Feedback deadline is: 4:00 PM on March 6, 2026
Summary
The College is seeking input on potential changes to the number, composition (pharmacist and pharmacy technician seats), and term limits of elected directors to address identified challenges with development and succession planning for Board and Committee leadership, capacity pressures on standing and statutory committees, and maintaining legal Board constitution if directors unexpectedly resign.
This consultation considers by-law changes that may address these issues through the addition of two elected directors (one pharmacist and one pharmacy technician), and the extension of term limits from a total of six consecutive years to nine consecutive years on the board, based on three-year elected terms. This consultation feedback, in conjunction with a concurrent environmental scan and policy review being completed by the College, will inform the Board’s decision on changes to the College By-Law in March 2026.
Background
In June 2025, the Governance Committee identified governance-related concerns raised by directors and committee members that included:
- Executive Committee Succession Planning: The current six-year term limits for Board members restrict effective succession planning and do not enable sufficient time for directors to gain the experience necessary to fully contribute and transition into leadership roles such as Chair or Vice-Chair.
- Discipline Committee Leadership Succession: The six-year term limit also hampers succession planning for the training and development of Discipline Committee panel chairs for hearings.
- Board Composition and Risk of Becoming Unconstituted: Maintaining the elected Board member composition at the minimum required level poses a significant risk. If an elected director resigns mid-term, the Board may become unconstituted and unable to make decisions until a replacement is appointed. This risk materialized within the first three months of the 2024/25 Board year, when two elected directors resigned. In both cases, the College narrowly avoided being unconstituted due to the prompt appointment of replacements. Additionally, the minimum number of Board directors poses capacity issues on the Discipline Committee, particularly related to setting up discipline hearing panels due to availability challenges.
To address these concerns, the Board directed College staff to develop and execute a work plan, as part of the 2026 Operating Plan, that examines and reports on the implications of current Board composition and term limits. This includes:
- the impact of maintaining the minimum number of elected and public directors and the potential benefits or risks of increasing those numbers
- the potential benefits of reinstating nine-year terms to support leadership development, continuity and succession planning
- the associated effects on Board and committee succession planning, continuity and the risk of becoming unconstituted
At its December 8, 2025, meeting, the Board also approved a 60-day pre-consultation to be held concurrent with the environmental scan and policy analysis being completed by the College. The intent is to gather and analyze feedback on proposed changes that would support a final decision on Board size, composition and term limits at the March 2026 meeting, in advance of the next election cycle. Your feedback will help ensure that any changes strike the right balance for good governance practices and addressing the identified concerns.
How you can participate
Registrants, members of the public and system partners are invited to participate in this 60-day pre-consultation by using the form below to comment before March 6, 2026 at 4 p.m.
When providing feedback, please consider addressing the following questions:
- Will adding additional elected Board directors effectively address the risk of becoming unconstituted and capacity pressures on committees (particularly related to discipline panel hearings) and also support governance best practice? If not, what alternative approaches would you suggest?
- If additional elected directors are added, how many should be added and of which type ( e.g. pharmacist, pharmacy technician)?
- Is extending term limits an appropriate approach to address the issue of succession planning and leadership development for the Board? If so, is nine years an appropriate duration?
The feedback we receive via the online form or email is published publicly in accordance with our posting guidelines. Please allow 1-3 business days for your feedback to be published. Under the guidelines, the College has the right to refuse to publish or remove comments that do not meet the posting guidelines. All comments provided as part of the consultation, whether published or not, will be reviewed and considered as part of the analysis provided to the Board.
Helpful Links
- December 2025 Board materials package (see Briefing note starting on page 273; proposed By-Law amendments start on page 314)
- June 2025 Board materials package (see Briefing Note starting on page 307)
Read The Feedback
This response was submitted by a pharmacist. Read the full submission here.
I remain a licensed pharmacist in Ontario and to date, have resisted weighing in on previous consultations conducted by OCP. Since 2011, I have provided consulting services founded on internationally identified best practices in regulatory governance and performance to regulatory bodies across professions and jurisdictions; it is my considerable insight and expertise in best governance practices, gained through this work, that compels me to share these comments. The proposal to increase the size of the OCP Board does not align with identified best governance practices internationally-where smaller rather than larger boards are considered to align with recognized principles of good governance. We are asked to provide feedback on a proposal to support increasing the size of the OCP Board, but in the absence of any evidence to show whether an increase is necessary or appropriate- its my view that this request for feedback is premature, and akin to ‘putting the cart before the horse’. The Board should consider holding off making any decisions about increasing the board size until its full consideration of the report it has asked staff to bring forward, based on research conducted and evidence found. There does not appear to be any evidence that supports the apparent urgency to make this change now; rather it appears based on a potential risk that the board could find itself un-constituted again, at some point down the road. In my experience a sudden resignation of a professional member of Council mid term happens infrequently and when it does, it rarely prevents a Council from doing its business. I would question whether the chances that this might happen again are high enough to justify a change that does not align with identified best governance practices? Options are available to all of the health regulatory boards in the event of an unexpected departure or resignation of an elected board member mid-term, and I would suggest that the Board explore these and consider options and alternatives to solving any such constitution issues before making any final decision on this proposal. Regarding term limits, maximum 9 year term limits are not uncommon on other regulatory, not-for-profit or corporate boards. Whether the 9 years are served by an individual consecutively or through different terms on the Board, best governance practice is to limit terms to a maximum of 9 years of total service on a Board. It is not good governance practice to permit an individual to serve for 9 years, go off the board for a time and then return for potentially another 9 years, as this prevents board turnover. At one regulatory board I reviewed, 5 professional members had collectively served 120 years on the board, because they enjoyed being on the board and were permitted to do so. The practice deterred interest from other interested members of that regulated profession from seeking an elected seat because they assumed that the ‘old guard’ would be elected. While remaining on the board for multiple terms may serve the interest of an individual, this practice doesn’t serve the best interest of the OCP Board, the public, the profession or the College. All would collectively benefit from maximum lifetime term limits that allow for a cyclical refreshing of skills, competencies, experiences, and the regular introduction of a diversity of views and perspectives on the Board, contributing to the board’s overall effectiveness and performance.
As a pharmacist & registrant, I am not supportive of these items. Will adding additional elected Board directors effectively address the risk of becoming unconstituted and capacity pressures on committees (particularly related to discipline panel hearings) and also support governance best practice? If not, what alternative approaches would you suggest? – Adding additional board members does not guarantee function. – In all realities if you are having capacity pressures, you should look internally at your Board members and the requests on their time & their dedicated time to the obligations to the Board. If people are seeking a “Board membership” but not dedicating the time to that board is unprofessional and needs to be managed within the Board structure, not by adding more resources . – A previous comment was **time in role should not be conflated with experience or effectiveness**. If a director is unable to develop the necessary governance, regulatory, and adjudicative competence within six years, it is unlikely that extending that same term to nine years will meaningfully change the outcome. I am in complete agreement with this. – As for specific content knowledge, the College should be hiring staff with specific operational expertise including process/ procedure to help the Board members/ members of committees (such as Discipline) run their work. In another organization, I was appointed to a “discipline-type” committee and there are both a mix of staff and appointed people so that there is not a loss of corporate memory with changes in appointed staff – Again in agreement with another comment – I believe the focus of any by-law amendments should be less on extending term limits and more on: * attracting and electing directors with the appropriate expertise, judgment, and governance aptitude; * robust orientation, education, and ongoing development for Board and committee members; and * thoughtful Board composition that supports effective committee functioning, particularly in high-demand areas such as discipline and adjudication – With 21 people and 6 years, there should be 3-4 people ONLY turning over. Consider a bylaw that allows for lower quorum/ constitution for short timeframe, in the time when someone quits mid-term. – Add a bylaw for replacing a member at year 3 or 4 if they are not contributing/ attending/ engaging instead of giving them a longer mandate. I would prefer a 4 year with re-election/ re-appointment based on their actual work than a 9 year If additional elected directors are added, how many should be added and of which type ( e.g. pharmacist, pharmacy technician)? – I would ONLY add public/ community members and no more professionals. One of the aspects that the Board seems to be intimating in their review is a lack of skill-mix. More people just contributes to an inappropriate case-mix of individuals to allow for effective and efficient Board function. Instead of adding pharmacy professionals who do not have the requisite skills the College is looking for, add more public members that can contribute in meaningful ways to the needs of the Board. – Alternately, consider how to train Staff to pick up operational process to embed function within the paid staff so that elected directors are being asked to provide information that they can – such as peer review/ Is extending term limits an appropriate approach to address the issue of succession planning and leadership development for the Board? If so, is nine years an appropriate duration? – Do not extend term limits, rewarding board members who are ineffective & not getting the Board work done by an additional 3 years is counter-intuitive and counter-productive to functioning organizations. – Consider auditing your own records to understand the knowledge and skills you are lacking or where the inefficiency is so that you can improve your internal processes. What are portfolios for people? What is being done outside of actual Board duties and being labeled as such? Often times, people want to contribute to topics which are not the Core Board functions, and unfortunately that should only be available Overall, increasing numbers and term lengths is a solution that works for very few issues. I want to be assured that the Board recognizes the limitations of this type of intervention on actually getting work done.
1. Yes, 2 additional directors to provide buffer and to avoid risk of un-constituted. 2. Should add 1 pharmacist and 1 pharmacy technician directors. However, current representation of hospital practices is under-represented in OCP. Hospital pharmacists represents 20% of the members, while the number of pharmacy technicians work in hospitals represent as high as 40%. Recommend the new additional directors are selected from the hospital field. 3. 3 x 3 year term is reasonable, allowing 1/3 of directors be re-elected every year to provide new ideas while maintaining continuity in leadership in the 2/3.
I feel it is important that the composition of the board appropriately represent all of the types of pharmacy practice sites. For hospital practice, between pharmacists and technicians, hospital practitioners make up ~40% of the membership but traditionally have had much lower rates of representation. Hospital practice is fundamentally different from other practice sites and the lack of proportional representation has led to a lack of understanding of the impact or practicality when standards are contemplated and/or implemented. I feel it is important that the hospital perspective is more appropriately represented. I also disagree with the extending the term of board members out to 9 years. It would seem extreme to potentially have someone sit on the board for 9 years with turnover occurring once a decade.
Thank you for the opportunity to provide feedback. Feedback item #1: I believe the board composition should reflect the actual practice areas of pharmacists and pharmacy technicians, the constituents of the College. To that effect, it is unclear to me why the previous Board position dedicated to hospital practitioners have been eliminated (i may have missed this in some communication so apologies in advance if i did). This is despite the increasing scrutiny of the College on hospital pharmacist/pharmacy technician/mdication system practice, and the much higher risk to the public associated with the medication system within a hospital vs the community counterpart. A large proportion of registered pharmacy technicians work within the hospital sectors, thus further emphasizing the importance of having adequate representation. Current general voting system makes it highly improbable that a hospital based Board candidate will ever receive enough votes to be sucessful given the shear number of registrants in the community sector. I believe OCP needs to reinstate the previously existing dedicated Board positions. Given the multitude of challenges with OCP programs applicability to the hospital sector, we must have representation in order to have any OCP program/regulations accurately reflect the very different practice issues in order to actually fulfil OCP’s mandate to protect the public. These comments are NOT meant to imply in nay way that community pharmacy practice is easy/without risk or anything close. It is simply highlighting that there are real differences that needs to be considered in policy decisions that will (and has) negative consequences that affects the public. Feedback #2: Term of Board members at 6 years, and potentially 9. I believe this term is excessive and will result in some opinions persisting without new/fresh ideas or different viewpints to be shared. Pharmacy practice is diverse and thus Board term should reflect such. For succession planning, if the incumbent cannot learn the role within a year or 2 then extending to 9 is unlikely going to help. Having board members stagger start/end of term is the way to ensure institutional knowledge/expertise is maintain, not a 9 year term in the days of rapidly changing information, practice, and technology. Given the already lack of representation (and it is clearly reflected in many of the recent OCP programs such as PACE where hospital practice and realities were not considered in its inception) mentioned, I believe an 6-9 year term should NOT be implemented.
In completing a cross jurisdictional scan of the other regulators in other provinces, the size of the Board is already the largest, exceeding the average significantly. Increasing the size of the board can slow policy implementation, responsiveness and strategic focus as consensus can be harder. Rather than increasing the board size, it would be more appropriate to focus on improved governance and processes for continuous improvement. 2 consecutive terms is usually the limit to help bring fresh perspective to the board table with new board members so the extension to 9 years could impede diverse perspectives. Improvement in the process of succession planning and information exchange would likely improve development vs. term extension.
I am submitting these comments as a pharmacist and registrant of the College, with a strong interest in ensuring that the College’s governance framework remains effective, forward-looking, and aligned with its public-protection mandate. I appreciate the College’s efforts to review Board composition and term limits and to engage in consultation in advance of the 2026 election cycle. Strong governance is essential to maintaining public trust, particularly at a time when the pharmacy profession is evolving rapidly in scope, complexity, and accountability. With respect to proposed changes to director term limits, I recognize the concern that a six-year maximum may constrain succession planning and leadership development. However, I would respectfully submit that **time in role should not be conflated with experience or effectiveness**. If a director is unable to develop the necessary governance, regulatory, and adjudicative competence within six years, it is unlikely that extending that same term to nine years will meaningfully change the outcome. In my view, effective governance is better supported by **selecting highly qualified, competency-aligned individuals at the outset**, rather than extending tenure to compensate for gaps in experience or readiness. Length of service alone should not be relied upon as a proxy for leadership capacity, judgment, or contribution—particularly in a regulatory environment that demands agility, independence, and accountability. This consideration is especially important given the pace at which the pharmacy profession is evolving. Pharmacists and pharmacy technicians are assuming expanded clinical roles, operating within increasingly complex practice environments, and navigating rapid changes in legislation, technology, and patient expectations. In this context, the Board requires directors who are well positioned to understand contemporary practice realities and contribute meaningfully within a defined and reasonable timeframe. For these reasons, I believe the focus of any by-law amendments should be less on extending term limits and more on: * attracting and electing directors with the appropriate expertise, judgment, and governance aptitude; * robust orientation, education, and ongoing development for Board and committee members; and * thoughtful Board composition that supports effective committee functioning, particularly in high-demand areas such as discipline and adjudication. I am supportive of exploring an increase in the number of elected directors beyond the statutory minimum, as this appears to be a more direct and proportionate way to address risks related to quorum, committee capacity, and workload distribution. Overall, I encourage the College to ensure that any proposed changes prioritize **competence, effectiveness, and responsiveness to an evolving profession**, rather than relying on longer tenure as a solution to governance and succession challenges. Thank you for the opportunity to provide input on this important matter. Respectfully submitted,
The December Briefing package lists 21 Board members. That is already a very large number and adding more members runs the risk of decreased efficiency in terms of sound governance. Rather than increase the numbers, more care should be exercised in selection of Board members and ensuring that appointments do not all expire at the same time so as to promote continuity. More attention should be paid to promoting a healthy organization culture and relationships between Board and OCP staff. Six years is already a long term. At nine years, members risk becoming “stale”. If good succession planning cannot be achieved within a 6 year term, there is something else that is not working e.g. training of Board members?? Selection of Board members. If you can’t learn within 6 years…..!!! More information regarding composition of Boards and term lengths in other regulatory Boards would have been helpful to inform feedback on these issues. OCP should look at models of successful Boards at other Colleges. It should also be kept in mind that other problems plagued OCP in recent years. Do more research into creating and maintaining effective governance Boards and fix what is broken!
Definitely concur with reinstating the nine-year term maximum for elected members. There is so much to learn and particularly for Discipline, I am awaare of the challenges to compose Panels with experienced professionals. I also concur with increasing the professionanl representation on the Board. This will allow a broader Board composition regarding diversity of experience, practice locale and type of practice and thus will be more reflective of the spectrum of pharmacy professionals in Ontario.
1. Yes 2. Either same ratio for example 9 with 2 being techs then 12 with 3 being techs. OR in same % as member base (if ocp members are 3/4 pharmacist and 1/4 techs). 3. Yes I think extend and the 9 years is appropriate.
1.The Decision of adding additional board members for the sake of addressing the risk of becoming unconstituted and capacity pressures on committees needs more informed opinion regarding the organizational chart of the College and the division of work among board members and committee members. Simply increasing the number of board members is not the best course of action to take to mitigate the risk of the board becoming unconstituted, instead offering more flexibility for attending meetings for example via video conference save alot of time and more convenient for board members who are not resident of Toronto. 3.Six years term limit for board members is more than enough for succession planning. However increasing the Term to 9 years reduces the organization transformation capacity and adaptability to external changes which is needed during the time of technological transformation that the healthcare sector is undergoing.