Feedback deadline is: 4:00 PM on May 31, 2026
OCP is seeking your input on proposed learning requirements for acute pharyngitis, otitis externa, herpes zoster and the administration of buprenorphine extended-release (Sublocade®). 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 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?
- 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for assessing and prescribing for acute pharyngitis, otitis externa, and herpes zoster, are listed on pages 2-3 of the draft Guidance – Requirements for Engaging in Specific Minor Ailments.
- 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:
- 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
- To obtain feedback on the proposed requirement that a pharmacist must complete the Sublocade™ Certification Program prior to administering extended-release buprenorphine (Sublocade®)
- 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:
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 acute pharyngitis, otitis externa, herpes zoster and the administration of buprenorphine extended-release (Sublocade®) 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 the specified minor ailment activities noted above 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.
Read The Feedback
Since the expansion of pharmacists’ scope to include assessment and prescribing for minor ailments, the expectations placed on frontline pharmacists have increased significantly. However, the operational, regulatory, and compensation frameworks surrounding these services have not evolved in parallel. This has created a growing gap between what pharmacists are being asked to deliver and the resources, protections, and remuneration available to support this work. 1. Inadequate Staffing and Unsafe Workload Pressures Many corporate pharmacy environments (Shoppers) have reduced technician and assistant hours despite the increased clinical responsibilities now required of pharmacists. These staffing reductions are often attributed to head office labor‑budget directives. As a result, pharmacists are frequently left working alone or with minimal support during peak hours while being expected to manage both dispensary operations and minor ailment assessments. Unlike medical clinics, pharmacies do not have receptionists or triage personnel to manage patient flow. When a pharmacist is already operating at maximum capacity, there is no mechanism to safely decline additional assessments without facing patient frustration or complaints. This places pharmacists in an untenable position and creates conditions that are not conducive to safe, high‑quality care. 2. Lack of Appropriate Clinical Infrastructure Most community pharmacies do not have dedicated clinical spaces or workflow systems designed to support medical assessments. Walk‑in patients often stand at the consultation counter requesting treatment for conditions such as UTIs or conjunctivitis, expecting immediate service. This environment is not aligned with the standards of privacy, assessment time, or clinical focus required for safe prescribing. 3. Compensation and Billing Inequities Currently, pharmacists perform assessment, diagnosis, documentation, and follow‑up for minor ailments, yet the compensation model does not reflect the level of responsibility or clinical risk involved. Physicians bill OHIP/ODB directly for comparable services at significantly higher rates, whereas pharmacists often receive no direct compensation. In many corporate settings, the payment flows to the business rather than the clinician providing the service. If pharmacists are to function as accessible primary care providers, the compensation model must be revised to allow direct billing to the pharmacist, subject to audit, similar to other regulated health professionals. 4. Need for Stronger Regulatory Oversight Given the rapid expansion of minor ailment services, I respectfully request that OCP consider implementing clearer regulatory requirements, including: minimum staffing standards when minor ailment services are offered mandatory dedicated clinical space for assessments guidelines allowing pharmacists to defer or decline assessments when workload compromises safety oversight of corporate practices that may pressure pharmacists to provide services under unsafe conditions structured training and competency requirements for all staff involved in minor ailment workflows advocacy for a fair and sustainable compensation model that reflects pharmacists’ clinical responsibilities Pharmacists are committed to supporting patient care and expanding access to essential health services. I personally welcome the opportunity to take on greater clinical responsibilities. However, the current system places disproportionate burden and risk on pharmacists without the necessary structural, financial, or regulatory support.
The College needs to go beyond a self -declaration mechanism in order to assure the public that registrants engaging in specified minor ailments prescribing and administering Sublocade are doing so safely, particularly since these have been identified as posing higher risk than other expanded scope activities. Mandatory learning and evaluation are recommended that test pharmacist knowledge, judgment, diagnostic ability, and in the case of Sublocade administration, hands on skills including assessment of potential adverse skin reactions.
Why is OCP reinventing the wheel? Just look at BC minor ailments. Those are actually minor ailments and a course is provided free of charge. Otitis externa and Strep throat are not minor ailments, these require physical assessment (= NOT MINOR) and should not be mandatory. How will OCP distinguish to the public that some minor ailments are mandatory and some are not? Without a high quality diagnositic platform and no full assess to patients chart = MEDICAL ERRORS and MISDIAGNOSES!!! Will it be clear to the public that physical assessment is required, a patient already called me this morning for a “refill” of her ciprodex and could it be delivered? She has the same symptoms as last time, why does she need to be assessed? She’s housebound. Etc etc etc. Customers are demanding when they are paying. This is not the right environment for antimicrobial stewardship and complex physical assessments. Like others have said, the customer is always right. I will just give oral and topical drops to all because I am not going to be held liable for missing otitis media coinfection. Everybody gets amoxicillin for strep! Let the resistance begin!
Serving patients when they need urgent care is a truly rewarding experience. The expanded scope for minor ailments will undoubtedly make a massive difference for the people of Ontario; there is no question about the positive impact it will have on community health. Regarding the discussion on additional training, while some feel that university studies should suffice, there is a strong argument for continuous learning. Human cognition and memory naturally shift over time, and regular reinforcement is essential to stay sharp and prevent errors. Staying updated isn’t just about learning new facts; it’s about refining judgment to ensure the highest standard of safety. To support this transition, it would be beneficial if the College provided a standardized, high-quality diagnostic platform for all practitioners—similar to the tools used at Shoppers Drug Mart, or perhaps even more robust. Since the College already collects renewal fees, a slight adjustment to fund a province-wide, uniform platform would be a worthwhile investment. Having one consistent system would create a significant, positive impact across the entire province, ensuring every pharmacist has the best tools available to provide top-tier care.
THIS DEFINITELY HAS TO BE OPTIONAL. THE PHARMACISTS SHOULD DECIDE WHETHER THEY WANT TO PARTICIPATE OR NOT. ANY CORUSE SHOULD BE ACCOMPANIED WITH APPLIED PRACTICAL TRAINING (WITH REAL PATIENTS). SIMPLY COMPLETING A THEROTECIAL COURSE IS INADEQUATE. PHARMACISTS SHOULD BE RESPECTED FOR THEIR EXTREMELY BUSY SNHIFTS AND MAY NOT BE AVIALABLE TO ATTEND TO THESE AILMENTS AND EXAMINING PATIENTS. I AM NOT SURE THIS A STEP IN THE RIGHT DIRECTION.
Once again, OCP is putting the cart before the horse. In hospital pharmacy, I was one of the first champions of eliminating pharmacy assistants and hiring only regulated pharmacy technicians. This freed up the pharmacists to do their clinical role. I believe that OCP should first mandate only regulated pharmacy technicians in the community and offer a practical bridging program THEN the pharmacists would be available to perform a clinical role.
I have no doubt that I could accurately diagnosis and treat all those minor ailments, given sufficient time, education, resources and payment structure. Physicians are given 20 minutes usually to do the exact same assessment and we would be expected to do this all in a 1 min consult over a pharmacy counter while other patients wait to get their prescriptions checked.Also without access to the patient full medical history and without proper diagnosis tools with patients who often know how to hide red flags. However, unless this is mandated (which it is not) I absolutely cannot in a high volume competitive money driven pharmacy while checking hundreds of prescriptions and dispensing methadone. I currently inject sublocade after doing a ridculous online course and had to learn by trial and error not to hurt and bruise the patients. Online modules do not teach hands on skills that require clinical supervision under the guidance of experienced practitioners. I have zero desire to increase my professional liability when my hourly rate of pay will stay exactly the same. Yet, patients will threaten to take their prescriptions elsewhere unless given exactly what they want for their minor ailment the moment they want it. Physicians can book appointments and take 2 weeks and charge fees to renew prescriptions yet we are expected to do all those same things. ONtario should be looking at the Quebec model where labour and work load for pharmacists are regulated. That would be actually “protecting the public” by insuring that pharmacists have time to do their job properly and not sucuumbing to the corporate pressures and ministry of health funding reductions that they are supposed to be protecting the public from! Shame on OCP!
Just reading through the comments. Have to say I agree with the comments from April 7th and April 14th re: appointments and medication errors/management. Our approach to patients has to change. We need to focus on providing pre-existing services at a higher standard rather than taking on random ailments. Basically, pharmacists are looking for appointment structures to manage the workload – the number one issue in the profession, and the OCP wants us to take on more patients off the street without appointments. Also I have worked in Australia. It is insane that Salbutamol is not OTC yet, but I can buy 4 bottles of Benadryl without seeing a single human being (self-checkout)
I agree with mandatory training with no cost and with option to pharmacist to decline same like injection training.
Mandatory training is needed . And on hands training for special injections , online courses are not enough.i would prefer something organized by U of T or University of Waterloo.
I disagree with some of the phrasing within the document entitled – GUIDANCE – Requirements for Engaging in Specified Minor Ailments Specifically regarding the examples of CCAP programs, CCCEP accredited courses for education and training. I believe these competencies can simply be learned through self teaching (e.g. reading an up to date version of JT Dipiro’s Pharmacotherapy or even therapeutic choices. I find the college unnecessarily promotes programs that are high cost, and there is little acceptance that pharmacists can seek out information on their own to learn new skills.
I believe it’s a great initiative. We can already see patients are getting benefit from minor ailments and adding otitis externa and phyrangitis in the list will definitely make live of patient easy and also benefit to reduce the burden on physicians. Looking forward to hear a great news on it.
I am in favor of the expansion of the Minor Ailment Program. I’m not in favor of the remuneration professional pharmacists are getting paid. Pharmacist are making and continue to make significant positive impact on OHIP and MOH by savings Millions of Health Care dollars by preventing Ontario citizens from accessing these Minor Ailments from the ED Department in hospitals. For example, for a typical, uncomplicated case like a UTI treated and discharged from the emergency department, the Ontario Ministry of Health is generally paying on the order of ~$300–$500 per visit. Why are pharmacist getting paid $15 to $19.00!! This is actually insulting! Why should pharmacists continue to offer their services for almost free to the MOH? This is something which requires a change ASAP!
I would strongly encourage OCP and fellow pharmacists to read the CBC series on pharmacist medication errors across Canada before mandating additional mandatory minor ailments. OCP is modeling minor ailments after other provinces, yet where is the evidence that this actually reduces burden on physicians? There is evidence that additional workload and burnout increases medication errors! https://www.cbc.ca/news/gopublic/pharmacists-prescriptions-medication-errors-near-miss-health-canada-9.7156873 You can say “book appointment” all you want but what help will appointments make for a solo pharmacist working alone? PLEASE LET US JUST DO OUR JOB TO REDUCE MEDICATION ERRORS AND COUNSEL PATIENTS ON MEDICATIONS!!! Do not make this mandatory – if other pharmacists have practices that allow them thats fine but I don’g
Subject: Feedback on Proposed Learning Requirements for Expanded Scope Activities Thank you for the opportunity to provide feedback on the proposed learning requirements. While the intent to improve patient access is appreciated, the proposal does not fully reflect the realities of community pharmacy practice. Pharmacists are currently managing high prescription volumes, limited staffing, and multiple competing responsibilities. Introducing higher-risk activities, including more complex assessments and Sublocade administration, without addressing these constraints may affect the ability to provide care safely and consistently. There is also concern regarding the corporate practice environment, where new clinical services can become performance targets. Previous experience with MedsChecks has shown that pharmacists may face pressure to meet quotas. Expanding into more complex and higher-risk services may lead to similar pressures, where care risks becoming volume-driven rather than based solely on clinical need. In addition, these activities require meaningful time for proper documentation and follow-up. Thorough assessments must be documented clearly, and appropriate follow-up with patients and prescribers is necessary to ensure safe outcomes. In current practice settings, pharmacists often do not have sufficient protected time to complete these responsibilities to the standard expected, which may impact continuity and quality of care. Learning requirements alone may not be sufficient to ensure safe implementation. Adequate time, staffing, workflow support, and safeguards against inappropriate performance expectations are essential to support pharmacists in delivering these services responsibly. Consideration of these factors would help ensure that any expansion of scope is implemented in a way that supports both patient safety and professional judgment.
I think there needs to be a mandatory learning requirement via individual, accredited courses for each high risk condition to promote the public’s confidence in the ability of pharmacists to consistently perform these tasks safely and also ensure a standard level of competency in regards to these conditions. As someone who works at a high volume, corporate retail pharmacy, one concern I have is the added workload with probably no additional pay. Maybe this can rolled out as an additional certification (i.e. Diabetes educator), in which can be optional as per each professional.
Let’s be real here, this is just a formality. There is no way OCP or big box stores are going to listen to any of this feedback. I have already seen Shoppers put out signs with pharmacists assessing a child’s throat! If it’s self declaration I will lie. I am not paying a single red cent for any of these courses when my return on my investment is exactly zero dollars. I already inject sublocade and get $0 from the government for administration fee. When customers come in for a “UTI”, my assessment is “What antibiotic do you want this time” and I give it to them. I will do the same for strep, OE, shingles whatever. Because I can’t afford $3000 complaint to OCP! I am eagerly waiting to see the first pharmacist charged with malpractice or refusing to give an antibiotic. There will be ZERO ability to say no to customers because they do not view themselves as patients when they are paying for a prescription!
The College is in an appropriate position to mandate specific continuing education courses to ensure competency in the suggested Minor Ailments. With successful completion of an approved continuing education course, a declaration would provide confidence to the public. However, do NOT mandate these courses to every licensed pharmacist. Allow these professionals to explore their own healthcare path. If they choose to take some or all of the courses then they can provide those services, but allow them the choice NOT to take these courses and to then NOT provide these services. These are educated professionals, let them exercise their free will.
I welcome the debate on expanding practice in the province. However, I feel these are steps in the wrong direction. Right now: 16% of all hospital admissions are related to poor medication management As many as 30% of dementia patients manage their own medications Only 25% of patients are counselled on the side effects of their medications All these issues exist, but our discussion is whether we should be examining people’s ears and diagnosing shingles? There are more simple, easy ways to help physicians: Salbutamol inhalers have been OTC products in Australia & New Zealand for 20 years, with a large body of evidence to support the practice. Why are we wasting physician time, when the evidence to support pharmacist involvement already exists. Counselling is abysmal in the province. With reports of pharmacists filling over 400 scripts per shift, how are they able to provide 10 minutes of counselling to every patient, which is the gold standard in literature. If we focused on doing this properly we would be preventing hospital admissions, and creating a lot more value for patients, engaging them in their health decisions. We are the only health profession that does not do appointments. Mandating appointments would manage the insane workload that community pharmacists have to deal with and ensure that counselling actually happens and pharmacies are appropriately staffed.
Big corporations like Shoppers make the system (Health watch) smart for assessment (this would be true for diagnosis in case of strep throat and ear infections or whatever ailments need proper diagnosis) as more and more minor ailments are approved. The associates are reducing the hours for the assistants and technicians as everyone says it’s pressure from the head office. But you can’t tell that to the patient if someone comes during peak hours or when a pharmacist is working alone. The only option for the pharmacist is to make an excuse to decline the services or to take on extra burden to avoid client frustration as their is NO receptionist like in doctor office saying we are NOT taking any more patients. Here the pharmacist has to face all these issues and their frustration. Doctors bill ODB directly which is much higher than what the pharmacy is getting and the worse part is that’s going into the associate/corporation pocket no matter the risk and burden was taken by someone else. I don’t mind taking extra responsibilities and going to the next level for the patients BUT the compensation model needs to be revised as this was NOT part of the university curriculum to provide assessment, diagnosis and to get paid nothing for these extra services. There should be direct billing for these services that goes to the pharmacists (subject to audit) and enough staff with structured learning and training. The pharmacy should have a separate area to accomodate all minor ailment appointments, as most of the time walk in patients stand at the consultation area and demand medications for UTI or pink eye, as they it’s much easier to get it from the pharmacy than through a clinic. OCP should make minor ailments in the pharmacy more regulated for the safety of the patients and pharmacist as I don’t see any initiative for direct billing, pay and regulating the big corporations enough on these areas.
Additional education would be very helpful to empower pharmacists to provide assessments for the new minor ailments with utmost confidence. However, with the advent of modern technology especially after COVID times, there should be more flexibility to allow finish the supplemental training. Online training solutions are widely available and should be an acceptable form of training. For example, UofT pharmacy students were given state of the art e-platforms to complete assessments for range of motion and lung auscultations during the peak pandemic to complete their learning outcomes. Feedback received from the affected cohorts expressed this learning approach was easy to use, accessible, comfortable, and more flexible. Similar platforms exist for otoscope use and pharyngeal swabs; moreover, oropharyngeal swabs were already conducted by pharmacists during the peak demand of SARS-COV-2 throat sample collection for PCR testing, and for COVID-19 RATs. Restricting training to in-person modules may pose hindrance to completing training in a timely manner and significantly strain rollout of the scope expansion to most pharmacists eager to practice at their fullest scope. Training should be as accessible to the pharmacist as pharmacists are accessible to patients.
I think self declaration is a poor substitute for actual hands on training . If we are going to be required to use an otoscope correctly there must be an assessment of that by another trained professional . And that goes for throat swabbing too. If we as professionals can make the time for hands on injection training , we can make the time to attend a session for this too. To say that we are too busy is a copout – if we want to provide this service we will make the time available to be trained properly. And if we want physicians to respect our role in minor ailments we need to at least demonstrate a substantive level of training. Personally I have no interest in doing either of those assessments , or in injecting Sublocade. Professional burnout due to heavy dispensary workload plus minor ailment prescribing is very real. There must be some regulation of staffing levels to accomodate the growing list of minor ailment activities to prevent the deterioration of other pharmacist duties . As a profession committed to patient safety , we need appropriate pharmacist staffing in place to prevent harm. We cannot rely on owners to put that staffing in place. At some point OCP needs to get involved in that and provide some direction.
No to anything needing antibiotics. Even UTI is a stretch.
There are many varieties of pharmacists, but there needs to be a minimum standard of care to ensure the public trust. No pharmacist should be mandated to provide these assessments, however I believe those who wish to should complete a course. Whether the pharmacist self-declares competence through CE or completes a mandatory course is not something I have taken a side on. With that said, if those courses are mandated, they should not cost the pharmacist any money. The training is for the public benefit and to ensure the public trust, and thus should be publicly funded.
As a relief pharmacist, having worked in many different pharmacies, rarely it there enough staff support or time to do all these extra minor ailments. Patients come in expecting instantaneous service which is usually not able to be accommodated. Patients are learning the system to get what they want. Once I made a referral due to a red flag and the patient responded that next time she would know how to answer that basically insinuating that she would lie to get the prescription. Another patient said that she knew enough time had passed since the last time she came for this, so the pharmacist would have to give it to her. I would rather have these addition minor ailments regulated to a dedicated clinical pharmacy appointment style to ensure enough time for each assessment, easing the pressure and workload off of the pharmacist which would ensure more safety for the patient. In most every pharmacy I have worked relief, I have still had to go to the cash register and count pills at times yet somehow there will be an expectation there will be adequate time and resources to do over 30 minor aliments. For the safety of the pharmacist and patients, there should be some kind of regulation to allow for adequate time and resources such as mandating a ratio of assistants and technicians to the number of pharmacists and minor ailments. OCP needs to protect the pharmacists as well against unrealistic pressures and burn out.
I reject this proposal. What do pharmacists gain from increased work load? Let someone else deal with it. Pharmacists have a lot more on their plate than we can chew.
A self-declaration strategy is not sufficient in ensuring licensed pharmacists are adequately prepared and competent to provide the new scope of activities. There should instead be a mandatory learning assessment and subsequent certification for pharmacists who pass this learning assessment.
Dear OCP, First, I absolutely support the motion to expand the scope of practice for Pharmacists to cover these areas as it would be very beneficial to the general public and improve our clinic skills. I feel really sorry for patients that needs treatment especially on weekends (when most doctors are closed) or when they don’t have family doctor and cannot afford to use the various online clinics. These expanded scope would really be accepted by the public. Next, as a UK and Canadian licensed Pharmacist, I can share some ideas. In the UK, Pharmacists are currently provide these services and prescribing antimicrobials for Shingles, Otitis Media, Acute Pharingitis, UTI, Insect Bite among others and the scope is expected to expand. When the program was launched in the UK, as expected there were many opposition and concerns from Pharmacists, Physicians, etc, however, the public embraced it and it is going very well. Training were mandatory and the Pharmacist has to self declare at the end of the training that they are competent and willing to provide the services. Employers were mandated NOT to compel Pharmacists to provide these services. This allowed Pharmacists to freely decide what they wanted to do. The program is currently in the 2 year now, most of my UK Pharmacist colleagues that were not initially interested to provide these services are now championing it. Learning and relearning is never too much. Yes, Pharmacists do have these knowledge, however, updating it is not a bad idea. Mandatory training would boost public confidence, prevent avoidable errors (mistakes) and improve the overall process. The world is changing rapidly. The global trend is clinical Pharmacist. Traditional dispensing is no longer enough to meet the growing health gap. Pharmacists do have a vital role to play. Absolutely, I appreciate and understand some Pharmacists would not want anything clinical. They want to stick to the traditional dispensing role. Let us not force them. Roll out the scope of work. As it progresses and successful, others would join. Thank you.
am generally supportive of the expanded scope of pharmacy practice. I believe that if educational programs are offered free of charge and participation remains optional, I would certainly be interested in taking advantage of those training opportunities. However, regarding the implementation of these services within the pharmacy setting, I believe it is time to reconsider the compensation model. While pharmacies may receive funding from the government for providing these minor ailment or expanded services, pharmacists themselves do not directly benefit from this increase in responsibilities. As the number and variety of services we provide continue to grow, our compensation as pharmacists has remained unchanged for many years. If a portion of the funding allocated for these services could also be directed toward pharmacist compensation, it would create a much stronger incentive for pharmacists to fully engage with and support the expanded scope. If this issue is addressed, I would be fully supportive of expanded scope services and would be willing to complete the necessary training programs, even if they are offered outside of regular working hours.
As per the many comments made already, Sublocade should be restricted only to OATC/ACT/Methadone clinics. Indeed further training is required for these ailments for which the College should be providing at no charge for all registrants. Further to this, all pharmacies wishing to engage in this activity should be inspected and approved with this being listed on OCPs website as they do for methadone providers. Sites need to show they have the space, capacity, staffing and workflow to safely and effectively provide this service to the public. Some pharmacies who use different software may not have access to the proper tools for differential diagnosis. Should this not also be part of the College’s directive to provide registrants with the right tools for these higher risk minor ailments to enable safe patient care?
I agree with the proposal as it is set out. Pharmacists have the necessary background to expand their scope and extra training will help insure public trust and pharmacist confidence. However, I believe that expectations need to be better layed out to the public and other health care providers about what a pharmacist can do. The greatest misconception I hear from the public is that we are now just dispensing medications for minor ailments without assessment. That these medications have essentially taken the place of a schedule 2 drug; that they are available without a prescription but must be kept behind the pharmacy counter. The disconnect between expectation and reality needs to be better addressed for the safety of pharmacists and the public. I should be able to feel that I can deny a patient a prescription, refer them to the appropriate provider, and not fear retaliation on the part of he patient. Essentially, we need better PR!
With proper set up in the pharmacy and continuous learning, I believe this would be a great opportunity for all the pharmacists in Ontario. This will help streamline our healthcare system, as at present patients have no choice BUT to wait in ER for what a pharmacist can help. Most of us know what Rx a patient is getting from the ER after a long wait. This would provide an opportunity for better patient care especially during weekends, and stat holidays. The scope would expand to consider skin conditions (infections from S.aureus, burns etc.) where almost every physician prescribe Cephalexin course and Flamazine for burns.
One question is , does Pharmacy need to do this? We are busy already!!!! WE are doing 16 minor ailments already! Sheesh! If A Pharmacist needs to be educated more than the payment for that minor ailment should be higher or forget about it! I’m not working harder and getting paid less!
Hi, I worked in a minor ailment clinic. I’m a big advocate of pharmacists prescribing. PHARMACISTS NEED TO THINK EXACTLY LIKE A DOCTOR. ITS THE SAFEST AND MOST EFFECTIVE WAY TO GET THE BEST TREATMENT FOR THE PATIENT. The scenario and thought process a pharmacist faces at 7 pm on a sunday is exactly the same as a doctor. don’t make it “easier” and “lighter” for pharmacists. Pharmacists should know all DIFFERENTIAL DIAGNOSES, and what likelihood ratios (BS podcast talks about this) are. Everything. This will take a lot of studying, fine. That’s the way to go. The more learning the better for the patient, or else you get “hmm not sure, let’s give a steroid cream and see what happens”- exactly what you don’t want. learningshould be Not from “weak” Resources, the resources need to be WRITTEN BY PHYSICIANS, who have experience with hundreds of real patients. Not someone from . example, Pearhealth, who’s read the chapter in minor ailments book and then made a few slides. thank you BScBiochem, BScPharm,
We use Medessist’s access to care system to treat strep throat (works through medical directives). When following the centor score assessment through their system it has been easy to implement. We have many people get screened and very few qualify for the swabbing. Rolling this out more broadly should ensure more appropriate use of antibiotics and better access for those who need treatment. Broad view of expanding scope: I feel the ability to expand our scope safely is primarily determined by the ability of the secondary software market to access our current patient data. If we don’t push the legacy systems (Kroll, Propel…etc) to allow us to access to reasonably priced APIs then the workflows become inefficient, the variation in service levels between pharmacies increases and more errors will occur. There’s so much potential to unleash in the pharmacy profession, but I feel that access to our data is the bottleneck that will hold us back.
I am writing in response to the consultation on proposed learning requirements for selected high-risk expanded scope activities. I respectfully oppose the introduction of additional mandatory training requirements for pharmacists in order to perform these expanded scope activities. Pharmacists in Ontario already undergo extensive university-level education, national board examinations, and ongoing continuing professional development requirements to maintain licensure. This training includes pharmacotherapy, patient assessment, and clinical decision-making. The proposed additional requirements risk duplicating competencies that pharmacists are already expected to possess and demonstrate in practice. Imposing further mandatory training may create unnecessary barriers to care, particularly at a time when the healthcare system is facing significant access challenges. Community pharmacists are often the most accessible healthcare professionals, and requiring additional certification could delay or limit the availability of timely treatment for patients, especially in underserved or rural areas. It is also important to recognize that pharmacists are regulated professionals who are already held to standards of professional judgment, accountability, and scope limitations. Pharmacists are expected to practice within their competence and to refer patients appropriately when a condition falls outside their expertise. This existing framework provides a flexible, patient-centered safeguard without the need for prescriptive additional training mandates. Furthermore, mandatory training requirements may impose financial and administrative burdens on pharmacists and employers, which could discourage participation in expanded scope services altogether. This would ultimately undermine the intent of improving access to care. A more balanced approach would be to: Continue relying on pharmacists’ professional judgment and existing competencies Encourage voluntary continuing education rather than mandating additional certification Provide guidelines and resources instead of rigid training requirements In conclusion, while patient safety must remain a priority, the current regulatory framework already ensures that pharmacists practice responsibly and within their competence. Additional mandatory training requirements are not necessary and may inadvertently reduce access to important healthcare services. Thank you for the opportunity to provide input on this important matter.
I do not want to do any of the activities listed. I vote “NO” to all.
Dear OCP, The expanded scope of acute pharyngitis would be very beneficial for the public health. Where a boundary for additional training is important is Sublocade due to the higher risk nature of the activity if done incorrectly. I would reserve this for specific locations (i.e OAT Methadone/Suboxone clinics) where every pharmacist must have specific training and skills, and must require subspecialized training such as post-graduate residency or training that is self-registered and initiated because not everyone is ready nor comfortable with injecting suboxone and would be a significant barrier in pharmacist uptake and consentual agreement if it was a mandatory requirement for employment because pharmacy schools do not routinely train pharmacists on this (as well as the significant risk danger profile) and according to general consensus across the profession, the current pharmacists are already hesitant to uptake minor ailments prescribing (which I fully support) which is already a major step and improvement. I would continue to add towards minor ailments prescribing, but am hesitant to add injectable sublocade to that may cause patient harm and barriers. Also OATC clinics typically have a physician right next to them on site which allows for ease of Sublocade adjustments if there is a drug therapy problem when the clinic, pharmacy, and doctor are all open or if the physician decides to prescribe something else entirely. The significant concern is if a patient came into an arbitrary Walmart or Rexall pharmacy at 9pm on a Friday night with no medical history demanding for last minute Sublocade injection and say there was a genuine drug therapy problem that cannot be reconciled due to the timing if the OATC physician is not available. The major concern is that patients will start routinely demanding for last minute / lack of clinical context service at random pharmacies at random times more frequently if this were to become live, without the ability to clinically check appropriateness or safety or context with the OAT doctor, and/or that pharmacist is not fully trained in it, leading to potential patient harm.
The expanded scope of acute pharyngitis would be very beneficial for the public health. Where a boundary for additional training is important is Sublocade due to the higher risk nature of the activity if done incorrectly. I would reserve this for specific locations (i.e OAT Methadone/Suboxone clinics) where every pharmacist must have specific training and skills, and must require subspecialized training such as post-graduate residency or training that is self-registered and initiated because not everyone is ready nor comfortable with injecting suboxone and would be a significant barrier in pharmacist uptake and consentual agreement if it was a mandatory requirement for employment because pharmacy schools do not routinely train pharmacists on this (as well as the significant risk danger profile) and according to general consensus across the profession, the current pharmacists are already hesitant to uptake minor ailments prescribing (which I fully support) which is already a major step and improvement. I would continue to add towards minor ailments prescribing, but am hesitant to add injectable sublocade to that may cause patient harm and barriers. Also OATC clinics typically have a physician right next to them on site which allows for ease of Sublocade adjustments if there is a drug therapy problem when the clinic, pharmacy, and doctor are all open or if the physician decides to prescribe something else entirely. The significant concern is if a patient came into an arbitrary Walmart or Rexall pharmacy at 9pm on a Friday night with no medical history demanding for last minute Sublocade injection and say there was a genuine drug therapy problem that cannot be reconciled due to the timing if the OATC physician is not available. The major concern is that patients will start routinely demanding for last minute / lack of clinical context service at random pharmacies at random times more frequently if this were to become live, without the ability to clinically check appropriateness or safety or context with the OAT doctor, and/or that pharmacist is not fully trained in it, leading to potential patient harm.
The college should absolutely require additional mandatory learning for the proposed minor ailments and Sublocade injection. These ailments and procedures are higher risk and require greater assessment skills, and knowledge of current guidelines. The self-declaration method would be sufficient for ensuring completion. The college should additionally be providing an approved learning course at no cost. This is not to assure the public of our competency as pharmacists, but for the safety of the public. The rolling out of the minor ailments program, and ability of pharmacists to administer injections, has led the public to believe that we are able to prescribe for any type of condition and give any injection. Community pharmacists are regularly being pressured by the patient to provide prescriptions so that the patient can avoid the inconvenience of visiting their doctor, whether it is within our scope or not. In light of this, the college should reconsider adding prescribing for conditions such as herpes zoster which can potentially be dangerous if misdiagnosed.
I do not want to be forced to do a minor ailments I am not comfortable with. Example I do not want to do swabs of any kind. I do not want to be forced to expose myself to close contact with patients who may have Covid, RSV, or other upper respiratory conditions while they are seeking help for “pharyngitis”. I am primary care giver for my mother in a nursing home and do not wish to increase risk of infection. I see no consideration in the development of these higher risk minor ailments for the pharmacist. Doctors work in a very controlled environment taking appointments one at a time in an appropriate examination room. I believe some high volume pharmacy sites are not appropriate for certain minor ailment evaluation. Is there going to be college certification that each physical pharmacy site is appropriate for doing swabs? For example, a store i work at has only 1 patient assessment room that is approximately 4 feet by 3 feet. Simply put, I do not want to feel pressured by my employer to do these higher risk minor ailments. It is easy for me, as I am in a position where I can just retire. I feel for other pharmacists that may not afford the choice.
I think having mandatory education is great. I think the public will expect that and it is easy to do. We should all be doing education. I feel self declared is appropriate.
The discussion that needs to be had is whether these so called “minor ailments”, particularly acute pharyngitis and otitis externa, are feasible for pharmacists to assess and prescribe for. They are not. Enabling pharmacists to assess and prescribe for acute pharyngitis, and notifying the public of such change, will result in a torrent of ill patients at every community pharmacy demanding antibiotics even when their use is not warranted (e.g. in cases that appear to be of a viral etiology). I’ve had patients lambast and verbally assault me for refusing to prescribe antibiotics for other conditions when their use is precluded due to the presence of red flag symptoms that necessitated referral, even though not issuing a prescription is in the patient’s best interest in these cases. The College is all too happy to promote these scope expansions to the public without adequately educating them on their limitations. Additionally for otitis externa, my workplace, along with many other community pharmacies I’m sure, does not have a suitable layout to install an otoscope. Furthermore I myself would not feel comfortable using one and giving patients the false impression that pharmacists are now (far) more accessible alternatives to physicians.
I do not believe that Pharmacists can safely prescribe for Otitis externa as many of the symptoms overlap with Otitis media and require at minimum examination of the inner ear for proper diagnosis as per the Canadian family physician guidelines. As someone who has actively engaged in minor ailment prescribing, unfortunately I have experienced many instances where the patient will deny or misrepresent their symptoms to prevent the detection of Red flags and attain a prescription from me. Unlike with Pharyngitis, where a swab is diagnostic, pharmacists will not be able to definitively confirm the condition which will inadvertently lead to patient harm. I do not believe any further education on the pharmacists’ behalf will prevent this. The public is facing a shortage of primary care and frankly I do not think they are particularly aware or interested in how much learning the Pharmacist has to allow for safe prescribing. To them it is about convenience. It is the Colleges responsibility to ensure that these high risk prescribing Minor ailments do not lead to further patient harm. As for sublocade, due to the necessity of atleast 2 doses to curb withdrawals I believe for patient and pharmacist safety Pharmacists should not be administering the first or second dosing of this medication. Further more, specific criteria needs to be on place to ensure that patients are to return to the original prescriber if there are missed doses. The college should not prioritize patient convenience over treatment success in this scenario.
I would suggest that, until these particular scope expansions are common professional practice eg. 5 years, that the mandatory learning be assessed and proven to third party assessors eg. take an approved course, pass it successfully and submit the certificate ie. more than self-declaration. There is only one chance to get this right. I would further suggest that pharmacy employers prepare for staffing situations where some pharmacists are certified to perform these new assessments and some are (voluntarily) not. This sounds like a small obvious thing but having community pharmacist groups with different certifications and skills may be new to the work environment in Ontario.
We need to support our community and provide best care when it is needed. Yes it’s a great initiative. Patient doesn’t need to wait for weeks to see physician or wait in emergency room. I am excited and looking forward to more expanded scope of Pharmacist in future as well.
I think Mandatory learning for higher risk minor elements must be mandatory to achieve confidence in prescribers and pt. Courses outlined for that can achieve that purpose. Self declaration for that course can achieve necessity of requirement.
I support the proposed expansion of minor ailments and the introduction of mandatory learning for higher-risk activities, as it will help improve public confidence in pharmacists. However, I think self-declaration alone is not enough. Instead, there should be a short MCQ-based assessment for each new activity, such as strep testing or Sublocade administration, with at least a 90% passing requirement. This would make sure pharmacists are truly prepared and would add more transparency if this certification is reflected on their profile. I also believe that for services like strep testing, there should be a dedicated room separate from the regular consultation or injection area to reduce the risk of infection spread. Another important concern is compensation. Right now, although the government pays for these services, the payment usually goes to corporates and not the pharmacists actually providing care. Like other healthcare professionals, pharmacists should be compensated directly for the services they provide. This would be fairer and would also encourage better quality care and more willingness to take on these expanded roles. Overall, I agree with the proposal and would also like to see even more responsibilities added for pharmacists in the future, as we are trained and capable of providing these services safely.
Hello, Several states in USA has online CE being offered by state and free of cost to the pharmacist for such training. These one-time training online CE would be good option. Training would lose its importance if every new scope would require repeated training again and again. It would be like tax on tax. Adding paid training would add burden to pharmacist, and lot of pharmacists would prefer to avoid it which would directly affect public at large. It would also create confusion among people why one pharmacist can prescribe and the other can not. Thank you
I don’t believe , with the current load of work and lack of assistant hours, that we the capacity to perform these tests. The public always assumes any pharmacist can do it , and if a pharmacist refuses due to lack of training , they tend to get frustrated and that creates issues and lowers the trust they have in pharmacists I don’t believe it’s in the public best interest to have high risk conditions assessed by the pharmacist
With increasing numbers of patients presenting symptoms like pharyngitis and herpes zoster when timely intervention is crucial. I would be very interested to receive appropriate training to deal with these conditions. The public trust in pharmacists has increased significantly since the introduction of minor ailments. Pharmacists have the capacity and knowledge to offload our healthcare system and contribute in enhancing patient experience.
Let pharmacist do the max to their capacity . The health care way behind when it comes to what pharmacists can do compared to other provinces and countries . It will help us alot get treated instead of going through long waiting time at hospitals and or walk in clinics .
Due to the variable hours for all pharmacist, learning needs to be virtual. Ideally it needs to be set up so pharmacists are actively listening and learning. For initial roll out – can webinars be organized, cameras on, with participation? If not then virtual online tutorials work. I would suggest a mandatory refresh every 2-3 years that may not be as intensive as the original certification.
It is frustrating that, as a licensed pharmacist, the College and the Ontario government treat us as if we practice daily without meeting a certain standard to practice. This is seen with prior limitations placed on prescribing minor ailments (e.g. unable to prescribe anti-histamines for allergic rhinitis but being able to prescribe for urticaria) and is seen again with the required reading we must do to prescribe for future minor ailments. Do physicians need to take a course in order to prescribe each and every medication available? No. So why do we?
I appreciate concern about public safety. Of course patients are first. Pharmacists are highly trained but most underused health professionals. With scope being expanded, They should have the updated knowledge about everything including all ailments and consultations. Identifying higher risk ailments helps for sure. Great work is being done into right direction by expanding scope. This will ease the burden on health care system and will most definitely help the ailing humanity !
I agree with proposed training and declaration Addition continuing education credit can be done periodically to ensure pharmacist aware of any guidlines updates or further recommendations
I believe Pharmacists are capable of prescribing for conditions mentioned above and have ability to inject sublocade. This expanded scope will ease burden on doctors and allow prompt and easy care for patient.