Consultation 027

Under high pressure work environment like in today’s time, having IT facilitated rather than hand writing & signing scripts far better to avoid diversions losses of Rx

Certainly, a person with license (irrespective of the type of physician's license) should be allowed to write prescription, as he/she was allowed license on some basis. It'll be great to have a supervisor's name on it, but sometimes, supervisors are busy, so at that time, one should be able to prescribe medicine in need, if they have a license issued by CPSA.
That person should be responsible for writing prescription totally.
In case, there's a supervisor available, one should discuss with him and then prescribe.

This is an important education opportunity. I began practice prior to electronic medical records and a patient did alter my prescription. There is nothing more frightening than having an RCMP officer come and visit you - as the patient had been quite prolific. Since then, I've always been very aware of these dangers.

We have been looking into EMR capabilities regarding the supervising physician piece. Most if not all EMR vendors can place the prescriber's name, address, license and phone number on a prescription, but most if not all cannot provide the supervising physician's information so this would have to be added by hand. If it is required, it would be a significant change to the EMR vendors, as several do not offer any formal supervising physician functionality at all. Connect Care does, but most community EMRs do not. One of the major EMR vendors does not even provide sign-out functionality and this all has to be done manually. This requirement would likely take a minimum of 6 months for the EMR vendors to implement, perhaps longer for the ones with no supervising physician capability at all currently.

While I can see the changes as applying to most clinical situations; fact is these regulations need to cover all practice scenarios and I recommend looking at prescribing in locations of supported and continuing care and acute care. The regulations as written would not be appropriate since many orders are phoned on call or covering scenarios, computer or order sheet written.
This regulation will be already out of date if you chose not to include realistic situations.

ok

None of this is relevant given retail pharmacists being permitted to change physician prescriptions without consent for the $20 adaptation fee billable to Alberta Health.

The regulations as proposed require a uniform regulated EMR capacity and as you know this does NOT happen to exist. The regulations as proposed must deal with all practice scenarios, and as proposed would be an added barrier to care, another hurdle to jump for both providers and patient’s. A one size fits all approach is NOT in the interests of patient’s, only easier for the regulator. This still needs a lot of work, for example a logical first step is getting all EMR vendors to a set standard for all prescriptions.

This is very important to document and make it clear for the patient and pharmacist as well.

I feel requiring physician info is another barrier to care.
PAs already work under supervision, are licensed HCPs, and have their own liability insurance

These changes/additions all seem reasonable to me.

Main comment is that the following section has multiple logical inconsistencies (as well as formatting inconsistencies, suggest a, b rather than 1, 2):

"2. A regulated member who transmits (e.g., faxes) a prescription must ensure the:
1. method is secure[G] to protect patient confidentiality and prevent diversion; and
2. provision for the purpose of dispensing can only be received by the intended licensed pharmacy."

where "secure" is defined as

"Secure: for the purpose of this standard, “secure” refers to the system in which a prescription is transmitted. Secure transmission involves messaging in a closed electronic system (e.g., PrescribeIT).1"

and "provision" is defined as

"Provision: the format in which a prescription is provided to a patient or transmitted to a pharmacy. This includes:
• produced by computer and hand-signed by the prescriber or affixed with an electronic signature that is initialled by the prescriber, then provided to the patient or faxed directly to the pharmacy from the prescriber;
• faxed directly from a password-protected electronic medical record (EMR) where the prescriber’s password protocol is the prescriber’s direct authorization in the absence of a signature;
• issued and transmitted via secure messaging in a closed electronic system (e.g., PrescribeIT) that enables monitoring and shared access by authorized prescribers and dispensers; or
• provided to the pharmacy verbally by telephone by the prescriber or their authorized intermediary.1
Note: handwritten prescriptions are acceptable; however, there is a degree of risk for forgery or diversion. Alternate means of providing the prescription directly to the pharmacy of the patient’s choice is preferable."

For extra clarity, paragraph 2 is about "transmitting (e.g., faxing)" a Rx, but subsection (2) is included to cover Rxs given to the pt by hand; "secure" in the context of "transmitting (e.g. faxing)" means something beyond faxing, e.g. PrescribeIT; etc.

Point of being nit-picky is that paragraph (2) ties this important issue up in knots, and needs sorting out. Clearly, if a Rx is given directly to a patient, it's impossible for the doc to also ensure the Rx "can only be received by the intended licensed pharmacy". Perhaps different requirements for hand-written Rxs given directly to patients, compared to faxing, compared to electronic options, makes more sense? These really are apples, oranges, and bananas.

The College of Physicians & Surgeons of Alberta's initiative to update the "Prescribing: Administration" standard reflects a commendable effort towards enhancing prescription safety and data integrity. The inclusion of a prescribing physician’s supervisor or attending physician's details is a significant stride in bolstering data quality. This addition, especially in the context of trainees and physician assistants, ensures a more transparent and traceable prescribing process. It is a proactive measure that could potentially streamline communication among healthcare professionals, leading to improved patient care.

The emphasis on the risks associated with handwritten prescriptions aligns with the evolving landscape of medical practice, where digital solutions are increasingly favored for their accuracy and security. This move not only mitigates risks of forgery and medication errors but also aligns with modern healthcare practices that prioritize patient safety and efficient data management.

However, these advancements are not without their challenges. The increased administrative requirements, while beneficial for patient safety, could pose an additional burden to healthcare providers, particularly in high-volume settings or areas with limited resources. Ensuring a uniform implementation of these changes across diverse healthcare environments, from urban hospitals to rural clinics, might require significant effort and adaptation.

Furthermore, the shift from handwritten to electronic prescriptions, although advantageous in terms of security and efficiency, may necessitate a period of adjustment, especially for those accustomed to traditional methods. This transition could require additional training and modifications to existing systems and workflows.

In conclusion, while the proposed changes mark a progressive step towards a more secure and efficient prescribing system, it is crucial to balance these enhancements with practical considerations of their implementation in everyday clinical practice. By addressing these challenges proactively, we can ensure that the benefits fully realize their potential in improving patient care and healthcare outcomes