About > Consultations > Public Consultation on Proposed Learning Requirements for Selected High-Risk Expanded Scope Activities

Public Consultation on Proposed Learning Requirements for Selected High-Risk Expanded Scope Activities

Feedback deadline is: 4:00 PM on May 31, 2026

OCP is seeking your input on proposed learning requirements for selected high-risk expanded scope of practice activities.  The consultation closes on May 31, 2026, at 4:00 p.m. EST.  

Background  

At its December 2025 meeting (see page 244 for details), and following a request from the Minister of Health, the OCP Board of Directors approved regulations that would authorize pharmacists to prescribe for an additional 14 minor ailments and to administer injectable buprenorphine extended-release (Sublocade®), among other activities. These regulations were subsequently submitted to the Minister. At the time of this consultation launch, the government has not yet authorized the proposed expansion of scope activities. 

Informed by a risk analysis of the expanded scope of practice activities included in the regulation package to the government, the OCP Board also determined at its December 2025 meeting that certain expanded scope activities (assessing and prescribing for acute pharyngitis, otitis externa, herpes zoster, and the administration of Sublocade) may pose a higher risk to the public if not managed appropriately. Accordingly, it resolved that it is in the public interest to establish learning requirements for these specific activities in order to ensure pharmacists have the knowledge, skills, abilities and competence to engage in them safely.    

At its March 2026 meeting, and based on direction provided to staff in December 2025, the OCP Board approved for the purposes of consultation a series of learning requirements for pharmacy professionals who might engage in these higher risk activities, along with a proposed self-declaration process. Members of the profession, system partners, and the public are invited to comment through this open consultation, which ends May 31, 2026 at 4:00 p.m. EST.

What are the Proposed Learning Requirements?  

  1. The proposed learning requirements for assessing and prescribing for acute pharyngitis, otitis externa, and herpes zoster, are listed on pages 2-3 of the draft Guidance – Requirements for Engaging in Specific Minor Ailments.   
  1. The proposed learning requirement for the administration of injectable extended-release buprenorphine (Sublocade®) is the completion of the manufacturer’s certification program. This program is free of charge and can be completed in under 30 minutes.  

 Exploring self-declaration as an appropriate way to assure requirements are met 

The College has proposed that each activity’s respective learning requirements are self-declared through the registrant’s online OCP profile, similar to past declarations related to completion of the Minor Ailments Module, with the expectation that the need for these declarations would be reassessed as the new scope becomes standard practice.  Proposed declaration statements are available under “Helpful Links”. 

What are we consulting on?  

The purpose of this consultation is:  

  1. To obtain feedback on the draft mandatory learning requirements for specified minor ailments (acute pharyngitis, otitis externa and herpes zoster) as outlined in the draft Guidance –  Requirements for Engaging in Specific Minor Ailments
  2. To obtain feedback on the proposed requirement that a pharmacist must complete the Sublocade™ Certification Program prior to administering extended-release buprenorphine (Sublocade®)
  3. To obtain feedback on the value and proposed declaration process of confirming that pharmacy professionals have met these requirements as outlined in the corresponding draft revised documents:
    1. Draft Revised Pharmacist Prescribing: Initiating, Adapting and Renewing Prescriptions Guideline
    2. Draft Revised Administering a Substance by Injection Guideline 

When providing your specific feedback, please consider these questions:  

Learning Requirements:  The Process for Determining How Learning Requirements Are Met:  
1. To what degree will mandatory learning requirements for the specified higher-risk minor ailment activities promote the public’s confidence in the ability of pharmacists to consistently perform these tasks safely?  

2. Are there potential drawbacks or concerns with mandating learning requirements for pharmacy professionals who practice these activities? If so, what are they?   

3. What else must the College consider prior to moving forward with any mandated learning for those who plan to practice these activities?    
1. Should the College take additional or alternative steps to assure the public that any learning requirements established by the Board for specified higher risk minor ailment activities have been met?  

2. Would establishing a self-declaration mechanism, such as what is proposed in the draft guidelines, serve as an appropriate and effective way to assure the public that registrants engaged in these activities have the required learning prior to practicing them safely?
a. If so, please comment on the draft declaration requirement found in the associated guidelines (linked below)
b. If not, why not?   

3. What else must the College consider before making a decision?   

How You Can Provide Your Input   

You can submit your feedback using the online form below. Please allow 1-3 business days for your feedback to be published. 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.  

Feedback must be submitted by Sunday, May 31 at 4:00 p.m EST.    

The feedback we receive via the online form or email is published in accordance with our posting guidelines. Under the guidelines, the College has the right to refuse to publish or remove comments that do not meet the posting guidelines.  

 Next Steps   

 Information gathered from this consultation will be brought to an upcoming Board of Directors meeting for discussion and consideration for final approval.   

 Helpful Links  

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