Together with the relevant legislative requirements and standards, policies articulate the College’s expectations for registrants for the practice of pharmacy, the provision of patient care, and the operation of pharmacies.
Approved: September 16, 2025
Effective: September 30, 2025
Version #: 1.10
Supplemental Guidance to the Virtual Care Policy
Purpose
To articulate the College’s expectations of registrants when providing virtual care to patients to ensure that pharmacy services provided virtually meet the Standards of Practice.
Scope
This policy applies to all registrants in Part A of the register, in any practice setting.
Definitions
Personal health information (PHI): Any information relating to a person’s health that identifies the person, including, for example, information about their physical or mental health, family health history, information relating to payments or eligibility for health care, and health card numbers, as well as any identifying information about a patient’s substitute decision maker.1
Professional Pharmacy Services: Patient care activities provided by a registrant within the scope of practice of pharmacy and the authorized acts of the profession2, but not dispensing, compounding or the sale of scheduled drugs3.
Virtual Care: A professional interaction between a registrant and a patient that occurs remotely using secure enabling technology that facilitates registrant-patient interaction (e.g., videoconferencing).
Policy
Registrants providing virtual care to patients must meet all applicable Standards of Practice and legislative requirements for in-person care. A patient must receive the same quality of care whether they are receiving that care in-person or virtually.
A registrant-patient relationship is established when pharmacy services are provided through virtual care, in the same way as it is established when providing pharmacy services in-person.
Documentation requirements remain the same regardless of whether pharmacy services are provided to a patient in-person or through a virtual interaction.
Providing Virtual Care
Registrants must practice within the limits of their knowledge, skills and judgement, and the decision to provide virtual care must be made in the best interest of the patient.
Before providing virtual care to a patient, registrants must determine if it is appropriate:
- The benefits to the patient must outweigh any risks.
- Virtual care and the method through which it is delivered are suitable to meet the patient’s needs and appropriate for the service(s) being provided.
- Consider the patient’s health status, specific healthcare needs and circumstances.
- All legal and professional obligations are met.
Registrants must ensure that the method used to provide virtual care is functioning properly to support the virtual interaction and have a contingency plan in place in the event of a technical failure.
Obtain Consent
A patient must be given a choice of whether to receive virtual care.
Before providing virtual care to a patient, registrants must obtain consent from the patient or their authorized agent to use and collect their personal health information (PHI).
- When the registrant is initiating the interaction, express consent must be obtained, either verbally or in writing.
- When the patient is initiating the interaction, the registrant may rely on consent being implied by the patient.
- Registrants must document that they have received consent in the patient’s record.
Maintain Privacy and Confidentiality
Maintaining privacy is a legal requirement and professional obligation.
Registrants providing virtual care must:
- Safeguard the patient’s right to privacy by ensuring that any technology used has privacy and security protocols to comply with the Personal Health Information Protection Act, 2004.
- Processes used to safeguard PHI must include a mechanism for notification of theft or loss as required by law.
- At a minimum, the technology used must have controls to ensure only the intended patient has access to the virtual visit.
- Whenever PHI is transmitted and/or stored, secure encryption must be used.
- Confirm the patient’s identity and location even if the pharmacy professional-patient relationship pre-exists.
- Provide virtual care in a private environment that ensures PHI is not overheard or seen by anyone outside of the patient’s circle of care.
- Advise the patient that they should be in a private environment to maintain confidentiality of their personal health information.
- Inform the patient how their privacy will be protected and how the confidentiality of their PHI will be maintained.
- Document the method used to provide virtual care in the patient’s record.
Ensure Safe and Appropriate Environment
Registrants must ensure that the physical setting in which care is being delivered is appropriate and safe. If observing the administration of a medication, registrants must have a plan in place to manage adverse events and/or emergencies.
Legislative References
- Personal Health Information Protection Act, 2004, s.4
Additional References
External References
- Information and Privacy Commissioner of Ontario – Privacy and Security Considerations for Virtual Healthcare Visits Guideline (February 2021)
Revision History
| Version # | Date | Action |
|---|---|---|
| 1.00 | June 2021 | Virtual Care Policy approved |
| 1.10 | September 2025 | Approval of reformatted policy with minor content revisions |
References
1 Personal Health Information Protection Act, s 4
2 Pharmacy Act, s 3,4
3 Pharmacy services involving the controlled acts of dispensing, compounding, and selling scheduled drugs must take place in an accredited pharmacy, in accordance with the Drug and Pharmacies Regulation Act (DPRA)