comments

           Health Professions Act                             Health Professions Act                                           on                                        on

    PHARMACISTS PROFESSION                             PHARMACISTS PROFESSION                              PHARMACISTS PROFESSION                             PHARMACISTS PROFESSION
         REGULATION                                    AMENDMENT REGULATION                                AMENDMENT REGULATION                               AMENDMENT REGULATION
                                                   The title is amended by adding “AND                 Resulting from a joint working group between the
                                                   PHARMACY TECHNICIANS” after                         Pharmacy Technician Society of Alberta and the
                                                   “PHARMACISTS”.                                      Alberta College of Pharmacist (the College), on
                                                                                                       behalf pharmacy technicians and the College, the
                                                                                                       College proposes regulation of pharmacy
                                                                                                       technicians as separate category under the
                                                                                                       Pharmacists Profession Regulation.

                                                                                                       To incorporate regulation of pharmacy technicians,
                                                                                                       it is proposed that the title of the Pharmacists
                                                                                                       Profession Regulation be amended to read as
                                                                                                       Pharmacists and Pharmacy Technicians
                                                                                                       Regulation. The College’s name will remain as
                                                                                                       the Alberta College of Pharmacists. Amending the
                                                                                                       title of the regulation underscores that that
                                                                                                       pharmacy technicians are not a category of
                                                                                                       pharmacists and provides clarity to the public
                                                                                                       regarding where to locate the regulations
                                                                                                       pertaining to pharmacy technicians.
Definitions

1 In this Regulation,                              Section 1 is amended                                Several definitions have been amended throughout
  (a)“Act” means the Health Professions Act;       (a) by repealing clause (b) and substituting the    this section to reflect that pharmacists and
  (b)“clinical pharmacist” means a regulated       following:                                          pharmacy technicians will each have their own
  member registered in the clinical register            (b)“clinical pharmacist” means a regulated     categories of registers which are separate and apart
  category of the regulated members register;           member registered in the clinical pharmacist   from each other.
  (c)“College” means the Alberta College of             register category of the regulated members
  Pharmacists;                                          register;
  (d)“Competence Committee” means the
  competence committee of the College;             (b) by repealing clause (g) and substituting the
  (e)“Complaints Director” means the complaints    following:
  director of the College;                              (g)“courtesy pharmacist” means a regulated
  (f)“Council” means the council of the College;        member registered in the courtesy pharmacist
(g)“courtesy pharmacist” means a regulated               register category of the regulated members
member registered in the courtesy register               register;
category of the regulated members register;
(h)“direct supervision” means direct supervision         (g.1)“courtesy pharmacy technician” means a      Definitions for courtesy pharmacy technician and
as described in section 23;                              regulated member registered in the courtesy      provisional pharmacy technician and have been
(i)“drug” means a drug as defined in the                 pharmacy technician register category of the     added.
Pharmacy and Drug Act;                                   regulated members register;
(j)“health professional” means a member of a
profession that provides health services;            (c) by repealing clauses (k), (l) and (n);           The two definitions in (k) and (1) are used only
(k)“Hearing Tribunal” means the hearing                                                                   once in the current regulation and will be amended
tribunal of the College;                             (d) by repealing clauses (p) and (q) and             to read “hearing tribunal of the college” for greater
(l)“Hearings Director” means the hearings            substituting the following:                          clarity.
director of the College;                                 (p) “pharmacy technician” means a regulated
(m)“indirect supervision” means indirect                 member registered in the pharmacy technician
supervision as described in section 23;                  register category of the regulated members
(n)“Pharmacists’ Standards of Practice” means            register;
the standards of practice of pharmacy adopted
by the College under section 133 of the Act;             (q) “provisional pharmacist” means a
(o)“pharmacy” means a licensed pharmacy and              regulated member registered in the provisional
an institution pharmacy, as defined in the               pharmacist register category of the regulated
Pharmacy and Drug Act;                                   members register;
(p)“pharmacy technician” means an individual
who has successfully completed a pharmacy                (q.1) “provisional pharmacy technician”
technician program recognized by the Council             means a regulated member registered in the
and who is registered in the pharmacy technician         provisional pharmacy technician register
register provided for in the bylaws;                     category of the regulated members register;
(q)“provisional pharmacist” means a regulated
member registered in the provisional register        (e) by adding the following after clause (u):        The current definition of “Pharmacists Standards
category of the regulated members register;               (u.1) “Standards of Practice” means the         of Practice” will be amended as the “Standards of
(r)“Registrar” means the registrar of the College;        standards of practice of pharmacy adopted by    Practice” adopted by the Council will apply to
(s)“Schedule 1 drug” means a Schedule 1 drug              the Council under section 133 of the Act;       both pharmacists and pharmacy technicians (note
within the meaning of the Pharmacy and Drug                                                               also that this definition clarifies that it is the
Act;                                                 (f) by repealing clause (w) and substituting the     Council who adopts the Standards of Practice,
(t)“Schedule 2 drug” means a Schedule 2 drug         following:                                           rather than the College as currently worded).
within the meaning of the Pharmacy and Drug               (w) “student pharmacist” means a regulated
Act;                                                      member of the College registered in the         The phrase “practice of pharmacy” used
(u)“Standards for the Operation of a Licensed             student pharmacist register category of the     throughout these amendments refers to the practice
Pharmacy” means the standards for the                     regulated members register.                     of a pharmacist as described in section 3(1) of
operation of a licensed pharmacy adopted by the                                                           Schedule 19 to the Health Professions Act (HPA).
College under section 29.1 of the Pharmacy and



                                                                                                                                                                  2
   Drug Act;                                                                                              The phrase “practice of pharmacy technicians” is
   (v)“structured practical training program” means                                                       the practice of a pharmacy technician described in
   a training program described in section 10;                                                            section 3(2) of Schedule 19 to the HPA.
   (w)“student pharmacist” means a regulated
   member of the College registered in the student
   register category of the regulated members
   register.


Register categories

2 The regulated members register established by       Section 2 is repealed and the following is          There will continue to be one regulated members
the Council under section 33(1)(a) of the Act has     substituted:                                        register but which will now be divided into 7
the following categories:                             2 The regulated members register established by     categories; these categories are also referred to as
    (a)clinical register;                             the Council under section 33(1)(a) of the Act has   registers.
    (b)provisional register;                          the following categories:
    (c)courtesy register;                                 (a) clinical pharmacist register;               In addition to the existing four categories for
    (d)student register.                                  (b) provisional pharmacist register;            pharmacists, three new categories will be added
                                                          (c) courtesy pharmacist register;               for pharmacy technicians (note: although the title
                                                          (d) student pharmacist register;                pharmacy technician student has been reserved
                                                          (e) pharmacy technician register;               under Schedule 19 of the HPA, the College does
                                                          (f) provisional pharmacy technician register;   not propose regulating pharmacy technician
                                                          (g) courtesy pharmacy technician register.      students for the foreseeable future). The proposed
                                                                                                          pharmacy technician registers will be described in
                                                                                                          the relevant sections below.
REGISTRATION

Clinical register

3(1) An applicant for registration as a regulated     Section 3 is amended                                The proposed amendments in this section will
member on the clinical register must                  (a) by repealing subsection (1) and substituting    create separate and distinct registers for
   (a)have received a baccalaureate degree in         the following:                                      pharmacists and pharmacy technicians.
   pharmacy from a pharmacy program approved                                                              Pharmacists and pharmacy technicians will have
   by the Council,                                    Clinical pharmacist register                        their own separate registration requirements
   (b)have successfully completed a structured        3(1) An applicant for registration as a regulated   including their own registration and ethics and
   practical training program, and                    member on the clinical pharmacist register must     jurisprudence examinations. The registration
   (c)have successfully passed the registration and       (a) have received a baccalaureate degree in     requirements for pharmacy technicians mirror
   the ethics and jurisprudence examinations              pharmacy from a pharmacy program approved       those currently required for pharmacists.
   approved by the Council.                               by the Council,


                                                                                                                                                                 3
(2) An applicant                                             (b) have successfully completed a structured
    (a)must have completed the requirements set out          practical training program for pharmacists,
    in subsection (1)(b) and (c) within the one-year         and
    period ending immediately before the applicant           (c) have successfully passed the registration
    submits a complete application, or                       and the ethics and jurisprudence examinations
    (b)must demonstrate to the satisfaction of the           for pharmacists approved by the Council.
    Registrar that the applicant is currently
    competent to practise pharmacy.                      (b) by repealing subsection (2)(a) and                 Clinical pharmacists register:
(3) For the purpose of subsection (2)(b), the            substituting the following:                            The College proposes amending the timelines for
Registrar may require the applicant to do one or             (a) must have completed the requirements set       meeting the registration requirements on the
more of the following:                                       out in subsection (1)(b) and (c) within the        clinical pharmacist register from one to two years
    (a)successfully complete coursework and                  2-year period ending immediately before the        immediately before the applying for registration;
    examinations;                                            applicant submits a complete application, or       two years would allow pharmacist students to take
    (b)undergo an evaluation of competencies;                                                                   the jurisprudence exam in their third or fourth year
    (c)complete an additional structured practical       (c) by repealing subsection (3)(c) and                 of their educational program.
    training program.                                    substituting the following:
(4) For the purpose of subsection (3), the Registrar          (c) complete an additional structured practical
may register an applicant on the provisional register.        training program for pharmacists.

                                                         (d) by repealing subsection (4) and substituting
                                                         the following:
                                                             (4) For the purpose of subsection (3), the
                                                             Registrar may register an applicant on the
                                                             provisional pharmacist register.

                                                         The following is added after section 3:

                                                            Pharmacy technician register                        Pharmacy technician register:
                                                            3.1(1) An applicant for registration as a           This is the main register for pharmacy technicians
                                                            regulated member on the pharmacy technician         and will include the majority of pharmacy
                                                            register must                                       technicians registered under the HPA.

                                                            (a) have received a certificate or diploma from     The minimum entry to practice requirement for
                                                            a pharmacy technician program approved by           pharmacy technicians is a certificate or diploma
                                                            the Council,                                        from a pharmacy technician program approved by
                                                                                                                Council. Under the HPA, Council will be
                                                            (b) have successfully completed a structured        responsible for approving programs and
                                                            practical training program for pharmacy             examinations for pharmacy technicians, however
                                                            technicians, and                                    Council must consult with the Minister of Health
                                                                                                                and Wellness and the Minister of Advanced



                                                                                                                                                                       4
   (c) have successfully passed the registration     Education before approving or removing the
   and the ethics and jurisprudence examinations     approval of a program.
   for pharmacy technicians approved by the
   Council.                                           In addition to meeting educational requirements,
                                                     applicants will also have to successfully complete
                                                     a structured practical training program (STP) and
(2) An applicant                                     have successfully passed examination
                                                     requirements.
   (a) must have completed the requirements set
   out in subsection (1)(b) and (c) within the       The College recognizes pharmacy technician
   2-year period ending immediately before the       programs that have received accreditation from the
   applicant submits a complete application, or      Canadian Council for the Accreditation of
                                                     Pharmacy Program (CCAPP). CCAPP began
   (b) must demonstrate to the satisfaction of the   accrediting pharmacy technician training programs
   Registrar that the applicant is currently         in 2008. The CCAPP approved colleges in
   competent to practise as a pharmacy               Alberta are NorQuest (since July, 2008) and Red
   technician.                                       Deer College, Bow Valley College and CDI
                                                     College-Edmonton (all since January 2009).
(3) For the purpose of subsection (2)(b), the
Registrar may require the applicant to do one or     The College proposes that individuals who have
more of the following:                               not graduated from an accredited program can
                                                     apply for registration using substantial equivalency
   (a) successfully complete coursework and          registration provisions outlined below.
   examinations;
                                                     The title “pharmacy technician” will be a protected
   (b) undergo an evaluation of competencies;        title i.e., only those individuals who have met the
                                                     registration requirements and are registered with
   (c) complete an additional structured practical   and regulated by the College will be able to use the
   training program for pharmacy technicians.        title “pharmacy technician”. Pharmacies will not
                                                     be required to employ pharmacy technicians;
(4) For the purpose of subsection (3), the           pharmacy employees may be employed to assist
Registrar may register an applicant on the           pharmacists under the supervision of the
provisional pharmacy technician register.            pharmacist in accordance with the supervision
                                                     rules provided later on in this regulation

                                                     The College Council proposes to adopt the
                                                     Pharmacy Examining Board of Canada’s (PEBC)
                                                     national entry to practice pharmacy technician
                                                     qualification examination The PEBC is a two-part
                                                     exam consisting of multiple choice questions and a



                                                                                                            5
                                                                                                       practical exam.

                                                                                                       The ethics and jurisprudence examination- for
                                                                                                       pharmacy technicians will be approved by the
                                                                                                       College Council.

                                                                                                       Section 3.1(2) addresses currency provisions for
                                                                                                       pharmacy technicians. As with pharmacists, the
                                                                                                       requirements for registration on the pharmacy
                                                                                                       technician register must be completed within 2
                                                                                                       years before submitting application.

                                                                                                       A second avenue for assessing currency is
                                                                                                       proposed for circumstances where an individual
                                                                                                       does not meet the two year timeline by
                                                                                                       demonstrating competency to practice by one or
                                                                                                       more of: completing coursework and exams,
                                                                                                       undergoing an evaluation or a STP.

                                                                                                       The current voluntary pharmacy technician register
                                                                                                       provided for in the College’s bylaws will end upon
                                                                                                       proclamation of these regulatory amendments
                                                                                                       however, membership on the voluntary register
                                                                                                       will not automatically qualify an individual for
                                                                                                       registration on the pharmacy technician register.
                                                                                                       Candidates on the voluntary register wishing to
                                                                                                       pursue regulated status, must apply to the college
                                                                                                       to be registered under section 6.1 of the regulation.
                                                                                                       (see details later in document)Those who do not
                                                                                                       wish to become regulated may continue to practice
                                                                                                       as unregulated pharmacy employees but will not
                                                                                                       be entitled to use the protected titles listed in the
                                                                                                       HPA and below and must work under direct
                                                                                                       supervision.

Provisional register

4(1) An applicant for registration as a regulated   Section 4 is amended
member on the clinical register may be registered   (a) by repealing subsection (1) and substituting   Amendments to the pharmacist register reflect that
                                                        the following:                                 pharmacists and pharmacy technicians are separate


                                                                                                                                                               6
initially on the provisional register if the applicant                                                           professions with separate, but similar, provisional
has successfully completed all the requirements for       Provisional pharmacist register                        register provisions.
the granting of a baccalaureate degree in pharmacy        4(1) An applicant for registration as a regulated
from a pharmacy program approved by the Council           member on the clinical pharmacist register may be
and the applicant                                         registered initially on the provisional pharmacist
    (a)has applied to write the registration              register if the applicant has successfully completed
    examination or the ethics and jurisprudence           all of the requirements for the granting of a
    examination approved by the Council,                  baccalaureate degree in pharmacy from a
    (b)has written and is awaiting the results of the     pharmacy program approved by the Council and
    registration examination or the ethics and            the applicant
    jurisprudence examination approved by the
    Council, or                                               (a) has applied to write the registration
    (c)is carrying out a structured practical training        examination or the ethics and jurisprudence
    program.                                                  examination for pharmacists approved by the
(2) An applicant may be registered on the                     Council,
provisional register under section 3, 5 or 6.
                                                              (b) has written and is awaiting the results of
(3) If a provisional pharmacist does not meet the
                                                              the registration examination or the ethics and
requirements for registration on the clinical register
                                                              jurisprudence examination for pharmacists
within 2 years of the date of registration as a               approved by the Council, or
provisional pharmacist, the Registrar must remove
the provisional pharmacist’s name from the                    (c) is carrying out a structured practical
provisional register.                                         training program for pharmacists.
(4) Despite subsection (3), the Registrar may, on
application by the provisional pharmacist, extend
the 2-year period in subsection (3) if the Registrar is   (b) in subsection (2) by striking out “provisional
satisfied that there are extenuating circumstances.       register” and substituting “provisional pharmacist
                                                          register”;

                                                          (c) in subsection (3)
                                                               (i) by striking out “clinical register” and
                                                               substituting “clinical pharmacist register”;

                                                              (ii) by striking out “provisional register” and
                                                              substituting “provisional pharmacist
                                                              register”.

                                                          The following is added after section 4:
                                                          Provisional pharmacy technician register
                                                          4.1(1) An applicant for registration as a regulated
                                                          member on the pharmacy technician register may



                                                                                                                                                                       7
be registered initially on the provisional pharmacy     The purpose and processes of the proposed
technician register if the applicant has successfully   provisional register for pharmacy technicians
completed all of the requirements for the granting      mirrors the provisional register for pharmacists.
of a certificate or diploma from a program
approved by the Council and the applicant
    (a) has applied to write the registration
    examination or the ethics and jurisprudence
    examination for pharmacy technicians
    approved by the Council,

   (b) has written and is awaiting the results of the
   registration examination or the ethics and
   jurisprudence examination for pharmacy
   technicians approved by the Council, or

   (c) is carrying out a structured practical
   training program for pharmacy technicians.

(2) An applicant may be registered on the
    provisional pharmacy technician register under
    section 3.1, 5.1 or 6.1.

(3) If a provisional pharmacy technician does not
meet the requirements for registration on the
pharmacy technician register within 2 years of the
date of registration as a provisional pharmacy
technician, the Registrar must remove the
provisional pharmacy technician’s name from the
provisional pharmacy technician register.

(4) Despite subsection (3), the Registrar may, on
application by the provisional pharmacy
technician, extend the 2-year period in subsection
(3) if the Registrar is satisfied that there are
extenuating circumstances.




                                                                                                            8
Equivalent jurisdiction

5(1) An applicant for registration as a regulated        Section 5 is amended                                 Equivalent jurisdiction is the second avenue for
member on the clinical register who is currently        (a) by repealing subsection (1) and substituting      registration of pharmacy technicians under the
registered as a pharmacist in good standing in              the following:                                    HPA. This provides a mechanism for the College
another jurisdiction recognized by the Council                                                                to implement agreements such as those developed
under section 28(2)(b) of the Act as having             Equivalent jurisdiction — pharmacists                 under Trade, Investment and Labour Mobility
substantially equivalent registration requirements      5(1) An applicant for registration as a regulated     Agreement (TILMA) and Agreement on Internal
and who successfully completes the ethics and           member on the clinical pharmacist register who is     Trade (AIT) and allows the College to recognize
jurisprudence examination approved by the Council       currently registered as a pharmacist in good          the registration requirements in other jurisdictions
may be registered on the clinical register.             standing in another jurisdiction recognized by the    as substantially equivalent to Alberta’s.
(2) The Registrar may register an applicant under       Council under section 28(2)(b) of the Act as
subsection (1) who has applied to write or has          having substantially equivalent registration          This section also mirrors the equivalent
written and is awaiting the results of an examination   requirements and who successfully completes the       jurisdiction provisions for pharmacists. As with
referred to in subsection (1) on the provisional        ethics and jurisprudence examination for              pharmacists, pharmacy technicians must
register.                                               pharmacists approved by the Council may be            successfully complete the ethics and jurisprudence
                                                        registered on the clinical pharmacist register.       examination.

                                                        (b) in subsection (2) by striking out “provisional
                                                            register” and substituting “provisional
                                                            pharmacist register”.

                                                        The following is added after section 5:

                                                        Equivalent jurisdiction — pharmacy
                                                        technicians

                                                        5.1(1) An applicant for registration as a regulated
                                                        member on the pharmacy technician register who
                                                        is currently registered as a pharmacy technician in
                                                        good standing in another jurisdiction recognized
                                                        by the Council under section 28(2)(b) of the Act as
                                                        having substantially equivalent registration
                                                        requirements and who successfully completes the
                                                        ethics and jurisprudence examination for
                                                        pharmacy technicians approved by the Council
                                                        may be registered on the pharmacy technician
                                                        register.

                                                        (2) The Registrar may register an applicant under


                                                                                                                                                                     9
                                                        subsection (1) who has applied to write or has
                                                        written and is awaiting the results of an
                                                        examination referred to in subsection (1) on the
                                                        provisional pharmacy technician register.

Substantial equivalence

6(1) An applicant for registration as a regulated       Section 6 is amended                                  Substantial equivalency is the third avenue for
member on the clinical register who does not meet           (a) by repealing subsection (1) and               registration which allows for assessment of an
the requirements of section 3(1) and (2) but whose              substituting the following:                   individuals qualifications who do not meet the
qualifications have been determined by the                                                                    requirements in sections 3 and 5 to determine if
Registrar under section 28(2)(c) of the Act to be       Substantial equivalence — pharmacists                 these qualifications are substantially equivalent to
substantially equivalent to the registration                                                                  the requirements in section 3.
requirements set out in section 3(1) and (2) may be     6(1) An applicant for registration as a regulated
registered on the clinical register.                    member on the clinical pharmacist register who        Amendments to the substantial equivalence
(2) In determining whether an applicant’s               does not meet the requirements of section 3(1) and    provisions for pharmacists reflect that pharmacists
qualifications are substantially equivalent under       (2) but whose qualifications have been determined     and pharmacy technicians are separate professions
subsection (1), the Registrar may require the           by the Registrar under section 28(2)(c) of the Act    with separate, but similar, substantial equivalency
applicant to undergo examination, testing and           to be substantially equivalent to the registration    provisions.
assessment activities and to successfully pass the      requirements set out in section 3(1) and (2) may be
ethics and jurisprudence examination approved by        registered on the clinical pharmacist register.
the Council.
(3) For the determination under subsection (2), the     (b) in subsection (2) by adding “for pharmacists”
Registrar may use the services of experts and other         after “jurisprudence examination”;
resources to assist with the examination, testing and
assessment activities.                                  (c) in subsection (5) by adding “for pharmacists”
(4) The Registrar may require an applicant to pay           after “training program”;
all the costs incurred under subsections (2) and (3).
(5) The Registrar may direct the applicant to           (d) in subsection (6) by striking out “provisional
undergo any education or training activities the            register” and substituting “provisional
Registrar may consider necessary in order for the           pharmacist register”;
applicant to be registered, including but not
restricted to completion of a structured practical      The following is added after section 6:
training program.
(6) The Registrar may register an applicant under       Substantial equivalence — pharmacy
subsection (1) on the provisional register for the      technicians
purpose of assessing whether the applicant’s
qualifications are substantially equivalent to the      6.1(1) An applicant for registration as a regulated   As with pharmacists, pharmacy technicians
registration requirements set out in section 3(1) and   member on the pharmacy technician register who        applying for registration by substantial
                                                        does not meet the requirements of section 3.1(1)      equivalence will be required to successfully


                                                                                                                                                                     10
(2).                                                    and (2) but whose qualifications have been            complete the ethics and jurisprudence examination
(7) The Registrar may request any further               determined by the Registrar under section 28(2)(c)    approved by council for pharmacy technicians.
information and evidence that the Registrar             of the Act to be substantially equivalent to the
considers necessary in order to assess an application   registration requirements set out in section 3.1(1)
under this section                                      and (2) may be registered on the pharmacy
                                                        technician register.

                                                        (2) In determining whether an applicant’s
                                                        qualifications are substantially equivalent under     See attached issue of the ACP’s Transition Times
                                                        subsection (1), the Registrar may require the         (Spring 2010) for details on transitioning
                                                        applicant to undergo examination, testing and         pharmacy technicians into a regulated system.
                                                        assessment activities and to successfully pass the
                                                        ethics and jurisprudence examination for
                                                        pharmacy technicians approved by the Council.         Applicants for registration by substantial
                                                                                                              equivalency will be registered on the provisional
                                                        (3) For the determination under subsection (2), the   register under section 4 for the purposes of
                                                        Registrar may use the services of experts and other   assessing whether the applicants qualifications are
                                                        resources to assist with the examination, testing     substantially equivalent.
                                                        and assessment activities.

                                                        (4) The Registrar may require an applicant to pay
                                                        all of the costs incurred under subsections (2) and
                                                        (3).

                                                        (5) The Registrar may direct the applicant to
                                                        undergo any education or training activities the
                                                        Registrar may consider necessary in order for the
                                                        applicant to be registered, including, but not
                                                        restricted to, completion of a structured practical
                                                        training program for pharmacy technicians.
                                                                                                              Applicants who are currently on the voluntary
                                                        (6) The Registrar may register an applicant under     register may apply for substantial equivalency
                                                        subsection (1) on the pharmacy technician             under section 6.1(1). Applicants currently on the
                                                        provisional register for the purpose of assessing     voluntary register who meet the fluency, good
                                                        whether the applicant’s qualifications are            character, and citizenship requirements outlined in
                                                        substantially equivalent to the registration          sections 11,12, and 14 of the regulations will be
                                                        requirements set out in section 3.1(1) and (2).       added to the provisional register under 6.1(6) and
                                                                                                              continue to provide the services they have been
                                                        (7) The Registrar may request any further             providing under indirect supervision as a
                                                        information and evidence that the Registrar           provisional pharmacy technician. See Transition



                                                                                                                                                                    11
                                                          considers necessary in order to assess an             Times (Spring 2010) for further information.
                                                          application under this section.




Courtesy register applications

7(1) An individual who is registered as a                 Section 7 is amended
pharmacist in good standing in another jurisdiction       (a) by repealing subsection (1) and substituting      Amendments to the courtesy register provisions
and who requires registration in Alberta on a                 the following:                                    for pharmacists reflect that pharmacists and
temporary basis for a specified purpose may apply                                                               pharmacy technicians are separate professions with
to be registered on the courtesy register.                Courtesy pharmacist register applications             separate, but similar, courtesy register provisions.
(2) The Registrar may register an applicant under         7(1) An individual who is registered as a
subsection (1) on the courtesy register for a period      pharmacist in good standing in another jurisdiction
of time specified by the Registrar if                     and who requires registration in Alberta on a
    (a)the specified purpose is approved by the           temporary basis for a specified purpose may apply
    Registrar, and                                        to be registered on the courtesy pharmacist
    (b)the Registrar is satisfied of the applicant’s      register.
    competence to provide the services related to the
    specified purpose safely and effectively.             (b) in subsection (2) by striking out “courtesy
(3) The Registrar may require an applicant for                register” and substituting “courtesy
registration on the courtesy register to successfully         pharmacist register”;
pass the ethics and jurisprudence examination.
(4) A courtesy pharmacist must maintain his or her        (c) in subsection (3)
registration in the other jurisdiction while registered
on the courtesy register.                                 (i) by striking out “courtesy register” and
                                                              substituting “courtesy pharmacist register”;

                                                          (ii) by adding “for pharmacists approved by the
                                                              Council” after “jurisprudence examination”;

                                                          (d) in subsection (4) by striking out “courtesy
                                                              register” and substituting “courtesy
                                                              pharmacist register””.



                                                          The following is added after section 7:




                                                                                                                                                                       12
                                                     Courtesy pharmacy technician register

                                                     7.1(1) An individual who is registered as a             This provision mirrors the courtesy pharmacist
                                                     pharmacy technician in good standing in another         register and allows for the short-term registration
                                                     jurisdiction and who requires registration in           of pharmacy technicians from other jurisdictions to
                                                     Alberta on a temporary basis for a specified            provide services for specific functions.
                                                     purpose may apply to be registered on the courtesy
                                                     pharmacy technician register.                           Registration on the courtesy register will be for a
                                                                                                             limited duration of time and for a specific purpose
                                                     (2) The Registrar may register an applicant under       if the Registrar is satisfied that the applicant is
                                                     subsection (1) on the courtesy pharmacy                 competent to provide the specific services.
                                                     technician register for a period of time specified by   Applicants may have to successfully pass the
                                                     the Registrar if                                        ethics and jurisprudence examination for
                                                         (a)the specified purpose is approved by the         pharmacy technicians.
                                                         Registrar, and
                                                         (b)the Registrar is satisfied of the applicant’s
                                                         competence to provide the services related to
                                                         the specified purpose safely and effectively.

                                                     (3) The Registrar may require an applicant for
                                                     registration on the courtesy pharmacy technician
                                                     register to successfully pass the ethics and
                                                     jurisprudence examination for pharmacy
                                                     technicians approved by the Council.

                                                     (4) A courtesy pharmacy technician must
                                                     maintain his or her registration in the other
                                                     jurisdiction while registered on the courtesy
                                                     pharmacy technician register.

Examination attempts

8(1) Subject to subsection (2), an applicant for
registration as a regulated member may attempt the   Section 8(3)(b) is repealed and the following is        As with pharmacists, pharmacy technicians may
registration examination and the ethics and          substituted:                                            attempt the registration exam and the ethics and
jurisprudence examination only 3 times each.                                                                 jurisprudence examination three times each. The
(2) An applicant who fails the registration          (b) to complete an additional period of structured      Registrar has the discretion to permit a fourth
examination or the ethics and jurisprudence              practical training for pharmacists or pharmacy      attempt but the Registrar may require the applicant
examination 3 times may apply to the Registrar for       technicians, as the case may be.                    to complete coursework, examinations and
                                                                                                             structured practical training before the fourth and


                                                                                                                                                                   13
permission for one final attempt.                                                                                 final attempt.
(3) The Registrar may require an applicant under
subsection (2)
    (a)to successfully complete coursework and
    examinations, and
    (b)to complete an additional period of structured
    practical training.
9 An applicant for registration as a regulated             Section 9 is repealed and the following is             Note: Student pharmacy technicians will not be
member on the student register must                        substituted:                                           regulated however the College will make rules
    (a)be registered in a university program               Student pharmacist register                            regarding the STP for pharmacy technician
    approved by the Council, and                           9 An applicant for registration as a regulated         students (which mirror the STP rules for
    (b)undertake to engage in the practice of              member on the student pharmacist register must         pharmacists developed by the College).
    pharmacy as part of a structured practical                (a)be registered in a university program
    training program.                                         approved by the Council, and
                                                              (b)undertake to engage in the practice of
                                                              pharmacy as part of a structured practical
                                                              training program for pharmacists.

Structured practical training program
10(1) The Council must make rules governing the            Section 10 is repealed and the following is            Council will be responsible for making rules for
structured practical training program, including           substituted:                                           structured practical training program for pharmacy
rules relating to                                          Structured practical training program —                technicians. These provisions mirror the rules for
    (a)the competencies to be acquired,                    pharmacists                                            pharmacists. (Refer to the attached Transition
    (b)the structure, duration and organization of the     10(1) The Council must make rules governing the        Times-Spring 2010 edition)
    program,                                               structured practical training program for
    (c)evaluation mechanisms, processes and                pharmacists, including rules relating to
    requirements for successful completion of the          (a) the competencies to be acquired,
    program, and                                           (b) the structure, duration and organization of the
    (d)any other matter directly related to the                program,
    structured practical training program.                 (c) evaluation mechanisms, processes and
(2) A structured practical training program must               requirements for successful completion of the
take place                                                     program, and
    (a)at a pharmacy or other facility approved by         (d) any other matter directly related to the
    the Registrar, and                                         structured practical training program for
    (b)under the preceptorship of a clinical                   pharmacists.
    pharmacist approved by the Registrar.                  (2) A structured practical training program for
(3) Despite subsection (2)(b), the Registrar may           pharmacists must take place
approve a preceptorship by an individual who is not        (a) at a pharmacy or other facility approved by the
a clinical pharmacist if the Registrar is satisfied that       Registrar, and
the individual has the training, skills and experience     (b) under the preceptorship of a clinical pharmacist



                                                                                                                                                                       14
necessary to teach the practice of pharmacy.             approved by the Registrar.
                                                     (3) Despite subsection (2)(b), the Registrar may
                                                     approve a preceptorship by an individual who is
                                                     not a clinical pharmacist if the Registrar is
                                                     satisfied that the individual has the training, skills
                                                     and experience necessary to teach the practice of
                                                     pharmacy to pharmacists.
                                                     Structured practical training program —
                                                     pharmacy technicians
                                                     10.1(1) The Council must make rules governing            It is proposed that a pharmacy technician, clinical
                                                     the structured practical training program for            pharmacist or courtesy pharmacist can all provide
                                                     pharmacy technicians, including rules relating to        preceptorship for pharmacy technicians.
                                                     (a) the competencies to be acquired,
                                                     (b) the structure, duration and organization of the
                                                         program,
                                                     (c) evaluation mechanisms, processes and
                                                         requirements for successful completion of the
                                                         program, and
                                                     (d) any other matter directly related to the
                                                         structured practical training program for
                                                         pharmacy technicians.
                                                     (2) A structured practical training program for
                                                     pharmacy technicians must take place
                                                     (a) at a pharmacy or other facility approved by the
                                                         Registrar, and
                                                     (b) under the preceptorship of a pharmacy
                                                         technician, clinical pharmacist or courtesy
                                                         pharmacist approved by the Registrar.
                                                     (3) Despite subsection (2)(b), the Registrar may
                                                     approve a preceptorship by an individual who is
                                                     not a pharmacy technician, clinical pharmacist or
                                                     courtesy pharmacist if the Registrar is satisfied
                                                     that the individual has the training, skills and
                                                     experience necessary to teach the practice of
                                                     pharmacy to pharmacy technicians.

Good character and reputation

11(1) An applicant for registration as a regulated   Section 11(2)(a)(ii) is repealed and the following       This section will include pharmacy technicians and
                                                     is substituted:



                                                                                                                                                                    15
member must provide evidence to the Registrar of                                                               describes evidence required from all applicants to
having good character and reputation.                    (ii) has previously been disciplined by another       establish that they are of good character.
(2) To comply with subsection (1), an applicant               regulatory body responsible for the regulation
must submit any one or more of the following, on              of pharmacists, pharmacy technicians or of
the request of the Registrar:                                 another profession;
     (a)a statement by the applicant as to whether the
     applicant
(i) is currently undergoing an investigation,
     alternative complaint resolution process, hearing
     or appeal related to unprofessional conduct
     under Part 4 of the Act, under the Pharmacy and
     Drug Act or any other enactment that regulates a
     profession, or
(ii) has previously been disciplined by another
     regulatory body responsible for the regulation of
     pharmacists or of another profession;
     (b)the results of a criminal records check;
     (c)a statement as to whether the applicant has
     ever pleaded guilty or has been found guilty of a
     criminal offence in Canada or an offence of a
     similar nature in a jurisdiction outside Canada
     for which the applicant has not been pardoned;
     (d)any other relevant evidence as required.
(3) If an applicant has engaged in an activity that
has, in the opinion of the Registrar, undermined the
applicant’s good character and reputation in the
past, the applicant may provide evidence to the
Registrar of rehabilitation.
(4) The Registrar may also consider information
other than that provided by the applicant in
determining whether the applicant is of a good
character and reputation, but if the Registrar
considers that information, the Registrar must give
the applicant sufficient particulars of that
information to allow the applicant to respond to that
information.
English language requirements

12(1) An applicant for registration as a regulated       Section 12(1) is amended by adding “or in the         This section will be amended to include pharmacy
                                                         practice of pharmacy technicians, as the case may     technicians. Fluency requirements will be


                                                                                                                                                                    16
member must be sufficiently proficient in English to      be” after “in the practice of pharmacy”.               consistent with other provinces and/or consistent
be able to engage safely and competently in the                                                                  with the minimum requirements for pharmacists.
practice of pharmacy.
(2) An applicant may be required by the Registrar
to demonstrate proficiency in the English language
in accordance with the requirements approved by
the Council.
Liability insurance
13(1) An applicant for registration as a regulated                                                               As with pharmacists, pharmacy technicians will be
member must provide evidence of having the type                                                                  required to obtain professional liability insurance.
and amount of professional liability insurance
required by the Council.
(2) The Council may set the amount and type of
insurance required based on the category of register
on which the applicant is registered.
Citizenship
14(1) Subject to subsection (2), an applicant for                                                                As with pharmacists, pharmacy technicians will be
registration as a regulated member must provide                                                                  required to be Canadian citizens or be legally
evidence that                                                                                                    entitled to work in Canada.
    (a)the applicant is a Canadian citizen, or
    (b)is lawfully admitted to and entitled to work in
    Canada.
(2) In the case of an applicant under section 9, the
applicant must provide evidence that
    (a)the applicant is a Canadian citizen, or
    (b)is lawfully admitted to and entitled to study in
    Canada.

                                                          The following is added after section 14:
                                                          Age requirement

                                                          14.1 An applicant for registration as a regulated      An age requirement is being proposed for
                                                          member on any one of the following registers must      regulated pharmacists and pharmacy technicians.
                                                          provide evidence to the Registrar that the applicant   An age requirement will not apply to pharmacy
                                                          is at least 18 years of age:                           students or provisional pharmacy technicians.
                                                          (a) clinical pharmacist register;
                                                          (b) courtesy pharmacist register;
                                                          (c) pharmacy technician register;
                                                          (d) courtesy technician register.



                                                                                                                                                                        17
TITLES AND ABBREVIATIONS

Authorization to use titles, etc.

15(1) A clinical pharmacist may use the following           The following is added after section 15:
titles, abbreviations and initials:                         Authorization to use titles                         This section lists the reserved titles for regulated
     (a)pharmacist;                                         15.1(1) A pharmacy technician and a courtesy        pharmacy technicians. Those individuals
     (b)clinical pharmacist;                                pharmacy technician may use the following titles,   employed in pharmacies who are not regulated
     (c)pharmaceutical chemist;                             abbreviations and initials:                         members under the HPA cannot use any of these
     (d)druggist;                                               (a) pharmacy technician;                        titles.
     (e)apothecary;                                             (b) pharmacy technologist;
     (f)registered pharmacist;                                  (c) dispensary technician;                      15.1(1) provides the list of titles which can be used
     (g)Ph.C.;                                                  (d) dispensary technologist;                    by regulated pharmacy technicians and courtesy
     (h)R.Ph.                                                   (e) regulated pharmacy technician;              pharmacy technicians.
(2) A provisional pharmacist may use the titles                 (f) registered pharmacy technician;
pharmacy intern and pharmacist intern.                          (g) Pharm.Tech.;                                Provisional pharmacy technicians may use the
(3) A courtesy pharmacist may use the following                 (h) PH.T.;                                      title, provisional pharmacy technician.
titles, abbreviations and initials:                             (i) R.Ph.T.
     (a)pharmacist;                                         (2) A provisional pharmacy technician may use
     (b)pharmaceutical chemist;                             the title provisional pharmacy technician.
     (c)druggist;
     (d)apothecary;
     (e)registered pharmacist;
     (f)Ph.C.;
     (g)R.Ph.
(4) A student pharmacist may use the titles
pharmacy student and pharmacist student.
(5) A clinical pharmacist and a courtesy pharmacist
with an earned doctoral degree in pharmacy or a
related area recognized by the Council may use the
title doctor or the abbreviations Pharm.D. and Dr. in
conjunction with the practice of pharmacy.
(6) A clinical pharmacist may use the title specialist
if the clinical pharmacist
     (a)meets the requirements established by
     Council for the use of the title specialist, and
     (b)is authorized by the Registrar to use that title.
(7) The Registrar must indicate an authorization



                                                                                                                                                                        18
under subsection (6) on the clinical register.
(8) The Registrar may impose conditions on an
authorization issued under subsection (6)(b).

RESTRICTED ACTIVITIES

Clinical pharmacists

16(1) A clinical pharmacist is authorized to             Sections 16 to 19 are amended by striking out      As mentioned previously in the definition section,
perform, within the practice of pharmacy and in          “Pharmacists’ Standards of Practice” wherever it   the phrase “Pharmacists Standards of Practice”
accordance with the Pharmacists’ Standards of            occurs and substituting “Standards of Practice”.   will be amended to “Standards of Practice” as the
Practice, the following restricted activities:                                                              standards of practice will apply to both
    (a)to dispense, compound, provide for selling or                                                        pharmacists and pharmacy technicians.
    sell a Schedule 1 drug or Schedule 2 drug;
    (b)to administer a vaccine or parenteral
    nutrition;
    (c)to compound blood products;
    (d)to insert or remove instruments, devices or
    fingers
        (i)beyond the anal verge, and
        (ii)beyond the labia majora;
    (e)to prescribe a Schedule 1 drug for the purpose
    of adapting an existing prescription;
    (f)to prescribe blood products for the purpose of
    adapting an existing prescription;
    (g)to prescribe a Schedule 1 drug if
      (i)it is not reasonably possible for the patient
      to see a health professional to obtain the
      prescription, and
      (ii) there is an immediate need for drug
      therapy;
    (h)to prescribe blood products if
      (i)it is not reasonably possible for the patient
      to see a health professional to obtain the
      prescription, and
      (ii)there is an immediate need for blood
      products.
(2) In subsection (1), “adapting an existing
prescription” means



                                                                                                                                                                 19
    (a)altering the dosage, formulation or regimen
    for a Schedule 1 drug that has been prescribed
    for a patient;
    (b)substituting another drug for a prescribed
    Schedule 1 drug if the substituted drug is
    expected to deliver a therapeutic effect that is
    similar to the therapeutic effect of the prescribed
    drug;
    (c)substituting a generic drug for the prescribed
    drug;
    (d)renewing a prescription to dispense a
    Schedule 1 drug or blood product to ensure
    continuity of care.
(3) Subject to subsection (4), a clinical pharmacist
is authorized to perform, within the practice of
pharmacy and in accordance with the Pharmacists’
Standards of Practice, the restricted activities of
prescribing a Schedule 1 drug and prescribing blood
products if the clinical pharmacist
    (a)has provided evidence satisfactory to the
    Registrar of having successfully completed the
    Council requirements to prescribe Schedule 1
    drugs and blood products, and
    (b)has received notification from the Registrar
    that the authorization is indicated on the clinical
    register.
(4) A clinical pharmacist authorized under
subsection (3) may prescribe a Schedule 1 drug or
blood products only if the clinical pharmacist
    (a)has determined that a Schedule 1 drug or
    blood products are appropriate for the patient
    through an assessment of the patient,
    (b)has received a recommendation that the
    patient receive drug therapy from a health
    professional who is authorized to prescribe a
    Schedule 1 drug or blood products, or
    (c)has determined in consultation with or has
    determined in conjunction with a health
    professional that a Schedule 1 drug or blood
    products are appropriate for the patient.



                                                          20
(5) A clinical pharmacist is authorized to perform,
within the practice of pharmacy and in accordance
with the Pharmacists’ Standards of Practice, the
restricted activity of administering anything by an
invasive procedure on body tissue below the dermis
or the mucous membrane for the purpose of
administering subcutaneous or intramuscular
injections if the clinical pharmacist
    (a)has provided evidence satisfactory to the
    Registrar of having successfully completed the
    Council requirements for the administration of
    injections, and
    (b)has received notification from the Registrar
    that the authorization is indicated on the clinical
    register.

Provisional pharmacists

17(1) A provisional pharmacist is authorized to
perform, within the practice of pharmacy and in
accordance with the Pharmacists’ Standards of
Practice, the restricted activities referred to in
section 16 under the supervision of a clinical
pharmacist or courtesy pharmacist.
(2) The supervision under subsection (1) may be
either direct supervision or indirect supervision, as
the supervising clinical pharmacist or courtesy
pharmacist considers appropriate to ensure the safe
and effective performance of the restricted activity.


Courtesy pharmacists

18 A courtesy pharmacist is authorized to perform,
within the practice of pharmacy and in accordance
with the Pharmacists’ Standards of Practice, the
restricted activities referred to in section 16(1) if the
restricted activity is directly related to the purpose
for which the regulated member is registered on the



                                                            21
courtesy register.


Student pharmacists

19(1) A student pharmacist is authorized to             Amend section 19 as follows:                            Note: student pharmacy technicians will not be
perform, within the practice of pharmacy, in            19(1) A student pharmacist is authorized to             regulated members of the college but the College
accordance with the Pharmacists’ Standards of           perform, within the practice of pharmacy, in            will set the rules for structured practical training
Practice and within the rules of the structured         accordance with the Standards of Practice, the          programs for student pharmacy technicians and
practical training program, the restricted activities   restricted activities referred to in section 16 under   student pharmacists.
referred to in section 16 under the supervision of a    the supervision of a clinical pharmacist or a
clinical pharmacist or a courtesy pharmacist.           courtesy pharmacist.
(2) The supervision under subsection (1) may be         (2) The supervision under subsection (1) may,
either direct supervision or indirect supervision, as   subject to the rules of the structured practical
the supervising clinical pharmacist or a courtesy       training program, be either direct supervision or
pharmacist considers appropriate to ensure the safe     indirect supervision, as the supervising clinical
and effective performance of the restricted activity.   pharmacist or a courtesy pharmacist considers
                                                        appropriate to ensure the safe and effective
                                                        performance of the restricted activity.

Conditions on restricted activities

 20 Despite sections 16 to 19, regulated members        Section 20 is repealed.                                 Relocated to section 21(4) and applies to both
    referred to in those sections must restrict                                                                 pharmacists and pharmacy technicians.
    themselves in performing restricted activities to
    those activities that they are competent to
    perform and to those that are appropriate to the
    regulated member’s area of practice and the
    procedure being performed.



Pharmacy technicians
21 A pharmacy technician employed in a                  Section 21 is repealed and the following is             This section outlines the restricted activities that
pharmacy is permitted to perform in that pharmacy       substituted:                                            the College proposes that pharmacy technicians be
the following restricted activities with the consent    Pharmacy technicians                                    authorized to perform.
of and under the indirect supervision of a clinical     21(1) Subject to subsection (2), a pharmacy
pharmacist or a courtesy pharmacist practising in       technician is authorized to perform, within the         The College proposes that regulated pharmacy
the same pharmacy:                                      practice of pharmacy technicians and in                 technicians be authorize to dispense Schedule 1



                                                                                                                                                                       22
(a)to compound a Schedule 1 drug or a Schedule   accordance with the Standards of Practice, the        and 2 drugs, compound and sell schedule 1 and 2
2 drug;                                          following restricted activities under the direction   drugs and compound blood products under the
(b)to compound blood products.                   of a clinical pharmacist or a courtesy pharmacist:    direction of a pharmacist. This is an increase in
                                                     (a)to dispense a Schedule 1 drug or Schedule 2    responsibility, accountability and liability for the
                                                     drug;                                             pharmacy technician from the current level of
                                                     (b)to compound, provide for selling or sell a     responsibility i.e. indirect supervision. The
                                                     Schedule 1 drug or a Schedule 2 drug;             pharmacist will ensure the prescription is
                                                     (c)to compound blood products.                    appropriate for the patient, be available to counsel
                                                 (2) A pharmacy technician who is authorized to        the patient and monitor the patient, but the
                                                 perform the restricted activity described in          pharmacy technician will be authorized to
                                                 subsection (1)(a) may only perform that restricted    compound and/or fill the prescription and sell the
                                                 activity if                                           drug etc after the pharmacists has evaluated the
                                                     (a)a clinical pharmacist or a courtesy            appropriateness of the prescription for the patient,
                                                     pharmacist has evaluated the prescription for     and the technician will be responsible for their
                                                     the drug,                                         own actions related to these activities.
                                                     (b)a clinical pharmacist or courtesy pharmacist
                                                     has assessed the patient, the patient’s health
                                                     history and medication record and has
                                                     determined that the drug therapy is appropriate
                                                     for the patient, and
                                                 (c)a clinical pharmacist or courtesy pharmacist is
                                                 available to counsel the patient and to monitor the
                                                 patient’s drug therapy.
                                                 (3) For the purpose of this section, a clinical       “Under the direction” means providing a system
                                                 pharmacist or courtesy pharmacist who is              that includes policies and procedures that are
                                                 responsible for providing direction to a pharmacy     monitored for compliance and outcomes rather
                                                 technician must:                                      than a system where supervision is provided
                                                                                                       through direct personal oversight of the pharmacy
                                                 (a) practice at the same pharmacy as the pharmacy     technician. The pharmacist providing direction
                                                 technician, unless otherwise authorized in writing    must practice at the same pharmacy/facility as the
                                                 by the Registrar;                                     technician, however other pharmacists may work
                                                 (b) ensure there is a system in place in the          with technicians when providing patient care.
                                                 pharmacy that complies with the Standards of          Therefore, the pharmacist who provides direction
                                                 Practice under which                                  does not always have to be present when the
                                                     (i) a clinical pharmacist or courtesy             technician is practicing, but does accept
                                                     pharmacist is available to consult with,          responsibility for the policies and procedures and
                                                     provide guidance to and, if necessary, provide    monitoring compliance of them.
                                                     assistance to the pharmacy technician,
                                                     (ii) the involvement of the pharmacy
                                                     technician in the restricted activities



                                                                                                                                                              23
     authorized under (1) can be monitored and
     assessed,
     (iii) the pharmacy technician reports to the
     clinical pharmacist or courtesy pharmacist
     who is responsible for providing direction to
     the pharmacy technician;
(c) be authorized to perform the restricted
activities in respect of which the clinical
pharmacist or courtesy pharmacist is providing
direction to the pharmacy technician; and
(d) in the case of a courtesy pharmacist, be
specifically authorized in writing by the Registrar
to provide direction to a pharmacy technician.
 (4) A pharmacy technician must not engage in a
restricted activity under (1) unless, acting
reasonably, the pharmacy technician is satisfied
that the clinical pharmacist or courtesy pharmacist
responsible for providing direction to the
pharmacy technician has complied with (3).
(5) If the Registrar authorizes a courtesy
pharmacist to provide direction to a pharmacy
technician under subsection (3)(e), that
authorization must be indicated on the courtesy
pharmacist register.

The following is added after section 21:
Provisional pharmacy technicians
21.1(1) A provisional pharmacy technician is
authorized to perform, within the practice of
pharmacy technicians and in accordance with the
Standards of Practice, the restricted activities
referred to in section 21(1) under the supervision
of a clinical pharmacist, courtesy pharmacist or
pharmacy technician.
(2) The supervision under subsection (1) may,
subject to the rules of the structured practical
training program, be either direct supervision or
indirect supervision, as the supervising clinical
pharmacist, courtesy pharmacist or pharmacy
technician considers appropriate, to ensure the safe



                                                       24
                                                      and effective performance of the restricted
                                                      activities.
                                                      Courtesy pharmacy technicians                           Courtesy pharmacy technicians will be authorized
                                                      21.2 A courtesy pharmacy technician is                  to perform restricted activities which are directly
                                                      authorized to perform, within the practice of           related to their duties as outlined on the courtesy
                                                      pharmacy technicians and in accordance with the         register.
                                                      Standards of Practice, the restricted activities
                                                      referred to in section 21(1) but only if the
                                                      restricted activity that is being performed is
                                                      directly related to the purpose for which the
                                                      regulated member is registered on the courtesy
                                                      pharmacy technician register.
                                                      Student pharmacy technicians                            Note that student pharmacy technicians will not be
                                                      21.3(1) A student who is enrolled in a pharmacy         regulated by the College however, pharmacists and
                                                      technician program approved by the Council is           pharmacy technicians will be permitted to
                                                      permitted to perform the restricted activities          supervise pharmacy technician students
                                                      referred to in section 21(1) under the supervision      performing restricted activities if certain
                                                      of a clinical pharmacist, a courtesy pharmacist, a      conditions are met as outlined in the supervision
                                                      pharmacy technician or a courtesy pharmacy              provisions.
                                                      technician.
                                                      (2) The supervision under subsection (1) may be
                                                      either direct or indirect supervision, as the
                                                      supervising regulated member considers
                                                      appropriate given the student’s abilities and
                                                      competencies at the time of the supervision.
                                                      Condition on restricted activities
                                                      21.4 Despite any authorization to perform a             This is a standard clause which appears in all
                                                      restricted activity in sections 16 to 21.2, regulated   health profession regulations and means that
                                                      members referred to in those sections must restrict     regulated members cannot perform a restricted
                                                      themselves in performing restricted activities that     activity unless they are competent to perform it
                                                      they are competent to perform and to those that are     and it is within their area of practice. For example,
                                                      appropriate to the regulated member’s area of           a pharmacy technician will be authorized to
                                                      practice and the procedure being performed.             compound blood products, but if they have not
                                                                                                              been trained to do so and it is not part of their area
                                                                                                              of practice, they are not to perform this activity
Pharmacy employees

22 An individual employed in a pharmacy is            Section 22 is amended by renumbering it                 Non-technician employees including currently
permitted to perform in that pharmacy the following   section 22(1) and adding the following after            practicing pharmacy technicians who do not
                                                      subsection (1:                                          choose to be regulated under the college will be


                                                                                                                                                                       25
restricted activities with the consent of and under    (2) Despite subsection (1), an individual             permitted to perform restricted activities as listed
the direct supervision of a clinical pharmacist or a   employed in a pharmacy is also permitted to           in this section with the consent of and under the
courtesy pharmacist practising in the same             perform in that pharmacy the restricted activities    direct supervision of a pharmacist or pharmacy
pharmacy:                                              described in subsection (1) with the consent of and   technician. However, note that these individuals
    (a)to compound, provide for selling or sell a      under the direct supervision of a pharmacy            will not be able to refer to themselves as
    Schedule 1 drug or Schedule 2 drug;                technician if                                         “pharmacy technicians” as this title is reserved for
    (b)to compound blood products.                         (a)a clinical pharmacist or courtesy pharmacist   regulated members (refer to list of restricted titles
                                                           consents to the activity being performed by the   in Schedule 19 of the HPA).
                                                           individual under the direct supervision of a
                                                           pharmacy technician, and
                                                           (b)the pharmacy technician who is to provide
                                                           the direct supervision consents.

Supervision rules

23 (1) A regulated member who consents to              Section 23 is amended by striking out
provide direct supervision under this Regulation       “Pharmacists’ Standards of Practice’” wherever it
must                                                   occurs and substituting “Standards of Practice”.
    (a)be authorized to perform the restricted
    activity being supervised,
    (b)be authorized to supervise the performance of
    the restricted activity being supervised,
    (c)be satisfied that the individual to be
    supervised is authorized or permitted to perform
    the restricted activity under the direct
    supervision of the regulated member,
    (d)ensure that the individual who is supervised
    complies with the Pharmacists’ Standards of
    Practice,
    (e)be present when the supervised individual is
    performing the restricted activity, and
    (f)be able to observe and promptly intervene and
    stop or change the actions of the individual who
    is under supervision.
(2) A regulated member who consents to provide
indirect supervision under this Regulation must
    (a)be authorized to perform the restricted
    activity being supervised,
    (b)be authorized to supervise the performance of



                                                                                                                                                                     26
   the restricted activity being supervised,
   (c)be satisfied that the individual who is
   supervised is authorized or permitted to perform
   the restricted activity under the indirect
   supervision of the regulated member,
   (d)ensure that the individual who is supervised
   complies with the Pharmacists’ Standards of
   Practice,
   (e)have procedures in place

       (i)that comply with the Pharmacists’
       Standards of Practice and the Standards for
       the Operation of a Licensed Pharmacy, and

        (ii)that ensure the safety and integrity of the
        dispensing or compounding of drugs by the
        individual who is under supervision,
    (f)ensure that the procedures described in clause
    (e) are complied with by the individual who is
    being indirectly supervised, and
    (g)be readily available for consultation by the
    individual who is under supervision and, if
    advisable, for providing hands-on assistance to
    the individual.
(3) Despite subsections (1) and (2), a regulated
member
    (a)shall not consent to supervise any individual
    performing a restricted activity if the regulated
    member is not satisfied that the individual will
    perform the restricted activity safely and
    effectively, and
    (b)is not required to consent to supervise even
    though all the requirements of this Regulation
    are complied with.




                                                          27
CONTINUING COMPETENCE

Continuing competence program

24 The continuing competence program of the                                                                   As with pharmacists, the continuing competence
College comprises                                                                                             program will apply to pharmacy technicians.
   (a)continuing professional development,
   (b)competence assessment, and
   (c) practice visits.

Continuing professional development

25(1) Each clinical pharmacist must undertake           Section 25 is amended by adding “or pharmacy          Continuing competence provisions will parallel
continuing professional development by                  technician” after “clinical pharmacist” wherever it   regulations for pharmacists.
    (a)undertaking learning activities in accordance    occurs.
    with the rules under section 28, and
    (b)taking programs or courses required by the
    rules under section 28.
(2) Each clinical pharmacist must
    (a)keep records, in a form satisfactory to the
    Competence Committee, of the activities that the
    clinical pharmacist undertakes for the purpose of
    continuing professional development, and
    (b)provide, on the request of and in accordance
    with the directions of the Competence
    Committee, copies of the records referred to in
    clause (a).


Competence assessment

26(1) The Competence Committee may require a            Section 26(1) is repealed and the following is        Competence assessment will parallel regulations
clinical pharmacist to undergo an assessment for the    substituted:                                          for pharmacists.
purpose of evaluating the clinical pharmacist’s         Competence assessment
competence.                                             26(1) The Competence Committee may require a          The Competence Committee may want to require a
(2) For the purpose of an assessment under              clinical pharmacist, courtesy pharmacist,             competence assessment of a courtesy pharmacist
subsection (1), the Competence Committee may use        pharmacy technician or courtesy pharmacy              or courtesy pharmacy technician.
any one or more of the following processes:             technician to undergo an assessment for the



                                                                                                                                                                28
   (a)examinations;                                     purpose of evaluating the regulated member’s
   (b)a review of the records described in section      competence.
   25(2)(a);
   (c)evaluation of a professional portfolio;
   (d)interviews;
   (e)any other type of evaluation required by the
   Competence Committee.


Practice visits

27 The Competence Committee is authorized to            Section 27 is repealed and the following is             Like pharmacists, pharmacy technicians will also
carry out practice visits and may, for the purpose of   substituted:                                            be subject to practice visits by the Competence
assessing continuing competence, select individuals     Practice visits                                         Committee.
or groups of clinical pharmacists for practice visits   27 The Competence Committee is authorized to
based on criteria approved by the Council.              carry out practice visits and may for the purpose of    The Competence Committee may want to require a
                                                        assessing continuing competence, select                 competence visit for a courtesy pharmacist or
                                                        individuals or groups of                                courtesy pharmacy technician.
                                                            (a)clinical pharmacists,
                                                            (b)courtesy pharmacists,
                                                            (c)pharmacy technicians, or
                                                            (d)courtesy pharmacy technicians
                                                        for practice visits based on criteria approved by the
                                                        Council.
Program rules

28 The Council must make rules governing the            Section 28(l) is amended by adding “, courtesy
operation of the continuing competence program,         pharmacists, pharmacy technicians or courtesy
including but not restricted to the following:          pharmacy technicians” after “clinical
    (a)the professional development activities for      pharmacists”.
    which program credits may be earned;
    (b)the number of program credits required
    within a specified period of time;
    (c)the number of program credits that may be
    earned for each professional activity;
    (d)the type and category of professional
    development activities that a regulated member
    must undertake in a one-year period;
    (e)the approval of program and learning
    activities for the purpose of earning continuing


                                                                                                                                                                   29
   competence credits;
   (f)the limitation of the number of professional
   development activities within a specific category
   for which a member may earn credits;
   (g)the requirements of a professional portfolio;
   (h)the records referred to in section 25(2)(a) and
   providing the records in accordance with the
   directions of the Competence Committee;
   (i)audits of a regulated member’s records
   referred to in section 25(2)(a);
   (j)approving programs and courses required to
   be taken as part of continuing professional
   competence;
   (k)how competence assessments are to be
   conducted;
   (l)the selection of clinical pharmacists for
   competence assessments;
   (m)respecting the minimum acceptable
   performance level for competence assessments.


Rule distribution

29 The rules and any amendments to the rules            No change from current regulation but will apply
under section 28 must be made available by the          to pharmacy technicians as well.
College
   (a)on the website of the College, and
   (b)in printed form on request to any regulated
   member or applicant for registration as a
   regulated member.


Actions to be taken

30 If a review of the records referred to in section    No change from current regulation but will apply
25(2)(a), a competence assessment under section 26      to pharmacy technicians as well.
or a practice visit is unsatisfactory or a regulated
member or a group of regulated members fails to
comply with the rules under section 28, the
Competence Committee may direct a regulated



                                                                                                           30
member or group of regulated members to
undertake any one or more of the following actions
within the time period, if any, specified by the
Competence Committee:
   (a)successful completion of continuing
   competence requirements or professional
   development activities;
   (b)successful completion of any examinations,
   testing, assessment, training, education or
   counselling to enhance competence in specified
   areas;
   (c)to practice under the supervision of another
   regulated member;
   (d)limitation of practice to specified procedures
   or practice settings;
   (e)to report to the Competence Committee on
   specified matters on specified dates;
   (f)to refrain from supervising the practice of
   pharmacy;
   (g)correction of any problems identified in the
   practice visit;
   (h)demonstration of competence gained in a
   specific area.


Members responsible for costs

31(1) Any action that a regulated member or group       No change from current regulation but will apply
of regulated members must undertake in response to      to pharmacy technicians as well.
a direction by the Competence Committee under
section 30 is undertaken at the cost of the member.
(2) If the College provides services to facilitate
compliance with any direction by the Competence
Committee under section 30, the member is
responsible for reimbursing the College for the costs
as determined by the Competence Committee.




                                                                                                           31
PRACTICE PERMIT RENEWAL

APPLYING FOR RENEWAL
32 Regulated members applying for renewal of             No change from current regulation but will apply
their practice permit must                               to pharmacy technicians as well.
    (a)provide any of the information specified in
    sections 11 to 14 at the request of the Registrar,
    and
    (b)meet the requirements of the continuing
    competence program.


ALTERNATIVE COMPLAINT RESOLUTION

Process conductor

33 When a complainant and an investigated person         The HPA provides that a process respecting
have agreed to enter into an alternative complaint       alternative complaint resolution is to be set out in
resolution process, the Complaints Director must         regulation. This process will apply to pharmacy
appoint an individual to conduct the alternative         technicians.
complaint resolution process.

Agreement

34 The individual conducting the alternative             This provision will apply to pharmacy technicians.
complaint resolution process must, in consultation
with the complainant and the investigated person,
establish the procedures for and objectives of the
alternative complaint resolution process, which
must be set out in writing and signed by the
complainant, the investigated person and the
representative of the College.


Confidentiality

35 The complainant and the investigated person           This provision will apply to pharmacy technicians.
must, subject to sections 59 and 60 of the Act, agree


                                                                                                                32
to treat all information shared during the process as
confidential.


Leaving the process

36 The complainant or the investigated person may                                                                 This provision will apply to pharmacy technicians.
withdraw from the alternative complaint resolution
process at any time.


REINSTATEMENT
Application under Part 4 of Act

37(1) A person whose registration and practice                                                                    The HPA provides that when a person’s practice
permit have been cancelled under Part 4 of the Act                                                                permit or registration has been cancelled through a
may apply in writing to the Registrar to have the                                                                 disciplinary action, then a re-application from that
registration and practice permit reinstated.                                                                      person must be dealt with in a process set out in
(2) An application under subsection (1) must                                                                      regulation. The process applies to pharmacy
    (a)not be made earlier than at least 3 years after                                                            technicians.
    the date of the cancellation, and
    (b)not be made more frequently than once in
    each 12-month period following a refusal of an
    application under section 38(3)(a).
(3) An applicant under subsection (1) must provide
evidence to the Registrar of qualifications for
registration.
(4) An applicant under subsection (1) must pay any
outstanding fees, costs or penalties and must pay a
reinstatement fee as set out in the bylaws before the
Competence Committee considers the application.

Review of application

38(1) An application under section 37 must be            Section 38(2)(b)(iii) is repealed and the                Proposed amendments reflect two types of practice
reviewed by the Competence Committee.                    following is substituted:                                now captured under section 3 of Schedule 19 i.e.,
(2) When reviewing an application under section             (iii)the applicant is fit to engage in the practice   pharmacists and pharmacy technicians.
37, the Competence Committee must                           of pharmacy or the practice of pharmacy
(a) consider                                                technicians, as the case may be, and does not



                                                                                                                                                                         33
(i) the record of the hearing at which the applicant’s      pose a risk to public safety or to the integrity of
     registration and practice permit were cancelled,       the profession.
     and
(ii) any recommendation of the Registrar, and
(b) consider whether
(i) the applicant meets the current requirements for
     registration,
(ii) any conditions imposed at the time the
     applicant’s permit and registration were
     cancelled have been met, and
(iii)the applicant is fit to practise pharmacy and does
     not pose a risk to public safety or to the integrity
     of the profession.
(3) The Competence Committee on reviewing an
application may make any one or more of the
following orders:
     (a)an order denying the application;
     (b)an order directing the Registrar to reinstate
     the person’s registration and practice permit;
     (c)an order directing the Registrar to impose
     specified conditions on the person’s practice
     permit.


Review of decision

39(1) An applicant whose application is denied or                                                                 This provision will apply to pharmacy technicians.
on whose practice permit conditions have been
imposed under section 38 may apply to the Council
for a review of the decision of the Competence
Committee.
(2) Sections 31 and 32 of the Act apply to a review
under subsection (1).


Access to decision

40(1) The Competence Committee, under section                                                                     This provision will apply to pharmacy technicians.
38, and the Council, under section 39, may order
that its decision be publicized in a manner it



                                                                                                                                                                       34
considers appropriate.
(2) The College must make a decision under
section 38 or 39 available for 5 years to the public
on request.


INFORMATION

Providing information

41(1) An applicant for registration as a regulated       Section 41(1) is amended                           The HPA sets out the information that must be
member and a regulated member must provide the           (a) by repealing clause (e) and substituting the   publicly available on a register of regulated
following information in addition to that required           following:                                     members. These provisions therefore apply to
under section 33(3) of the Act, on the initial                                                              pharmacy technicians.
                                                         (e)degrees, certificates, diplomas and other
application for registration, when there is a change
                                                                                       qualifications;
to the information or at the request of the Registrar:                                                      A regulatory college must provide this information
    (a)home address and business telephone                                                                  in response to a request about a regulated member.
    numbers and fax numbers;                             (b) in clause (p) by adding “or pharmacy
    (b)business mailing addresses;                           technician, as the case may be” after
    (c)e-mail address;                                      “pharmacist”.
    (d)previous names, if applicable;
    (e)degrees and other qualifications;
    (f)school of graduation and location of the
    school;
    (g)year of graduation;
    (h)date of birth;
    (i)gender;
    (j)employer’s name or place of business;
    (k)job title and position description;
    (l) practice sector;
    (m)employment status and weekly hours
    worked;
    (n)areas of practice;
    (o)date of employment;
    (p)names of other jurisdictions in which the
    member is registered as a pharmacist;
    (q)any other colleges of a regulated health
    profession in which the member is registered
    and whether the member is a practising member



                                                                                                                                                                 35
    of that college;
    (r)a recent passport photo;
    (s)other information that the Registrar may
    request that is relevant to the role of the College
    under the Act.
(2) A regulated member must inform the Registrar
of any change to the information provided under
subsection (1) within 14 days of the change
occurring.
(3) The Registrar may require a regulated member
to provide the information under subsection (1) at
any time.
(4) If the Registrar issues a request under
subsection (3), the regulated member must provide
the information within 14 days after the request is
delivered to the address of the regulated member on
the register.
(5) A regulated member that retires from active
practice must advise the Registrar no later than 14
days after the retirement.
(6) Subject to section 34(1) of the Act, the College
may disclose the information collected under
subsection (1)
    (a) with the consent of the regulated member
    whose information it is, or
    (b) in a summarized or statistical form so that it
    is not possible to relate the information to any
    particular identifiable individual.

Section 119 information

42 The periods of time during which the College is        Section 42(d)(ii) is amended by adding “of the   The HPA has specific provisions relating to public
to provide information under section 119(4) of the        College” after “hearing tribunal”.               availability of certain types of information.
Act are as follows:                                                                                        Regulatory colleges are required to make
    (a)information referred to in section 33(3) of the                                                     regulations about how long they plan to make this
    Act entered in a register for a regulated member,                                                      information publicly available. These provisions
    while the registered member is registered as a                                                         will apply to pharmacy technicians.
    member of the College and for 2 years after
    ceasing to be registered, except for the



                                                                                                                                                                36
information referred to in section 33(3)(h) of the
Act;
(b)information referred to in section 119(1) of
the Act respecting
    (i) the suspension of a regulated member’s
    practice permit, while the suspension is in
    effect and for 10 years after the period of
    suspension has expired,
    (ii) the cancellation of a regulated member’s
    practice permit for 10 years after the
    cancellation,
    (iii) the conditions imposed on a regulated
    member’s practice permit, while the
    conditions are in effect and for 10 years after
    the conditions are removed,
    (iv) the directions made that a regulated
    member cease providing professional
    services, while the directions are in effect and
    for 10 years after the directions are cancelled,
    and
    (v) the imposition of a reprimand or fine
    under Part 4 of the Act, for 10 years after the
    imposition of the reprimand or fine;
(c) information as to whether a hearing is
scheduled to be held under Part 4 of the Act with
respect to a named regulated member, until the
hearing is concluded;
(d) information respecting
    (i) whether a hearing has been held under
    Part 4 of the Act with respect to a named
    regulated member, for 10 years from the date
    the hearing is concluded, and
    (ii) a decision and a record of the hearing
    referred to in section 85(3) of the Act of a
    hearing held under Part 4 of the Act, for 5
    years after the date the hearing tribunal
    rendered its decision.




                                                       37
TRANSITIONAL PROVISIONS, REPEALS
AND COMING INTO FORCE

Transitional provisions

43 On the coming into force of this Regulation, a
registered member described in section 8 of
Schedule 19 to the Act is deemed to be entered on
the regulated members register in the register
category that the Registrar considers appropriate.

Repeals

44 The Pharmaceutical Profession Regulation
(AR 322/94), the Prescription of Drugs by
Authorized Practitioners Regulation (AR 83/98)
and the Scheduled Drugs Regulation (AR 86/2002)
are repealed.


Coming into force

45 This Regulation comes into force on the
coming into force of Schedule 19 to the Health
Professions Act and the Pharmacy and Drug Act.




                                                     38
  Working toward
                                          Technician scope                         Steps to                   Registering
    regulation                                                                                                                             Next steps
                                             of practice                          regulation                   with ACP
    since 2003


       Spring 2010




       The                       TransitionTimes
                                         H E L P I N G                    Y O U     N AV I G AT E              C H A N G E




      t
                  in
       o keep ding:
                                                                   Welcoming a new
Things hile rea
mind w pharmacy technsiciatnr and
             e term
                      let e
                             or

                                          w
                               this ne fers to a
                                                                   healthcare profession
     hen th           sed in
 n W       ian is u tandards, it
                                             re
   technic      ctice s                  o will
                                                  be
            pra                   l wh
    in the            d ividua
             ted in           CP.
     regula         with A                            ulatio
                                                             n
            tered                             n Reg
      regis                       r ofessio hat defines
                         cists P               nt
              harma                   islatio             and
   n   The P               the leg                 acists
                d to is                  pharm
        referre            ro les for             cu rrently
                 sional                ns. It is
         profes              hnicia                 date
                   a cy tec               commo s.
          pharm ended to ac hnician
                   am                         c                 e
          being                      acy te              e nam
                          pharm dments, th
               ulated                  en                    n will
           reg                 e am                 gulatio th
                    rt of th ofession Re                   to bo
            As pa           ts Pr                  pplies
                       acis                at it a
             Pharm              f lect th
                       e to re
              chang                                            lation
                       ssions
                                .                       n regu
               profe                        te chnicia effect once
                                   es for            into
                         rocess             l come Profession
           n    The p              re wil
                          ed he                   acists      expec
                                                                    ted
                outlin             ed Ph
                                            arm
                                                       hat is
                  the   amend            enac   ted. T
                             tion is           2010.
                   Regula            in late
                    to ha   ppen

                                                                   Understanding the pharmacy
                                                                   technician regulation process
                                                                   Alberta is looking forward to welcoming          Patients, professions, and the
                                                                   the new profession of regulated pharmacy         province will benefit from
                                                                   technicians. This new profession will            regulated pharmacy technicians
                                                                   provide benefits to patients, pharmacy
                                                                                                                    Regulated pharmacy technicians will be
                                                                   technicians, pharmacists, and our health
                                                                                                                    directly responsible and accountable for the
                                                                   system.
                                                                                                                    technical functions related to prescription
                                                                   The framework and processes for                  preparation and processing. They will have
                                                                   regulating technicians has evolved over
                                                                                                                    to demonstrate key competencies through
                                                                   several years and has been shaped by the
                                                                                                                    nationally administered exams and will
                                                                   involvement of many individuals and
                                                                                                                    take on the responsibility, accountability,
                                                                   groups. This newsletter outlines where we
                                                                                                                    and any resulting legal liability for their
                                                                   are today – including what possibilities
                                                                                                                    work. They will then be authorized to
                                                                   were considered and what decisions were
                                                                   arrived at – and what the next steps will be.                               continued on page 2



         H e a l t h y            A l b e r t a n s               t h r o u g h     e x c e l l e n c e      i n   p h a r m a c y     p r a c t i c e
Spring 2010                                  The TransitionTimes                                                  alberta college of pharmacists




                                             Welcoming a new healthcare profession         appropriateness of each prescription and
                                             continued from page 1                         counseling patients, pharmacy technicians
                                                                                           will be able to compound, dispense and
                                             work under the direction of a pharmacist
                                                                                           sell drugs unsupervised. They will also be
                                             (i.e., unsupervised), rather than under
                                                                                           able to supervise other technicians,
                                             supervision. This change will produce
                                                                                           assistants and pharmacy technician
                                             many benefits.
                                                                                           students in the pharmacy.
                                             Patients will benefit because
                                                                                           The health system will benefit because
                                             pharmacists, freed from the technical
                                                                                           health professionals’ skills will be used
                                             aspects of the dispensing process, will be
                                                                                           more appropriately and patients will have
                                             more accessible to patients and will be
                                                                                           increased access to care from pharmacists.


  FAQs
   from technicians
                                             able to focus on more comprehensive
                                             patient care through medication
                                             management, prescription adaptation
                                             and initial prescribing, immunization,
                                                                                           The Alberta College of Pharmacists will
                                                                                           benefit because the regulation of pharmacy
                                                                                           technicians helps fulfill two of the college’s
                                                                                           primary goals: protecting the public and
                                             counseling and follow-up.
                                                                                           optimizing the use of pharmacy
   If I do not qualify to register           Pharmacists will benefit because the
                                                                                           professionals’ skills.
   will I lose my job?                       work in the areas of prescription
                                             processing and preparation can shift          Unlike a professional association or
   ACP does not expect that all              from the pharmacist to the technician,        advocacy group which acts in the interest
   individuals currently working as          thereby allowing pharmacists to more          of its members, a professional college acts
   technicians will pursue registration.     appropriately use their skills and            in the interest of the public. The mandate
   Pharmacy licensees will not be            knowledge to deliver patient care.            of the Alberta College of Pharmacists
   required to hire a pharmacy               Pharmacists will be able to let go of         (ACP) is to protect the public’s health and
   technician. In fact, we anticipate that   some dispensing roles, knowing that           well-being. Therefore, ACP has a
   the process will be gradual and that      pharmacy technicians have met                 responsibility to ensure that only
   there will continue to be a variety of    educational standards and                     individuals who have the knowledge and
   viable pharmacy business models           demonstrated their competency.                who can demonstrate the required
   with and without regulated                                                              competencies be registered.
                                             Pharmacy technicians will benefit because
   technicians.
                                             by having met defined and recognized          By regulating pharmacy technicians,
   Can I still use the title pharmacy        standards for education and competency,       ACP can be assured – and can assure the
   technician if I don’t qualify for         they will have the knowledge, skills, legal   public - that these regulated individuals
   regulation?                               authority and confidence to practice more     have met national and provincial entry-
                                             independently and to take on more             to-practice standards and are competent
   No. Only individuals who are
                                             authority. While pharmacists will still be    to take on more responsibility within the
   registered on ACP’s pharmacy
                                             responsible for assessing the                 compounding and dispensing functions.
   technician register will be able to be
   called a pharmacy technician and
   only these regulated individuals will
   be permitted to practice unsupervised             Acronym Key
   and conduct the final quality
   assurance check on dispensed                  ACP           Alberta College of Pharmacists
   prescriptions.
                                                 CAPT AB       Alberta branch of the Canadian Association of Pharmacy
   Once the legislation has been                               Technicians
   enacted, will there be a pay scale
                                                 CCAPP         Canadian Council on the Accreditation of Pharmacy Programs
   that has to be followed?
                                                 CPTEA         Canadian Pharmacy Technician Educators Association
   ACP is not legally authorized to set
   pay scales or negotiate                       NAPRA         National Association of Pharmacy Regulatory Authorities
   reimbursement for pharmacists or              PEBC          Pharmacy Examining Board of Canada
   pharmacy technicians, so will not be
   entering into any reimbursement               PTCB          Pharmacy Technician Certification Board of Alberta
   discussions. ACP’s mandate is to                            (later known as PTeB)
   protect the public by setting and             PTeB          Pharmacy Technician Board of Canada
   enforcing high standards of
                                                 PTSA          Pharmacy Technician Society of Alberta
   competence and ethical conduct.


                                                                  2
Spring 2010                                    The TransitionTimes                                                         alberta college of pharmacists




Working toward regulation since 2003
For almost a decade, pharmacy technicians,     2007 The Pharmacy Technician                        responsibility, there has been national
pharmacists, and ACP have worked               Regulation Working Group was                        coordination to ensure that processes are
together to develop the framework for          established to develop a plan to achieve            similar and credentials are transferable
technician registration in Alberta.            technician regulation in Alberta.                   across the country.
 2003 A steering committee comprised of        n 4 appointees from ACP, 3 appointees               The diagram below summarizes other key
pharmacy technicians and pharmacy                from the Pharmacy Technician                      national initiatives in which pharmacists
technician educators was established by          Regulatory Committee of Alberta                   and pharmacy technicians have partnered
the Alberta branch of the Canadian
                                               n This group recommended that                       to facilitate technician regulation. All
Association of Pharmacy Technicians
                                                 pharmacy technicians in Alberta be                provinces pursuing technician regulation
(CAPT AB) and the Pharmacy Technician
                                                 regulated within the Alberta College of           are basing their programs on these
Certification Board of Alberta (PTCB, later
                                                 Pharmacists.                                      initiatives.
known as PTeB) to consider the merits of
self-governance of pharmacy technicians.        2008 ACP began accepting applications              In all cases there has been direct
 2005 The CAPT AB/PTCB steering                for the voluntary Pharmacy Technician               participation or consultation with
committee made a proposal for technician       Register. To date there are 975 pharmacy            pharmacy technicians or pharmacy
regulation to the provincial Minister of       technician members of ACP.                          technician educators from across Canada,
Health. At that time, the Minister indicated   While technician regulation is a provincial         including Alberta.
support for the idea, but said no new
professions would be recognized until all
of the current professions said were
recognized under the Health Professions Act.
 2006 Pharmacy technicians formed the
Pharmacy Technician Regulatory
Committee of Alberta. This committee                                                          1
was comprised of volunteers from                                                 Educational outcomes to support
CAPT Alberta and PTeB and other                                            the standardization of pharmacy technician
interested individuals.                                                       training programs were led by CPTEA.
                                                               A              These outcomes outline the essential
                                                            bridging             learning required by graduates at
                                                          program (four            entry-to-practice and provide
                                                        courses) to assist              consistent standards
                                                                                                                            Competency
                                                      in determining the              for pharmacy technician
                                                                                                                          Based Standards
                                               5    academic equivalence
                                                   of individuals who have
                                                                                        programs both inter-
                                                                                        and intra-provincially.
                                                                                                                        for Entry to Practice
                                                                                                                           development was
                                                  not graduated from                                                led by NAPRA. They were
                                                 accredited programs was                                            developed by technicians,
                                                 developed in Ontario through                                   regulators and representatives
                                                the leadership of the Ontario                                          from national pharmacy
                                                                                          Cooperative
                                                College of Pharmacists and                                         organizations and approved
                                                                                     national initiatives
                                                pharmacy technician
                                                candidates.                           toward pharmacy
                                                                                                                            by NAPRA’s Board of
                                                                                                                  Directors in November 2007.
                                                                                                                                                       2
                                                                                           technician                  This document outlines
                                                                                           regulation              the competencies required
                                                  Examinations for                                                  for pharmacy technicians
                                                   entry to practice                                                     to perform their role
                                                    are being led              The accreditation of technician                 in a regulated
                                               4     by PEBC.                  training programs is being led
                                                                           by CCAPP at the request of technician,
                                                                                                                              environment.

                                                                       technician educator and pharmacist groups.
                                                                           Accreditation standards are based on
                                                                            CPTEA’s Educational Outcomes and
                                                                         NAPRA’s Entry to Practice Competencies.
                                                                         CCAPP began accepting applications for
                                                                                accreditation and accrediting
                                                                                      programs in 2008.


                                                                                           3
                                                                3
Spring 2010                              The TransitionTimes                                                           alberta college of pharmacists




   Technician
   observers
   appointed to
   ACP council
   in 2008
   In 2008, the ACP council appointed
   two technician observers, Robin
                                        Technician
   Burns and Teresa Hennessey, from a
   list of nominations submitted by
   technicians. Robin and Teresa have
                                        scope of
   participated in all council
   discussions, particularly those
   related to the regulation of
   pharmacy technicians. They, and
                                        practice
   other ACP staff, have presented at
   many technician conferences and      The biggest changes resulting from the regulation of pharmacy technicians will not only be
   meetings. Robin and Teresa have      in the scope of their practice, but in the fact that technicians will become legally responsible
   also contributed input on the        and accountable for their work. Although practitioners feel a personal responsibility for the
   amendments to the Pharmacists        work they undertake now, this is different than the legal accountability and liability
   Profession Regulation and the        conferred with regulation.
   development of national fluency
                                        Some non-pharmacists may now be performing at higher levels than others in pharmacy
   requirements for pharmacy
                                        settings, but there is currently no regulatory process which holds them directly responsible to
   technicians at entry to practice.
                                        the public for their practice. Having mechanisms to ensure accountability is important to
                                        the public, the profession, and the college. The regulation of technicians will provide a
                                        greater degree of protection for the public as pharmacy technicians move to higher levels of
                                        responsibility (e.g., conducting restricted activities unsupervised and supervising others)
                                        and permit more effective use of the skills of pharmacists.

                                        What will a regulated pharmacy technician be able to do?
                                        Schedule 19 of the Health Professions Act (as proposed in the Health Professions Amendment
                                        Act) provides the following role statement for pharmacy technicians:
                                        In their practice, pharmacy technicians promote safe and effective drug distribution and, in relation to
                                        that, do one or more of the following under the direction of a pharmacist:
                                        a) receive, gather, enter and store prescription and patient information,
   Robin Burns                          b) store and repackage products,
                                        c) participate in the management of systems for drug distribution and inventory control,
                                        d) participate in the research, development, implementation and evaluation of quality assurance and
                                           risk management policies, procedures and activities,
                                        e) provide restricted activities authorized by the regulations,
                                        f) instruct patients about the use of health aids and devices, and
                                        g) teach the practice of pharmacy technicians.

                                        Subsection (e) refers to restricted activities. What are these?
                                        The amendments to the Pharmacists Profession Regulation propose that, under the
                                        direction of a clinical or courtesy pharmacist, a pharmacy technician be authorized to:
                                        a) dispense a Schedule 1 drug or Schedule 2 drug;
   Teresa Hennessey                     b) compound, provide for selling or sell a Schedule 1 drug or a Schedule 2 drug;
                                        c) compound blood products.

                                                                4
Spring 2010                                        The TransitionTimes                                                  alberta college of pharmacists




A pharmacy technician may only perform the restricted activity if:                                * Note the difference between direction
a) a pharmacist has evaluated the prescription for the drug,                                        and supervision.
b) a pharmacist has assessed the patient, the patient’s health history and medication record        Supervision is provided by the
   and has determined that the drug therapy is appropriate for the patient, and                     pharmacist on shift that day and that
c) a pharmacist is available to counsel the patient and to monitor the patient’s drug               pharmacist must be available to
   therapy.                                                                                         provide hands-on assistance, either
                                                                                                    immediately or within a reasonable
What does “under the direction of” mean?                                                            period of time.
For the purpose of this section, “under the direction of” means that the clinical pharmacist        Direction is provided by a pharmacist
or courtesy pharmacist who is providing the direction must                                          who works in the same pharmacy, but
a) practice at the same pharmacy* as the pharmacy technician, unless otherwise authorized           not necessarily on the same shift as the
   in writing by the Registrar,                                                                     technician. That pharmacist is
b) ensure there is a system in place in the pharmacy that complies with the Standards of            responsible for ensuring that there are
   Practice under which                                                                             appropriate policies and procedures in
   i)   a pharmacist is available to consult with, provide guidance to and, if necessary,           place to maintain the integrity of the
        provide assistance to the pharmacy technician,                                              dispensing and compounding
                                                                                                    processes and for making sure that a
   ii) the involvement of the pharmacy technician in the restricted activities can be
                                                                                                    pharmacist is available to work with
       monitored and assessed,
                                                                                                    the technician as required in the
   iii) the pharmacy technician reports to the pharmacist who is responsible for providing          regulations and the standards.
        direction to the pharmacy technician; and
c) be authorized to perform the restricted activities for which the pharmacist is providing
   direction to the pharmacy technician.



                        Role comparisons
                          Pharmacists will                              Pharmacy Technicians will (proposed)
              Roles       n assess patient                              n prepare and distribute prescriptions
                          n review patient history, medication          n compound
                            history                                     n sell
                          n ensure appropriate drug therapy             n check to ensure correct drug is dispensed
                          n counsel patient                             n copy prescriptions for authorized recipients
                          n monitor ongoing therapy                     n transfer prescriptions to, and receive prescriptions from, other
                          n provide direction to technician               pharmacies
                          (Pharmacists will continue to be              n receive and transcribe verbal prescriptions given by a prescriber
                          authorized to conduct all pharmacy            n instruct patients re: health aids and devices
                          technician roles.)                            n be authorized to check work of individuals employed in a
                                                                          pharmacy

Responsibilities          n continue to be accountable for the          n Always practice in an environment where:
                            overall supervision of pharmacies             • procedures are in place to ensure the safety and integrity of
                            and the systems that are in place               the dispensing or compounding process (i.e., under the
                            to ensure the safe storage,                     direction of a pharmacist).
                            compounding, packaging and                    • a pharmacist is available to ensure appropriateness
                            distribution of drugs.                          of drug therapy and consult with patients.
                          n continue to be solely responsible           n Exercise professional judgement at
                            and accountable for assessing the             all times and be able to recognize
                            appropriateness of drug therapy               when the clinical expertise
                            (both new and continuing) and                 of the pharmacist is
                            providing patient consultation.               required.
                            A prescription cannot be released
                            to the patient without a
                            pharmacist having performed
                            these functions.


                                                                        5
Spring 2010                                                              The TransitionTimes                                                                                    alberta college of pharmacists




                                                                                         Steps to regulation
                                                                                         All provincial bodies pursuing technician regulation have agreed that
                                                                                         requirements for pharmacy technicians will parallel the process for
                                                                                         pharmacists where possible and will be in keeping with the Agreement on
                                                                                         Internal Trade. Adhering to the Agreement means technician qualifications
                                                                                         will be recognized across the country. This will enable pharmacy technicians
                                                                                         to work anywhere in Canada without having to re-qualify.
                                                                                         To become a regulated pharmacy technician, individuals currently working
                                                                                         in the field as well as those just entering the profession will need to
                                                                                         successfully complete the required steps outlined below.




Technician Regulation Process

                                                Path 1: Transition                                                      Path 2: New entries
                                                                       m                                                                           m
                                            2000 hours worked in past 3 years                                                      Graduate from
                 Step 1                                    OR                                                                 CCAPP accredited program                                            Step 1
                                            Currently on ACP voluntary register                                                   (available now)

                                                                       m                                                                           m
                                                  PEBC Evaluating Exam                                                              Complete structured
                                                (or PTCB-AB or OCP exam)                                                             practical training
                                            Note: Must complete by Jan. 1, 2013                                                            (SPT)
                 Step 2                                                                                                                                                                           Step 2
Expires 2015




                                                    Bridging Program
                                                Completion of all 4 courses
                                                            OR                                                                    Jurisprudence/Ethics
                                             Professional Practice course* and                                                            Exam
                                             challenge exam in other 3 courses                                                        (through ACP)
                                                   * includes jurisprudence/ethics exam

                                                                                          m                                      m
                                                                                            PEBC Qualifying Exam
                                                       Step 3 †                              (written and practical)
                                                                                                                                                            Step 3 †

                                                                                                             m
                                                       Step 4                               Registration with ACP                                           Step 4




† Although PEBC does not require individuals to have successfully completed all four bridging courses (Path 1) or all three levels of SPT (Path 2) before sitting the Qualifying Exam, both PEBC and ACP strongly
  recommend this step. The extra knowledge and resource information attained will help candidates achieve success on the Qualifying Exam.

                                                                                                       6
Spring 2010                                                           The TransitionTimes                                                                                 alberta college of pharmacists




Steps to Regulation
Path 1: Transition
Individuals already working in the field
who did not graduate from a CCAPP-                                                                                       Path 1: Transition
accredited program will have until Jan. 1,
2015 to register via Path 1. After that time,                                                                                                   m
anyone wishing to become regulated will
have to take Path 2 and successfully                                                                                  2000 hours worked in past 3 years
complete a pharmacy technician program                                                     Step 1                                    OR
offered through a CCAPP-accredited                                                                                    Currently on ACP voluntary register
institution.
                                                                                                                                                m
 STEP 1       Meet Minimum Criteria
                                                                                                                           PEBC Evaluating Exam
To enter the process, a current                                                                                          (or PTCB-AB or OCP exam)
technician must either be on ACP’s
                                                                                                                     Note: Must complete by Jan. 1, 2013
voluntary register or have worked in
pharmacy practice for a minimum of 2000                                                    Step 2
                                                                          Expires 2015




hours in the past 3 years. Specific duties                                                                                    Bridging Program
defined as pharmacy practice are                                                                                          Completion of all 4 courses
identified on the Pharmacy Examining                                                                                                  OR
Board of Canada (PEBC) website at                                                                                      Professional Practice course* and
www.pebc.ca (Note: if a current technician                                                                             challenge exam in other 3 courses
does not meet the minimum criteria, they                                                                                    * includes jurisprudence/ethics exam
would seek regulation through Path 2 by
enrolling in an accredited pharmacy                                                                                                            m
technician program.)
                                                                                                                               PEBC Qualifying Exam
                                                                                           Step 3 †                             (written and practical)
 STEP 2PEBC Evaluating Exam and
ACP Bridging Program
                                                                                                                                               m
Contrary to some other provinces that
require candidates to complete the PEBC                                                    Step 4                              Registration with ACP
Evaluating Exam prior to enrolling in
bridging courses, ACP is letting candidates
complete these in any order. ACP’s goal is
to provide as much flexibility as possible
for each candidate to meet the                                       key locations across Canada. More details                             approved education program. Until
requirements.                                                        on the Evaluating Exam, including the                                 CCAPP accreditation in 2008, there was no
                                                                     exam sitting schedule, are available at                               system to ensure consistency across
The completion of both the PEBC
                                                                     www.pebc.ca.                                                          education programs, and no standard
Evaluating Exam and the ACP Bridging
                                                                     Note: Path 1 candidates must complete the                             requirement for an individual choosing to
Program is required1 by all individuals
                                                                     PEBC Evaluating Exam by Jan. 1, 2013.                                 become a pharmacy technician. As a result,
seeking regulation via Path 1. (Note: the only
                                                                                                                                           there is a high degree of diversity among
exception, as per PEBC’s policy, is that those                       The bridging program is designed to                                   those choosing to become regulated
who successfully completed the PTCB-AB (up                           prepare individuals for their role as                                 pharmacy technicians. Their knowledge
to 2008) or OCP (up to 2008) exam do not need                        regulated health professionals, including                             and skills, and roles and practice settings
to sit the PEBC Evaluating Exam. They are still                      the additional responsibilities described in                          differ. This poses a challenge; as a
required to complete the bridging program.)                          the entry-to-practice competencies for a                              regulatory body, ACP needs to ensure that
The PEBC Evaluating Exam is a 3 hour, 150                            pharmacy technician.                                                  individuals applying for registration have
multiple choice question exam. The exam is                           One of the most essential requirements for                            demonstrated the defined competencies to
offered by the PEBC two times per year in                            entry to practice is completion of an                                                                      continued on page 8



1 Where candidates have not graduated from a CCAPP-accredited education program, PEBC requires that candidates also successfully pass an Evaluating Exam. This is not an ACP policy, but rather a PEBC
  policy consistent for both pharmacist and PT candidates.

† Although PEBC does not require individuals to have successfully completed all four bridging courses before sitting the Qualifying Exam, both PEBC and ACP strongly recommend this step.

                                                                                                    7
Spring 2010   The TransitionTimes                                                    alberta college of pharmacists




              Path 1: Transition continued from page 7            communication skills. Students will
                                                                  enhance their ability to practice
              practice safely and effectively within the          competently within the professional
              scope of their profession.                          practice framework. To minimize
              Because of the diversity amongst                    learners’ costs and time, APC has
              individuals and the absence of previous             incorporated the jurisprudence exam as
              educational standards and measures, the             part of this course, rather then a
              college is incorporating a bridging                 separate element.
              education program that will prepare
              individuals to practice in the new regulated     n Management of Drug Distribution
              role. Building on the knowledge these              (39 hours)
              individuals have gained through formal              This course will examine various drug
              education or on-the-job training, this              distribution systems in pharmacy
              bridging program will prepare them to               practice, and prepare learners to
              meet the educational requirements and               effectively manage operations in
              responsibilities of a regulated pharmacy            different practice settings to ensure safe
              technician.                                         and effective drug supply and
              The bridging program is divided into four           distribution. Learners will explore
              courses: Pharmacology, Professional                 distributive functions in institutional
              Practice, Management of Drug Distribution           settings, as well as common drug plans
              Systems, and Product Preparation. The               and their formularies, adjudication
              content is being developed nationally and           challenges, inventory management
              then modified as required for each                  elements and common business
              province.                                           practices. Accurate product release
                                                                  within the parameters of the pharmacy
              Technicians who feel that they already
                                                                  technician role receives special
              have the necessary knowledge, skills, and
                                                                  emphasis.
              abilities to challenge a particular bridging
              course may do so through an exam process         n Product Preparation (33 hours)
              referred to as Prior Learning Assessment
                                                                  This course deals with the theoretical
              and Recognition (PLAR). The PLAR option
                                                                  knowledge and practical skills
              was incorporated so technicians who are
                                                                  essential for safe and accurate
              confident in their skills can “fast track”
                                                                  preparation of sterile and non-sterile
              bridging. All bridging courses, with the
                                                                  pharmaceutical products. For non-
              exception of the Professional Practice
                                                                  sterile preparation, students will focus
              module which is mandatory for everyone
                                                                  on compounding practices for various
              in Path 1, are PLAR-eligible.
                                                                  internal and external preparations and
              n Pharmacology (33 hours)                           specialty dosage forms, equipment
                                                                  and tools, professional guidelines,
                 This course provides a practical, applied
                                                                  standards and legislation,
                 approach to pharmacology. Through a
                                                                  pharmaceutical calculations, and
                 variety of learning tools such as
                                                                  documentation requirements. For
                 assignments, quizzes, case studies and
                                                                  sterile product preparation, areas of
                 group work, students will enhance their
                                                                  emphasis include infection control,
                 ability to practice competently and
                                                                  aseptic technique, parenteral dosage
                 contribute to a safe patient care setting.
                                                                  forms, accurate calculations,
                 Participants will gain basic knowledge
                                                                  appropriate use of equipment, and
                 related to the pharmacological uses of
                                                                  quality control. Best practices
                 drugs within a variety of commonly
                                                                  associated with the preparation of
                 encountered medical conditions.
                                                                  Total Parenteral Nutrition (TPN) and
              n Professional Practice (45 hours) –                antineoplastics are also covered.
                mandatory, no PLAR                             ACP is working with three publicly
                 Students will be prepared for entry to        funded colleges to offer the bridging
                 practice in five main areas of focus: legal   program. Each course will be offered
                 requirements, scope of practice, ethical      online as well as in classroom. Each of
                 principles, professionalism and
                                                                                           continued on page 10


                                    8
Spring 2010                                         The TransitionTimes                                            alberta college of pharmacists




     FAQs
                                                              re: process for individuals
                                                              who did not graduate from a
                                                              CCAPP-accredited program

       Overall process
       Why was Jan. 1, 2015 picked as the end date
       for current technician transition? Is that still
       feasible given that bridging hasn’t started
       yet?
       A deadline was required that allowed enough time for
       individuals currently working in the field to complete
       transition without a great deal of pressure, but that sent
       a clear message that those entering the field today are
       expected to attend an accredited program rather than
       attempt to begin working in the field. This date is
       consistent with the date that other provinces are using.
       Availability of the bridging courses has been delayed,
       but is expected by fall 2010. That will still allow more
       than four years to complete the transition.                      How do I know the bridging program is
                                                                        of value?
       If the deadline for transition is Jan. 1, 2015,                  All four bridging courses have now been delivered twice
       why does the PEBC Evaluating Exam have to                        in Ontario. Participant evaluations show that 81% of
       be completed by Jan. 1, 2013?                                    learners felt the courses met their learning needs.
       The transition pathway (Path 1) is intended for                  Furthermore, 83% of learners felt that the participant
       individuals who are now working in the field. The                materials provided with the course were useful.
       deadline to complete the Evaluating Exam was set to
       clearly indicate to individuals who are entering the field       Why must technicians be evaluated more
       now that they must attend an accredited program and              than once on the same subject matter
       qualify via Path 2. In addition, completion of the               (e.g., through bridging and/or PLAR and
       Evaluating Exam by Jan. 1, 2013 ensures individuals              PEBC exams)?
       working toward regulation via Path 1 will have time to
                                                                        Bridging is not an evaluation mechanism, but a process to
       complete all the requirements by 2015.
                                                                        supplement the knowledge gained through formal
                                                                        education and on-the-job training with the competencies
       Will individuals in other provinces be able to                   that will be required to take on the role and
       write the PEBC Qualifying Exam and become                        responsibilities of a regulated pharmacy technician.
       a regulated technician (in Alberta or
                                                                        The requirement to take both the Evaluating and
       elsewhere) without taking the bridging                           Qualifying Examinations is a PEBC requirement,
       program?                                                         consistent with their requirement for pharmacists. PEBC
       All provinces currently pursing technician regulation            is making one exception in their process: anyone who
       require completion of a bridging program. At present             successfully completed PTCB-AB (up to 2008) or OCP (up
       that, includes Ontario, BC, Alberta, Saskatchewan and            to 2008) exam is exempt from writing the Evaluating
       Nova Scotia.                                                     Exam. This will minimize time and costs for candidates.




                                                                    9
Spring 2010                                      The TransitionTimes                                                  alberta college of pharmacists




Path 1: Transition continued from page 8

the four courses is in various stages of
development and modification and the              PEBC Examinations
anticipated rollout is September 2010.
Course information will be posted on the          for technicians
ACP website as it becomes available.
                                                  If I passed the PTCB exam several years ago but did not recertify
Costs and grant information                       with PTCB, will I have to write the PTCB exam again?
Final course costs will be determined by          No. Anyone who successfully completed the PTCB exam is able to write the
the colleges delivering them. It is               Qualifying Exam without writing the Evaluating Exam. (You will still be required
estimated that the cost to complete all           to complete the bridging program.)
four courses of the program will be
approximately $1400.00. The cost of the           What type of work “counts” toward the 2000 hours of work
PLAR process is not yet known; however,           experience listed in Path 1?
it is expected to be approximately half the       The PEBC website includes a list of duties that qualify for the 2000 hours of work
cost of completing the full module.               experience. It does not matter what your job title is as long as you have been
ACP has requested that Alberta Health             completing duties that are included on the list for at least 2000 hours in the past 3
and Wellness provide a grant to                   years.
reimburse candidates for at least a
portion of the registration costs for the         If I am currently voluntarily registered with ACP, do I still need to
bridging courses.                                 submit 2000 hours of work experience to be able to take the PEBC
                                                  evaluating exam?
 STEP 3       PEBC Qualifying Exam
                                                  Yes. PEBC will require information about your work experience when you register
The PEBC Qualifying Exam consists of
                                                  to write the Evaluating Exam.
two parts – a written multiple choice
question exam (MCQ) and a                         When will the exams be available?
performance-based exam called an
                                                  The next Evaluating Exam (which must be completed before the Qualifying
Objective Structured Performance Exam
                                                  Exam) will be offered on Sept. 18. The application deadline is June 28.
(OSPE). PEBC is expected to offer the
exam nationally at key locations twice            The next Qualifying Exam will be offered
a year.                                           on Aug. 28 and 29. The application
                                                  deadline is June 4. See the PEBC website
Note: Although PEBC does not require
                                                  (www.pebc.ca) for the most current
individuals to have successfully completed all
                                                  exam schedule.
four bridging courses before sitting the
Qualifying Exam, both PEBC and ACP                What happens if I write the
strongly recommend this step. The extra           Qualifying Exam and do
knowledge and resource information attained
                                                  not pass?
from the bridging courses will help candidates
achieve success on the Qualifying Exam.           As with pharmacists, pharmacy
                                                  technicians may attempt the
 STEP 4       Register with ACP                   PEBC Qualifying Exam three
                                                  times. The ACP Registrar has
Other requirements at entry to practice
                                                  the option to permit a fourth
such as fluency, good character,
                                                  attempt, but may require the
professional liability insurance, product
                                                  applicant to complete
release proficiency, and registration and
                                                  coursework, examinations
annual permit fees will be established by
                                                  and structured practical
ACP council to coordinate with the
                                                  training before the fourth
amendments to the Pharmacists
                                                  and final attempt.
Profession Regulation (see pages 14 and
15 for details).
All registration requirements are
consistent with those for pharmacists and
other regulated health professionals
governed by the Health Professions Act.



                                                                  10
Spring 2010                                        The TransitionTimes                                                   alberta college of pharmacists




Why wouldn’t grandfathering
current pharmacy technicians be wise?
An accelerated regulation process for              Throughout the planning, council has            Grandfathering those with formal
pharmacy technicians sounds appealing at           always sought to minimize time and costs        education
first. However, there are many reasons why         to participants while still protecting the      There was no standardization of education
ACP council decided against                        public. This is demonstrated through:           programs prior to the development of
grandfathering current technicians.                n the option for when candidates may            CPTEA educational outcomes and the
1. To date there has been no standardized            write the PEBC Evaluating Exam,               resulting CCAPP accreditation standards.
   education, scope of practice, role              n ACP’s work to ensure the bridging             Therefore, programs offered very different
   definition, restricted title, or legal            courses will be offered in class and          levels of knowledge and practical
   responsibility for individuals identified         online from multiple colleges,                experience. It is impossible to evaluate and
   as pharmacy technicians. The result is a                                                        compare programs that were delivered in
                                                   n the incorporation of the jurisprudence
   very mixed population of “technicians.”                                                         the past, in some cases many years ago, so
                                                     exam into the Professional Practice
   ACP respects that, amongst these, some                                                          a fair assessment can not be made. Because
                                                     course,
   individuals do perform at higher levels                                                         there have been no requirements for
   than others as a result of their education      n the PLAR option in bridging, and              continuing education, the college also can’t
   and experience. However, without the            n ACP ’s pursuit of government funding          know if individuals maintained all the
   proposed process, the college currently           to offset bridging program costs for          knowledge and skills required of
   has no way to measure the competence              technicians.                                  pharmacy technicians. Additionally,
   of pharmacy technicians and thus                                                                graduates of each program have different
                                                   ACP council believes that the proposed
   cannot assure patients, technician peers,                                                       practice experiences since graduating,
                                                   framework for pharmacy technician
   pharmacists, other health professionals,                                                        depending on their employment.
                                                   candidates to transition to regulated health
   and the public of their competency.
                                                   professionals appropriately balances            Applying conditions on the title or
2. Pharmacy technicians have no history            accountability, accessibility, and              having two levels of technicians
   of being regulated, contrary to other           affordability.
   professions that are becoming self-                                                             The Health Professions Act outlines one
                                                   ACP’s approach to evaluating pharmacy           scope of practice for a pharmacy technician
   regulated under the Health Professions          technician candidates at entry to practice is
   Act. Pharmacy technicians will be a new                                                         and all national documents, including
                                                   consistent with that being pursued by
   regulated profession.                                                                           entry to practice competencies and
                                                   other provinces and with the processes
                                                                                                   educational outcomes, describe a single
3. Pharmacy technicians have had no                established under the Health Professions Act,
                                                                                                   group of competencies for a pharmacy
   requirement to maintain personal                as used in evaluating pharmacists at entry
                                                                                                   technician. Individuals who wish to qualify
   competence, regardless of how they              to practice.
                                                                                                   as a pharmacy technician must
   have gathered knowledge and skills to
                                                   What grandfathering alternatives                demonstrate all the required competencies.
   perform their roles. Therefore, ACP has
   no means of ascertaining the                    were considered?                                Keep in mind that the regulation of
   maintenance or growth of an                     Extending the recognition date for              pharmacy technicians does not preclude
   individual’s knowledge and skills               those graduating from now-accredited            pharmacists from hiring unregulated
   during the period of their past practice.       programs                                        persons to work in the pharmacy. A
                                                   Recognizing those who graduated from a          pharmacist may hire whomever they wish
4. Pharmacy technicians have only been
                                                   CCAPP-accredited program for a set              to assist them as long as the pharmacist
   authorized to practice under
                                                   number of years before accreditation was        provides direct supervision and takes
   supervision, and have held no legal
   responsibility, accountability, or shared       considered by ACP council. For example,         responsibility for the work completed by
   in any potential liability when                 although Red Deer College’s program was         the unregulated individuals.
   providing this assistance.                      only accredited in 2009, recognition could
                                                                                                   Grandfathering individuals already on
                                                   have been extended to those who
The competencies for entry to practice                                                             the ACP voluntary register
                                                   graduated two, five, or eight years earlier.
cannot be measured through a single                                                                The voluntary register established in 2008
                                                   However, council realized that it was
examination or by a single evaluation tool.                                                        was always intended to be an interim step
                                                   impossible to know how educational
Grandfathering alternatives are at the best        programs had changed over the years,            toward the regulation of pharmacy
subjective and introduce an unacceptable           and thus to know how many years was             technicians. All candidates were informed
level of risk; it is not possible to objectively   enough or too many. A line had to be            that registration on the voluntary register
identify programs or cut-off dates that            drawn at some point; council decided that       would not imply eligibility as a regulated
would provide confidence to ACP or                 CCAPP accreditation was the best place to       technician because additional evaluation
fairness to all candidates.                        draw the line.                                  would be required.

                                                                        11
Spring 2010                                                            The TransitionTimes                                                                                alberta college of pharmacists




Steps to Regulation
Path 2: New entries
 STEP 1 CCAPP-Accredited
Program                                                                                           Path 2: New entries
An accredited program is a program of
study offered by either a public or                                                                                         m
private post-secondary institute that has                                                                     Graduate from
met the accreditation standards for a                                                                    CCAPP accredited program                                         Step 1
pharmacy technician program
                                                                                                             (available now)
established by the Canadian Council for
Accreditation of Pharmacy Programs                                                                                          m
(CCAPP). The CCAPP accreditation
process ensures that accredited                                                                               Complete structured
programs contain the necessary content                                                                         practical training
to teach the competencies (knowledge,                                                                                (SPT)
skills and abilities) necessary for                                                                                                                                       Step 2
successful graduates to safely and
effectively do the job of a regulated                                                                        Jurisprudence/Ethics
pharmacy technician.
                                                                                                                     Exam
In Alberta, four colleges began offering                                                                         (through ACP)
CCAPP-accredited Pharmacy
Technician programs: NorQuest College
in 2008, and Red Deer College, Bow                                                                                           m
Valley College, and CDI (Edmonton)
in 2009.                                                                                                    PEBC Qualifying Exam
                                                                                                             (written and practical)                                      Step 3 †
The CCAPP-accredited programs are a
minimum duration of 34 weeks and                                                                                             m
consist of a minimum of 26 weeks
instruction (25 hours/week in class or                                                                      Registration with ACP                                         Step 4
lab; 5 days/week), and 8 weeks of
practicum experience (35 hours/week;
7 hours/day). The program curriculum
covers the same broad content areas as
found in the bridging program required                               based training period within a                                            level is the provision of drug
for current technicians:                                             pharmacy that includes regular                                            distribution. This level may be
                                                                     assessment by a pharmacist or another                                     completed as part of an individual’s
n Pharmacology
                                                                     regulated technician. This training                                       program practicum.
n Professional Practice                                              allows soon-to-be-regulated technicians
                                                                                                                                           Level II – minimum 320 hours*
n Management of Drug Distribution                                    the opportunity to practice their skills in
                                                                     a supervised practical environment                                    n The learner is required to
n Product Preparation                                                                                                                        demonstrate competencies
                                                                     before assuming sole responsibility. 
                                                                                                                                             proficiently. Expectations regarding
 STEP 2 Structured Practical                                         The Alberta College of Pharmacists’                                     the demonstration of professionalism
Training (SPT) and                                                   pharmacy technician SPT program is                                      and management knowledge and
Jurisprudence/Ethics Exam                                            divided into three levels:                                              skills, and quality assurance are
Once a student has graduated from a                                                                                                          increased.
                                                                     Level 1 – minimum 320 hours*
CCAPP-accredited program, they will
be required to successfully complete a                               n The learner is required to acquire                                  Level III – minimum 160 hours*
Structured Practical Training (SPT)                                    and/or demonstrate competencies at                                  n Level III is intended to confirm
program2; a supervised competency-                                     an acceptable level. The focus of this                                proficiency. Learners are expected to


2 S3(1)(b) Pharmacists Profession Regulation

† Although PEBC does not require individuals to have successfully completed all three levels of SPT before sitting the Qualifying Exam, both PEBC and ACP strongly recommend this step.

                                                                                                   12
Spring 2010                                 The TransitionTimes                                               alberta college of pharmacists




   work independently, acting as a
   pharmacy technician,
n Successful completion of Level III
  requires demonstration of
  proficiency of product release,
  specifically ensuring the accuracy
  and quality of the final product.
* The hours listed are minimums.
  Successful completion of each level
  requires demonstration of the required
  competencies; additional time may be
                                              Education
                                             FAQs
  required to do so.

Jurisprudence/Ethics Exam
The requirement to successfully
complete a jurisprudence/ethics exam
is consistent with the registration
process for pharmacists and is designed
to test relevant provincial legislation
and ethics which is not included on the
national PEBC Qualifying Exam.
                                             Who determines which post-secondary programs are accredited?
                                             The Canadian Council for Accreditation of Pharmacy Programs (CCAPP), which
 STEP 3       PEBC Qualifying Exam           is the same organization that accredits pharmacy programs, is responsible for
The PEBC Qualifying Exam consists of         accrediting pharmacy technician programs in Canada. A committee with
two parts – a written multiple choice        representatives from pharmacy technician, technician educator, and pharmacist
question exam (MCQ) and a                    groups developed the accreditation standards.
performance-based exam called an             The accreditation process ensures that accredited programs contain the necessary
Objective Structured Performance             content to teach the competencies (knowledge, skills and abilities) necessary for
Exam (OSPE). PEBC is expected to             successful graduates to safely and effectively do the job of a regulated pharmacy
offer the exam nationally at key             technician.
locations twice a year.

 STEP 4       Register with ACP              Which post-secondary institutions are currently offering a
Other requirements at entry to practice
                                             CCAPP-accredited Pharmacy Technician program?
such as fluency, good character,             Please check the CCAPP website for the list of Accredited Pharmacy Technician
professional liability insurance, and        Programs: www.ccapp-accredit.ca/documents.
registration and annual permit fees will
be established by ACP council to             Will regulated pharmacy technicians be required to complete
coordinate with the amendments to the
                                             continuing education?
Pharmacists Profession Regulation (see
pages 14 and 15 for details).                Yes. Registrants on the pharmacy technician register must earn a minimum of 15
                                             continuing education units (CEUs) per year (1 hour of learning is equivalent to 1
All registration requirements are
                                             unit). These credits may be earned either from accredited pharmacy continuing
consistent with those for pharmacists and
                                             education or non-accredited learning or a combination of the two.
other regulated health professionals
governed by the Health Professions Act.      Continuing competence program requirements will be developed by the ACP
                                             Competence Committee and pharmacy technician representatives.




                                                             13
Spring 2010                                         The TransitionTimes                                                    alberta college of pharmacists




   Resources
   Note: The inclusion of a resource on this list
   does not imply any endorsement by ACP.

   Associations, Organizations
   and Licensing Boards
   n Alberta College of Pharmacists –
     pharmacists.ab.ca
   n American Association of
     Pharmacy Technicians –
     www.pharmacytechnician.com
                                                    Registering
   n Canadian Association of Pharmacy
     Technicians – www.capt.ca
   n Canadian Council for Accreditation
                                                    with ACP
     of Pharmacy Programs –
     www.ccapp-accredit.ca/index.php
   n Canadian Pharmacy Technician                   Creation of new registers                       Proof of English fluency
     Educators Association –                        Upon approval of the regulation, ACP will       For Path 1: Candidates who have not
     www.cptea.ca                                                                                   graduated from a high school, university,
                                                    create a provisional register for those
   n National Association of Pharmacy               working toward registration, a pharmacy         community college, private vocational
     Regulatory Authorities –                                                                       college or equivalent in Canada or the
                                                    technician register for those who have met
     www.napra.org                                                                                  United States, must provide evidence of
                                                    the registration requirements, and a
   n Pharmacy Examining Board of                                                                    fluency by submitting the results of a
                                                    courtesy register for individuals registered
     Canada – www.pebc.ca                                                                           NAPRA-recognized English language
                                                    as pharmacy technicians in good standing
   n Pharmacy Technician Educators                                                                  fluency test completed within the past two
                                                    in another jurisdiction and who require
     Council – www.rxptec.org                                                                       years.
                                                    registration in Alberta on a temporary basis
   n Pharmacy Technician Society of
                                                    for locum work or accredited CE provision.      For Path 2: Candidates educated outside of
     Alberta –
     www.pharmacytechnicians.ab.ca                  Registration on the provisional register will   North America must provide proof of
                                                    be open to:                                     English language fluency using any one of
   Useful Links                                                                                     the tests approved by ACP council. (See
                                                    n graduates of CCAPP-accredited
   n Moving Forward - Pharmacy Human                                                                https://pharmacists.ab.ca/nCollege/
                                                      pharmacy technician programs, or
     Resources for the Future –                                                                     resource.aspx?id=6744 for details.)
     www.pharmacyhr.ca/index.html                   n candidates on the ACP voluntary
                                                      register, or                                  Demonstration of good character
   n Canadian Healthcare Network
                                                                                                    For the purposes of demonstrating good
     (formerly Pharmacy Gateway) –                  n candidates enrolled in bridging
     www.canadianhealthcarenetwork.ca                                                               character and reputation, applicants must
                                                      programs, or
                                                                                                    provide:
   Documents                                        n candidates who successfully completed
                                                                                                    n a statutory declaration indicating
                                                      the PEBC Evaluating Exam (or PTCB-
   n Agreement on Internal Trade                                                                       • whether they are undergoing
     www.ic.gc.ca/eic/site/ait-aci.nsf/               AB or OCP exam), or
                                                                                                         investigation or discipline or have
     eng/home                                       n candidates who have 2000 hours
                                                                                                         been previously disciplined by a
   n Educational Outcomes for Pharmacy                worked in the last 3 years.                        professional college, and
     Technician Programs in Canada
                                                    Individuals currently on ACP’s voluntary           • whether they have pleaded guilty or
     www.cptea.ca/private_pgs/Educatio
                                                    register will be eligible to move                    been found guilty of a criminal
     nal OutcomesMar2007.pdf
                                                    immediately to the provisional register, but         offence for which they have not been
   n Professional Competencies for
                                                    must apply to do so. The application                 pardoned
     Canadian Pharmacy Technicians at
                                                    process will be introduced once the
     Entry-to-Practice                                                                              n a criminal records check current within
     www.napra.org/Content_Files/Files              legislation is proclaimed.
                                                                                                      six months of application.
     /Professional_Competencies_for_
     Canadian_Pharmacy_Technicians                  Registration requirements for                   Proof of citizenship
     2007.pdf                                       pharmacy technicians                            Applicants must provide evidence in the
   n Standards for Accreditation of                 In addition to completing the steps to          form of a Canadian birth certificate or
     Pharmacy Technician Programs                   regulation already described, pharmacy          passport or a valid Canadian employment
     www.ccapp-accredit.ca/standards                technicians will be required to provide the     visa that they are a Canadian citizen or are
                                                    following:                                      entitled to work in Canada.

                                                                         14
Spring 2010                                        The TransitionTimes                                                             alberta college of pharmacists




Liability insurance                               there be a demonstrated proficiency in                managing the registration process, ACP
Registrants on the pharmacy technician            completing the final check for product                will also:
register must maintain a minimum of               release. Therefore, council has directed
                                                                                                        n manage the continuing competence
$1 million of personal malpractice                that individuals applying for registration
                                                                                                          process for technicians,
insurance (claims made or occurrence). The        must demonstrate this proficiency by
policy must be in the technician’s name.          completing 100 final checks with 100%                 n manage the complaints resolution
                                                  accuracy, with a minimum of 20 checks a                 processes for technicians,
We anticipate that liability insurance for
technicians will be available from a              day within three months. Individuals                  n organize the election of pharmacy
variety of vendors. For example, PTSA is          who have successfully completed the                     technician members to ACP council,
finalizing details for one option and will        Alberta Health Services checking
                                                                                                        n maintain and make available the
have program specifics soon.                      verification may instead submit that as
                                                                                                          jurisprudence exam for technician
                                                  proof of proficiency.
                                                                                                          candidates,
Demonstrated product release                      Path 2 candidates will demonstrate this
proficiency                                                                                             n make college publications available to
                                                  proficiency in their structured practical
                                                  training.                                               technicians, and
Individuals with the practice experience
required for Path 1 have been exempted                                                                  n liaise with government and other
from the structured practical training            Registration fees                                       stakeholders concerned with practice
portion that is included in Path 2, but           ACP will create and manage the register                 and patient safety issues on behalf of
ACP council felt it was important that            for pharmacy technicians. In addition to                pharmacy technicians.

ACP council has established the following 2011 fee schedule for pharmacy technicians:
 Fee Name                   Amount   Formula used             Rationale                        When it applies
 Technician                 $250     Same as pharmacist       Same work involved in            First time registration with ACP.
 registration fee                    registration fee         registering regulated            Those who have already paid to join the voluntary
                                                              technician as a pharmacist;      register will not be charged this fee when they are
                                                              therefore, should be equal.      moved to the provisional register.
                                                              Voluntary technicians are
                                                              currently paying $234 for
                                                              registration.
 Provisional Register       $80      $78 (current voluntary   This equates to current          When registering as a provisional technician until all
 permit fee                          technician permit fee)   voluntary register fee.          conditions have been met to register as a regulated
                                     + 2% cost of living                                       technician.
                                     allowance (COLA)
 Regulated technician       $450     $735 (pharmacist         Calculated as 60% of the         When registering on the pharmacy technician register.
 practice permit fee 2011            permit fee) + 2% COLA    pharmacist permit fee.
                                     x 60%
 Pro-rated regulated        $248     $450 annual fee x 50%    This calculation is consistent   When a provisional technician or locum technician is
 technician practice                 + 10% for admin costs    with what is used for the        changing status to a regulated technician and is a first-
 permit fee 2011                                              pharmacist pro-rated fee.        time registrant as a regulated technician is joining ACP
                                                                                               between July 1, 2011 and Dec 31, 2011.
 Non-compliance fee         $77      $75 (current non-        There is the same amount of      Dec 1, 2011- Dec 31, 2011 for technicians who do not
                                     compliance fee for       work and costs involved for      meet the payment or submission requirements prior to
                                     pharmacists)             non-compliant technicians as     the end of the renewal period.
                                     + 2% COLA                for pharmacists.
 Reinstatement fee          $250     $245 (current            There is the same amount of      If a cancelled (cancelled for non-renewal, discipline or
                                     pharmacist               work and costs involved for      other reasons) or suspended technician is reinstating to a
                                     reinstatement fee)       reinstating a technician as      regulated technician.
                                     + 2% COLA                there is for a pharmacist.
 Jurisprudence Exam fee     $139     $136 (current            The exam will cost ACP the       If a provisional registrant fails the first attempt of the
 (re-challenge or                    pharmacist exam fee) +   same whether it is a             exam, the fee will be charged for all subsequent attempts.
 reinstatement)                      2% COLA                  pharmacist or technician         If a reinstating regulated technician has been away from
                                                              writing.                         practice for 2 years or more, they must pay to write the
                                                                                               exam.

 Courtesy register/ locum   $248     $450 x 50% + 10%         Based on same formula used       When registering as a courtesy pharmacy technician to
 permit                              admin                    for pharmacist locum fee.        practice temporarily in Alberta (locum) or to provide CE.


                                                                          15
Spring 2010                                    The TransitionTimes                                                 alberta college of pharmacists




                                                    Next
                                                    steps

Amend the Pharmacists                         by-laws to accommodate the election of         circulate information via our website
Profession Regulation                         voting pharmacy technician members to          (pharmacists.ab.ca), The Link (our e-
                                              the council.                                   newsletter), emails to registrants, and
ACP and technicians have worked together
with government to draft the amendments                                                      acpnews (our quarterly newsletter).
                                              Read, listen, ponder, and
necessary to the Pharmacists Profession                                                      We will also work with PTSA
                                              participate
Regulation for technician regulation. A                                                      (www.pharmacytechnicians.ab.ca) to
consultation on the amendments will be        ACP is looking forward to the                  distribute information to technicians.
conducted by Alberta Health and Wellness      consultations and to receiving your
                                                                                             If you have questions or would like to
this summer. Once the amendments are          feedback. Only through the input and
                                                                                             comment on any of the information in this
approved, an effective date for the           participation of all parties can we ensure
                                              we’ve explored all the possibilities and       newsletter, please email us at
Regulation will be set and technician
                                              ended up with the best process for creating    acpinfo@pharmacists.ab.ca.
regulation in Alberta can begin.
                                              this new profession.
                                                                                             Stay tuned
Amend the Standards of Practice
                                              How do you participate in the                  Technician regulation is an evolving
ACP, again with technician input, has
                                              consultations?                                 process. To keep up to date, look to the
drafted amended Standards of Practice to
accommodate regulated technicians. ACP        Alberta Health and Wellness is conducting      Pharmacy Technician Information link in the
will conduct a consultation on these          the consultation on the amendments to the      Bulletin Board section of the ACP website
amendments this summer.                       Pharmacists Profession Regulation. They        and The Link, ACP’s e-newsletter,
                                              will be using all channels available to them   delivered every two weeks. (Note that
Amend ACP by-laws                             to solicit your feedback.                      archived editions of The Link are available
ACP will be circulating a discussion          For the consultations on the Standards of      on the ACP website under News &
document as a precursor to amending its       Practice and ACP’s by-laws, ACP will           Events/ACP newsletters.)




                                  Suite 1200, 10303 Jasper Ave NW
                                  Edmonton, AB T5J 3N6
                                  Telephone: 780-990-0321
                                  Toll free: 1-877-227-3838
                                  Fax: 780-990-0328
                                  pharmacists.ab.ca




                                                                    16
                                                                                    June, 2010
                                Backgrounder:
                          Health Professions Act and
                      Regulation of Pharmacy Technicians


The purpose of this background document is to describe the key features of the Health
Professions Act (HPA) and how the HPA affects all regulated health professions. These
features will apply to pharmacy technicians once the profession is regulated under the
HPA.

Background information about the pharmacy technician profession is also provided for
the benefit of stakeholders who may not be familiar with this profession.

Key Features of the Health Professions Act

The HPA addresses, amongst other things, registration requirements for entry into the
profession, ongoing competence requirements, continuing education requirements and
disciplinary procedures for all health professions. The HPA includes profession-specific
schedules that address areas unique to each profession, such as protected titles and
descriptions of the practice for that profession. Schedule 19 for the Profession of
Pharmacists has been amended to include the profession of Pharmacy Technicians.

Each profession has its own regulation which addresses profession specific areas such as
the required qualifications for entry into the profession. In the case of pharmacists, the
HPA regulation is the Pharmacists Profession Regulation.

Restricted Activities
Under the HPA, health services that pose significant risk and require a high level of
professional competence to be performed safely are restricted. Restricted activities can
only be provided by persons authorised by legislation. Non-authorized people can
perform restricted activities under the supervision of authorised people, but only if there
are regulations under the HPA that describe the nature of the supervision.

Mandatory Registration
The HPA provides that people who have the required qualifications and provide
professional services directly to the public must be registered with a regulatory college.
This also applies to those who teach students of the profession, as well as those
supervising regulated members of the profession who provide professional services to the
public.

Registration Requirements
The HPA sets out three basic routes of entry into a profession. The first is the most
straightforward route: graduating from a recognized education program, passing any
required entry exams and meeting practical experience requirements (if any). The second
route is being registered in another jurisdiction that is recognised and accepted by
Alberta. The third route is recognition of substantial equivalency (e.g. applicants from
outside Canada who must be assessed on an individual basis).

Requirements for registration in regulated health professions are a matter of public
interest, as many stakeholders are affected by these requirements. The regulations under
the HPA will clearly set out professional entry requirements for each profession.

Registration requirements for pharmacy technicians are presented beginning on page 4 of
the four column document.

Title Protection
Professional titles are protected for regulated members. The HPA protects the use of the
words “registered” or “regulated” in association with the name of a health profession for
professions regulated under the HPA. Also, the use of the title “Doctor”, in connection
with providing a health service is reserved for regulated members (however, academic
use of the title “doctor” is not affected by the HPA).

Pharmacy technician titles are listed on page 18 of the four column document.

Continued Competence
Under the HPA, professions are required to develop continuing competence requirements
for their members. Professions have five years to develop their programs. Regulated
members will have to meet the continuing competence requirements to renew their
practice permits.

Continuing competency requirements for pharmacy technician are presented beginning
on page 28 of the four column document.

Disciplinary Process
The key features of the disciplinary process in the HPA are listed below. These will
apply to pharmacy technicians upon regulation:
 A complaint resolution process;
 Tribunal hearings are open to the public;
 Disciplinary decisions are available to the public;
 Disciplinary outcomes are to be published;
 A “complaints director” will be appointed in every college;
 Public members must attend hearings and appeals.

Review of the Provincial Ombudsman
The Ombudsman may review the actions of a regulatory college. A complaint to the
Ombudsman is the last avenue of review – all other college processes must be exhausted
first. This avenue of complaint is available to investigated persons, complainants,

                                                                                  - 2 -
persons denied registration and others directly affected by the actions of a regulatory
college.

Other Features about Regulatory Bodies
   All regulatory bodies use the word “college” in their name;
   All regulatory college councils, hearing tribunals and complaint review committees
    require 25 per cent public membership;
   Regulatory colleges may not engage in negotiating professional fees or setting fee
    guidelines, unless the Minister of Health and Wellness otherwise approves.
   Regulatory colleges will be expected to engage in a consultative process when they
    approve education programs for the purpose of registration.

                       The Pharmacy Technician Profession

Current State
Pharmacy technicians are not currently regulated in Alberta or in any other Canadian
province. There are an estimated 2,000 to 3,000 pharmacy technicians in Alberta.
Pharmacy technicians are a diverse group of health practitioners resulting from the
availability of a variety of educational programs, various scopes of practice and few
requirements to maintain professional competence.

The Alberta College of Pharmacists (ACP) established a voluntary register for pharmacy
technicians in December, 2007. At present, approximately 970 pharmacy technicians are
registered on the ACP’s pharmacy technician register.

Pharmacy technicians work under the supervision of a pharmacist. Their duties and
responsibilities vary depending on their level of training and where they are employed.
Most pharmacy technicians are employed in retail pharmacies or hospital/medical centre
pharmacies. Some are employed by health insurance or pharmaceutical companies, drug
wholesalers and pharmacy supply companies. Pharmacy technician responsibilities range
from preparing compounds to filling dose carts for nursing stations, preparing sterile
products such as intravenous solutions, preparing and labelling prescription medications
and administrative duties.

Proposal for Regulation

Under the proposal for regulation, pharmacy technicians will be governed by the ACP.
The Pharmacists Profession Regulation will be amended to include provisions to govern
pharmacy technicians and the title of the Regulation will be changed to “Pharmacists and
Pharmacy Technicians Profession Regulation”. The regulatory body will, however,
continue to be known as the Alberta College of Pharmacists. Pharmacy technicians will
have their own separate and distinct register apart from the pharmacist register.

To become a regulated pharmacy technician, individuals currently working in the
profession, as well as those just entering the profession, will need to successfully
                                                                                       - 3 -
complete several steps required by the ACP (see page 6 of the attached issue of the
Transition Times (Spring 2010). The ACP does not anticipate that all individuals
currently employed as technicians will pursue registration. Unregulated individuals may
continue to work in a pharmacy and assist the pharmacist as long as the pharmacist
provides direct supervision and takes responsibility for the work completed by
unregulated individuals. Note that only individuals who are registered on the ACP’s
pharmacy technician register will be able to use the title “pharmacy technician”.

Details about each area of proposed regulation for the pharmacy technician profession are
provided in the four-column document.

Pharmacy Technician Practice Statement
The practice statement for regulated pharmacy technicians is set out in section 3(2) of
Schedule 19 of the HPA which states:
    In their practice, pharmacy technicians promote safe and effective drug distribution
    and, in relation to that, do one or more of the following under the direction of a
    pharmacist:
    (a) receive, gather, enter and store prescription and patient information,
    (b) store and repackage products,
    (c) participate in the management of systems for drug distribution and inventory
    control,
    (d) participate in the research, development, implementation and evaluation of quality
    assurance and risk management policies, procedures and activities,
    (e) provide restricted activities authorized by the regulations,
    (f) instruct patients about the use of health aids and devices, and
    (g)teach the practice of pharmacy technicians.
                              (Health Professions Amendment Act, 2008, Chapter 34, section 28, 2009)



Proposed New Restricted Activities
Pharmacy technicians will be authorized to perform the following restricted activities
under the direction of a pharmacist.
 To dispense a Schedule 1 or Schedule 2 drug;
   To compound, provide for selling or sell a Schedule 1 drug or a Schedule 2 drug;
   To compound blood products.
The four-column document contains details regarding the proposed new restricted
activities commencing on page 22 and details what it means to practice “under the

                                                                                           - 4 -
direction of a pharmacist”. While pharmacy technicians will be required to practice
under the direction of a pharmacist, they will have an increased measure of independence
and will be held individually accountable as regulated health professionals.




                                                                                 - 5 -
                                           10025 Jasper Avenue
                                           P.O. Box 1360, Station Main
                                           Edmonton, Alberta
                                           T5J 2N3


     Stakeholders for Consultation on Regulation of Pharmacy Technicians under the
         Pharmacists Profession Regulation pursuant to the Health Professions Act


If you are aware of other organizations or individuals who may have an interest in the regulation
of pharmacy technicians, please let us know and we will forward a consultation package to them.

Alberta Health Services

Alberta Health Profession Regulatory Bodies:
Acupuncture Health Discipline Committee
Alberta Opticians Association
Alberta College of Medical Laboratory Technologists
Alberta College of Medical Diagnostic and Therapeutic Technologists
Alberta College of Optometrists
Alberta College of Occupational Therapy
Alberta College of Paramedics
Alberta College of Pharmacists
Alberta College of Combined Laboratory and X-ray Technologists
Alberta College and Association of Respiratory Therapists of Alberta
Alberta Dental Association and College
Alberta Podiatry Association
Alberta College of Speech Language Pathologists and Audiologists
Alberta College of Social Workers
Alberta College of Speech Language Pathologists and Audiologists
College of Chiropractors of Alberta
College of Alberta Dental Assistants
College of Registered Dental Hygienists of Alberta
College of Alberta Denturists
College of Dental Technologists of Alberta
College of Hearing Aid Practitioners of Alberta
College of Licensed Practical Nurses of Alberta
College of Physicians and Surgeons of Alberta
College of Alberta Psychologists
College of Dietitians of Alberta
College and Association of Registered Nurses of Alberta
College of Registered Psychiatric Nurses of Alberta
College of Physical Therapists of Alberta
Midwifery Health Disciplines Committee
Alberta Government Ministries:
Employment and Immigration
Advanced Education and Technology
Children and Youth Services
Seniors and Community Supports
Insurance Policy and Communications,
Alberta Finance and Enterprise
Justice and Attorney General

Alberta Government Provincial Labour Mobility Coordinator

All Provincial and Territorial Ministries of Health

Educational Institutions:
Southern Alberta Institute of Technology
Red Deer College
Bow Valley College
Lakeland College
NorQuest College,
Grand Prairie Regional College
Private vocational training colleges

Pharmacy Technician Society of Alberta

Canadian Association of Pharmacy Technicians

The Canadian Pharmacists Association

Alberta Pharmacists’ Association

Health Sciences Association of Alberta

Alberta Continuing Care Association

Alberta Home Care and Support Association

Alberta Home Care Services

Interested Individuals

Others:
Alberta Blue Cross
Workers’ Compensation Board
Canadian Life and Health Insurance Association
                             Notice Regarding the
                          Freedom of Information and
                           Protection of Privacy Act
You have been requested by Alberta Health and Wellness to be part of a consultation process.
The purpose of this notice is to provide you with general information on the Freedom of
Information and Protection of Privacy Act (the Act), as the records created as a result of this
consultation process will be subject to the Act.

The Act generally allows any person a right of access to records in the custody or under the
control of Alberta Health and Wellness, subject to the provisions of the Act. The Act applies to
“records” which include information in any form including documents, letters, vouchers,
papers, books and any information that is written, photographed, recorded or stored in any
manner. Although the records created will be subject to the Act, the provisions of the Act and
procedures there under will determine if the records may or may not be released in response to
a specific request.

If you are involved in the consultation process as a private individual you have certain privacy
rights. Your name may appear on various records but if such disclosure amounts to an
unreasonable invasion of personal privacy, it would not be disclosed under the provisions of
the Act for obtaining access to information, unless you consent to that disclosure. Your
personal views or opinions, except if they are about someone else, are considered “personal
information” under the Act and disclosure is limited as provided in the Act.

The identity and views of an organisation participating in a consultation process are generally
releasable, as public and private sector organisations do not have privacy rights under the Act.
Your identity may also be releasable, if you are a senior official in a publicly funded
organisation writing or speaking on behalf of the organisation. If you are participating as a
member of the public but are using your organisational title or address for convenience and
you want your privacy protected, this must be stated and recorded at the outset of the
consultation process.

The Act is an Act of last resort. If an information request is received by Alberta Health and
Wellness, the requester would initially be encouraged to approach organisations to directly
access their submissions or views. If a request is then received by Alberta Health and
Wellness, it is standard procedure to consult with the program areas managing the consultation
process, as well as with named individuals regarding the possible impact of releasing the
records. This assists in identifying possible harm that could result from disclosure.

If you would like more information about the Freedom of Information and Protection of
Privacy Act, please contact Shirley Pate at (780) 415-0209. This notice is not to be taken as
legal advice. For legal advice regarding the Act, you may wish to consult with your personal
solicitor.

				
DOCUMENT INFO
Shared By:
Categories:
Tags:
Stats:
views:15
posted:8/15/2012
language:
pages:63