LICENSING/REGISTRATION OF PHARMACISTS IN CANADA Provincial changes implemented due to COVID-19 Pandemic

In response to the COVID-19 pandemic, many Provincial Pharmacy Regulatory Authorities (PRAs) approved changes to the licensing/registration requirements for pharmacists, regulated pharmacy technicians and new pharmacy graduates (i.e., emergency/conditional registration to support pharmacy workforce demands). For some retired or non-practicing pharmacists, changes allowed them to register and return to practice. For new graduates, these changes addressed delays in registration as pharmacists due to postponement of the Pharmacy Examining Board of Canada (PEBC) examinations and PRA jurisprudence exams.

AB NB NS PE

Pharmacists (i.e. retired or non-practicing returning to practice)

Pharmacy Graduates (i.e. class of 2020)

YTONSK MBBC QC NL NT NU

Revised May 20, 2020

Regulatory changes: Approved No changes Pending

• On March 16, 2020, as part of BC’s COVID-19 response, the BC government requested all health regulators to begin the emergency registration of non-practising or retired health-care professionals, including professionals from other jurisdictions and the armed forces.

• Bylaw changes allow for granting 4 categories of temporary registration: Limited Pharmacist (under pharmacist supervision), Temporary Pharmacist, Temporary Pharmacy Technician (hold equivalent registration in another jurisdiction in Canada or the US or be a former registrant who was last registered as a full pharmacist or pharmacy technician no more than 3 years ago) and Temporary Student Pharmacist Registration.

• New UBC graduates can register as a Temporary Limited Pharmacist (i.e. pharmacy graduates who have completed their Structural Practical Training (SPT) requirements but not all the required assessments for registration; OR pharmacy graduates who have completed their Jurisprudence Exam, PEBC Qualifying Exams, but not their SPT). A Temporary Limited Pharmacist can perform restricted activities/pharmacy services under the direct supervision of a full pharmacist.

• https://www.bcpharmacists.org/news/temporary-registration-now-available-support-bc’s-covid-19-response#overlay-context=news

• To help support the increased demand for health services during the COVID-19 pandemic, the Alberta Health Emergency Operation Centre asked regulated health professions to facilitate the return of retired or otherwise nonpracticing members to practice.

• The new ACP policy allows individuals who recently became inactive (not on the clinical pharmacist or pharmacy technician register in Alberta within the last three years) and/or are actively registered within another Canadian jurisdiction to be granted conditional registration (i.e. practice permit, with conditions, until July 31, 2020; no registration or practice fees charged).

• No changes for new graduates currently, however ACP has a provisional pharmacist registration status (i.e. intern; still needs to complete PEBC exam). Once ACP has received graduation confirmation from UoA, student status will change to provisional pharmacist (intern). All Canadian pharmacy graduates applying for initial licensure in Alberta must complete Level 3 of the ACP online SPT program (Level 3 requires completion of: minimum of 100 hours, the ACP jurisprudence learning module; the Ethics & Jurisprudence exam; and the PEBC Qualifying Exam Parts I and II). Interns who have successfully completed Level 3 of the SPT program but are not yet ready or able to register on the clinical register (e.g., still need to complete the PEBC exam) may work under indirect supervision, at the discretion of the supervising pharmacist. The level of supervision must be agreed upon by both the intern and the preceptor. Direct supervision is still required for any intern administering drugs by injection.

• https://abpharmacy.ca/emergency-registration-covid-19-pandemic

• https://abpharmacy.ca/applying-acp

• New Bylaw amendments provide Expedited Emergency Registration/Licensure (April 20/20). They ensure expedited, no-fee, temporary emergency licensure/registration for Retired, Associate, Non-Practising members, pharmacy professionals who were previously registered/licensed with the SCPP, and pharmacy professionals (in good standing) from other Canadian jurisdictions. These professionals must have been previously licensed/registered within the last three years, be in good standing, etc.

• Interns: New Extended Internship Category: SCPP extended the internship category to include graduates from a pharmacy degree program who had not yet successfully completed the entry-to-practice requirements (i.e. PEBC exams), rather than issuing a Conditional Practising license. An exemption for Advanced Method Certification (AMC) is in place for 2020 graduates only as part of the emergency licensure bylaws (AMC allows for intradermal, subcutaneous or intramuscular injection). At the discretion of the Registrar, this new authority will ensure an optimal number of pharmacy professionals are available to administer the flu vaccination, a potential COVID-19 vaccination, or other necessary medications by injection or other routes. A pharmacy intern is not a licensed pharmacist, therefore cannot preform the final signo� of prescriptions, nor can they work alone (i.e. only under direct supervision).

• https://www.saskpharm.ca/site/coronavirus-information

• https://saskpharm.ca/site/registration/temporaryRegistration?nav=sidebar

• No changes in process for licensing of pharmacists (e.g. retired/resigned) indicated on CPhM website. However, the College already has a process for Temporary Certificate of Registration and Temporary Licensure Application (i.e. for pharmacists licensed in other provinces if they are able to satisfy the Council that there is a genuine and urgent need for pharmacist services that cannot reasonably be met by a current member of CPhM).

• Graduating students are required to complete a 600-hour internship, split into a pre-graduation phase (240 hours) and post-graduation phase (360 hours). As interns they can practice to full scope under direct supervision (cannot register as a pharmacist until completion of jurisprudence and PEBC exams). Due to the postponement of the May 2020 PEBC Qualifying Examinations, the CPhM Board approved that all applicants for registration and licensure from the 2020 UoMB graduating class, who have met all other requirements for registration and licensing, including completion of the post-graduate internship, will be placed on the Conditional Register and issued a practising licence with the following conditions: cannot be a pharmacy manager, Extended Practice Pharmacist or preceptor; must have quick access (e.g. via telephone) to a licensed pharmacist (with no conditions on their licence), for guidance should they require; must undertake the PEBC exams at the next sitting; and is not eligible for labour mobility, provided under the NAPRA Mobility Agreement for Canadian Pharmacists (i.e. cannot apply for licensure outside Manitoba). In addition, graduates with additional practice experience beyond that of the undergraduate program, can choose an accelerated 120-hour (3 weeks) internship option. To qualify, both the intern and the preceptor must meet certain criteria and receive College approval.

• https://www.cphm.ca/index.html

• https://cphm.ca/uploaded/web/2017%20Applications/14%20-%20Pharmacist%20-%20Temporary%20Reg%20%26%20Licensure.pdf

• https://cphm.ca/uploaded/web/documents/Licensing%20FAQ%20for%20the%202020%20Graduating%20Class%20of%20the%20College%20of%20Pharmacy%20-%20April%209,%202020.pdf

• https://cphm.ca/uploaded/web/2017%20Applications/03%20-%20Pharmacist%20-%20Conditional%20Register%20Application.pdf

• OCP has enabled pharmacists and pharmacy technicians who have resigned/retired within the last 3 years as eligible to be reinstated with the College (i.e. no examinations or assessments are required). A pharmacist who currently is registered in the non-patient care class (Part B) can apply to transfer to the patient-care registration class (Part A), and provide patient care under the supervision of a Part A pharmacist. The College will reimburse anyone who reinstates/registers temporarily for the purpose of providing care and support during the COVID-19 pandemic.

• Graduating students can currently register as interns and practice to full scope under direct supervision (cannot register as a pharmacist until completion of jurisprudence and PEBC exams)

• https://www.ocpinfo.com/registration/reinstating-coronavirus-covid-19/

• https://www.ocpinfo.com/registration/register-pharmacist/ontario-undergrad/

• No changes in process for licensing of pharmacists (e.g. retired/resigned) indicated on OPQ website.

• New graduates: both Université de Montréal and Université Laval graduated their students early (~ 6 weeks). As PEBC’s are not required in Quebec, as soon as students have successfully completed their PharmD degree, and the faculty of pharmacy confirms their success, they can apply for their license to practice and register on the Order.

• https://www.opq.org/fr-CA/l-ordre/reglementation/

• https://www.opq.org/fr-CA/etudiants-et-residents/demande-de-permis/

• NBCP established the Conditional: Emergency Register for pharmacists and pharmacy technicians who are 1) retired/non-active/not currently registered, but were registered on the Active: Direct Client Care register within last 2 years, 2) those registered on the Active: Non-Direct Client Care register within last 2 years, and 3) those licensed in Canada but not NB. Decisions on licensing in the pandemic balance the risks to the public of insu�cient human resourcing against the risk of an individual without recent proven competency in providing care for patients.

• Graduates: new graduates are considered students and require supervision in practice. Currently they must complete the jurisprudence and PEBC exams, and a minimum of 4 weeks post-grad training. NBCP has drafted a new set of regulations that pertain to registration during times of emergency (approval expected at members’ meeting on June 7, then ratified by the NB Minister of Health). Once ratified, the College may permit graduates, during an emergency, who meet criteria for application, onto the Conditional: Emergency register for Pharmacists and Pharmacy Technicians. The jurisprudence and PEBC exams would be temporarily waived in order to practice on this register. The College recommends that graduates complete their post-graduation internship as it will be required for eventual registration and licensure as an Active: Direct Client Care pharmacy professional. The timeframe for regulation approval is mid-July.

• https://nbcp.in1touch.org/document/5346/COVID-19%20Emergency%20Registration%20and%20Licensure%20Phase%20I%20Web%20page%20comm%20March23%20EN.pdf

• https://nbcp.in1touch.org/document/1623/Graduating%20Pharmacist%20Student%20Information%20Package%20EN%20FINAL%20Mar2015.pdf

• No changes in process for licensing of pharmacists (e.g. retired/resigned) indicated on NSCP website. The College is working with the government regarding emergency/provisional licensure.

• New Graduates: NSCP has been granted authority from the NS government to provide a pharmacist licence to new pharmacy graduates during the public health emergency in order to meet anticipated pharmacy workforce demands. Under this authority, the NSCP is able to license recent pharmacy graduates without delay by: deferring the completion of the PEBC Certification Exam (must be successfully completed at the next exam sitting); and modifying the requirements for completing unstructured practice experience (internship hours) such that it can be completed during the first months of practising as a pharmacist under this licence. Newly licensed pharmacists must practise in the presence of a licensed pharmacist who does not have this condition. The licence issued to new graduates is a full Direct Patient Care Pharmacist Licence and they can practise to the full scope of a pharmacist and are fully responsible and accountable for all aspects of their practice. There is no requirement for another pharmacist to review or sign-o� on their practice activities. New graduates can also initially register as an intern; if so, they can only practise pharmacy under the direction of a pharmacist who assumes responsibility for the intern and their actions. (note: not yet posted on NSCP website; provided in email from Registrar)

• https://www.nspharmacists.ca/?page=pharmacist

• The PEI Public Health Act enables PEICP to do emergency registration. Pharmacists who are registered in another Canadian jurisdiction may apply for Special Class Registration for 45 days (specific purpose includes covering pharmacist services in the event of an emergency). A former pharmacist or pharmacy technician member may reapply for reinstatement, if resignation was less than three years ago.

• New graduates: PEICP is working on details for licensing of new grads. Currently, before registering as a pharmacist, they must complete the jurisprudence and PEBC exams and complete the required post-graduate practice experience hours (i.e. 280 hours of structured practice experience under the supervision of a preceptor after completion of a pharmacy degree program). A process for Provisional Registration for new graduates was in place prior to COVID-19. A provisional registrant is an individual who is completing a period of practice experience after having graduated from a pharmacy degree program or is applying as an international graduate, before completing the final requirements for registration as a pharmacist.

• https://www.pepharmacists.ca/site/SPECIAL?nav=04

• https://www.pepharmacists.ca/site/ccappgrad?nav=04

• https://www.pepharmacists.ca/site/PROVreg?nav=04

• No changes in process for licensing of pharmacists (e.g. retired/resigned) indicated on NLPB website.

• New graduates: no changes. Currently they must complete the NLPB Registration Examination and PEBC exams, and complete the required 280 hours of unstructured practice experience under the supervision of a preceptor after graduation. Can licence as an intern and work to full scope under supervision.

• https://nlpb.ca/registration-and-licensing/registration-information/#students-interns

PROVINCIAL DETAILS

British Columbia CPBC

Alberta ACP

Saskatchewan SCPP

Manitoba CPhM

Ontario OCP

Quebec OPQ

New Brunswick NBCP

Nova Scotia NSCP

Prince Edward Island PEICP

Newfoundland & Labrador NLPB

Association of Faculties of Pharmacy of Canada

Association des facultés de pharmacie du Canada