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Administering COVID-19 Vaccine in Community Pharmacies
Health Canada provides update on the AstraZeneca and COVISHIELD COVID-19 vaccines
On April 14, 2021, Health Canada released an update on its ongoing safety review of the AstraZeneca and COVISHIELD COVID-19 Vaccines. A letter from AstraZeneca Canada Inc was also recently shared with healthcare providers outlining the most recent outcomes of the safety review and additional resources available to healthcare providers.
The Health Canada safety review of AstraZeneca and COVISHIELD is available here:
A copy of AstraZeneca’s letter to healthcare professionals is available here:
Vaccine Eligibility and Professional and Ethical Obligations
The College of Pharmacists of Manitoba (CPhM) reminds pharmacists of their ethical obligations as trusted healthcare providers to practice in accordance with standards, practice expectations, and the Code of Ethics. This includes expectations to demonstrate professional behaviours and act as a role model with regard to observing public health measures that contribute to public safety, including vaccine eligibility. Providing inaccurate or misleading information, or encouraging others to do so, to obtain faster access to a COVID-19 vaccine is not consistent with holding a position of trust.
On March 3, 2021, The Emergency Measure Act Order re: Vaccination Eligibility Verification was proclaimed. The order allows Shared Health to investigate and confirm the eligibility of healthcare workers who have received vaccinations. If the investigation confirms an individual provided false information for the purposes of receiving early access to the COVID-19 vaccine, this information can be disclosed to the individual’s employer, professional regulatory body, and/or law enforcement.
Any reports of such conduct that are brought to CPhM’s attention may be subject to further investigation or steps to ensure accountability.
COVID-19 Vaccine Program FAQ
Do I need to have an active CPhM certification of authorization to administer drugs and vaccines by injections?
Yes, for the purposes of administering the COVID-19 vaccine in community pharmacies, all pharmacists wishing to participate must have an active certification of authorization to administer drugs and vaccines by injection from CPhM, including a current CPR level C and First Aid certification.
For more information on how to obtain authorization, please see the Administering Drugs and Vaccines by Injection Information Sheet.
Who can administer COVID-19 vaccines in a pharmacy?
Only certified pharmacists and certified pharmacy interns can administer COVID-19 vaccines in a pharmacy.
On April 6, 2021, a revised Ministerial Order under The Regulated Health Professions Act (vaccine administration) came into effect permitting certified pharmacy interns to administer COVID-19 vaccines in pharmacies.
Before a pharmacy intern can administer COVID-19 vaccines in a pharmacy, they MUST:
- Fill out an Application for Intern Certification of Authorization to Administer COVID-19 Vaccines by Injection;
- Scan and send it to the College by email to email@example.com; AND
- Receive certification from the College.
Note that this certificate of authorization is only required if an intern wishes to participate in the COVID-19 vaccination efforts at the pharmacy.
Pharmacy students and pharmacy technicians are not permitted to administer COVID-19 vaccines in a pharmacy as per the Ministerial Order.
Are there record-keeping requirements in addition to PHIMS entry?
According to section 113 of the Pharmaceutical Regulation, pharmacists must make a drug administration record, which must be retained for at least five years, containing the following information:
- the patient’s name and address;
- the name of the drug and total dose administered;
- for an advanced method or vaccination by any method, identification of the manufacturer, lot number and expiry date of the drug;
- for an advanced method, the route of administration and the location on the body where the drug was administered;
- the name of the member administering the drug;
- the date and the time of administration;
- any adverse events;
- the price, if there is a charge for administration.
The recommended way to meet these record keeping requirements is to ensure all data required in PHIMS is entered, along with ensuring that all the information in the COVID-19 consent forms is completed and kept on the patient record.
All Records must be retrievable and auditable upon College request.
Pharmacists must also adhere to the practice direction on Administration of Drugs including Vaccines here.
It is up to the pharmacy’s discretion if they would like to enter a record into DPIN as well, although it is not required as long as all COVID-19 vaccines have been documented in PHIMS. If COVID-19 vaccines are entered into DPIN for pharmacy-specific reasons, they should be entered using the DU code. The inclusion of the PS code is not required for the COVID-19 vaccine. (NOTE: if the PS code is unintentionally entered, it will not be pulled into PHIMS to avoid duplicate entries).
If I enter the drug administration data into PHIMS, do I also need to enter it into DPIN?
No, direct data entry into PHIMS is sufficient. For more information about entering COVID-19 vaccine data into DPIN if this will be your practice, please see the MHSC website: https://manitoba.ca/covid19/vaccine/partners/faq.html
When will pharmacy professionals be eligible for vaccination against COVID-19?
Staff of pharmacies and medical clinics that are registered (or registering) to participate in the Manitoba COVID-19 Immunization Program are not currently eligible to receive the COVID-19 vaccine. After vaccine is available and allocated to pharmacies and medical clinics, participating pharmacy and medical clinic staff will be eligible to receive the COVID-19 vaccine.
Pharmacists and physicians who currently meet provincial eligibility criteria (https://www.gov.mb.ca/covid19/vaccine/eligibility-criteria.html) may get the COVID-19 vaccine at any time.
Is the pharmacy required to use the Manitoba Health COVID-19 vaccine consent form? *NEW*
All community pharmacy sites registered to provide the COVID-19 vaccine are required to use the Manitoba Health COVID-19 vaccine consent form approved by the provincial Vaccine Implementation Task Force. In-house consent forms do not fulfill provincial requirements.
Can COVID-19 vaccine administration take place at an on off-site location? *NEW*
Yes, as long as the pharmacy records the immunizations provided into PHIMS and meets the guidelines for holding clinics during the COVID-19 pandemic. NACI released Guidance for Influenza Vaccine Delivery in the Presence of COVID-19 (https://www.canada.ca/en/public-health/services/immunization/national-advisory-committee-on-immunization-naci/guidance-influenza-vaccine-delivery-covid-19.html) the same principles should be followed when administering COVID-19 vaccine.
In addition, the cold chain storage and handling of the vaccine during transport and on site should follow Manitoba’s Cold Chain Protocol and that the COVID-19 vaccines are managed so that vaccine doses are not wasted. These vaccines will have limited time for use once the vials are punctured, as they do not contain preservatives. Appropriate planning will be required.
Pharmacists must follow all the requirements of injection and vaccine administration outlined in the Practice Direction of Administration of Drugs Including Vaccines, such as readily accessible supplies for emergency situations, and monitoring patients after administration.
Please also review the Manitoba Health website for additional guidance for health care professionals on PPE and patient contact during the pandemic here. The CPhA website also has information on best practices for PPE and administration of injections that can be found here.
COVID-19 Vaccine Resources
Please see the following resources to support COVID-19 vaccine delivery in your pharmacy.
Manitoba COVID-19 Vaccination Program Webinar
On February 25, 2021, Pharmacists Manitoba hosted a Community Pharmacy COVID-19 Vaccination Panel in partnership with the Manitoba Government and the College of Pharmacists of Manitoba.
The webinar featured a presentation by
- Dr. Joss Reimer, Medical Lead with the Provincial Vaccine Implementation Task Force
- Mr. Joe Funk, Deputy Team Lead – Distributed Channel Workstream
The presentation was followed by a live Q & A session with
- Dr. Joss Reimer, Medical Lead with the Provincial Vaccine Implementation Task Force
- Mr. Joe Funk, Deputy Team Lead – Distributed Channel Workstream
- Inga Hossack, BSc., Policy Analyst, Communicable Disease Control
- Pawandeep Sidhu, Pharmacists Manitoba President
- Wendy Clark, President of the College of Pharmacists of Manitoba
To view the webinar recording, click here.
Government of Manitoba Resources
Please check the Government of Manitoba COVID-19 Vaccines, COVID-19 Vaccine Information for Health Care Professionals and Physician and Pharmacist Vaccination Partners sites often.
- COVID-19 Vaccination in Manitoba Task Force Update – January 27, 2021
- Manitoba COVID-19 Vaccination Plan – Priority Population Sequencing – January 27, 2021
- COVID-19 Vaccine Clinical Practice Guidelines for Use in Special Populations – January 20, 2021
The Manitoba government launched a new website on March 17, 2021, to provide people with up-to-date information about the provincial COVID-19 vaccination campaign. Through protectmb.ca, Manitobans have easy access to eligibility criteria, immunization sites, and myth-busting information.
Manitobans also have the option of signing up to receive updates on the vaccination program directly to their email inbox. When there is a change in eligibility or supply, an urgent message can be sent to ensure people receive the timeliest information.
Visit protectmb.ca for more information.
Read the Government of Manitoba news release at the following link:
PHAC COVID-19 Vaccination Toolkit for Healthcare Providers
You can use the Public Health Agency of Canada (PHAC) COVID-19 Vaccination Toolkit for Healthcare Providers as a quick resource to help your patients and colleagues make informed decisions about COVID-19 vaccination by sharing credible information and resources with them.
Within the toolkit, you will find links to general information about COVID-19, an overview of authorized vaccines, guidance for managing COVID-19 vaccination clinics, an overview of vaccine safety, as well as a number of additional resources such as digital tools, communication materials, and provincial/territorial specific resources
Government of Canada Resources
Preventing Errors with COVID-19 Vaccines: Learning from Vaccine Incidents
Please review the following Safety Bulletin from the Institute for Safe Medication Practices Canada (ISMP Canada) for leading practices that facilitate the safe administration of a COVID-19 vaccine:
Please see the following resources to support educating patients and public about COVID-19 vaccines:
- Frequently Asked Questions about Vaccines – Manitoba Health
- COVID-19 Vaccine Questions and Answers – Government of Manitoba
- Manitoba Health Resources and Forms – COVID-19 Vaccine Factsheet
- CANVax COVID-19 Questions and Answers for Health Care Providers
- What you need to know about the COVD-19 vaccine (PHAC)
- Centre for Effective Practice – COVID-19 Vaccines (please note some of this information may be specific to Ontario)
Ethical Frameworks and Emergency Preparedness
Guidelines relevant to COVID-19, including updated guidelines and policies, will be posted on this page. Important changes and updates will also be distributed to registrants through the bi-weekly Friday Five.
Pharmacy Professional's Duty During an Emergency, Disaster, or Pandemic Ethical Framework
The College of Pharmacists of Manitoba (CPhM) has established the following ethical framework identifying the values for use in consideration of informed decision-making by Manitoba pharmacists during a significant health emergency, such as a pandemic. This ethical framework examines the values that should inform decision-making. Unlike a policy or guideline, it is not prescriptive and represents principles, rather than recommending a course of action. This framework was developed using the ethical values identified in Stand on Guard for Thee: Ethical Considerations in Preparedness Planning for Pandemic Influenza (Upshur, R. et al. 2005), a report developed by the University of Toronto Joint Centre for Bioethics Pandemic Influenza Working Group.
These guiding principles are intended to inform pharmacy professionals of their responsibility to provide care, along with the values to be implemented in decisions that support and protect healthcare professionals as they deliver patient care under extraordinary circumstances, such as an emergency.
Research shows that many healthcare professionals have reservations, based on personal safety concerns, with reporting to work during an emergency such as a pandemic. Pharmacy professionals who are undecided about how much personal risk they will accept during an emergency, such as a pandemic, must take into account their professional Code of Ethics. The CPhM Code of Ethics includes Statement VII: “Pharmacists shall hold the health and safety of each patient to be a primary consideration” and Statement IX: “Pharmacists shall respect the rights of patients to receive healthcare”, whereby pharmacists must ensure the continuity of care for patients until it is no longer required, wanted, or until another suitable healthcare professional has assumed responsibility for that care.
Health emergencies represent exceptional situations that impose a serious threat to public health. They require collective efforts and appropriate timely strategies. In these situations, many of the high-level planning and policy decisions will be made by federal and provincial governments. Decisions regarding the delivery of health care and guidelines for healthcare professionals will be made by organizations such as public health agencies and health authorities. Despite this, pharmacy professionals will need to make many important decisions at an individual level and the time to decide one’s professional commitment in the face of threats to personal safety is not during a public health emergency, but before such an emergency occurs.
The report Stand on Guard for Thee identifies 10 substantive values that CPhM recommends pharmacists use in guiding decision-making in the event of a health emergency:
- Individual liberty: Canadians hold individual liberty as an important principle. Restrictions to individual liberty may be necessary and relevant in protecting the public from serious harm.
- Protection of the public from harm: Health organizations and public health authorities may be required to take actions that impinge on individual liberty.
- Proportionality: Restrictions to individual liberty and measures taken to protect the public from harm should use the least restrictive means to address the actual level of risk to the community and be applied without discrimination.
- Privacy: A right to privacy in the disclosure of health care information is central to an individual’s rights. Individual’s rights to privacy in health care may need to be weighed against the right to protect the public from serious harm. Private information should only be released if there are no less intrusive means to protect the health of the public.
- Duty to provide care: This principle is inherent in CPhM’s Code of Ethics, which states that a fundamental responsibility of a pharmacist is to hold the health and safety of each patient to be of primary consideration. Pharmacists will be met with significant challenges regarding resource allocation, scope of practice, professional liability, workplace conditions and addressing their personal risk versus their obligation to provide care for patients. This duty is qualified by the obligation of the employer, regulator, and/or public health authority to ensure adequate resources are available to support a safe environment that will minimize short- and long-term risks for the healthcare professional.
- Reciprocity: Society must support those who are required to take increased risks or face a disproportionate burden in protecting the public (healthcare professionals), and also take steps to minimize these burdens as much as possible. Social solidarity should flow in both directions. If, in the case of a health emergency, pharmacists have certain obligations towards society, then society has certain reciprocal obligations towards pharmacists. CPhM agrees that the federal and provincial governments and professional advocacy organizations play an important role in supporting this concept.
- Equity: As stated in the Canada Health Act, “The primary objective of Canadian health policy is to facilitate reasonable access to health services without financial or other barriers”. Due to resource limitations, the onset of a health emergency (such as a pandemic), will impose difficult decision-making regarding which health services will be maintained, and which will be deferred. During a pandemic, decision-makers must attempt to maintain the principle of equity when considering the interests of pandemic affected patients, as well as those requiring treatment for other chronic diseases.
- Trust: Trust is an essential component of the relationship between healthcare professionals, patients, staff and their organizations, and the public. Trust must be maintained with all stakeholders through the demonstration of transparency, accountability and ethical processes in all decisions.
- Solidarity: This process requires the use of collaborative approaches that set aside traditional values of self-interest or territoriality among healthcare professionals, services or institutions. Solidarity requires that decision-makers and pharmacists support positions arrived at by consensus and uphold them.
- Stewardship: Both institutions and individuals will be entrusted with control over scarce resources such as vaccines, antivirals, ventilators, personal protective equipment, hospital beds, and healthcare professionals. Those entrusted with this control are guided by ethical behavior and good decision-making based on evidence and reason that achieves the best patient and public health outcomes.
Obligation to Provide Care and Social Reciprocity
There is an ethical obligation for pharmacy professionals to care for patients, even in the face of personal risk. According to the Stand on Guard for Thee report, the duty to care for those in need is a primary ethical obligation for all healthcare professionals for several reasons, including the following:
- The ability of healthcare workers to provide care is greater than that of the public, thus increasing their obligation.
- By freely choosing a profession devoted to caring for the ill, they assume risks.
- The profession has a social contract that calls on members to be available in times of emergency.
CPhM agrees that pharmacy professionals have a professional and ethical obligation to help others in times of crisis. A pharmacist’s decision to not be involved during a health care emergency shifts the burden to others, including fellow pharmacists and other healthcare professionals and their facilities. It also places the public at risk.
Along with the healthcare professional’s obligation to provide care during a health emergency, it is the reciprocal obligation of society towards the healthcare professional. Reciprocity plays a key role in the social contract between pharmacy professionals and the public. Appropriate measures and resources must be in place during times of crisis for pharmacy professionals to face risks and provide care to those in need. Societal obligations extend to governments, employers, public health authorities, regional health authorities, and pharmacy advocacy groups, to ensure appropriate resources and policies are in place to support a safe environment.
All pharmacy professionals have the same ethical obligations to provide care during an emergency. There is also an obligation to take any steps required to protect themselves. It is recognized that some pharmacy professionals will have greater needs and challenges than others. There may be personal challenges or vulnerabilities that prevent some pharmacy professionals from assuming the same level of involvement in the provision of care to the public. It is expected that colleagues and employers will recognize and protect/support these pharmacy professionals.
Standards of Care during a Health Emergency
During a healthcare emergency, pharmacy professionals may be presented with an ethical dilemma, where the emergency has overwhelmed healthcare resources. This may require pharmacists to shift their standard of care from one that focuses on individual patients, to one that focuses on what is best for the greatest number of patients.
Allocation of Medications and Stockpiling
The needs of individuals must be balanced against that of the greater good. During a pandemic, pharmacy professionals are expected to continue using their knowledge, skills and professional judgement on an individual patient-basis when considering allocation of medications, which maintains the best interests of the patient and society as a whole. Unless otherwise directed by public health officials, during a pandemic, pharmacy professionals should consider all aspects of care for each patient in determining optimal allocation of medications. This includes ensuring patients are provided appropriate amounts of prescription medications, considering the patient’s access to pharmacy services, and potential strains on the national drug supply, which may lead to exacerbating drug shortages.
Pharmacy professionals must be cognizant of the issues associated with stockpiling medications and the consequences to provincial and national drug supply. For recent guidance on issues of stockpiling of medications, please refer here. For recent guidance from the Canadian Pharmacists Association on issues of stockpiling of medications, please refer here.
This ethical framework is intended to assist pharmacy professionals in understanding their professional and ethical responsibilities in the event of a health emergency. It is also intended to guide pharmacy professionals in their decision-making processes during such a crisis.
Pharmacy professionals must consider the 10 substantive values set out in the Stand on Guard for Thee report when developing their emergency processes and providing care. Ultimately, pharmacy professionals are free to make necessary independent decisions during the course of a health crisis, but they should be prepared to reasonably justify these decisions, if necessary.
Pharmacy managers must have a plan in place regarding the delivery of health care services during an emergency, disaster or pandemic.
This framework provides direction and substantive values for pharmacy professionals to use in careful consideration of the ethical decisions expected in the face of a health emergency, disaster, or pandemic.
Ensuring Pharmacy Accessibility During a Health Crisis or Pandemic
It is recognized that during a health crisis or pandemic, specific measures may be implemented globally in order to ensure the protection of the public. For example, during a pandemic, public health officials may recommend, or direct the employment of social distancing, along with requirements for self-isolation. Social distancing is a measure used to deliberately increase the physical space between people to avoid spreading illness.
While pharmacy professionals have an inherent duty to provide and maintain care, particularly during an emergent health crisis such as a pandemic, it is equally as important to ensure the safety of patients, as well as all pharmacy staff during the delivery of such care. The following guidance should be considered as a temporary safety measure during a pandemic, in ensuring the responsible provision of medications and care.
Pharmacy facilities are constructed in a manner that offers essential pharmacy care via physical accessibility, with direct contact between the pharmacy professional, pharmacy staff, and patient.
During a pandemic, pharmacies may choose to consider the implementation of alternative
measures, such as limitations on public physical accessibility to the pharmacy. This is an
extraordinary measure and intended to be used temporarily during an emergency.
Limitations on physical access to a pharmacy facility may include:
- Restrictions on number of patients allowed in the facility
- Reliance on the use of telephone contact with patients, care givers, and agents as much as feasibly possible.
- Delivery of prepared prescription medications directly to patients or identified agents. This measure allows for continuity of care, with limited physical contact between patients and pharmacy professionals.
- It remains essential for pharmacies to be accessible to the public and patients. Accessibility may be redefined during a pandemic, with limited physical contact, and the use of other means of contact, such as telephone.
Pharmacies choosing to temporarily limit public/patient physical access to the pharmacy facility as a safety precaution, must ensure patients are notified through appropriate signage, which includes clear details for contacting the pharmacy for care (ex. Pharmacy phone number, and hours of operation).
Pharmacy professionals should encourage delivery of prescriptions for all patients during a health crisis or pandemic (even those patients that may not be considered as vulnerable). This health safety measure further allows for limitations on physical contact, and a maintenance of social distancing.
These measures are of high importance while considering the health impacts on the vulnerable patient sector (elderly, immunocompromised, patients with pre-existing health conditions).
Pharmacy professionals must recognize that any limitations imposed on physical accessibility to the pharmacy facility are only temporary, and extraordinary measures during an emergent health crisis, such as a pandemic. These temporary measures have an expiration based on direction from public health authorities, and/or regulatory authorities.
Emergency Planning and Central Fill Pharmacy Services during the COVID-19 Pandemic
As a result of the COVID-19 pandemic, pharmacies must have plans in place to ensure
continuity of care for their patients in the event of unforeseen pharmacy staff shortages or
There are various measures that pharmacies may put into place as part of their planning, which can include:
- reduction of pharmacy hours
- increased utilization of delivery services
- limiting in-person contact with patients and their agents
- employing additional staff, such as interns/recent graduates, and
- utilization of centralized prescription filling services
A pharmacy can participate in central fill by either:
a. Providing central fill services to other pharmacies, or
b. Having prescriptions filled by a central fill pharmacy
Pharmacies that are looking to centralize part of the prescription filling process during the
COVID-19 pandemic are reminded to review the Central Fill Practice Direction on the College of Pharmacists of Manitoba’s website. The practice direction outlines the responsibilities of the patient contact pharmacy and the central fill pharmacy.
Compliance with the Central Fill Practice Direction is required from all pharmacies in Manitoba that provide centralized prescription processing services to another pharmacy or obtain centralized prescription processing services from another pharmacy.
Providing central fill services to other pharmacies:
Pharmacies wishing to provide central fill services to other pharmacies in Manitoba must have approval from the College for this added component to their community pharmacy license.
Patient-contact pharmacy seeking central fill pharmacy services:
If part of the pharmacy’s pandemic planning includes partnering with a central fill pharmacy to provide centralized prescription filling, the patient-contact pharmacy must ensure that there is a clear agreement in place, and patients are informed. It is important to review the responsibilities of the patient contact pharmacy described in the above linked practice direction.
There may be cases where a pharmacy is unable to continue to operate due to illness, self-isolation or other circumstances and must close temporarily. In these cases, the primary
consideration must be the continuity of care for the patients. Patients must be able to access their records and information in the event of a closure. If the pharmacy must close temporarily, please remember to review the Permanent and Temporary Pharmacy Closure Practice Direction, complete the Temporary Closure checklist and submit the information to the College.
Please see the list of guidelines and resources below to inform and support patient care during the COVID-19 Pandemic.
Administration of Injections During the COVID-19 Pandemic
- Pharmacists should use their professional judgement and consider the following guidance when deciding on the appropriateness of administering an injection to a patient during the COVID-19 pandemic:
Patients with symptoms and/or exposure criteria consistent with COVID-19 should be directed to immediately self-isolate and contact Health Links – Info Santé (204-788-8200 or toll-free at 1-888-315-9257).
- Patients who do not exhibit symptoms and do not have exposure criteria consistent with COVID-19 should result in further consideration:
- If the injection is part of a series with a wide or flexible dosing schedule (eg. 6 –12 months), then safely delay the administration.
- If the injection is part of a rigid schedule (eg. medroxyprogesterone) and a delay can negatively impact the patient’s health, prioritize the administration as appropriate.
Pharmacists and staff should practice social distancing, even during the initial screening with the patient and initiate the discussion by phone, whenever possible. Should a pharmacist decide to administer an injection to a patient, a pharmacist must proceed
with caution and ensure good hand hygiene and proper use of personal protective equipment (PPE).
If a pharmacist does not have PPE and the administration is urgent, then a pharmacist must refer the patient to an alternative health care provider who can safely administer the injection with the appropriate safety precautions.
Pharmacists are also encouraged to review the Administration of Drugs Including Vaccines Practice Direction, which outlines the responsibilities of pharmacists when administering a drug, including a vaccine.
COVID Positive Patients
If one of your patients has COVID-19 and was in the pharmacy recently, please refer to the COVID-19 Screening Tool or Contact Health Links-Info Santé at 204- 788-8200 or 1-888-315-9257 (toll-free) immediately.
Manitoba Prescribing Practices Program Temporary Exemptions
As a temporary measure, M3P prescriptions may be faxed from prescribers directly to the pharmacy of the patient’s choice in accordance with the Ensuring Safe Access to M3P Prescriptions for Patients During the COVID-19 Outbreak guidance document.
Updates for pharmacists regarding the M3P program during the COVID-19 pandemic can be found on your Registrant Login
Take-Home Dosing (Carries) for Patients on Opioid Agonist Therapy
Please refer to the joint CPhM and CPSM guidance document titled Advice Regarding Take-Home Dosing (Carries) for Patients on Opioid Agonist Therapy with Methadone or Suboxone.
You can access this document and other M3P-related information on your Registrant Login.
Federal Subsection 56(1) Class Exemption
The Federal Subsection 56(1) class exemption of the Controlled Drugs and Substances Act (CDSA) is NOT in effect in Manitoba, as it has not been passed by the provincial minister of health.
Verbal orders and transfers of narcotics are not permitted between pharmacies within Manitoba. Manitoba pharmacies are also not permitted to accept verbal orders and transfers of narcotics from pharmacies in other provinces.
The Joint Guidance to Physicians, Nurse Practitioners and Pharmacy Professionals: Narcotic and Controlled Drug Prescriptions for Personal Care Home Residents, permits verbal orders from physicians and RN(NP)s for narcotics and controlled drugs under the CDSA for residents of personal care homes during the pandemic. The provincial regulation governing the Manitoba Prescribing Practices Program (M3P Program) does not apply to personal care homes and so the Subsection 56(1) class exemption for verbal orders of narcotic prescriptions is in effect for personal care homes only.
Narcotic and Controlled Drug Prescriptions for Personal Care Home Residents
The Joint Guidance to Physicians, Nurse Practitioners and Pharmacy Professionals: Narcotic and Controlled Drug Prescriptions for Personal Care Home Residents, approved on April 7, 2020, permits verbal orders from physicians and RN(NP)s for narcotics and controlled drugs under the CDSA for residents of personal care homes during the pandemic. This joint statement is in line with the provisions granted in Health Canada’s Subsection 56(1) Class Exemption. This exemption has been extended and will remain in place until September 30, 2021, which may be reassessed upon expiry.
Please be reminded that this exemption applies to residents of a personal care home only.
Drug Shortages and Dispensing Restrictions
In the spring of 2020, Manitoba Health and Seniors Care put a limit on the number and quantity of prescription drugs dispensed to only one month’s supply in order to stabilize the drug supply in Canada.
Although the broad restriction on all prescription drugs was lifted in May 2020, some restrictions are still in place for certain prescription medications that are at risk of a shortage. Only drugs currently listed on the Manitoba Health Drug Shortage Quantity Restrictions List are subject to the one-month fill limit. This list is updated regularly.
Provincial information on drug shortages and supply restrictions can be found at the following link:
The following resource from ISMP Canada addresses patient safety gaps introduced by drug shortages:
Point-of-Care Testing for COVID-19 by Pharmacists
There are several Point of Care Testing (POCT) medical devices for COVID-19 that have been approved by Health Canada or are currently under review. They include antigen-detecting and antibody-detecting (immunodiagnostic) tests for the purposes of diagnosis and surveillance. The College of Pharmacists of Manitoba (the College) continues to receive questions from practicing pharmacists about their ability to administer and/or interpret the results of such tests.
According to guidance provided by Manitoba Health, Seniors and Active Living (MHSAL), all COVID-19 testing is currently being coordinated provincially. This ensures that all results are integrated with the health system, tracked and reported daily, and that positive test results immediately trigger Public Health interventions including expedited contact tracing.
In addition, licensed pharmacies are not authorized provincial testing sites, and pharmacists are not permitted to conduct COVID-19 testing in licensed pharmacies. POCT in community pharmacies presents several safety concerns, as very few pharmacies in the province have the infrastructure to properly isolate suspected COVID-19 cases to protect staff and other pharmacy patrons alike.
Lastly, the College reminds all registrants that according to section 2(2) of the Pharmaceutical Act, pharmacists in Manitoba can only interpret, but not administer, patient self-administered automated tests. POCT for COVID-19 does not fit that criteria, as they are screening/diagnostic procedures and must be administered and interpreted by a trained healthcare provider. All pharmacists are encouraged to review the Test Interpretation Practice Direction for additional information.
Should pharmacists wish to participate in the provincial COVID-19 testing efforts, more
information on the pathway to employment at a provincial testing site as per the ministerial order announced on October 14, 2020, can be found here.
Prescribing and Dispensing of Drugs to Treat COVID-19
Increased urgency to affirm appropriateness of use
There has been significant mention in both the media and on the internet on the use of certain antimalarial, antibiotic and antiviral therapies in the treatment of COVID-19 patients. Notwithstanding the widespread hope that a cure or treatment for COVID-19 symptoms is found quickly, Manitobans have an expectation that their health team members, including physicians, nurse practitioners and pharmacists, continue to work together to ensure that prescribing and dispensing of medications for the treatment of this deadly virus is evidence-based and in the best interest of patient and public safety.
There has been a significant increase in the number of prescriptions written and dispensed for some drugs associated with media and internet claims (e.g., Kaletra®, hydroxychloroquine) over the past two weeks in Manitoba. Assessing patients and critically evaluating prescriptions are foundational responsibilities of physicians, nurse practitioners, and pharmacists in supporting appropriate drug therapy.
Due to the recent yet-to-be-proven claims of effectiveness of hydroxychloroquine sulfate against COVID19 and the growth in prescribing for it, we are now faced with a very serious shortage (and some brands, outages) of the product. This presents very serious challenges for long-term continuity of care for patients suffering from rheumatoid arthritis and lupus.
CPhM would like to remind pharmacists of their responsibilities to their patients and the public, as outlined in Section III and VII of the Code of Ethics. Additionally, pharmacists are encouraged to review Section 83 of the Pharmaceutical Regulations, which outline a pharmacist’s responsibility to ensure the appropriateness of treatment and to ensure that a drug has been prescribed in accordance with the standards of care and patient safety.
CRNM would like to remind RN(NP)s of their responsibilities to their patients and the public, to meet the Practice Expectations of RNs and RN(NP)s and the Code of Ethics.
CPSM reminds prescribing members of section 6 in the Code of Ethics and Professionalism and the provisions defining good medical care in the CPSM Standard of Practice Regulation section 3.
Collectively, CPSM, CRNM, and CPhM recognize and appreciate your extraordinary efforts during these unprecedented and challenging times. Your diligence will support appropriate use, improved health, and the continued availability of these drugs for those who need them most.
Influenza Vaccination During COVID-19
- Pharmacists Manitoba Influenza Resources
- Suggested Best Practices for Community Pharmacies Providing Influenza Immunizations During the COVID-19 Pandemic (Canadian Pharmacists Association)
- Guidance for influenza vaccine delivery in the presence of COVID-19 (Public Health Agency of Canada)
Delivery of Medications During the COVID-19 Pandemic
Pharmacists are encouraged to review Section 2.6 of the Drug Distribution Practice Direction, which outlines minimum standards for drug delivery by community pharmacies in Manitoba.
Prior to arranging the medication delivery, pharmacists should confirm if their patient is experiencing symptoms of COVID-19 or if they are self-isolating. If this is the case, the medication should be delivered to the patient without direct contact, while ensuring that appropriate security measures are followed to ensure the patient received the medication.
Pharmacists need to be mindful of the potential risks associated with leaving medications in a patient’s mailbox or at their door, including medication loss, theft, and temperature considerations. Security measures (e.g. delivery driver calling recipient once medication is left, waiting for follow-up call from patient to confirm receipt, etc.) should be implemented in order to minimize risks.
It would be up to the pharmacists’ professional judgment as to how they would like to ensure the prescription was properly delivered to the correct patient. Some options would be to work with the delivery personnel to confirm delivery by phone or work with the patient to confirm delivery by phone. For all narcotic, controlled, and targeted substances prescription deliveries, if a signature is not obtained, the reasons and confirmation of delivery must be properly documented.
Individuals and groups in Manitoba are offering to pick-up groceries and other essentials for Manitobans that are unable to leave their homes during this time. Pharmacists should remain diligent and ensure that the patient has authorized this individual to serve as their agent.
Other important delivery considerations include:
- Any payments should be processed in advance of the delivery, if applicable, by secure
means when delivery is arranged with the patient, to limit interaction between patients and delivery personnel.
- On the outside of the packaging, indicate transport conditions (related to temperature, fragility, and safety) and only the information required for delivery to the patient or other recipient (name, address, etc.).
- Ensure any reusable totes used for delivery are sanitized inside and out before they come into the pharmacy and between each use.
Over-the-Phone Patient Assessment and Prescribing Exemption for Pharmacists
An exemption is granted by College Council to permit pharmacists to complete a telephone assessment when a pharmacist is considering issuing a prescription within their scope of practice to a patient.
All other requirements must be met as described in the Act, Regulation, and the Prescribing and Prescribing and Dispensing Practice Directions. This exemption has been extended and will remain in-place until September 30, 2021, which may be reassessed upon expiry.
Please see the list of guidelines and resources below to inform and support pharmacy operation during the COVID-19 Pandemic.
Requirements for Post-Consumer Returns Containing Controlled Substances
In response to the evolving health risk posed by the COVID-19 pandemic, the Office of Controlled Substances (OCS) is taking temporary measures to reduce the likelihood of spreading COVID-19 between consumers and pharmacists when returning products that may contain controlled substances to a pharmacy.
Please read the full bulletin here: Update to Requirements for Post-Consumer Returns Containing Controlled Substances
Pharmacists Manitoba has established lists of individuals who are available for relief work in the event that pharmacies are short-staffed during the COVID-19 pandemic:
- Pharmacist Relief List
- Pharmacy Technician / Assistant Relief List
The lists may be found on Pharmacists Manitoba website: COVID-19 resources page.
Pharmacists Manitoba is also planning to create a list of pharmacy students available to provide relief in appropriate roles.
To be added to one of the lists please forward your contact information to Danielle at firstname.lastname@example.org and indicate the appropriate list (Pharmacist, Pharmacy Technician / Assistant, or Student).
Temporary and Permanent Pharmacy Closure
For information on Permanent and Temporary Pharmacy Closures, please review the Permanent and Temporary Pharmacy Closures – Practice Direction and the Ensuring Pharmacy Accessibility During a Health Crisis or Pandemic document.
If a pharmacy must close or cease to operate, either temporarily or permanently, the Registrar must be notified of the intended closure at least 30 days (or as soon as reasonably possible) prior to the closure date to ensure appropriate notification. This notification must also include information advising of where patient records will be securely stored and maintained in the case of a permanent closure, allowing for complete and uninterrupted patient access to care.
The Permanent and Temporary Pharmacy Closures Checklist includes a clear process to ensure compliance and provide a seamless transition of care for your patients. Should further guidance about pharmacy closure requirements be required, please contact the College.
Temporary Changes to Hours of Operation
A pharmacy manager can log onto their manager profile on the College website and update the hours of operation. Each pharmacy must complete this change online, and this will serve as the only required correspondence with the College required. Please also notify your patients of your change of hours of operation through signage (e.g., Primary Pharmacy entrance, dispensary counter, etc.), updating your website, and updating your phone messaging system.
When you are determining your reduced operating hours, it is important to remember Section 34(2) of the Pharmaceutical Regulation:
34(2) In addition to the requirements of subsection 30(1), an applicant for a community pharmacy licence must provide evidence satisfactory to the registrar that
- (a) the facility will be accessible to the public;
- (b) the hours of operation will meet the needs of the community served by the pharmacy as determined by an hours-of-operation policy set by the council;
- (c) the facility will be staffed and managed by members who have the requisite knowledge, skill and judgment to operate a community pharmacy; and
- (d) the facility will comply with practice directions respecting community pharmacies.
The pharmacy’s hours of operation must meet or exceed 25 hours a week over a 4-day period.
Health and Safety
Please see the list resources below to inform and support pharmacy health and safety during the COVID-19 Pandemic.
Mental Health Resources for Pharmacy Professionals
Manitoba pharmacy professionals are experiencing an increase in patients, COVID-19 information and related practice changes, and medication and staffing shortages, which has lead to enormous stress and increased workload for pharmacy teams. It is important that you care for your mental health during COVID-19.
If you recognize that you or a colleague is in distress, it is best to seek support or encourage your colleague to do so. It may be advisable to temporarily step away from practice to receive the care and support necessary. It is always advisable to contact your professional regulator to best address your concerns. Please note, you must report your concerns to the regulator if patient safety or a colleague’s safety is a concern.
- Klinic Community Health Crisis Support
For those needing immediate support, please do not hesitate to contact Klinic Crisis. They operate a variety of crisis phone lines and online support services, providing free and confidential counselling, support and referrals for people who are suicidal, in crisis or struggling to cope.
- Manitoba Suicide Prevention & Support Line
(24/7) Tollfree: 1-877-435-7170
- Klinic Crisis Line (24/7)
Phone: (204) 786-8686
- Manitoba Suicide Prevention & Support Line
- Canadian Pharmacists Association – Supporting Pharmacists’ Mental Health and Wellness Webinar
- Canadian Psychological Association Psychology works for COVID-19 — psychologists giving back to front line service providers (free mental health support for health care workers)
- Mental Health Commission of Canada COVID-19 Resources
- Canadian Mental Health Association Tips for managing anxiety