Feedback deadline was: 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 the Canadian Society of Healthcare-Systems Pharmacy (CSHP) – Ontario Branch. Read the full submission here.
Not recommending extension of term
To address the Discipline committee workload discussed in the March 4, 2026 feedback. I present the following option. The Broad should consider an alternate process for the matters that are referred to the Discipline Committee similar to the CPSO’s “Ontario Physicians and Surgeons Discipline Tribunal” (OPSDT) to hear all discipline matters. The following is an excerpt form the OPSDT website: “The Ontario Physicians and Surgeons Discipline Tribunal is a neutral, independent, administrative tribunal that adjudicates allegations of professional misconduct or incompetence of Ontario physicians made by the College of Physicians and Surgeons of Ontario. The Tribunal is part of a group of tribunals called the Health Professions Discipline Tribunals, which holds hearings for several health colleges in Ontario, using a shared set of rules and processes. By shifting to a different model to adjudicate discipline matters, would “free” up board members to focus on governance matters and not having to write discipline decisions.
Governance structures for health profession regulators should reinforce the public interest mandate of the organization, maintain an appropriate balance between professional and public representation, and support regular renewal of leadership and perspective. These principles informed the College’s previous decision to reduce Board size and limit director tenure in order to align with recognized governance practices across Canadian regulatory bodies. For these reasons, I do not support increasing the number of elected professional directors or extending director term limits from six to nine consecutive years. Increasing the number of professional directors without a corresponding increase in public members risks shifting the balance between professional expertise and independent public oversight that underpins credible self-regulation. Maintaining that balance is essential to public confidence and should remain central to any governance reform. Extending director tenure to nine years would also move the College away from the governance principles that previously guided reform. While continuity and leadership development are important, effective boards rely on regular renewal. Turnover introduces new perspectives, strengthens oversight, and helps prevent governance practices from becoming entrenched over time. A six-year limit already provides sufficient time for directors to develop governance expertise and contribute meaningfully, including in committee and leadership roles. The recent risk of the Board becoming unconstituted following multiple director resignations should also give the Board pause. Governance resilience is not primarily determined by increasing board size or extending tenure. Stability is more closely related to governance culture, effective succession planning, and conditions that allow directors to participate constructively in their roles. Structural changes alone are unlikely to address those underlying issues. Finally, if any changes to Board composition or term limits are adopted, they should apply prospectively only and not to currently serving directors. Directors were elected under a defined governance framework, and altering those conditions mid-term risks undermining the integrity of the election process, and presents a potential conflict of interest, a incumbent directors may directly benefit from their own decision making. Maintaining the current Board size and six-year term limit best supports balanced representation, appropriate renewal, and alignment with recognized governance practices in health profession regulation.
Thank you for the opportunity to provide input on the topic : Public Consultation on Board Size. Composition and Term Limits. Questions: 1. : 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? When the number was reduced to 6, I was concerned this was going to be a problem for the following reasons: – The amount of committee involvement by Board members did not change such as Discipline Committee and Hearing participation, ICRC , QA ,etc. All these committees have significant time involvement in terms of committee preparation for meetings/hearings which is in addition to Board meeting preparation which is significant. – The Board participates (both professional and public members) usually have day jobs which of course takes precedence when balancing daily workload. – Spreading the workload from committees over six Board members then increased the pressure on the remaining six Board members to complete the work – Workload in the discipline area is increasing and becoming more complicated in terms of more contested hearings which require more time and expertise – Workload at ICRC is also increasing with more complaints being filed online – Likewise, QA work increases as the pharmacist/pharmacy technician roles expand and public protection expectations increase with this expanded role. – All the above eventually creates pressures on individual Board members who then decide that something has to change in what they are doing …. Possibly resulting in a resignation from the Board. Therefore, I am in favour of adding 2 or 3 Board positions . 2. If additional elected directors are added, how many should be added and of which type (e.g. pharmacist, pharmacy technician)? For the additional members noted above add one (preferably two) hospital pharmacists and one technician positions. Hospital pharmacists offer experience and insight into the health care system from a hospital perspective and offer additional clinical input from this area of pharmacist practice. Under the current system of elections there is no guarantee that this area of practice will be represented on the Board. The additional technician position provides more input from this area of practice which pharmacists must start to depend on if they are to do the many non dispensing functions that is expected of them by the public. The additional Board positions will help with the workload generated by the various committees. Also, given the public protection mandate of the College, ensuring that the main areas of practice are represented on the Board (Community and Hospital pharmacists and Pharmacy Technicians) such a change will only enhance this mandate. 3. 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? I feel the 6 year duration is acceptable with the following possible additions: -the 6 year term could have an additional 3 year extension if necessary to retain a particular skill set that the Board needs and cannot find an appropriate replacement – that consideration be given to an “distinct” Executive Committee term of 4 years (2 years for Chair- Elect to allow for training, 1 year for Chair and 1 year for Past Chair). The 4 Year Executive term is in addition to the 6-year term on the board and is not subject to election by the electorate – the Executive will change by one person each year as the members of the Executive committee work their way through the various positions. This will allow for sufficient training for these positions and build Board and College experience for decision making. These decisions then eventually go to the Board. Elections for the Executive committee would be held by the Board. – the College should consider going away from Board elections by registrants of the College and move to a nominations committee process where the College and Board will identify skill sets that the Board needs in order to move ahead with their strategic plan and budget and then have registrants apply to the nominations committee for consideration to serve on the Board . The current system of elections I feel does not work – Board members no longer represent a district (as in the past) and are not “responsible “to specific districts (which was an issue in the past since once elected the new Board member was advised that they do not represent a district). Instead, a list of registrants run for election, and everyone votes (I am not sure what the number of registrants who vote is but I suspect it is low). A example of an alternative method is at the University of Toronto Board of Governors where the election of the six alumni representatives on the Board is the responsibility of the College of Electors (aka Nominations Committee) who after consultation with the Board and University management seeks a group of individuals who meet the criteria for consideration for the Board of Governors representing the alumni of the university. I realize I have not given the university’s system the detail necessary which I suspect you will review in greater detail if interested. 4. Additional Comment re: Discipline Committee I have been a member of the discipline committee for many years and serve in a capacity of Hearing Chair as well as Hearing PHC Chair when assigned. I am retired from a long career in pharmacy at the hospital pharmacy management level and at the executive level in the pharmaceutical industry. I have served in executive board positions at OPA, CSHP and The Foundation for Pharmacy. In retirement I have the time to commit to discipline hearing preparation and decision writing. If I was still working this time commitment would not have been possible. Changes are needed in the discipline committee functions- the College’s Hearing Office staff are amazing – very experienced, helpful, and thorough- and assist the discipline committee with the management of the various cases which in recent years have increased significantly and are more complex (in particular contested hearings). However, the Hearings Office can do only so much. A rate limiting step is the writing of decisions – often committee members are not willing to commit to chairing a hearing because the chair has to write the decision which can take significant time. This leaves only a few, from a time-consuming perspective, who are in a position to do so and who are not conflicted because they participate in other committees, e.g. ICRC which may conflict with their participation in a particular hearing. There is a solution to this – appoint lay members to the Discipline Committee who are experienced in decision writing e.g. lawyers, para legals, etc.) who would participate in the hearing as a lay person member of the panel, who would deliberate with the panel and write the first draft of the decision for review by the Panel Chair which would then go to the entire Panel for approval prior to then going to Independent Legal Counsel (ILC) for review. Such a change would be a solution to the decision writing dilemma and Panel chair participation- a larger number of Discipline Committee members would then accept a Panel Chair position.
I am submitting these comments as a pharmacist, registrant and past member of the College Board. I appreciate the opportunity to provide input on the proposed governance changes and recognize the Board’s efforts to undertake this review in advance of the 2026 election cycle. Strong governance is foundational to public trust. At a time when the pharmacy profession is expanding in scope, complexity, and accountability, it is critical that any structural changes clearly strengthen—rather than inadvertently weaken—the College’s public-protection mandate. Board Composition and Capacity I do not support the proposed changes. Increasing the number of elected directors may appear to be a practical solution to quorum risk and committee workload—particularly in high-demand areas such as discipline hearings—but expanding board size does not automatically improve governance performance. Effectiveness is driven by engagement, competence, and accountability—not by headcount. If the Board is experiencing capacity pressures, the first step should be a rigorous internal assessment of governance practices. Before adding members, the Board should ask: Are directors consistently meeting attendance and preparation expectations? Are committee assignments aligned with demonstrated skills? Is Board time being directed toward core regulatory responsibilities? Being on the Board is a significant time commitment and professional obligation. If participation gaps exist, they should be addressed through performance standards and accountability mechanisms—not by diluting responsibility across a larger group. Adding more directors without first resolving engagement or structural inefficiencies risks compounding, rather than solving, the problem. Term Limits and Effectiveness Time in role should not be conflated with competence or effectiveness. Extending term limits risks entrenching underperformance and weakening accountability at precisely the moment when regulatory boards must remain agile and responsive. With a 21-member Board and six-year staggered terms, turnover should already be gradual and manageable. Only three to four members rotate off in a typical cycle. That level of renewal supports both continuity and fresh perspective. Permanently extending term limits is not the solution. More importantly, governance best practice would suggest: Fixed terms with re-election or re-appointment contingent upon demonstrated contribution; Clear and enforceable attendance and engagement standards, with a mechanisms to remove or replace directors who are not fulfilling their obligations. Accountability strengthens governance. Tenure alone does not. Skill Mix and Board Expansion If the Board determines that additional elected directors are necessary, I would strongly recommend prioritizing the Board identified concerns about skill mix. Adding more board members does not inherently resolve gaps in governance, adjudication, or regulatory oversight expertise. In fact, it may complicate decision-making and reduce efficiency if competencies are not carefully aligned with Board needs. If there are identifiable skill deficiencies—such as adjudicative expertise, governance leadership, financial oversight, or regulatory strategy—those gaps should be explicitly defined and addressed through targeted recruitment and training. Increasing public representation would enhance credibility, strengthen independence, and reinforce the College’s public-interest mandate without duplicating professional voices already present. Operational Expertise and Staff Support It is also important to distinguish between governance capacity and operational capacity. Many pressures—particularly in discipline and adjudicative work—are operational in nature. High-functioning regulatory boards rely on experienced staff to provide procedural, legal, and administrative continuity. Embedding process expertise within staff preserves institutional knowledge, reduces reliance on director tenure, and ensures consistent standards across committees. Elected directors should focus on governance, oversight, and professional judgment—not procedural mechanics that can and should be supported by trained staff. Strengthening operational infrastructure may yield greater gains in efficiency and continuity than expanding Board size or extending mandates. Succession Planning and Governance Best Practice Extending term limits is not, in my view, an effective succession-planning strategy. Succession is built through deliberate leadership development, mentorship, committee experience, and governance education—not through longer tenure by default. If leadership readiness is a concern, the more strategic approach would include: A formal audit of Board competencies and identified gaps; Structured onboarding and ongoing governance education; Leadership development pathways within committees; Clear portfolio definitions and performance expectations; A review of internal processes to identify inefficiencies. Increasing the number of directors or lengthening their terms are blunt structural tools. They address symptoms, not root causes. If the objective is stronger governance, greater efficiency, and improved public confidence, the solution lies in selecting the right people, holding them accountable, equipping them effectively, and ensuring operational support is appropriately resourced. I respectfully encourage the Board to prioritize competence, accountability, and structural clarity over tenure expansion. Governance reform should demonstrably improve performance—not merely expand duration or numbers. Thank you for the opportunity to provide input on this important matter.
The College is seeking input on potential changes to the number, composition (pharmacist and pharmacy technician seats), I have been a practicing pharmacist for 26 years and the OCP does necessary work. What is not necessary is for an increased board size or composition with excessive fees being charged to licensed pharmacist and pharmacy technicians. Our salaries neither hospital nor community support the ability to pay these fees. In the past number of years pharmacist fees has almost doubled; our salaries and ability to pay has not. Putting members under this unnecessary strain is forcing them to work longer and harder to pay fees and make mistakes and adopt uncaring practices for you to investigate and punish. Do you see the cycle here? Reduce limits to bring new ideas and approaches. Reduce sizes of committees and number of staff overall to bring yourself as an organization into a cost efficient model of operation and cease increasing all fees, the last number of inflationary increases should give you enough operational room for quite a number of years to come.
Thank you for the opportunity to provide feedback on the proposed changes to Board size, composition and term limits. I appreciate the transparent approach to consultation and the effort to proactively address governance risks that have been identified. I support increasing the number of elected directors. The recent experience with mid term resignations demonstrates that operating at the minimum required composition creates real governance vulnerability. Expanding the Board would strengthen continuity, reduce the risk of becoming unconstituted and improve capacity pressures on committees, particularly the Discipline Committee. From a governance perspective, building in structural resilience is both prudent and responsible. As a hospital pharmacist, I would also encourage the Board to consider representation across practice settings as part of any expansion. The profession is diverse, and regulatory decisions benefit from informed perspectives across community and hospital environments. Increasing the number of elected directors presents an opportunity to ensure that the Board reflects the breadth of contemporary pharmacy practice. Even if seats remain elected at large, attention to sector diversity should be an explicit consideration. I do not support extending consecutive term limits to nine years as a general policy. While I recognize the challenges related to succession planning and leadership development, extending tenure for all directors risks reducing renewal and limiting opportunities for broader member engagement. Strong governance requires both continuity and fresh perspective. Nine consecutive years on a regulatory board is a significant duration and may not be necessary to achieve the stated objectives. If succession planning for Executive and Discipline Committee leadership is the core issue, I would encourage exploration of more targeted solutions. These could include structured leadership development pathways, earlier identification and mentoring of potential Chairs, or limited extensions tied specifically to executive roles rather than a blanket increase in term limits for all directors. Such approaches would preserve renewal while strengthening leadership continuity. In summary, I support increasing Board size to enhance resilience and capacity, and I encourage thoughtful attention to representation across practice settings. I do not support extending term limits to nine consecutive years, and I recommend that alternative mechanisms be considered to address succession planning concerns. Thank you for considering this feedback.
I am writing to formally oppose the proposed increase in Board term limits from six years to nine years. The Ontario College of Pharmacists previously reduced Board term lengths to six years specifically to align with recognized governance best practices. That decision reflected widely accepted principles that emphasize regular Board renewal, independence of oversight, and the importance of introducing new perspectives to support effective governance in the public interest. Reversing this policy now represents a significant step backward from those standards. Extended term limits increase the risk of governance stagnation, entrenchment of power, and groupthink—particularly in a regulatory context where independence, accountability, and transparency are paramount. A six-year maximum already provides ample time for directors to develop governance competency, contribute meaningfully, and provide continuity, while still ensuring regular renewal of ideas, skills, and perspectives. The assertion that extending term limits is necessary for effective governance is not supported by prevailing governance literature or regulatory best practices. Concerns cited in support of the proposal—such as succession planning, committee capacity, and continuity—are governance management issues that should be addressed through stronger recruitment, onboarding, mentoring, and committee support structures, rather than by lengthening individual tenures. Structural or operational challenges should not be solved by reducing turnover and accountability at the Board level. Importantly, extending term limits also risks undermining public confidence in the College. Regulatory bodies derive legitimacy not only from expertise, but from visible independence and renewal. Longer tenures can create the perception—whether intended or not—of insularity and self-preservation, which is particularly damaging for an organization whose mandate is to regulate in the public interest. If the College nevertheless proceeds with increasing the maximum term length, it is critical that any change not apply to current Board members. Applying extended term limits retroactively would be inherently self-serving and inconsistent with good governance principles. Best practice dictates that changes to term limits apply prospectively only, allowing current directors to complete their service under the rules by which they were elected or appointed. Anything less risks further eroding trust and raising legitimate concerns about conflicts of interest. In summary: The six-year term limit already aligns with governance best practices and should be retained. Governance challenges should be addressed through improved systems, not extended tenures. Extending term limits risks reduced accountability, weaker renewal, and diminished public trust. Any change, if adopted, must apply only to future Board members and not to the current Board. For these reasons, I strongly urge the College to maintain the existing six-year term limit and focus instead on strengthening governance processes that support effective, accountable, and transparent regulation in the public interest.
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.