Changes to the College’s Registration and Quality Assurance Processes

Why is the College eliminating the pharmacy student class of registration as of October 1, 2024?
To reduce the regulatory and administrative burden for students. Pharmacy has been the only health profession in Ontario with the requirement to register as a student.

Will the scope of practice change for pharmacy students when these regulation changes go into effect?
No. If you are enrolled in a pharmacy education program*, you can engage in any of the controlled acts within the scope of the pharmacy profession – including dispensing, selling and compounding drugs – under the supervision of a Part A pharmacist.  You can practice to scope during or outside of your program’s standard hours (i.e., on weekends and evenings) as long as supervision under a Part A pharmacist is maintained.

*Includes those enrolled in a CCAPP-accredited pharmacy education program, an ACPE-accredited pharmacy education program, or those enrolled in the approved bridging program (IPG program).

How will pharmacy students be supervised once the regulations are in effect?
Similar to other health professions, pharmacy students will practice under supervision based on authority laid out in the Regulated Health Professions Act. Pharmacy students* may perform the controlled acts that are within the scope of practice of the pharmacy profession provided they are supervised by a Part A pharmacist. For more information, refer to the Supervision of Pharmacy Personnel Policy.

*Includes those enrolled in a CCAPP-accredited pharmacy education program, an ACPE-accredited pharmacy education program, or those enrolled in the approved bridging program (IPG program).

I’m currently a registered pharmacy student with the College. What happens when the regulation changes are implemented on October 1, 2024?

• You will no longer:
  • Hold a Certificate of Registration as a student
  • Be listed on the College’s public register – a searchable database of registered pharmacy professionals and accredited pharmacies in Ontario.
  • Be required by the College to obtain personal professional liability insurance. Your employer or school may still require you to have insurance.
• You will continue to be able to:
  • Engage in any of the controlled acts within the scope of the pharmacy profession – including dispensing, selling and compounding drugs – under the supervision of a Part A pharmacist.
  • Register as a pharmacy intern once you have graduated and practice to scope under supervision.

Can pharmacy students be employed outside of their school’s co-op placement/experiential learning opportunities?
Yes. If you are a student enrolled in an educational program for the purposes of fulfilling the requirements to become a pharmacist*, you can engage in the scope of practice of the profession under the supervision of a Part A pharmacist or pharmacist (emergency assignment). This applies even if there is a break between your pharmacy courses.

*Includes those enrolled in a CCAPP-accredited pharmacy education program, an ACPE-accredited pharmacy education program, or those enrolled in the approved bridging program (IPG program).

What will the requirement for personal professional liability insurance be?
As of October 1, 2024, the College no longer requires students to hold personal professional liability insurance; however, employers or schools may require students to have insurance. Check with your school or employer if this is a requirement.

As of October 1, 2024, how current do my registration requirements need to be when I apply to be registered as a pharmacist?
You must complete registration requirements within two years before submitting a College application to be registered as a pharmacist. Registration requirements include:

• Proof of graduation from an accredited pharmacy program*
• PEBC Qualifying Exam*
• Language proficiency
• Jurisprudence, Ethics and Professionalism exam
• Practice-based assessment

*Applications must demonstrate currency of education (“current” means within 2 years before submitting a College application to be registered as a pharmacist). The PEBC Qualifying Examination requirement doesn’t expire; it can also be used as proof of currency of education if it has been completed within those two years. Currency of education can also be demonstrated by proof of graduation from an accredited pharmacy program within the two-year period before submitting an application; however, this does not exempt the applicant from completing the PEBC Qualifying Examination.

I’ve already paid my student registration fee with the College. Will I be reimbursed?
Registration as a student with the College remains a requirement for certain pharmacist registration pathways until the regulatory changes take effect on October 1, 2024. Registration fees already paid to OCP will not be reimbursed. This approach is consistent with all OCP registration classes – registration fees apply for any period of time the registrant practices or uses the protected title within the year.

Can pharmacy students administer the flu shot?  Yes, provided the pharmacy where the student is employed is participating in the Universal Influenza Immunization Program (UIIP), the supervising pharmacist has registered their injection training with the College, and the student has completed injection training.

It’s on or after October 1, 2024, and I’m in the process of completing Practice Assessment of Competence at Entry (PACE). Can I continue PACE now that there is no pharmacy student class of registration and I’m not registered with the College?
If you meet the below criteria, you will automatically become an intern and be able to continue PACE:

• Are in the process of completing PACE. “In the process” means you have begun (but not yet completed) either the PACE orientation phase, the PACE assessment phase, or the PACE development phase.
• Completed your education or bridging program (or the PEBC Qualifying Exam) within the past two years
• Meet all the intern registration requirements, including personal professional liability insurance, police background check, and declaration of good character

You will be issued an intern Certificate of Registration after College staff verify your requirements and process your intern registration fee.

If you do not meet the above criteria, you will be required to discontinue PACE. College registration staff can help guide you on your next steps. You can contact them at [email protected] orphone 416-962-4861 / 1-800-220-1921 ext. 3400.

July 18 information session – pharmacy students and pharmacy schools

I’m currently studying in a pharmacy technician program. How do these changes affect me?
As of October 1, 2024,

• You will continue to be able to engage in the practice of the profession if:
  • You are a student enrolled in an accredited pharmacy technician program*, and
  • You are acting under the supervision of a Part A pharmacist or Part A pharmacy technician

*Includes those enrolled in a CCAPP-accredited pharmacy technician education program or those enrolled in the approved pharmacy technician bridging program.

Can pharmacy technician students be employed outside of their school’s co-op placement/experiential learning opportunities?
Yes. If you are a student enrolled in an educational program for the purposes of fulfilling the requirements to become a pharmacy technician*, you can engage in the scope of practice of the profession under the supervision of a Part A pharmacist, pharmacist (emergency assignment), Part A pharmacy technician, or pharmacy technician (emergency assignment). This applies even if there is a break between your pharmacy technician courses. For more information, refer to the Supervision of Pharmacy Personnel Policy.

*Includes those enrolled in a CCAPP-accredited pharmacy technician education program or those enrolled in the approved pharmacy technician bridging program.

As of October 1, 2024, how current do my registration requirements need to be when I apply to be registered as a pharmacy technician?
Your registration requirements – including the Jurisprudence, Ethics and Professionalism exam, the practice-based assessment and the PEBC Qualifying Exam – must be completed within two years before submitting an OCP application to be registered as a pharmacy technician. Note that your PEBC Qualifying Exam results do not expire (i.e., they are valid indefinitely), but their ability to demonstrate currency of education does.

Once I graduate from my pharmacy technician program, what do I need to do to be able to practice in the profession?
As of October 1, 2024, pharmacy technician applicants will need to register with the College as an intern technician – a new registration class at OCP – to perform the authorized acts of the profession as you work to meet the practice-based registration requirements. Note intern technicians are not yet authorized to administer the influenza vaccine, respiratory syncytial virus (RSV) vaccine, or Coronavirus (COVID-19) vaccines.

You will be required to obtain intern technician-level personal professional liability coverage before your OCP application to become an intern technician may be processed.

Why is the College creating a new intern technician class of registration?
An intern technician registration class will allow pharmacy technician graduates to practice while completing their practice-based registration requirements.

What is the scope of practice for the new intern technician registration class?
As an intern technician, you can practice any of the activities in the scope of practice for a pharmacy technician with some exceptions: intern technicians are not yet authorized to administer the influenza vaccine, respiratory syncytial virus (RSV) vaccine, or Coronavirus (COVID-19) vaccines.

Intern technicians must always practice under the direct supervision of a Part A pharmacist, pharmacist (emergency assignment), Part A pharmacy technician, or pharmacy technician (emergency assignment). For more information, refer to the Supervision of Pharmacy Personnel Policy.

How long can I be an intern technician? Once you are issued an intern technician Certificate of Registration, it is valid for one year. This allows time for intern technicians to complete their practice-based registration requirement before applying for a pharmacy technician Certificate of Registration.

Can I complete Structured Practice Training (SPT) without registering as an intern technician?
Yes, but you will only be able to participate in SPT activities, and not practice the scope of the profession.

Note that in fall 2024, the College will be transitioning from the SPT program to the Practice Assessment of Competence at Entry (PACE) model for pharmacy technician applicants. The last day for pharmacy technician applicants to apply for SPT is September 3, 2024. The last day for pharmacy technician applicants to start SPT is September 16, 2024. To complete PACE, pharmacy technician graduates must register as an intern technician.

When do I need to declare if I am going to be Part A or Part B? Are there specialized courses I need to take to provide patient care?
All pharmacy technicians are trained as Part A pharmacy technicians, which means they are able to practice patient care to scope.

Once you complete all your registration requirements and register as a pharmacy technician, you will have the opportunity to declare if you will be practicing as a Part A or Part B pharmacy technician. Part A is for those who provide patient care and Part B is for those who do not provide patient care. You can move from Part A to Part B at any time.

At this time, there are no additional educational requirements to practice as a Part A pharmacy technician.

July 30 information session – pharmacy technician students and pharmacy technician schools

• Graduate from CCAPP Canadian Pharmacy Technician Program 
• All pharmacy technician registration pathways

I’m an international pharmacy graduate registered as a student with OCP. How can I continue to practice while I work to meet OCP’s entry-to-practice requirements?
As of October 1, 2024, you will be required to register as a pharmacy intern, if eligible, to be able to continue to practice to scope as you work towards completing OCP’s entry-to-practice requirements.

Pharmacy intern registration requirements, including language proficiency, must have been completed within two years for your intern application to be processed.

I am enrolled in the International Pharmacy Graduate (IPG) Program. Now that I am no longer registering with the College as a student (as of October 1, 2024), to whom do I submit my proof of language competency, police check, declaration of good character, and background check? Are these things still necessary?
The IPG Program has its own admissions criteria, which includes proof of language proficiency and may include some of the other things listed. Proof of language proficiency, police/background check, and your declaration of good character will be required when you register with the College as an intern after graduating from the IPG program.

I am in my second year of completing the PEBC Qualifying Exam, Jurisprudence, Ethics and Professionalism Exam, and practice-based assessment. I am not sure if I will be able to finish by the time these changes go into effect (i.e., within the two-year time frame). Will I be granted extra time?
The short answer is no, extra time will not be granted for you to complete your entry-to-practice requirements.

If your Jurisprudence, Ethics and Professionalism Exam expires, you will need to successfully complete the exam again.

If you are more than two years past graduating from an PEBC-recognized pharmacy degree program, successfully completing bridging education (if required), and successfully completing the PEBC Qualifying Exam, we recommend you apply to a panel of the Registration Committee for consideration of your unique situation.

Why is the College creating a two-part register (Part A and Part B) for pharmacy technicians?
A two-part register – Part A for those who provide patient care and Part B for those who do not provide patient care– aligns with the current two-part register for pharmacists. It also recognizes that pharmacy technicians can have different roles, in different practice settings. For examples of patient care activities, please refer to the question “What does patient care look like for pharmacy technicians?”.

I’m currently registered as a pharmacy technician. Will I automatically become a Part A pharmacy technician as of October 1, 2024?
Yes. Once the regulations are implemented on October 1, 2024, all registered pharmacy technicians will automatically become a Part A pharmacy technician. At any time, pharmacy technicians can self-select into Part B if they do not provide patient care.

What are the expectations of a Part A pharmacy technician?
Part A pharmacy technicians must:

• Complete a self-declaration of competency to provide patient care during annual renewal
• Participate in a practice assessment when selected to do so
• Participate in a self-assessment when selected to do so
• Participate in professional development and maintain a learning portfolio
• Have personal professional liability insurance

As a Part A pharmacy technician, how do I self-declare that I have maintained competence to practice?
During the College’s annual renewal process, you will be required to make a self-declaration of competency. The self-declaration will consist of a statement of competence and an affirmation of requirements. Details on how to complete the self-declaration will be provided during the annual renewal process.

How can I move from Part A to Part B of the Register?
Once the regulations are implemented on October 1, 2024, all registered pharmacy technicians will automatically become Part A pharmacy technicians. At any time, a pharmacy technician can move into Part B of the Register if they do not provide patient care. For examples of patient care activities, please refer to the question “What does patient care look like for pharmacy technicians?” If you would like to move to Part B of the Register on or after October 1, 2024, please notify the College by emailing [email protected]. The change would take place immediately or on the effective date you provide.

What does patient care look like for pharmacy technicians?
Examples of patient care activities for pharmacy technicians include, but are not limited to:

• Providing pharmacy services to individual patients or their advocate (e.g., a patient’s caregiver)
• Educating patients with the selection and demonstration of drug administration devices, monitoring devices, and health and compliance aids
• Supporting a culture of patient safety by appropriately resolving missing doses (including referring to a pharmacist if needed), identifying medication incidents and near misses/good catches, or identifying and reporting safety issues
• Preparing sterile or non-sterile compounds according to all relevant guidelines and standards of practice.
• Performing point-of-care tests within scope
• Administering vaccines by injection within scope
• Preparing a Best Possible Medication History (BPMH) as part of the medication reconciliation process
• Product preparation and dispensing as part of the drug distribution process
• Referring patients who require assessment, clinical analysis, or application of therapeutic knowledge to the pharmacist
• Confirming the pharmacist has reviewed the therapeutic appropriateness of the drug therapy/products prior to release for both new and refill prescriptions/orders
• Confirming patient assessment by a pharmacist prior to vaccine administration
• Maintaining inventory systems
• Supporting the maintenance of safe and efficient management or product distribution anywhere drugs are stored
• Contributing to management within a pharmacy, including maintaining inventory (including automated inventory) and appropriate storage; completing audits and reconciliations for controlled substances according to current laws, regulations and policies, identifying and reporting any discrepancies; workflow management; routine equipment maintenance and cleaning, including compounding, packaging, dispensing, and storage equipment; creating and maintaining policies and procedures to ensure a safe workplace environment; and collaborating with other healthcare providers in the organization

Am I required to participate in the College’s Quality Assurance Program?
As of October 1, 2024, all Part A pharmacy technicians are required to participate in the College’s Quality Assurance Program. The Quality Assurance Program assures the public that healthcare professionals are competent to provide patient care. It also contributes to individual and system-wide continuous quality improvement.

The College’s Quality Assurance Program consists of four components – self-assessment, knowledge assessment, practice assessment and a learning portfolio. Although a knowledge assessment for pharmacy technician is not yet available, this will be considered as the College evaluates the evolution of its Quality Assurance Program.

Do pharmacy technicians already participate in the College’s Quality Assurance Program?
Currently, all components of the Quality Assurance Program available to pharmacy technicians – self-assessment, practice assessment and learning portfolio – are voluntary for pharmacy technicians. Many pharmacy technicians have already voluntarily engaged in some elements of the College’s Quality Assurance Program. As of October 1, 2024, Part A pharmacy technicians will be required to participate in the College’s Quality Assurance Program.

I work part-time or casually as a pharmacy technician and provide patient care. Do I need to participate in elements of the Quality Assurance Program, including the practice assessment?
Yes. If you are a Part A pharmacy technician (provides patient care), you are required to participate in the Quality Assurance Program, regardless of the number of hours you practice. This includes participating in a practice assessment when selected.

How will the selection criteria change for the Quality Assurance Program?
As of October 1, 2024, the College will have the authority to select registrants based on risk rather than random selection. This will allow the Quality Assurance Program to focus on a risk-based, right-touch selection criteria.

I’m currently a registered pharmacy intern. How do these changes affect me once they come into effect on October 1, 2024?
As a registered pharmacy intern, you must continue to have pharmacy intern-level personal professional liability insurance.

When you submit your final application to register as a pharmacist, all registration requirements, including the Jurisprudence, Ethics and Professionalism exam and Practice Assessment of Competence at Entry (PACE), must have been completed within two years before submitting your application. If your education was completed more than two years ago, but the PEBC Qualifying Exam has been completed within the last two years, your education will be considered current.

I’m submitting my final pharmacist application to OCP on or after October 1, 2024. It has been more than two years since I successfully completed some of the registration requirements. What can I do?
If it has been more than two years since you completed some of the registration requirements, you must take additional action.

If you wrote and passed the Jurisprudence, Ethics and Professionalism Exam more than two years from October 1, 2024, you will be required to re-write the exam as your results will have expired. If you completed PACE more than two years ago, you will be required to submit a request to a panel of the Registration Committee. The panel will determine next steps.

Results of the PEBC Qualifying Examination do not expire; however, its ability to show currency of education after the two-year period does. If you are in a unique situation in which you have graduated from a pharmacy education program or bridging program approved by the College’s Board of Directors (Council) and completed the PEBC Qualifying Exam more than two years before applying for your final pharmacist Certificate of Registration, send an email to [email protected] or phone 416-962-4861 or 1-800-220-1921 ext. 3400 for further direction.

As of October 1, 2024, how current do my registration requirements need to be when I apply to be registered as a pharmacist or pharmacy technician?You must complete registration requirements within two years before submitting a College application to be registered as a pharmacist. Registration requirements include:

• Proof of graduation from a PEBC-recognized international pharmacy education program and, if required, successful completion of bridging education*
• PEBC Qualifying Exam*
• Language proficiency
• Jurisprudence, Ethics and Professionalism exam
• Practice-based assessment

*Applications must demonstrate currency of education (“current” means within 2 years before submitting a College application to be registered as a pharmacist). The PEBC Qualifying Examination requirement doesn’t expire; it can also be used as proof of currency of education if it has been completed within those two years. Currency of education can also be demonstrated by successful completion of any required education within the two-year period before submitting an application; however, this does not exempt the applicant from completing the PEBC Qualifying Examination.

What is required to supervise pharmacy students (those enrolled in a pharmacy education program)?
Individuals supervising pharmacy students must be:

• A Part A pharmacist
• Physically present if you and the pharmacy student are practicing in an accredited community pharmacy, as stipulated in the Drug and Pharmacies Regulation Act
• Comfortable providing the level of supervision needed for the pharmacy student based on their current skills and abilities
• Accountable for the actions of the pharmacy student under your supervision

For more information, refer to the Supervision of Pharmacy Personnel Policy.

What is required to supervise pharmacy technician students (those enrolled in a pharmacy technician education program)?
Individuals supervising pharmacy technician students must be:

• A Part A pharmacist or a Part A pharmacy technician
• Physically present if you and the pharmacy technician student are practicing in an accredited community pharmacy, as stipulated in the Drug and Pharmacies Regulation Act
• Comfortable providing the level of supervision needed for the pharmacy technician student depending on their current skills and abilities
• Accountable for the actions of the pharmacy technician student under your supervision

For more information, refer to the Supervision of Pharmacy Personnel Policy.

Am I responsible for the pharmacy student or pharmacy technician student I am supervising?
Yes. The supervising pharmacy professional continues to be responsible for services being provided under their supervision. A supervisor’s responsibilities remain unchanged with the elimination of the student class of registration on October 1, 2024. For more information, refer to the Supervision of Pharmacy Personnel Policy.

Can I supervise multiple students at once?
Appropriately and safely supervising students is a responsibility not to be taken lightly. Supervising pharmacists must assess their own abilities, workload, and limitations, to decide how many students they are able to safely supervise at once. For more information, refer to the Supervision of Pharmacy Personnel Policy.

Will students be registered with the College?
As of October 1, 2024, students enrolled in a pharmacy program will not be registered with the College until they graduate, at which point they will be eligible to register as an intern. Students enrolled in a pharmacy education program can practice under supervision based on authority laid out in the Regulated Health Professions Act.

What does it mean if a pharmacy student is not listed on the public register?
Nothing changes for a pharmacy student once they are no longer listed on the public register as of October 1, 2024. Students enrolled in a pharmacy education program* can continue to practise all the controlled acts of the profession under the supervision of a Part A pharmacist or pharmacist (emergency assignment).

Verification of student status can be obtained through a valid student card, a letter of enrollment, a recent transcript or other direct communications with the pharmacy school.

*Includes those enrolled in a CCAPP-accredited pharmacy education program, an ACPE-accredited pharmacy education program, or those enrolled in the approved bridging program (IPG program).

Will students have professional liability insurance?
As of October 1, 2024, the College will not require students to obtain personal professional liability insurance. Employers or schools may require students to have insurance.

How can I verify I am employing a student who is enrolled in a pharmacy program?It continues to be the responsibility of an employer to ensure the person working in their pharmacy and performing the controlled acts of the profession under supervision is authorized to do so. This has not changed. Verification of student status can be obtained through a valid student card, a letter of enrollment, a recent transcript or other direct communications with the pharmacy school.

July 31 information session – supervisors and employers

• Supervision of Pharmacy Personnel Policy
• Supervision Authority – Community Pharmacy Environment