Public Consultation: Prescribing Requirements
*This consultation has ended. Please watch for updates.**
CPSM Requests feedback on the following documents:
- DRAFT CPSM Standard of Practice - Prescribing Requirements
- DRAFT CPSM Practice Direction - Electronic Transmission of Prescriptions
Background
A working group consisting of representatives from several Manitoba regulatory colleges met in 2022-2023 to review prescribing-related legislation and existing Standards of Practice and Practice Directions.
Currently, prescribing rules are set out in various Standards of Practice and Practice Directions:
- Standard of Practice - Prescribing Requirements
- Practice Direction - Manitoba Prescribing Practices Program (M3P)
- Practice Direction - Electronic Transmission of Prescriptions
- Practice Direction - Facsimile Transmission of Prescriptions
- Practice Direction - Prescribing Practices: Doctor/Pharmacist Relationship
(View the Standard and Practice Directions here.)
The working group recommended consolidating the current requirements into one Standard of Practice and one Practice Direction. In addition to consolidating, the working group recommended updating the content of these documents to reflect better prescribing practices.
Request for Feedback
Prescribing medication is a major responsibility of CPSM registrants. The public relies on safe, efficient, and reliable prescribing of medication. It is CPSM’s duty to establish appropriate standards that prioritize the public's safety and well-being.
CPSM is seeking feedback on:
1. DRAFT Revised Standard of Practice: Prescribing Requirements
A) Clinical indication, and/or treatment goal, and/or diagnosis on prescriptions
B) Verbal prescriptions for M3P drugs
See below for more details.
2. DRAFT Revised Practice Direction: Electronic Transmission of Prescriptions
See below for more details.
1. DRAFT Revised CPSM Standard of Practice: Prescribing Requirements (the Standard)
Key Updates Include:
- Section 7 on Manitoba Prescribing Practices Program (M3P Drugs) - As the list of M3P drugs is attached to this Standard of Practice, the current Practice Direction for Manitoba Prescribing Practices Program (M3P) will be repealed. This prevents duplication and consolidates prescribing rules.
- Section 4 on Verbal Orders - This consolidation involves moving the verbal prescribing expectations, currently located in the Practice Direction for Prescribing Practices: Doctor/Pharmacist Relationship, to this Standard.
- Section 3.8 - The information on statutory requirements on Pharmacist’s dispensing - There are certain statutory rules governing dispensing of which prescribers may not be aware, at times leading to friction between the professions. These include federal rules where the pharmacist has no discretion such as certain refills, repeats, and part-fills for different drugs and controlled substances. Additionally, a list of involved medications is being developed and will be included as an appendix in the Standard.
- New sections clarify that the Standard applies to both prescribing in the community (Part A) and what are called “orders” in a hospital (Part B). It also clearly specifies which prescribing rules do not apply in a hospital, Personal Care Home, or other institutional settings.
Additionally, within the Standard, CPSM seeks feedback on:
A. The potential requirement to include either a clinical indication, and/or treatment goal, and/or diagnosis on all prescriptions.
CPhM requested that clinical indication, and/or treatment goal, and/or diagnosis should be included on all prescriptions.
This would be beneficial for patients in allowing pharmacists to determine prescription appropriateness in a timely manner. Conversely, physician time in writing indications, and delays whilst pharmacists confirm indications before dispensing medications remain points of concern.
The three options below are being considered. In your response, we ask that you provide your feedback on your preference regarding the use of indications.
a) Should indication, and/or treatment goal, and/or clinical indication be required on all prescriptions?
b) Should indication, and/or treatment goal, and/or clinical indication be required on all new and “off-label”* prescriptions only?
c) Should indication, and/or treatment goal, and/or clinical indication be recommended only on all prescriptions?
*Off-label is defined as the use of a medication that has not been approved for the treatment of a specific disease by Health Canada, as listed in the Canadian drug product monograph.
The College of Pharmacists has advised CPSM Council that:
“Pharmacists will continue to act in the best interests of the patient and use their professional judgement when prescriptions are missing content, which may include dispensing a prescription without an indication noted and confirming with the prescriber afterwards”.
Environmental Scan:
Quebec is the only Canadian province that requires an indication on:
-
- new prescriptions,
- prescriptions containing a change in dosage/medication, and
- prescriptions where multiple physicians or healthcare professionals are providing medical care (e.g., in a team-based environment).
B. The Implementation of verbal prescriptions for M3P drugs under limited circumstances when timely fax or electronic transmission is not possible AND may otherwise lead to a delay in access to urgently needed medication.
Section 7.8 of the draft Standard of Practice for Prescribing Requirements specifies the situations in which the verbal prescribing of M3P drugs would be permitted and the necessary requirements for the same. However, prior to implementing this change an amendment to the College of Pharmacists of Manitoba General Regulation is required.
CPSM requests feedback on this proposed change and whether the regulation amendment should be pursued.
2. DRAFT Revised CPSM Practice Direction: Electronic Transmission of Prescriptions*
Key updates include:
- The Practice Direction combines the Practice Direction - Electronic Transmission of Prescriptions and Practice Direction - Facsimile Transmission of Prescriptions. Combining these into one Practice Direction makes it easier for physicians (and pharmacists) to ensure completeness of their prescriptions while eliminating redundancy between these two documents.
*Please note: This Practice Direction does not permit the transmission of prescriptions via email. The necessary IT infrastructure to allow for secure and safe email transmission of prescriptions between the various prescribers and pharmacies does not currently exist in Manitoba. As such, it is prudent not to allow email prescribing for confidentiality reasons at this time.
How to submit your feedback
- Review the DRAFT Standard of Practice - Prescribing Requirements.
- Review the DRAFT Practice Direction on Electronic Transmission of Prescriptions
- Submit your comments in writing by email to: CPSMconsultation@cpsm.mb.ca
The deadline for feedback is Friday, September 29, 2023.