Voluntary Election

Each year upon completing their annual renewal, members of the College will confirm their election into either of two parts of the Register, Part A or Part B.

Part A

Part A is the "patient care" part of the College Register. Pharmacists electing into Part A are retrospectively declaring that they have worked a minimum of 600 hours in patient care over the past three years as part of the annual renewal process. Currently pharmacists practicing patient care in any Canadian (or United States) jurisdiction may elect into Part A of the Register.

In addition to the required practice hours, pharmacists in Part A of the Register are required to:

1. maintain a learning portfolio
2. complete the Self-Assessment when randomly selected to do so
3. participate in the Peer Review when randomly selected to do so

Patient Care
The College considers that a pharmacist is providing "patient care" if they are providing pharmacy services to the public. This includes: dispensing, selling and/or compounding drugs and providing nonprescription drugs, health care aids and devices; providing information related to drug use; and directly supervising the part of a pharmacy where drugs are kept. (Regulations to Pharmacy Act, 1991 section 45)
If as a pharmacist you engage in any of the following activities, you must elect to be in Part A of the Register.

• Counsel or dialogue with patients or their agents about medications including non-prescription medications and health care aids
• Provide information related to drug use, in the course of practicing the profession, directly to patients or their agents
• Perform either or both cognitive and/or technical functions of compounding or dispensing
• Supervise the compounding or dispensing function, as above
• Directly supervise the part of a non-accredited pharmacy where drugs are kept
• Review any prescription order for individual patients, or perform a patient profile or clinical review for an individual patient
• Develop drug therapy protocols or policies directly related to drug therapy practices specific to the institutional setting in which you practise.

Part B

Pharmacists choosing Part B, the "no patient care" part of the Register, are declaring that they will not be providing patient care. This means that the member cannot work as a pharmacist in an Ontario pharmacy or perform any of the controlled acts that are associated with providing pharmacy services to the public.
A pharmacist in Part B of the Register may not:

• Work in a pharmacy as a pharmacist
• Fill in as a pharmacist on an occasional basis
• Provide information related to drug use to patients, agents or health care providers in the course of providing patient care as a pharmacist, or
• Be the designated manager of an accredited pharmacy

Although a pharmacist electing to Part B cannot be the designated manager of an accredited pharmacy, he or she can, as a registered pharmacist in Ontario, be an owner of a pharmacy, or a director of a corporation owning a pharmacy in Ontario. Pharmacists in Part B may also be the manager, director or supervisor of a pharmacy department in a hospital or health care facility, and could therefore supervise pharmacists and technicians in an institutional setting but may not provide patient care.

Those pharmacists who provide information related to drug use in their usual workday, but who do not provide patient care while practising the profession, would be expected to elect into Part B of the register. Examples could include, but not be limited to, pharmacists currently working in: administration (including College staff), academia, government, the pharmaceutical industry, and consulting firms. However, such pharmacists wishing to remain in Part A of the register could do so provided that they fulfill the practice requirement of 600 hours of patient care while practising the profession, over a three-year period.

Pharmacists in Part B, like those in Part A, are required to maintain a record of continuing professional development (i.e. a learning portfolio), and are expected to maintain the ethical and practice standards of the profession set by College Council. Pharmacists in Part B are not required to meet the minimum practice requirement of 600 hours over three years, nor will they be subject to random selection for quality assurance activities (i.e. Self-Assessment or Peer Review).

Movement from Part A to Part B

A member may move from Part A to Part B of the Register at any time simply by notifying the College, in writing, of his or her intent to do so. The change in election would take place immediately or on the effective date provided by the member.

Movement from Part B to Part A

A member may move from Part B to Part A of the Register by notifying the College, in writing, of his or her intent to do so and by successfully undergoing the College's Peer Review. Peer Reviews are currently held four times yearly. Every attempt is made to ensure that a member wishing to undergo a Peer Review for the purposes of transferring from Part B to Part A is promptly scheduled into the next available administration.Members who have not notified the College otherwise, but who seek to change their election from Part B to Part A during the annual renewal process, will be contacted by staff to confirm that a change in election is indeed being requested, and to schedule the member into the next mutually convenient Peer Review. Current policy allows a member in Part B to work in a pharmacy under the direct supervision of a pharmacist in Part A, for the purposes of preparing for the Peer Review, for a period of time not to exceed two consecutive six-month periods without the approval of the Quality Assurance Committee. In order to do this, pharmacists in Part B must notify the College in writing of their intention, citing the name of the pharmacist under whom they will be working, the name and address of the practice site, and the anticipated start and finish dates. Members are required to be enrolled in an upcoming Peer Review prior to commencing work. A member will be transferred from Part B to Part A provided they successfully complete the Peer Review and also satisfy the educational and practice requirements that may be specified by the Quality Assurance Committee. Members are considered to have successfully completed the Peer Review if they met or exceeded the set standard in the following areas of assessment: clinical knowledge, gathering information, patient management and follow-up, and communication skills. Generally, the Quality Assurance Committee will not transfer a member from Part B to Part A unless it is satisfied that he or she has met or exceeded the standards in both the areas of clinical knowledge and communication skills.

Powers of the Quality Assurance Committee to transfer from Part A to Part B

The Quality Assurance Committee has the discretion to transfer a member from Part A to Part B of the Register by the authority granted under Section 47(3) of the College's quality assurance regulation, which reads:

If a pharmacist listed in Part A fails to undergo a required practice review, the Committee may transfer the pharmacist to Part B after giving him or her a reasonable opportunity to make written submissions.This section would apply to any member who fails to participate in either Phase I (Self-Assessment) or Phase II (Peer Review) of the Practice Review process after being randomly selected to do so. The Quality Assurance Committee would only act under the authority of this section in instances where repeated communications from the College to a member have gone unanswered. Section 47(3) gives the Quality Assurance Committee the power to transfer a member from Part A to Part B in such instances after giving him or her reasonable opportunity to make written submissions to the Quality Assurance Committee. Members must be given 14 days in which to make written representation or to request an appearance before the Quality Assurance Committee in order to make an oral submission to the Quality Assurance Committee citing reasons why they should not be transferred into Part B.