Organization
[August 11, 2022 4:27 PM]

Ontario Medical Association (OMA)
Note: Some content has been edited in accordance with our posting guidelines. Response in PDF format.

Organization
[August 07, 2022 8:32 PM]

Ontario Medical Association (OMA) Section on Plastic Surgery
Response in PDF format.

Member of the public
[July 31, 2022 12:57 PM]

Vaccine administration during the COVID-19 pandemic was offered in some Ontario doctors offices as they chose and with supervision of administration. Cost to patients was not relevant however accuracy of storage temperatures, preparing for multiple doses per vial, use of appropriate syringes,proper disposal of prepared but unused vaccine supply at the end of the day recording were all critical. During early 2022 it was reported that in one medical office the entire vial was administered as one dose (an overdose). When realized the adult patients were contacted and this dosing error in a doctors office was reported. There were several other reports of dosing errors among children age 5 years and above. Caution must be taken when any drug dispensing is assumed by a doctor in an office practice. This month, doctors offices are offered the administration to young children ages 6 months to 4 years of Moderna COVID-19 vaccine from ten dose multi dose vials. Ntegrity of storage, mixing, preparing each of the ten doses must be conducted with absolute accuracy along with patient and parent education with respect to potential for side effects and return fate for second dose in eight weeks.

Physician (including retired)
[July 30, 2022 11:32 PM]

I think its great to have this policy in place. I would suggest removing point #4 of mandating physicians to not be able to charge a profit for dispensing medications - that does not make sense and I'm quite surprised that the College of Pharmacists would allow a policy like that to exist. The second part of this policy which I think is important which would include significant advocacy for physicians is to make a seamless process for physicians to be able to bill 3rd part insurance companies for prescribed medications for dispensing. For example, a women's health clinic offering IUDs - many female patients may not have the time and patience to book an appointment for a consultation, then agree to have an IUD inserted, then receive a prescription, take that to a pharmacy, then wait to receive the IUD from the pharmacy, then book a followup appointment with their physician to have an insertion. This process creates many barriers to care and its much easier for the physician office to have the billing software that can bill ODB or other third party insurance companies on the spot for the IUD and have them insert it in the same visit. There plenty of other similar examples such as the morning after pill, mifegymiso abortion pill, etc. Not to mention a lot of other similar examples for travel medicine setting (ie. that last minute traveller needing anti-malarial pills or Yellow-Fever vaccine that may not be easily found in local pharmacies).

Other health care professional (including retired)
[July 22, 2022 3:06 PM]

I don't quite understand why this is even in consultation. This invites FURTHER conflict of interest in the arena of insurance companies forcing patients to go to certain pharmacies/receive mail order in order to maintain their coverage. In pharmacy, we don't even know half the time that a patient has been taking physician samples of a drug, making our interaction checking process irrelevant at times. I realize in this policy, it would require physicians to mention that the Rx is available at a pharmacy if they wish to have it dispensed there. (It is naive to think that this will be mentioned each and every time. It is also naive to think that the patient would agree to travel elsewhere to receive their meds, if truly given the choice. I cannot help but feel this entire consultation is in retaliation to the minor ailments for pharmacists that will soon be rolled out.

Physician (including retired)
[July 15, 2022 9:18 AM]

This a response to the CPSO consultations regarding dispensing guidelines. The draft policy states that dispensing by physicians should meet the same standards as that of pharmacies. Item 5 of the policy states physicians should offer to the patient the choice to go to a pharmacy obtain their prescription drug . ( 5. Physicians must be transparent and inform the patient of the option to purchase the drug(s) from a pharmacy of their choice, if this option is available.) This is problematic for dispensing of temperature sensitive injectables which are dispensed at point if service immediately before administration of the the drug . I am referring in particular to neurotoxin for Therapeutic use . This new policy will give insurance companies more leverage than they already have to force doctors to send their patients to a particular pharmacy to purchase these injectables. This interferes with the smooth operation of the medical facility which dispenses injectables directly out of cold storage ( often subzero T) and the patient who ends up making 2 visits to the doctor ( and 1-2 visits to the pharmacy ) instead of one visit. This costs the public system one additional unnecessary visit in addition , very importantly, a break in cold chain. The cost to patient is generally equal or less when obtained directly at point of administration. There are currently one or two insurance companies who will not reimburse patients if they obtain the injectable from the medical facility at the time of the visit for administration. This is a great disruption to clinic operation which includes the extra visit to facilitate there demand and a significant cold chain break especially in summer. I would like to see this portion of the policy redacted for reasons above to prevent insurance companies from forcing their operational policies in the instance onto patients and physicians. Thank you

Organization
[July 14, 2022 2:57 PM]

Canadian Ophthalmological Society
Thank you for including the COS in your consultation for your Dispensing Drugs policy. We have reviewed the policy and find that it provides useful guidance. We have no concerns or edits to suggest.