Supplemental Guidance documents provide additional information to support registrants with meeting the expectations of the accompanying policy. It is intended to assist with policy implementation and not to be applied in isolation of the policy. Supplemental guidance is updated as needed to reflect current practice.
Published: October 15, 2025
Last reviewed: October 15, 2025
Version #: 1.00
Introduction
Virtual care is intended to facilitate access to pharmacy care in a way that best meets the needs of a patient. Providing pharmacy care using virtual methods may not be appropriate in every instance. The types of conditions that can be managed virtually vary, and differences exist in patient access to technology and comfort in using this technology.
Registrants are accustomed to providing care over the telephone, however, the availability of technologies (including software and hardware) to enable other methods of patient interaction continues to expand. The choice to implement technology to provide virtual care requires careful consideration and due diligence by registrants to understand how to do so safely and effectively.
Principles
- The benefit of providing virtual care must outweigh any risk to the patient.
- The patient’s best interests must always override the registrant’s own interests.
- Virtual care may not be appropriate for every patient.
- Patients receive the same quality of care, whether provided virtually or in person.
Guidance
The policy applies to Part A registrants in any setting. Does this mean a registrant can only provide virtual care from a community or hospital pharmacy?
The scope of practice and authorized acts for registrants is defined in the Pharmacy Act s 3, 4. The “dispensing, selling or compounding a drug or supervising the part of a pharmacy where drugs are kept” must take place in an accredited pharmacy, as per the Drug and Pharmacies Regulation Act.
In contrast, cognitive skills and knowledge reside with the individual registrant and may be used in a variety of practice settings. When practicing outside of a pharmacy, it is the registrant’s duty to exercise due diligence implementing procedures that will fulfill their professional and legal responsibilities.
Registrants are reminded that the record-keeping and length of retention requirements, described in the Record Retention, Disclosure, and Disposal Guideline, must also be met.
Is care provided over the telephone considered virtual care?
Yes, if it meets the definition of a professional interaction between a registrant and a patient. An active video component is not a requirement to provide virtual care.
Routine phone calls that are administrative or clerical in nature would not be classified as virtual care (i.e., interactions that are also appropriate for assigning to unregulated personnel due to their nature or that don’t require a registrant-patient relationship).
Examples of registrant-patient interactions over the phone that would be considered providing virtual care include those that meet the definition of professional pharmacy services:
- Involves a service within the scope of practice of a registrant such as:
- The provision of information and education related to drugs and devices (e.g., patient counselling on a medication or medical device)
- The prevention and treatment of disease through monitoring and management of medication therapy (e.g., following up on a care plan, medication reconciliations)
- The assessment of conditions for the purposes of providing medication therapies (e.g., a patient is seeking treatment for a minor ailment) even when the result is a referral to another health care professional or recommendation of non-prescription or self-care therapies)
- Involves performing a controlled act authorized to a registrant (e.g., prescribing a drug, adapting or renewing a prescription) or under delegation of authority from another regulated health professional.
What types of secure enabling technology are approved by the College for providing virtual care?
The College does not identify, evaluate, or approve technology that a registrant may use to provide virtual care. It is the registrant’s responsibility to do so, considering the nature of their practice, the needs of their patient population and their ability to use the technology appropriately.
The onus lies on the registrant to exercise due diligence to select hardware (e.g., audio visual equipment) and/or software (e.g., applications or programs) that enable them to meet the expectations of the policy, applicable legislation, and Standards of Practice. This might involve consulting with peers and professional associations, carefully reviewing literature provided by the technology vendor, and seeking independent legal advice on terms and conditions of any contractual agreements.
Examples of additional resources and guidance available from various organizations include:
- OTNHub (formerly Ontario Telemedicine Network)
- Ontario Health
- The Information and Privacy Commissioner of Ontario
- Canadian Centre for Cyber Security
Can a registrant access the patient records at their workplace using a remote connection to provide virtual care from another location?
Yes, if remote access is provided using secure transmission, incorporates access control, and does not store unencrypted personal health information on the registrant’s remote device (e.g., laptop, mobile, tablet, shared or public computer) to prevent unauthorized access during or after the virtual care interaction. The flexibility or convenience of providing care outside of the workplace cannot risk compromising patient confidentiality and data security.
Additional information can be found on the Canadian Centre for Cyber Security website such as:
- Cyber security at home and in the office: Secure your devices, computers, and networks (ITSAP.00.007)
- Cyber security tips for remote work – ITSAP.10.116
Why doesn’t the policy address informed consent?
Informed consent has a specific definition and is required by the Health Care Consent Act before a pharmacist initiates a treatment or procedure. For instance, a pharmacist using virtual care to assess and treat a minor ailment must also adhere to the Pharmacist Prescribing: Initiating, Adapting & Renewing Prescriptions Policy and informed consent must be obtained.
The policy requires the patient to consent to receiving care virtually. To support the patient in making an ‘informed’ choice, the pharmacist might provide a brief explanation about the technology being used and their rationale for why virtual care is appropriate for this interaction. This information can also help the pharmacist decide that virtual care is suitable for the patient’s preferences and needs.
Importantly, consent to collect and use their personal health information is required by the Personal Health Information Protection Act. Although patients may inherently trust the registrant providing their care, they should be given the opportunity to ask any questions. Additional resources to support registrants with PHIPA compliance can be found at:
How can a registrant confirm the patient’s identity and location?
The policy is not directive in how a registrant meets the expectations of the policy, nor is it intended to create an administrative or otherwise unimportant burden on either person.
Since personal health information is being exchanged, reasonable efforts to ensure the interaction is with the right patient are expected; even for an existing patient, visual verification isn’t possible over the phone. For existing patients, reasonable efforts could include confirming demographic information (e.g., date of birth, address) or other identifying information on the patient’s profile (e.g., prescriptions or services they have received). Registrants may want to preface these questions by explaining their purpose.
It is equally important to confirm the identify agent authorized to act on their behalf of the patient (e.g., a family member, caregiver, substitute decision maker) so that personal health information is not inadvertently disclosed to the wrong person.
Location is important since cross-jurisdictional pharmacy services are subject to the Cross-Jurisdictional Pharmacy Services Policy (i.e., if the patient is outside of Ontario). Aside from confidentiality purposes, another benefit of the patient being in a private location is to minimize interruptions during the interaction.
Note: External resources in this document are provided as additional sources of information for pharmacy professionals who wish to explore a topic further. Inclusion of selected resources is not exhaustive and should not be construed as an endorsement of the content or organization.
Review History
| Version # | Date | Action |
|---|---|---|
| 1.00 | October 2025 | Initial publication |